Delegating Authority
The Compliance Ambassador
Program at Siemens Industry, Inc.
April 27, 2012
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Agenda

Assessing the need for a Compliance Ambassador (COA)
Program

Benefits for the Company

Mission Statements

Desirable attributes, roles, & responsibilities of a Compliance
Ambassador

Implementation process

Benefits for Compliance Ambassadors

Lessons learned

Q&A
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Siemens Compliance Office
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Assessing the Need For A Compliance Ambassador
Program: National Presence
Headquarters:
Buffalo Grove, IL
 Over 120 offices
 8,741 employees
 More than 5,000
service vehicles
Compliance
Ambassador
Location
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Siemens Compliance Office
Benefits for the Company

Establish network of contacts to serve as local compliance
champions

Establish a conduit between compliance and the business

Ensure that compliance communications reach employees
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Mission Statements
The mission of the Compliance Ambassador Program is to assist the
Divisional Compliance Officer (DCO) by bringing Compliance closer to
the business as an advocate to support the role of the DCO as a
trusted adviser. The Compliance Ambassadors serve as
communication conduits between the DCO and the business, actively
promoting a culture of integrity and responsibility thereby protecting
the employees and safeguarding the Company’s assets. In this role,
the Compliance Ambassadors report to the DCO who retains
complete compliance governance.
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Desirable Attributes, Roles, & Responsibilities
Compliance Ambassador should possess the following
attributes:

Leadership

Business competence

Knowledge of internal policies and guidelines

Respected

Knowledge of compliance tools

Communication Skills

Conflict management skills
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Desirable Attributes, Roles, & Responsibilities
Limited Delegation of Authority:

Compliance Ambassadors can be given responsibility to carry
out certain duties

Compliance Department retains ultimate decision-making role
and responsibility

Maximize effectiveness of Compliance program and minimize
risk that flawed advice is given
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Desirable Attributes, Roles, & Responsibilities
Compliance Ambassadors do:

Act as local compliance champions

Serve as the local “representative” for compliance

Ensure targeted and necessary communications reach
employees (e.g. “Compliance Week”)

Support Compliance Officer with special projects

Direct employees with compliance concerns or allegations to
the Compliance Officer or a whistleblower hotline

Build knowledge and best practice sharing through regular
meetings

Channel feedback and improvement ideas from the business
to the Compliance Organization
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Desirable Attributes, Roles, & Responsibilities
Compliance Ambassadors do not:

Counsel management and employees or provide independent
Compliance advice

Participate in investigations or Compliance cases

Review or approve business transactions from a Compliance
perspective using compliance tools

Represent Compliance in audits or operational reviews

Perform Internal Compliance Standards (ICS) checks
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Implementation Process

Executive Management approval of concept

Determine the ideal number of COA’s for the entity

Request that sub-units identify potential COA candidates and
confirm that no HR issues exist

Interview candidates

Company President and Compliance Office send appointment
letters to the COA’s selected

Kick-off event

Welcome by Executive Management – explain potential
benefits to COA’s career

Provide background of program and training

Inclusion and brainstorming

Have fun
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Process for Implementation (continued)

Promotion of the Ambassadors

Communication campaign within Divisions

Regular COA meetings and feedback sessions (via phone or
in-person)

COAs participate as guest speakers during division training
sessions and meetings

Consider creation of reward system
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Benefits for Ambassadors

Networking - allows Ambassadors to meet employees from
other Divisions and/or geographic areas

Enhances Ambassadors’ own career prospects since they gain
a deep and valuable understanding of their company as well
as Compliance and Compliance-related issues

Gives Ambassadors a direct stake in the company’s public
perception
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Lessons Learned

Secure executive management approval and support early

Make sure the selected COAs cover a diverse spectrum of
authority and subject matter

Clearly define roles and responsibilities

Fixed, short-term [renewable] appointments

Ensure that COA’s are themselves interested in the position
and are not simply participating because they were told to do
so by a manager
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Q&A
Douglas Doty
Compliance Officer
Siemens Industry, Inc.
Infrastructure & Cities Sector
1000 Deerfield Parkway
Buffalo Grove, Illinois 60089
Telephone: 847.941.5883
Email: douglas.doty@siemens.com
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