Code of Ethics for Financial Matters

This Code of Ethics for Financial Matters applies to the Chief Executive Officer, the Chief

Financial Officer and the Head of Financial Reporting, controlling Department of the parent

company, Siemens AG, as well as toall company employees performing similar functions in and

outside Germany and to all other employees handling financial matters who are not subject to

German works council codetermination regulation. The Code comprises rules regarding individual

responsibilities within a framawork of proper and effective checks and balances -- for example,

the Siemens four-eyes-priciple, which requires the financial function to exercise independent

judgment and control. In particular, the individuals subject to the Code are required to:

   (1)  act with honesty and integrity avoid and apparent conflicts of interest

         in personal and professional relationships;

   (2)  ensure the timely and accurate documentation in the financial statements

         of all business-related occurrences, in full compliance with all applicable

         interal rules, guidelines and accounting regulations(U.S. GAAP);

   (3)  provide full, fair, accurate, timely and understandable disclosure in reports

         and documents and in all other public communications;

   (4)  act responsibly and in good faith and with due care, competence, prudence and

         diligence, without misrepresenting facts or allowing their own judgments and

         decisions to be subordinated to or guided by extrinsic considerations, such as

         aspects of compensation; in case of doubt, each decision should reflect a

         conservative evaluation of business transaction;

   (5)  ensure responsible use of, and control over, all assets and resources entrusted

         to, used or owned by Siemens;

   (6)  promote proactively ethical behavior as a responsible partner among colleagues

         and subordinates;

   (7)  comply with all applicable laws, guidelines and regulations;

   (8)  share appropriate knowledge and maintain relevant skills relating to the needs

         of internal and external business partners;

   (9)  assume responsibility for compliance with this Code of Ethics for Financial Matters;

         and

   (10) report promptly every violation of this Code of Ethics for Financial Matters and

         every explicit or implicit approval of the failure to the Corporate Officer for

         Compliance (COC) or to the Compliance Officer of the relevant Siemens unit, whereby

         departure from a provision of this Code of Ethics for Financial Matters will constitute

         implicit approval.