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Guideline<br />
Siemens in its Business Conduct Guidelines forbids the offering, promising or<br />
granting, directly or indirectly, of any unjustified benefit to any public official or private<br />
commercial counterparty to influence official action or to obtain an improper<br />
advantage.<br />
This prohibition applies without exception likewise to so-called facilitation payments,<br />
as these are equally detrimental and usually pave the way for even more serious<br />
corruption issues. However, employees and management experience uncertainty<br />
handling this commonplace form of corruption.<br />
Unrestricted © Siemens AG 2015 All rights reserved.<br />
Page 2<br />
July 2, 2015<br />
Dr. Klaus Moosmayer, CCO<br />
Panel II – Tackling Facilitation Payments in Corporations<br />
36
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