Code of Conduct

Siemens Energy wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions in which we purchase goods and services, this maxim of Siemens Energy business policy was considered in the principles of our Code of Conduct. It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the Siemens Energy “Business Conduct Guidelines”, which establish fundamental principles of sustainability and apply to the entire company.

Siemens Energy conducts business responsibly and in compliance with the legal requirements and governmental regulations of the countries in which we operate. Therefore, the company will under no circumstances tolerate illegal or non-compliant behavior. We have set ourselves globally binding Business Conduct Guidelines that require all employees and managers to behave in an ethical, law-abiding manner. Equally, Siemens Energy expects its partners to comply with all applicable laws and regulations.

The core internationally recognized human rights are contained in the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, coupled with the principles concerning fundamental rights in the eight ILO core conventions as set out in the Declaration on Fundamental Principles and Rights at Work). Depending on circumstances, business enterprises may need to consider additional standards.Partners should pay heightened attention to ensuring respect of human rights of specifically vulnerable rights holders or groups of rights holders such as women, children or migrant workers, or of (indigenous) communities. Specifically, Siemens Energy expects its partners to respect the fundamental employment rights set out in international conventions of the United Nations (UN) and the International Labor Organization (ILO).

We demand the elimination of all forms of forced labor and our partners must contribute to this by implementing appropriate measures and control mechanisms – not only within their own organization but also in their supply chain, e.g. when using labor brokers, temporary employment agencies, etc. Under no circumstances can we accept that e.g. employees’ IDs are confiscated, salaries are not paid periodically or only after long periods, or physical or psychological pressure is put on employees or their families.

We expect you as our partner to:

Neither use nor contribute to slavery, servitude, forced or compulsory labor and human trafficking.
Implement respective control mechanisms in your own supply chain.

Our partners shall promote equal opportunities and treatment of employees during the recruiting process and their employment period, irrespective of skin color, race, nationality, ethnicity, political affiliation, social background, disabilities, gender, sexual identity and orientation, marital status, religious conviction, or age.

They refuse to tolerate any unacceptable treatment of individuals such as mental cruelty, sexual harassment or discrimination including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative.

We expect from you as our partner the following:

You have internal regulations governing respect for applicable employment rights.
When hiring employees, and in other personnel-related activities such as training and continuing professional development and advancement, you abide by the principles of equal opportunities and equal treatment, and implement internal regulations created for this purpose. For example, discrimination, including on the basis of race or skin color, is prohibited within your company.
You have established internal rules for the fair treatment of others and monitor their observance. Your employees are free to lodge complaints with their superiors without fear of reprisal.

Everyone has the right to fair remuneration ensuring for himself and his family an existence worthy of human dignity. Our partners, therefore, must pay appropriate wages and ensure reasonable limitation of working hours and periodic holidays with pay. They recognize the legal rights of workers to form or join existing trade unions and to engage in collective bargaining; they neither disadvantage nor prefer members of employee organizations or trade unions. In the event of cross-border personnel deployment, all applicable legal requirements, especially with regard to minimum wages, must be adhered to.

We expect you as our partner to:

Recognize the legal rights of workers to form or join existing trade unions and to engage in collective bargaining; neither disadvantage nor prefer members of employee organizations or trade unions.
Adhere to all applicable working-hours regulations globally.
Pay fair wages for labor and adhere to all applicable wage and compensation laws globally.
In the event of cross-border personnel deployment, all applicable legal requirements, especially with regard to minimum wages must be adhered to.

Siemens Energy expects its partners to take responsibility for the health and safety of their employees.

Your contribution, as a partner, to actively implementing the Code of Conduct regarding health and safety for employees is to fulfill minimum requirements, depending on the category (see also chapter “Health and safety management system – categorization according to the supplier’s size or type of activities”):

There is a clear commitment by management to occupational health and safety.

You take measures to prevent accidents on building sites, in plants and in projects.
You eliminate unsafe and dangerous conditions immediately.
You control hazards and take the best possible precautionary measures against accidents and occupational diseases, which means: assessing hazards and effects of activities, products and services and implementing appropriate measures to eliminate or minimize the risks and their effects as far as possible.
You regularly develop minimum requirements further internally and keep your suppliers informed about them.
You have a person who is responsible for occupational health and safety matters and who trains and educates your employees.
You support your suppliers actively in implementing these standards also. If a supplier repeatedly or seriously breaches these standards, you exclude this supplier from further business transactions.
You have an occupational health and safety management system in place in accordance with ISO 45001 or equivalent. Implementing an occupational health and safety management system includes: risk assessment, risk minimization, systematic and complete description of process workflows, identification of requirements and efficient implementation, regular monitoring and assessment. In addition, our partners must adhere actively to the principles of occupational health and safety, both when selecting suppliers and in the conduct of their business relationships.
We act with integrity in business, and our behavior complies with our moral principles and values.

We defined stricter “Occupational Health and Safety Standards” for our contractors and made them mandatory in our procurement contracts. Important parts of this standard are the strict supplier selection and intensive training in each case before the contractor starts working on a Siemens Energy site/project.

Health and safety management system – categorization according to the supplier’s size or type of activities

The supplier’s relevance and responsibility in terms of occupational health and safety depends essentially on the type of activities that its employees perform. A distinction is therefore made between suppliers that perform solely administrative/management or advisory functions, e.g. sales- and marketing-related activities (category 1), and those who also manufacture products or in any other way process or rework products (category 2 or 3).

Category 1 suppliers are expected to provide evidence of compliance with following occupational health and safety requirements:

Availability of safety specialists.
Instruction and training for employees.
Conducting risk assessments and risk control measures.

In addition to the requirements in Category 1, we expect Category 2 suppliers to provide:

Written statement of commitment to occupational health and safety by the company`s management.
Written assessment of and plan for compliance with legal requirements.
Written emergency plan.

Additionally, Category 3 suppliers have to show evidence of implementation of an occupational health and safety management system.

Employees as well as companies’ stakeholders need the possibility of reporting misconduct – if necessary, anonymously.

We therefore ask our partners to implement a grievance mechanism which can, depending on the size of the company, vary from a complaint box to a sophisticated electronic tool and/or access to an external ombudsperson.

A grievance mechanism must ensure anonymous reporting and must guarantee no negative consequences for all those who report a possible misconduct or a reasonable suspicion.

Practical actions for implementing a Grievance Mechanism may involve:

Nominating a company responsible who is setting up a complaint process.
A roadmap for remediation and resolving complaints.
Timelines for resolving grievances. Processes to respond to complaints if agreement is not reached or if its impacts are particularly severe.

Compliance Hotline "Speak up"

The compliance hotline “Speak up” is a secure way of reporting potential compliance violations. Reports can be submitted at any time of the day or night, anywhere in the world, in a safe, confidential and if desired, anonymous manner, either online or by telephone, in up to 13 languages. The call center and website are operated by an external provider specializing in the secure and confidential handling of sensitive content. Incoming reports are not traced and reporting parties are not automatically registered. The content of incoming reports is forwarded by the service provider to the Siemens Energy Corporate Compliance Office for clarification. The decision on further actions to be taken is made there. All reports are treated confidentially.

"Speak up" (Secure external internet server)

Ombudsperson

In addition to the compliance hotline “Speak up”, possible compliance violations can also be reported to the Siemens Energy ombudsperson. The attorney Dr. Sibylle von Coelln of the Dusseldorf law firm of HEUKING · VON COELLN Rechtsanwälte has been appointed to serve as an external ombudsperson for the company, in order to give employees a protected reporting channel for possible compliance violations. All our stakeholders can contact this impartial individual on a confidential and anonymous basis if they have observed any improper business practices in the company:

Dr. Sibylle von Coelln
Rechtsanwältin
HEUKING ∙ VON COELLN Rechtsanwälte
Prinz-Georg-Straße 104
40479 Düsseldorf
Tel: +49 211 44 03 57 76
siemensenergy-ombudsperson@hvc-strafrecht.de

“Speak up” can be reached via a secure external Internet server.

Siemens Energy environmental protection policy is based on global standards for environmental management. Where our products are concerned, we take a holistic approach to environmental protection, ensuring that all products are environmentally compatible during the whole product life cycle, from development through manufacturing and use, to reuse, recycling or disposal. We also expect you, our partners, to make every effort to protect the environment, and to keep the impact your activities have on it as low as possible. Among other things, we expect your environmental management policy to include the efficient use of energy and other resources.

Antitrust law protects free, undistorted, and effective competition for the benefit of customers, companies, and society as a whole. Antitrust laws, amongst others, prohibit agreements and concerted practices between companies that restrict competition. Anticompetitive agreements include bid rigging, price agreements, market, customer, or territory allocations, and project agreements with competitors. Abusing a dominant position is also prohibited. Siemens Energy has a strict policy to act in compliance with antitrust laws and expects its contractual partners to do the same.

Inter alia, we expect you to handle confidential information from Siemens Energy and third parties, such as competitors, customers, and sales partners, with care. Furthermore, Siemens Energy expects its partners to respect the intellectual property rights of others, e.g. copyrights, patents and trademarks and trade secrets and to act within the limits of licenses granted (e.g. with respect to software).

We expect from you, our partner:

To act in accordance with national and international antitrust laws and e.g. not to participate in price fixing, market or customer allocation, market sharing or bid rigging with competitors.
To respect trade secrets and the intellectual property rights of others.

Conflicts of interest can hinder the success of a company, lead to economic damages and also tarnish the company’s reputation if they become public, for instance, if the conflict of interest leads to uneconomical decisions, if customers go elsewhere because they lose confidence in the integrity of the company or if restricted information is disclosed as a result.

Siemens Energy’ partners undertake:

To make business decisions in the best interests of the company and not on the basis of personal interests.
To anticipate and avoid situations in which the appearance of a conflict of interest may arise.
To avoid engaging companies with which personal interests exist if it could personally benefit the partner.
To inform Siemens Energy of any personal interest that might exist in connection with the business relationship.
To establish measures which prevent conflict of interests.
To avoid their employees using their position to offer gifts, invitations or other advantages to Siemens Energy employees or other third parties. This does not apply to occasional gifts of purely symbolic value or meals or entertainment of appropriate value.

In addition to monetary support, terrorism financing may include other assets such as goods or merchandise. Siemens Energy strives to maintain business relationships only with reputable customers, partners, and companies whose business activities comply with legal requirements and whose financial resources are of legitimate origin.

How do you, as a partner, actively support us?

You support us in identifying relevant shareholder(s), ultimate beneficial owner(s) and legal representative(s), when necessary.
You take appropriate, risk-based measures to verify the identity and economic background of your customers, business partners, and other third parties, and the origin of payments to ensure they come from legitimate sources.
You follow up on suspicious business relationships, activities, and transactions immediately and report those to law enforcement authorities, when necessary.

Siemens Energy’ partners undertake not to facilitate money laundering or terrorism financing, directly or indirectly

The protection of personal data plays an important role in our digitized world. The loss or improper use of personal data can have serious consequences for the individuals concerned. It is therefore very important for Siemens Energy to ensure that this data is effectively protected and used only for legitimate purposes.

We expect from our partners:

To collect and process personal data confidentially, only for legitimate, predetermined purposes, and in a transparent manner.
Only process personal data if it is protected against loss, modification, and unauthorized use or disclosure by appropriate technical and organizational measures.
Immediately inform our company’s local Data Protection Organization of possible data protection violations in connection with Siemens Energy business

We expect from our partners:

To provide us with the applicable product-related export control classification numbers, harmonized system numbers, country of origin and, if asked, for free trade preferential origin.
To avoid purchasing products from sanctioned persons, companies or organizations, and in order to be able to continue to jointly employ efficient and secure import and export processes, their support concerning customs-related supply chain security programs and its requirements.

Compliance with these regulations is essential to protect Siemens Energy and our global operations. In the same way, Siemens Energy expects from its partners that the applicable foreign trade regulations are carefully complied with when goods are traded or transported, services are provided, or other technical know-how or software is transferred, including checking regulations on EU and US sanctions lists.

Until the present day, trade with minerals in Conflict-Affected and High-Risk Areas (CAHRAs) is affected by violent conflicts and violation of human rights, especially in the Democratic Republic of the Congo and its adjoining countries (the DRC region). The local population is facing systematic exploitation in the fight between armed groups for control of the mines and trading routes. Siemens Energy is committed to ensuring that minerals contained in its products are sourced with due respect for human rights, that sourcing those minerals does not contribute to any risk defined in Annex 2 of the OECD Due Diligence Guidance, and that Siemens Energy supply chain practices support the development in the CAHRAs.

For our partners too, a large proportion of the value added is generated in the supply chain. It is therefore important to us that they take active steps to promote and implement compliance with our Code of Conduct or their own equivalent code of conduct in their supply chain. For this reason, we expect our partners not only to comply with the Code of Conduct in their own organization but also to ensure in turn that their suppliers adhere to the international standards summarized in the Code of Conduct. Our values as well as increasing legislation expect companies – in particular, multinational enterprises – to conform with international standards. The ‘OECD Guidelines for Multinational Enterprises’ and the respective ‘OECD Due Diligence Guidance for Responsible Business Conduct’ explain the international expectations and possibilities to implement necessary processes.

Siemens Energy operates in areas of business that are of major importance for today‘s society. These areas are all closely aligned with the guiding objectives of business sustainability: greater security, more efficient use of resources, and long-term environmental and social compatibility. Siemens Energy sources goods and services worth approximately half of its yearly revenue in more than 150 countries – a huge source of business for suppliers all over the world. Sourcing goods and services on this scale – in a variety of markets and for a large number of locations – poses major challenges to our Supply Chain Management and exerts a significant influence on the environment, societies and local economies in which we operate. An integrated Supplier Management creates the conditions for the common optimization of this value chain. It ensures our global competitiveness and our adherence with our broad sustainability requirements.

Siemens Energy code of conduct for suppliers

Sustainability in the Siemens Energy Supply Chain brochure

Siemens Energy’ global activities entail collaboration with many different partners all over the world. Mutual trust is essential to these relationships.

Siemens Energy Code of Conduct

Legal compliance

Human rights and labor practices

Management system for occupational health and safety

Health and safety management system – categorization according to the supplier’s size or type of activities

Management system for occupational health and safety

Employees as well as companies’ stakeholders need the possibility of reporting misconduct – if necessary, anonymously.

Compliance Hotline "Speak up"

Ombudsperson

Environmental protection

Management system for environmental protection

The following questions can help an employee to assess whether there is a conflict of interest or an appearance of a conflict

Siemens Energy code of conduct for suppliers

Sustainability in the Siemens Energy Supply Chain brochure

Siemens Energy’ global activities entail collaboration with many different partners all over the world. Mutual trust is essential to these relationships.

Siemens Energy Code of Conduct

Legal compliance

Human rights and labor practices

Management system for occupational health and safety

Prohibition of forced labor

Non-discrimination and respect for employees

Respect for employees working hours, wages & benefits

Health & safety of employees

Management system for occupational health and safety

Grievance mechanism of partners

Environmental protection

Management system for environmental protection

Prohibition of corruption and bribery

Respect fair competition, antitrust laws and intellectual property rights

Awareness of conflicts of interest

Prohibition of money laundering and terrorism financing

Respect data privacy

Observe export control and customs regulations