Siemens Medical Solutions Diagnostics Global Compliance Program ensures its employees conduct business with the utmost integrity and in strict adherence to the laws and regulations of every place we operate, regardless of the business outcome. This commitment is exemplified through the strong leadership of the company.

As a Siemens employee or contractor, you are a representative of the values that the company demonstrates as it conducts business globally. The detailed policies and procedures that have been developed and updated for Siemens Medical Solutions Diagnostics provide all employees and contractors with direction on the appropriateness of conducting business without compromising our integrity and ethics. Some of the key policies and procedures to help guide our daily interactions include:

• Policies and Procedures
  This governs our behavior and interactions with our customers. This is applicable in the US only.
  
• Code of Conduct
  Our Compliance Program contains information about the Siemens Code of Conduct, which
  expresses our fundamental values.
  
• International Business Ethics and Compliance Program
  International Business Ethics and Compliance Program focuses on ensuring compliance for
  our international employees as they conduct their business affairs
  
• Business Conduct Guidelines
  The Business Conduct Guidelines are globally binding rules applicable to all employees.
  This manual details our Policies and Procedures around topics such as Free Goods,
  Business Meals, Gifts, Charitable Contributions and Educational Grants and Distributor
  Relationships.

Compliance Committee

Siemens Compliance Program is led by our Chief Compliance Officer, Daniel Garen. The Compliance Committee, which is comprised of senior members of the executive team, is supervised by Mr. Garen. His mandate is to implement a comprehensive Compliance Integration Plan, which includes policy promulgation, training, investigations and promoting awareness of compliance tools. The charter of the Compliance Committee was fully adopted as of February 23, 2007.

Compliance Training

Siemens provides regular compliance training to its Local Compliance Officers, employees, officers and vendors in the various regions. Training has included classroom education, where participants interact to discuss fact patterns and case studies, and online training modules for all employees. Existing employees as well as newly hired employees will also be required to take refresher compliance training periodically.
For more information about the Compliance Training available, please contact your Local Compliance Officer or send an email to
dxcompliance.med@siemens.com

Communication

All employees, contractors, officers, and vendors are encouraged to discuss all compliance violations, issues, or concerns with their manager or other manager / supervisor without fear of retaliation. Employees, contractors, officers and vendors should also be assured that the matter(s) discussed will be kept confidential.
Other reporting mechanisms include:

• Siemens Compliance Hotline:
  The Compliance Hotline is an anonymous vehicle that can be used to report ethical violations and concerns or to provide visibility to a potential problem. The Compliance Hotline is available 24 hours a day, 7 days a week.
  
  In the United States, you can dial the Hotline toll-free at 1.866.637.4448.
  
  If you are calling from outside the United States, you will need a reference code to be able to dial this toll free number. Please follow the steps on this website to obtain a reference
  http://www.business.att.com/bt/tollfree.jsp for your country.
  
  Once you dial the reference code, wait for the tone or prompt and then dial 1.866.637.4448.
  
  Siemens Medical Solutions Diagnostics utilizes an independently contracted third party to handle all calls into the Hotline. The calls are not traced and all callers can remain anonymous if they choose. The Compliance Hotline Representative gathers all of the information when you call, reviews the information collected with you, and forwards the issue to the Siemens Compliance Office. Callers can indicate if they would like to call back to get an update on the issue.
• Siemens Compliance E-Mail:
  The Siemens Compliance team has set up an email address dxcompliance.med@siemens.com
  to address any inquiries that are forwarded to this mailbox.
• Contacting the Chief Compliance Officer (CCO):
  The Chief Compliance Officer is actively engaged with all of the regional Local Compliance Officers as well as employees at all levels in the organization. Emails to the
  dxcompliance.med@siemens.com mailbox will be routed to the CCO.
• Management Reporting on Compliance:
  The CCO provides senior management with a weekly and monthly dashboard highlighting
  the progress on all compliance projects and initiatives. Management is also engaged in
  discussions around compliance issues and resolutions on an ongoing basis.
• Communication with the Compliance Committee:
  The CCO sets an agenda of compliance related topics to discuss with the Compliance
  Committee on a periodic basis. This ensures that proper communication of significant
  issues are presented and escalated to the committee expediently.

For all other inquiries, send an email to:
dxcompliance.med@siemens.com

Monitoring and Auditing

Monitoring and auditing ensures that Siemens continues to evaluate the effectiveness of its Compliance Program. It also ensures that the organization solves for any gaps in the integration of Compliance Policies and Procedures. This has included FCPA Audits in some countries.

Accountability and Enforcement

The Siemens Code of Conduct, Siemens International Business and Ethics Compliance Program, Siemens Business Conduct Guidelines and FCPA FAQs are tools that have been deployed to educate employees, contractors and vendors about our company’s focus on ethical and appropriate business practices. Compliance is taken very seriously at Siemens. Failure to comply with set standards, policies and procedures may result in disciplinary ramifications, which may include suspension and/or termination of employment. Appropriate action is taken after a detailed investigation has been completed.

Response & Prevention

It should be the expectation of every associate of Siemens Medical Solutions Diagnostics that all compliance issues that are reported or escalated via one of the identified communication vehicles (the toll-free Hotline number, emailing the Compliance mailbox, contacting the Chief Compliance Officer, management discussions, etc.) will be reviewed in detail, investigated and resolved expeditiously.