OSRAM emphasizes its responsible business conduct in every country in which we operate. Abiding by laws and official rules is a basis for successful and sustainable business. Any illegal and unlawful behavior within the company will not be tolerated. We demand from all our employees and executives to behave ethical and lawful amongst ourselves as well as externally towards our customers, partners and suppliers. To further ensure transparency, compliance must become part of our corporate culture. We herewith enter a new area of business culture . OSRAM closely coordinates its compliance and anti-corruption efforts with Siemens. This ensures a professional application within the company.

Worldwide Compliance Perception Survey
In 2008 OSRAM conducted a worldwide compliance perception survey under 1,000 randomly chosen employees throughout the world representative for all regions. In order to get a clear view of the status of the company’s compliance culture, the following categories have been evaluated: compliance practices, compliance impact, management culture, compliance communication, employee engagement. This survey is planned to be conducted annually for the purposes of evaluating how firmly compliance measures are embedded in our organizational culture. It will be utilized as the basis for defining and implementing continuous improvement strategies within this discipline.
With a participation rate of 41 percent, OSRAM is below Siemens average. However, our results in total are slightly better than average.
Here is a short extract of our results both positive and negative that were differing most from the Siemens average:

Top differences from Benchmark – some of the statements from OSRAM employees are well above the Siemens average:

* “I am proud to be part of OSRAM.”
* “Focus on compliance will give OSRAM a real competitive advantage in our markets in the long run.”
* “Top management sets the right tone on importance of compliance and ethical behaviour.”

Bottom differences from Benchmark – we must focus on improving our performance in these areas:

* “I have a clear understanding to address our helpdesk “Ask us / Tell us” in cases of non-compliance.”
* “My immediate manager addresses compliance matters regularly in our meetings.”

These results show a rather clear picture of how Compliance is being seen and handled with in our organization. On the one hand the need for a focus on compliance is fully understood and the management sets the right tone on its importance. On the other hand though, communication can still be improved. The handling of formal compliance processes is becoming the norm in day-to-day business. All in all, the results call for more that needs to be done to raise the appropriate awareness for compliance and confidence in handling it.

Our challenge:
Raising awareness about compliance and transparency throughout the organization is an important step towards improving the handling of compliance matters. Hence, a global roll-out of web-based anti-corruption trainings already started in 2008 and is to be continued in 2009. Another step that is necessary is simplifying our internal compliance guidelines, especially with regard to presents, incentives and hospitality.
In addition, executives must act as role-models for their employees. They are to carry out their duty of setting an example and lead the way to a responsible handling of certain subjects.
To ensure reaching our goals mentioned above, it is vital to train our workforce top down and raise awareness about the importance of compliance for our business. One key-factor is that employees in management positions act as compliance ambassadors and guide their employees the way how to proceed with this subject and taking it seriously.
Our compliance department is constantly working on improving our internal compliance guidelines to making them more transparent and therefore easier for our employees to stick to. In the end, everyone should be confident in handling and implementation.