Compliance

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OSRAM does not tolerate corruption, illegal or unethical behavior. This is laid out in our Business Conduct Guidelines, which constitute a binding document for all our employees. We do not leave it at that however: Our compliance organization is carrying out compliance training, and our operational units are checked by internal audits.

Training
Different types of training are carried out at OSRAM, depending on the function of the employee trained. The roll-out of these trainings is continuing smoothly, starting with our headquarter in Munich and expanding globally.
• Training for senior management takes place as an in-person training covering Anti-Bribery and the Foreign Corrupt Practices Act (FCPA), Gifts & Entertainment, Competition Law, and the process of possible investigations. A total of ?? managers were trained in 2007, 100% of relevant senior managers.
• A web-based training was implemented for employees with signing authority, employees in management positions, and employees with direct contact to customers. The training covers anti-bribery laws and the principles of global fair competition. 2007 saw 500 employees taking this training in Germany, with the global roll-out to follow in 2008.

Cooperation with SIEMENS

OSRAM closely coordinates its compliance and anti-corruption efforts with SIEMENS. This ensures a professional application within the company, following the ‘Tone from the top’ strategy.

Handling of Complaints

In addition to the compliance office at OSRAM and a compliance Helpdesk shared with SIEMENS, an external ombudsman has been established to allow employees and third parties to report any incorrect business practices in the company. This provides a protected communication channel on a confidential and anonymous basis. The contact details:

Attorneys Dr. Beckstein & Colleagues
Attorney Hans-Otto Jordan
Thumenberger Weg 12
90491 Nuremberg, Germany
Tel.: (+49 911) 5984020

Further information
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