Compliance

Understanding compliance in the Volkswagen Group includes: Adherence to legal requirements, internal corporate policies, ethical principles, and self-imposed values for the protection of the company and its brands.

In the long term, a company can only be successful if it acts with integrity, complies with statutory provisions worldwide, and stands by its voluntary undertakings and ethical principles, even when this is the harder choice. We remain committed to this principle and compliance must be second nature to all Volkswagen Group employees.

Volkswagen takes a preventive approach to compliance, which heightens employee awareness and knowledge in order to prevent potential rule breaches before they happen. In 2015 and 2016 alone, over 380,000 employees across the Group received training on compliance issues. Group Internal Audit and Group Security complete systematic compliance checks, conduct necessary investigations on a regular basis, perform spot checks in the absence of suspicion, and examine the circumstances in cases of alleged misconduct. Human Resources and Group Legal respond by applying the relevant measures. These processes are closely integrated to form a holistic compliance management system. However, we are aware that even the best compliance management system can never fully exclude the possibility of criminal action by individual employees.

The section further explores the following compliance topics:

  • The Volkswagen Group Code of Conduct for Employees
  • The Volkswagen Group Code of Conduct for Business Partners
  • The Volkswagen Group Anti-Corruption Guidelines
  • The Volkswagen Group Whistle-blower System

Code of Conduct for Employees

The Code of Conduct is a common set of guidelines for all employees in the Volkswagen Group. It helps in complying with existing rules and regulations and offers guidance, advice and support in everyday work situations and decision-making. The focus is on the responsibility of each individual employee to comply with the rules of ethical conduct.

The Code of Conduct is based on shared values. It is a guide that incorporates both legal requirements and the Company’s own regulations. The focus is on honest, ethical conduct, integrity, and the issue of “responsibility” in general. Whether at work, in your role as a business partner, or as a member of society – the Code of Conduct is aimed at making it easier to deal with existing rules in the Company and at providing help and guidance in delicate situations.

Hiltrud D. Werner, Board Member of the Group Board of Management for Integrity and Legal Affairs, highlights the significance of the Code of Conduct: “It is our joint responsibility to breathe life into the concept of “integrity” at Volkswagen. Specifically, this means that we should all know the existing rulesets, act responsibly, and make the right decisions”. The content of the Code of Conduct has been updated, expanded and sharpened. The revised version also takes into account the frequently expressed wish for transparent and clear rules on ethical conduct. The new structure is well laid out, and the texts are easy to understand and concise. There are plenty of practical examples to help you apply the Code of Conduct in everyday practice.

Code of Conduct for Business Partners

The following requirements define the Volkswagen Group’s expectations regarding the way business partners act in their corporate activities. The requirements are considered a basis for successful business relations between the Volkswagen Group and its partners.

Anti-Corruption Guidelines

Corruption is not a trivial offence. It could damage the company, its business, and its employees. Raising awareness and improving understanding therefore plays an important role. The Volkswagen Group offers a number of training courses and support channels for its staff. It has also drawn up its own guidelines covering the issue of anti-corruption.

The aim of these guidelines is to make every employee more aware of corruption and highlight its importance.

Whistle-blower System

Complying with statutory regulations and internal rules has top priority at Volkswagen. We can only avoid damage to our company, our employees, and business partners if rules and standards are respected. Consequently, misconduct must be recognised swiftly, processed and immediately remedied.

That calls for vigilance on the part of everyone along with a willingness to draw attention to possible serious regulatory violations based on concrete evidence. We also value information of this nature from business partners, customers and other third parties.

The Whistle-blower system guarantees the greatest possible protection for whistle-blowers and persons implicated. An investigation is only initiated after very careful examination of the facts and concrete evidence of a regulatory violation. There will be strict confidentiality and secrecy throughout the investigative process. Information will be reviewed fairly, promptly and in a sensitive manner.

Where do I send my report?

The Whistle-blower system is available as a point of contact to all persons including employees, franchisees, business partners and/or suppliers, who are willing to report confidential evidence of suspected crimes of this type or of similarly serious irregularities relating to the Volkswagen Group.

You have the option of using an internet-based communication platform to contact the Investigation Office, exchange documents and conduct a dialog with the lawyers via a separate mailbox. This system is confidential and protected. Whistle-blowers can decide for themselves whether they wish to give their names. If you would like to send a confidential report to the lawyers in the Investigation Office you can use the secure reporting channel to submit a report.

Phone

You can contact us by phone (German and English) using the international toll-free number:

+800 444 46300.

If your local telephone provider does not support the toll-free service, you can call the following chargeable number:

+49 5361 946300.

Please note that personal and traceable data such as the phone number may be transmitted indirectly when making a phone call. This data could reveal the identity of the caller.

E-mail

You can get in contact with the Investigation Office of the Volkswagen Group via E-Mail:

io@volkswagen.de

Please note that personal and traceable data such as the IP address may be transmitted indirectly when sending an e-mail. This data could reveal the identity of the sender. This also applies to e-mail accounts created especially for this purpose.

Postal Address and in-person

Ombudspersons of the Volkswagen Group

Dr. Rainer Buchert and Thomas Rohrbach, the external ombudspersons appointed by the Volkswagen Group, act as special counsel to accept reports of potential statutory or internal violation of regulations or any other kind of harmful conduct in the Group, and to review these with respect to plausibility and substantiality. They consult with the whistle-blower if necessary and if the identity of the whistle-blower has been identified. Finally, they forward all the information that has been agreed with the whistle-blower to the Investigation Office for further processing.

All information is treated as confidential and it is the whistle-blower who decides whether he or she wishes to protect his or her identity vis-à-vis the Group. The ombudspersons appointed by the Group ensure that reports from whistle-blowers who do not wish to be identified by the Company are forwarded to the Investigation Office anonymously.

If you want to get in contact with the Ombudspersons you can find their contact point on the following homepage:

http://www.ombudsmen-of-volkswagen.com/

How do I make a report?

It is important to make sure the information contained in the report you submit to the Investigation Office is as concrete as possible so that it can be processed and investigated in the appropriate manner. It is helpful if your report covers the following five questions:


  • who?
  • what?
  • when?
  • how?
  • where?


Please make sure that the descriptions contained in your report can be easily understood by persons who are not specialists in your field. Maybe you would be available to answer further questions? That would be very helpful. If you would be willing to do so, but wish to remain anonymous and do not wish your identity to be disclosed to the Company, please contact the ombudspersons to make your report.