Code of Conduct VWFS CZ 2024 by Volkswagen Financial Services

OUR CODE

TABLE OF CONTENTS

WE ARE ONE

WE ARE COMMITTED INDIVIDUALS

WE ARE RESPONSIBLE PARTNERS

1.1

Human rights

3.1

Conflicts of interest

1.2 1.3

Ethical leadership Diversity, equal opportunities

3.2

Benefits

3.3

Prohibition of corruption

and equal participation

3.4 3.5

Prohibition of insider trading Prohibition of money laundering

1.4

Speak Up

1.5

Employee representation

and terrorism financing 3.6 3.7

Fair and free competition Business partners, procurement and sales

WE ARE RELIABLE COLLEAGUES

3.8

2.1

Occupational health and safety

3.9

2.2 2.3

Handling Company assets Security and protection of

Accounting and financial

information, know-how and

Export control

WE ARE GOOD CORPORATE CITIZENS

intellectual property 4.1

Communication and marketing

4.2

Political lobbying

4.3

Dealings with public officials

4.4

Donations and social sponsorship

4.5

Taxes and customs

4.6

Data protection

4.7

IT security

4.8

Product Compliance

4.9

Environmental protection

SUPPORT

TABLE OF CONTENTS

reporting

GROUP ESSENTIALS

We take on responsibility for the environment and society.

We are honest and speak up when something is wrong.

We break new ground.

We live diversity.

We are proud of the work we do.

We not me.

We keep our word.

GROUP ESSENTIALS

The Group Essentials are our Group’s foundation of values that connects all people in all brands and companies. They form the basis of our corporate culture.

WE ARE ONE

We are one

Our fundamentals for Integrity and Compliance

The Volkswagen Group Code of Conduct,

intelligence. Transparency is important to us

OUR CODE, is the ethical and values-based

and our approach to innovative technologies

foundation for acting with integrity and

ensures that users‘ rights and security are

in compliance with the rules in our Group.

respected.

It serves as a binding guideline for all employees in all brands and companies

We do not tolerate violations of the Code

– all over the world.

of Conduct. Anyone who violates our rules make sure that does not happen we seek

collaboration, our workplace, the environment,

advice and support so that together, we

sustainability, and society. We approach one

protect our Company, its values, and the

another and everyone else with respect and

reputation of all the brands.

fairness, as equals. We take a stance, we are steadfast and courageous in standing up

Each of us is personally responsible for

for our values and principles – regardless of

complying with OUR CODE. It is up to all of

time, economic or social pressure.

us to familiarize ourselves with the Code’s principles and to be guided by them in our

We are firmly convinced it is essential for

day-to-day decision-making. For a Group on

each and every one of us – employees,

the move, for the protection of people and

members of the Board of Management and

the environment, and for future generations.

managers – to act with honesty in order to foster trust in our Company, our products, services, and innovations. That is why the decisions we take in all areas of work and in all roles must be in accordance with our corporate values, and comply with valid national and international laws, regulations, and internal voluntary commitments. This also holds true for the continued evolution of our Company as well as the choice, procurement, development, and use of innovative technologies such as artificial

WE ARE ONE

must expect appropriate consequences. To Together, we bear responsibility for our

WE ARE COMMITTED INDIVIDUALS We embrace our corporate values, principles and rules, thus promoting trustful, sincere and fair interaction with one another. We are all role models.

1.1 Human rights 1.2 Ethical leadership 1.3 Diversity, equal opportunities and equal participation 1.4 Speak Up 1.5 Employee representation 8

1.1 Human rights

We take responsibility for human rights CORPORATE PRINCIPLE

MY CONTRIBUTION

Respect for human rights is of paramount

As an employee, I can also make my

importance. We are convinced that

contribution to respecting human rights.

sustainable economic activity is only

I regard human rights as a fundamental

possible by acting ethically and with

guideline, and I am vigilant against human

integrity. Within the framework of

rights abuse that is happening around me

our entrepreneurial activities, we are

or of which I become aware.

regarding human rights. The Group

If I have concerns regarding human rights

Board of Management, the Volkswagen

abuse in my professional surroundings,

Group European Works Council and the

I prevent it or stop it immediately. If

Volkswagen Group Global Works Council

necessary, I inform my supervisor or get

have fulfilled this responsibility in the

in touch with any of the contacts listed in

Group’s Declaration on Social Rights,

the chapter on “Support”.

WE ARE COMMITTED INDIVIDUALS

fully committed to our responsibility

Industrial Relations and Business and Human Rights, known as the Social Charter. We confirm our commitment to major international agreements and declarations, in particular the International Bill of Human Rights and the core labor standards of the

EXAMPLE

International Labour Organization (ILO). Our entrepreneurial activities follow the UN Guiding Principles on Business and Human Rights (UN Global Compact), which determine the most important cornerstones for our actions.

Someone has written to you with information

System of your concerns about human

that one of our suppliers is not paying their

rights abuse. Our Company will examine the

employees their correct wages and is violating

allegations in greater detail and take the

labor law by tolerating 80-hour weeks. In

necessary measures. This may include

addition, the pay of some of the supplier’s

terminating business relations with the

employees is below the minimum wage.

supplier in question.

Inform your superior and the Whistleblower 9

1.3 Diversity, equal opportunities and equal participation

We lead based on our values

We live diversity

CORPORATE PRINCIPLE

EXAMPLE

CORPORATE PRINCIPLE

MY CONTRIBUTION

We embrace our corporate values,

In order to complete a project to schedule,

Diversity, equal opportunities, and equal

I observe the principles of diversity, equal

principles, and rules, take responsibility for

your team would like to skip one step in the

participation are important principles for

opportunities and equal participation and

both personal and corporate growth, and

process. They say the step is unnecessary.

fair, non-discriminatory, and respectful

encourage people around me to do the

lead by example. We perform our duties,

You point out that the valid rules must

coexistence. We believe in cooperation in

same.

and manage our powers and roles in an

be followed, regardless of any pressure.

a spirit of partnership, in tolerance and in

appropriate, fair and responsible manner.

Together, you search for a solution that

mutual respect. We foster diversity in the

If I see any violations of the principles of

That also applies for personal relationships

complies with the requirements and our

workforce and support an inclusive work

equal opportunities and equal participation,

in the workplace, in particular insofar as

values. You undertake to revise the process

environment.

such as unequal treatment, harassment, and

existing employment or hierarchical

in collaboration with everyone involved

dependencies may be exploited. Our

and, where possible, to make it leaner. You

We offer equal opportunities for everyone

of their misconduct. If I am not in a position

decisions are always transparent, show

commit to that as a manager and team

and reject all forms of discrimination.

to directly influence events, I notify the HR

good judgment, are guided by integrity,

member.

This applies in particular to unequal

department of the incident immediately or

and are taken in the best interests of the

treatment due to ethnic or social origin,

get in touch with the contacts listed in the

Company and its employees, business

skin color, biological sex, nationality,

chapter on “Support”.

partners and shareholders. We strengthen

language, religion, ideology, age, physical

trust and shape change in the Company

or mental disabilities, gender identity,

through our values-based leadership.

sexual orientation, political views, or any

bullying, I make the persons involved aware

EXAMPLE

other characteristics protected by law. We

You hear some of the people you work with

live diversity, actively support inclusion,

making disrespectful comments about people

and create an environment that not

on account of their nationality, gender, sexual

only encourages the engagement of all employees, but also fosters each employee’s

orientation, or skin color.

model both within the Company and in a broader context. My conduct and actions

individuality in the interests of the Company.

Either speak up straight away about this

MY CONTRIBUTION I am aware of my function as a role

discrimination or get in touch immediately

are always guided by integrity and a sense of responsibility, and are based on this Code

Our employees are selected, hired, and

with one of the contacts listed in the chapter

of Conduct, our corporate values, principles

developed based on their qualifications

on “Support”.

and rules. I advocate interaction with one

and their skills.

another in a spirit of trust, honesty, and fairness, and I am open to different points

of view.

WE ARE COMMITTED INDIVIDUALS

1.2 Ethical leadership

1.4 Speak Up

CORPORATE PRINCIPLE

MY CONTRIBUTION

We want to learn from mistakes and

My first point of contact for questions,

continuously improve. That is why we

concerns, or the reasonable suspicion of a

speak up about wrongdoings, or as soon

violation of internal or external regulations

as something doesn’t feel right, even if

is my supervisor, or alternatively I can seek

that is awkward and uncomfortable. To

advice from the relevant subject matter

do that, we promote a culture of integrity

experts. The HR department and employee

and actively seek a dialog within our

representatives as well as Compliance are

team and with our supervisors. We seek

also available to provide support. In addition,

advice and support if we have questions

I should report any reasonable suspicion

and problems. We protect everyone who

of Serious Regulatory Violations via the

contributes to this culture.

Whistleblower System. As a Management Level employee, I am obliged to report any such suspicion.

For us, compliance with external and internal rules at all times is a given. We do not tolerate misconduct. We believe that

EXAMPLE

turning a blind eye can never be the right solution. That is why we react immediately

The deadline for a decision proposal

and appropriately to misconduct and

submitted to a committee has expired and

violations of our rules.

you notice that you and your team have made a mistake. You know it is not possible

Managers always lead by example through

to take a meaningful decision on the basis

conduct that is in accordance with our rules

of the data submitted.

and regulations. They perform this important function by supporting employees to comply

Inform your supervisor and the departments

with the rules, promoting an error culture,

responsible for the committee immediately.

and following up on violations.

Jointly find a way to correct the document. In addition, you and your team discuss how such errors can be avoided in future.

WE ARE COMMITTED INDIVIDUALS

We speak up when something is wrong

1.5 Employee representation

We work together in close partnership – constructive, cooperative and fair We recognize the basic right of all employees to establish trade unions and employee representations. We are committed to working with employee representatives in candor and trust, to conducting a constructive and cooperative dialog, and to striving for a fair balance of interests. Professional dealings with employee representatives are part of our corporate culture. Safeguarding the future of the Group and its employees is achieved in a spirit of cooperative conflict management and social commitment, on the basis and with the goal of ensuring economic and technological competitiveness. Economic efficiency and job protection are equal-ranking and shared goals.

WE ARE RELIABLE COLLEAGUES We take our responsibility in the workplace seriously and protect what is valuable for our team, our Company, and our customers.

2.1 Occupational health and safety 2.2 Handling Company assets 2.3 Security and protection of information, know-how and intellectual property

2.1 Occupational health and safety

2.2 Handling Company assets

We respect and promote health and safety

We protect our assets – whether visible or invisible

CORPORATE PRINCIPLE

EXAMPLE

We take our responsibility for the safety and

I make an active contribution to maintaining

We respect the Company’s tangible and

High-end software is installed on your

health of our employees very seriously. We

and promoting my health by voluntarily

intangible assets and do not use them

business laptop. A friend who knows this

promote occupational health and safety

participating in preventive healthcare

for non-business purposes, but solely to

asks you to lend them your laptop so that

in line with the provisions of national laws

and health promotion activities. I follow

achieve the Company‘s business objectives.

they can use one of these programs for

and regulations and with the occupational

instructions, attend training, and align my

Exceptions are possible if internal policies

private purposes.

health and safety policy of the Company.

daily actions with them.

and guidelines permit private use.

Occupational health and safety for all

EXAMPLE

MY CONTRIBUTION

sustainable future for our Company and to

You notice that a device in your department

I adhere to the Company’s rules and exercise

positioning our Company as an attractive

appears to have an electrical defect.

care when handling Company assets.

property and Company IT may not be made

employees is fundamental to ensuring a

available to third parties.

employer. All accidents at work and workrelated illnesses are generally preventable.

Do not activate the device and notify the

We therefore aim to ensure the protection

responsible supervisor to coordinate further

and promotion of physical and mental

measures. It is not permitted to repair

health. This requires the cooperation and

electrical equipment yourself because this

participation of all.

might be dangerous.

MY CONTRIBUTION I comply with occupational health and safety regulations and instructions. I do not endanger my own health and safety or that of my team or third parties. I support them, do not look the other way, and accept help. Within my area of responsibility, I take all appropriate and statutory measures to ensure a safe working environment. I draw attention to unsafe actions or conditions.

WE ARE RELIABLE COLLEAGUES

You say no, because you know that Company

2.3 Security and protection of information, know-how and intellectual property

We protect information and intellectual property

CORPORATE PRINCIPLE

EXAMPLE

We are aware of the value of Company

You are involved in the development of an

know-how and take great care to protect

innovative technology. You are to present

it. We respect the intellectual property of

your development at various Company sites

competitors, business partners and other

and want to take your laptop, which you

third parties.

have used to store the relevant documents, WE ARE RELIABLE COLLEAGUES

with you for presentation purposes. You intend to go over these documents again

MY CONTRIBUTION

on the plane or the train on the way to the various sites.

I handle all Company information carefully and do not disclose it to unauthorized persons. I take particular care with regard

You must make sure that no one obtains

to information relating to technical know-

knowledge of sensitive information belonging

how, patents, and trade and business

to the Group, as this could lead to serious

secrets.

competitive disadvantages. Do not retrieve this type of information in places where third parties can access it or take note of it.

WE ARE RESPONSIBLE PARTNERS Trust is our greatest asset. That is why we rely on honest, reliable, transparent, and fair business relationships.

3.1 Conflicts of interest 3.2 Benefits 3.3 Prohibition of corruption 3.4 Prohibition of insider trading 3.5 Prohibition of money laundering and terrorism financing 3.6 Fair and free competition 3.7 Business partners, procurement and sales 3.8 Accounting and financial reporting 3.9 Export control 24

3.1 Conflicts of interest

We take decisions based on facts, thus avoiding conflicts of interest CORPORATE PRINCIPLE

MY CONTRIBUTION

We act with integrity. That is why it is especially important for us to avoid

If I identify that I face or suspect that I

creating potential conflicts of interest when

I immediately notify my supervisor and the

performing our job responsibilities and to

relevant HR and Compliance departments

recognize and disclose possible conflicts

and disclose the facts. If a conflict exists,

that we face or that we observe. A potential

we jointly seek a solution that safeguards

conflict of interest already exists if private

the interests of the Company.

or personal financial interests of employees influence or could influence their business

EXAMPLE

decisions. This also applies for personal relationships in the workplace, in particular

Your boss asks you to review offers from

with regard to existing employment

several suppliers of plastic components

relationships or hierarchical dependence.

and to pre-select potential candidates. You discover that one of the most favorable bids

Conflicts of interest may arise both from

is from the company of a good friend.

employees themselves or through persons

related to them, in particular as a result of

Inform your supervisor of this personal

involvement in other companies, through

connection that could be understood as

secondary employment, in connection with

personal bias. Withdraw from the decision-

memberships or with regard to employees’

making process to avoid any appearance of

personal financial circumstances. In this

a conflict of interest.

context, business relations with third parties, such as other companies in the Group or suppliers, may also be relevant.

WE ARE RESPONSIBLE PARTNERS

may face a potential conflict of interest,

3.2 Benefits

CORPORATE PRINCIPLE

EXAMPLE

Our products and services define who we

You work in purchasing. A supplier sends

are. Therefore, benefits in the form of gifts

you an invitation to a multi-day sports event.

and invitations are only permitted if they are

This supplier is one of the bidders in a current

appropriate.

call for tender.

Our internal policies on handling gifts,

Invitations and gifts from suppliers to

invitations and business meals set out what

purchasing employees must always be

benefits are appropriate and what steps

scrutinized very carefully. During a call for

must be taken when accepting and / or

tenders in particular, the acceptance of

granting them.

benefits from participants is not permitted,

WE ARE RESPONSIBLE PARTNERS

We carefully check all Benefits

as this could give the impression of undue influence. If you have any concerns, contact

MY CONTRIBUTION

your supervisor and if necessary the relevant Compliance department.

I familiarize myself with the policies on handling gifts, invitations and business meals, and strictly abide by them. I check whether my behavior is appropriate and whether it might influence my business decisions.

3.4 Prohibition of insider trading

We do not bribe others and do not accept bribes ourselves

We do not share insider knowledge

CORPORATE PRINCIPLE

EXAMPLE

CORPORATE PRINCIPLE

Corruption is prohibited worldwide.

You visit a supplier to inspect components

We handle information pertaining to share

If I have access to inside information, I

Corruption means that someone abuses

for local production. During your visit it

Company performance in accordance

do not purchase or sell any financial

their professional position to gain an

becomes obvious that the components

with capital market requirements and do

instruments based on this information. This

advantage for themself or a third party

have significant defects. Your contact at

not tolerate any insider trading. Insider

applies not only to trading with shares of

and thereby harm others.

the supplier offers you a sum of money for

information is information of a precise

listed companies belonging to the Group or

ignoring the defects and to persuade you to

nature that has not been made public

derivatives thereof, but also to trading with

accept the defective items.

and that, if it were made public, would be

financial instruments in general, i.e., also

likely to have a significant effect on the

those of suppliers.

Benefits such as invitations and gifts, especially when dealing with public officials, can be evidence of corruption.

On no account accept the money. Contact

price of the relevant financial instrument,

Therefore, benefits should be exceptions in

your supervisor or the relevant Compliance

e.g., stocks and shares. We may only use

business transactions. Benefits may only be

department immediately. Any attempt

knowledge relating to insider-relevant

granted or accepted within the framework

at bribery is not tolerated under any

projects and processes internally in

You learn through your work that the

of internal policies and applicable laws.

circumstances.

accordance with the applicable internal

acquisition of a large company well-known

policies and may not divulge such

worldwide is going to be announced soon. As

knowledge to any outside party, including

part of your job, you have been informed that

family members, e.g., a spouse.

the Company‘s share price will rise significantly

MY CONTRIBUTION

EXAMPLE

once this transaction has been announced. You

I do not bribe others and I do not accept a bribe myself, and I avoid even the

know that a good friend is currently considering

MY CONTRIBUTION

whether to sell their shares in our Company. You

appearance of improper influence. I keep myself informed by consulting the internal

I do not engage in insider trading, nor do

consider telling your friend that he should hold

rules before I give or accept gifts and issue

I make any such recommendations to any

off on selling his shares.

or accept invitations.

third party or induce any third party to engage in insider trading. Furthermore, I do

Do not tip your friend off for any reasons

If I receive any corruption-related hints,

not divulge inside information unless this

whatsoever. Since the information of which

I immediately inform one of the contacts

is required during the course of my normal

you are aware is not public, but insider

listed in the chapter on “Support”.

work, and I comply with the relevant internal

knowledge, you are not permitted under any

policies. I undertake to familiarize myself

circumstances to share this knowledge with

with the applicable internal rules.

others. Transmitting this knowledge directly or indirectly would make you liable to prosecution.

WE ARE RESPONSIBLE PARTNERS

3.3 Prohibition of corruption

3.5 Prohibition of money laundering and terrorism financing

CORPORATE PRINCIPLE

MY CONTRIBUTION

Money laundering occurs when funds

I take no action whatsoever that may violate

or other assets originating directly or

money laundering provisions at home

indirectly from criminal offenses are put

or abroad. I am vigilant and immediately

into circulation in the legal economy,

assess any suspicious conduct on the

making their source appear legal. Terrorism

part of customers, business partners and

financing occurs when money or other

other third parties. If there is information

resources are made available to commit

providing sufficient grounds for suspicion,

criminal acts of terrorism or to support

I immediately get in touch with the contact

terrorist organizations. Liability does not

person responsible for money laundering

require the person involved to be aware

prevention.

WE ARE RESPONSIBLE PARTNERS

We are committed to clean business practices

that money is being laundered through

the relevant transaction. Inadvertent

I abide by all applicable provisions for

involvement in money laundering may

recording and posting transactions and

already be a criminal offense for the

contracts within my area of responsibility

parties involved.

in the accounting system.

We carefully check the identity of customers, business partners and other third parties with whom we wish to do business. It is our declared aim to conduct

EXAMPLE

business solely with reputable partners who

operate in line with legal provisions and

A customer or business partner has overpaid

the customer why the amount cannot be

who use resources from legitimate sources.

and asks for the excess amount to be repaid

repaid through the same channel used for

by transferring it to a foreign account held

the original payment. Seek advice from

We assign incoming payments to the

in another country or by paying it in cash

the contact person responsible for money

corresponding services without delay

instead of via bank transfer to the original

laundering prevention.

and post them accordingly. We ensure

business account.

transparent and open cash flows. This kind of request requires an explanation. Do not accept the suggestion readily but ask

3.6 Fair and free competition

We are committed to fair and free competition

Free and fair competition is protected by

We conduct business solely on the basis

antitrust legislation valid throughout the

of merit and market economy principles

world. Complying with this legislation

as well as free and open competition.

ensures that there is no undue distortion

We like to measure ourselves against our

of competition in the relevant markets

competitors, always abiding by laws and

– to the benefit of all market players.

regulations and observing ethical principles.

In particular, agreements and concerted

We do not enter into any anti-competitive

practices between competitors intended

agreements with competitors, suppliers,

to achieve or effect the prevention or

or customers. If our Company holds a

restriction of free competition are prohibited.

dominant market position, we do not abuse

WE ARE RESPONSIBLE PARTNERS

CORPORATE PRINCIPLE

this position. This includes in particular exchanges on prices and price components, terms and

We comply with the specific antitrust

conditions, carving up customer groupings

provisions for distribution systems in our

and territories, and restrictions on

dealings with our authorized distribution

innovations. In addition, the exchange

partners.

of competitively sensitive information is prohibited. The abuse of a dominant market

MY CONTRIBUTION

position is also prohibited. Furthermore, the proper implementation of merger control

Whenever I come into contact with

procedures is required with regard to

competitors, I make sure that no information

cooperations and transactions.

is given or received that would allow conclusions to be drawn about current or

EXAMPLE

future business conduct.

Anti-competitive conduct has the potential not only to significantly damage the good

You meet with competitors’ employees at a

with details that could impact free and fair

reputation of the Company, but can also

In discussions or any other contacts with

trade conference. You exchange ideas with

competition. Such information includes

incur severe fines, penalties, and financial

competitors, I avoid issues that could be of

them. Make very sure you do not betray

the pricing of products and services, pay or

compensation for damages.

relevance for competition among each other.

any trade secrets – especially information

strategic details.

3.8 Accounting and financial reporting

We carefully check who we do business with

We are committed to correct financial accounting and reporting

CORPORATE PRINCIPLE

EXAMPLE

We carefully select suppliers, service

I do not purchase any products or services

We strictly comply with the statutory

You urgently need new equipment. However,

providers and partner companies based

without having first gathered information on

provisions for proper accounting and

your department’s budget for the current fiscal

on objective criteria and make use of

the market and alternative suppliers. I follow

financial reporting. Transparency and

year has already been used up. You consider

competition. We only cooperate with

the applicable procurement guidelines and

correctness are our top priorities, because

acquiring the equipment nevertheless and

business partners in line with statutory

involve the relevant purchasing department

any irregularities may have serious

posting the cost in the next fiscal year when

requirements, internal rules and guidelines.

at an early stage before the planned delivery

consequences for the Company as well

your budget has been refreshed.

and performance of services in line with

as for the persons responsible. To that

valid purchasing processes.

end, we regularly inform all capital market

Do not take any action of the kind. Entries

players of our financial position and

must always be assigned correctly. Posting

We check the integrity of potential business partners carefully before entering into business relations and follow the processes

I make sure that remuneration is only paid

business developments. We publish our

entries inaccurately may have serious

and contact procedures set out in the rules

for services that are actually rendered and

periodic financial statements punctually in

consequences for the Company and the

and policies.

that the payments are commensurate with

accordance with national and international

individual employee.

the services rendered.

accounting regulations.

and services, we involve the relevant

I also comply with the relevant policies

MY CONTRIBUTION

departments in the process in good time in

before commissioning Group companies.

When purchasing or selling products

accordance with the applicable policies.

I organize processes in such a manner as EXAMPLE

to ensure all business financial data are entered correctly and promptly in the

MY CONTRIBUTION It comes to your attention that a supplier,

accounting system. If I have any questions

I make myself familiar, that the integrity

service provider or partner company is to

about the correct recording of data, I

of potential business partners has been

be commissioned without involving the

contact my supervisor or the appropriate

checked before entering into business

relevant purchasing department.

finance department.

relations and follow the processes and contact procedures set out in the rules and

Get in touch with the relevant purchasing

policies. I show no bias in favor of a supplier,

department or one of the contacts listed

service provider or partner company

in the chapter on “Support”, to make sure

without an objective reason, and I promote

the bid that is most cost-effective for the

competition.

Company is given consideration.

WE ARE RESPONSIBLE PARTNERS

3.7 Business partners, procurement and sales

3.9 Export control

We ensure compliance with all regulations in cross-border trade CORPORATE PRINCIPLE We are aware of our social responsibility

Should I become aware that export control

to fulfill export control and sanctions

regulations are being violated in my area

obligations and expressly commit to

of responsibility, I immediately take every

complying with the relevant legislation.

possible action to prevent or remedy such violations.

transactions may be subject to prohibitions,

If in doubt, I seek advice from the relevant

restrictions, approval requirements or

export control contact.

other supervisory measures under export control regulations. These may relate to the

EXAMPLE

relevant business partners, goods, countries, financial resources, or intended use. This

You commission a long-standing partner

applies to technologies and software as

company with the development of a

well as goods and products. In addition, it

software component. To offset cost pressure

applies to temporary cross-border transfer

the partner suggests commissioning a

and technical transmissions, for example, by

subsidiary outside the EU with some of the

e-mail or cloud. Furthermore, certain imports

development activities. The subsidiary is

may be subject to export control regulations.

based in a country that is on country list A defined by the Groups export control unit.

We ensure compliance with applicable export control regulations and the relevant

There may be embargo regulations

internal policies.

prohibiting certain activities in the country. This must be coordinated both internally

and with the export control authorities

MY CONTRIBUTION

before you can agree. I am responsible for regularly checking that I am familiar with internal information and

Contact the relevant export control unit to

policies on export control. That is how I keep

coordinate the next steps.

up to date on whether my day-to-day work is subject to export control regulations.

WE ARE RESPONSIBLE PARTNERS

Cross-border business processes and

WE ARE GOOD CORPORATE CITIZENS We bear responsibility for society and ensure that our Company contributes to sustainable development.

4.1 Communication and marketing 4.2 Political lobbying 4.3 Dealings with public officials 4.4 Donations and social sponsorship 4.5 Taxes and customs 4.6 Data protection 4.7 IT security 4.8 Product Compliance 4.9 Environmental protection 40

4.2 Political lobbying

We communicate clearly and respectfully

We represent our Company’s positions in a responsible and clear way

CORPORATE PRINCIPLE

EXAMPLE

CORPORATE PRINCIPLE

EXAMPLE

We ensure that our communication is

You read comments on the internet from

As a member of society, we can specifically

You have a relative who works for the

clear and consistent in order to maintain

someone criticizing production methods

promote the Company’s positions during

transport ministry and who asks for your

the confidence of customers, investors

in Asia and you know the comments are

decision-making processes, such as those for

opinion on draft legislation that will impact

and other stakeholders. Before committing

completely unfounded.

legislation plans through political lobbying.

the automotive industry. They also ask you

We conduct political lobbying centrally

for the Group’s position on this legislation.

to and / or executing any communication or marketing measures, such measures

Even if you would like to put the facts

and in line with the principles of openness,

must first be coordinated with the relevant

right straight away, contact the relevant

accountability, and responsibility. It goes

Do not comment. Political lobbying in

department. Thoughtfulness and respectful

department first, because they are in a

without saying that our interaction with

the Company is exclusively coordinated

interaction with one another are second

position to respond comprehensively and

political parties and interest groups is

centrally and conducted openly and

nature to us.

appropriately to these comments.

based on the principle of neutrality. Undue

transparently. The authorized contact for

influence in politics or legislation is not

such lobbying activities is the External

MY CONTRIBUTION

permitted.

Relations department.

I do not issue any public statement on

MY CONTRIBUTION

behalf of my Company and always refer any requests to the Communications

I do not attempt to intervene in political

department. If I make any comments at

decisions on behalf of the Company if I am

public, trade or cultural events or on the

not authorized to do so. If I am authorized to

internet, I make it clear that I am voicing

do so, I observe the relevant internal policies

solely my own personal opinion. I consult

in the performance of my duties.

the Company’s social media guidelines for advice on proper conduct in social networks.

WE ARE GOOD CORPORATE CITIZENS

4.1 Communication and marketing

4.3 Dealings with public officials

We exercise caution when dealing with public officials CORPORATE PRINCIPLE

EXAMPLE

In view of national and international

The guests invited to a full-day event

legislation, there is an increased risk of

include a university professor, who has been

corruption when dealing with public

asked to give a lecture. You are considering

officials. This is taken into account in

what you need to keep in mind. Among

our internal policies, which lay down the

other things, your department would like to

framework with regard to benefits. In

invite the guests to lunch.

or expediting payments, i.e., payments to

Because the rules governing dealings

public officials that facilitate or expedite

with public officials – this also includes

regular or routine official acts.

academic staff at state universities – are

WE ARE GOOD CORPORATE CITIZENS

particular, we do not make any facilitation

especially strict, seek the advice of the relevant Compliance department in

MY CONTRIBUTION

advance.

I am aware that there is an increased risk of corruption when dealing with public officials. Therefore, I familiarize myself with the applicable special rules. I understand that I have a binding obligation to consult the Compliance department in this regard.

4.5 Taxes and customs

We commit to society in many ways

We meticulously observe tax and customs regulations

CORPORATE PRINCIPLE

MY CONTRIBUTION

CORPORATE PRINCIPLE

EXAMPLE

We make donations, i.e., voluntary

If I consider a particular sponsorship measure

As a global company, we are aware of

You are responsible for posting certain

contributions without a return service

to be worthy of support, I make initial contact

our social responsibility to meet our

business transactions, for example general

by the recipient, and grant sponsorships,

with the appropriate departments in the

obligations with regard to foreign trade,

overheads such as maintenance expenses,

i.e., contributions based on a contractually

Company, e.g., Communications, External

taxes and customs, and we explicitly

and production costs, in the statutory

agreed return service for social objectives,

Relations, and Human Resources.

endorse compliance with national and

financial statements. One project exceeds

international legislation.

certain controlling parameters early in

to achieve a positive impact in terms of

our reputation and public perception. In

The granting of donations must be

order to avoid conflicts of interest and

transparent, i.e., the purpose, the recipient of

to ensure standard conduct within the

the donation, and the financial management

Company, donations and sponsorship

must be documented and verifiable.

I design internal structures and processes

transaction unquestionably relates to an

measures are permitted only in the context

I comply with internal processes and

in such a manner as to ensure that the taxes

investment and must therefore be treated

of the respective legal framework and in

general conditions and do not initiate any

and customs to be paid by the respective

as capitalized production costs.

accordance with the applicable internal

donation that could damage the reputation

Group companies are calculated correctly,

rules of the Group brands and companies.

of our Company.

promptly and in full, are disclosed in

Post the entry in line with legal requirements.

reporting, and are paid to the relevant

All business transactions must be correctly

EXAMPLE

fiscal authorities.

reported pursuant to commercial law and

transparent approval process. We grant

A local politician asks you for a cash

If I have information concerning a violation

records form the basis for tax returns.

payments and / or non-cash benefits for

donation from your Company for the

of tax and customs regulations in my area of

Accounting errors could therefore result

scientific, charitable, cultural or religious

election campaign.

responsibility, I undertake every action I can

in incorrect tax returns and lead to serious

to prevent or stop this violation. If that is not

consequences under tax and customs

Donations and sponsorship measures

the financial year. You therefore receive instructions to make an entry under

MY CONTRIBUTION

maintenance expenses even though the

are only granted in accordance with a

tax regulations because these accounting

purposes. In addition, we grant donations exclusively to institutions which are

Turn down the request. Donations may only

possible, I get in touch with the appropriate

law for the Company and the employees

recognized as charitable and / or tax-

be granted after going through the required

contact person in the tax and customs

responsible.

privileged.

approval process. In this specific case, the

department.

donation cannot be approved because an internal guideline prohibits donations to political parties, related institutions, and politicians.

WE ARE GOOD CORPORATE CITIZENS

4.4 Donations and social sponsorship

4.6 Data protection

CORPORATE PRINCIPLE

EXAMPLE

We attach great importance to handling

You are planning a market analysis for

data responsibly, securely and transparently.

the Company. The analysis involves the

We collect, process, use, and store personal

collection and evaluation of customers’

data solely in accordance with statutory

personal data. Another department

requirements. We protect the personal data

would also like to use this data at a later

of customers, employees – including former

point. Valid data protection legislation

employees and applicants – and partners

states that data may only be collected

such as suppliers and development partners.

and processed on a specific legal basis and that the customers concerned must always be adequately informed. In addition,

MY CONTRIBUTION

as a general principle data may only be I handle personal data confidentially and my

processed for the purpose for which it was

actions are clear and transparent. I integrate

collected.

data protection in my actions and processes

and ensure the security of all data in my

Please clarify with your supervisor or the

area of responsibility. I take responsibility

relevant data protection unit whether the

and pay attention to secure data exchange

customers’ consent must be obtained prior

throughout the value chain. If in doubt, I

to collection, how the customers are to be

contact my supervisor or the relevant data

informed, and the terms on which the data

protection department.

could be used by another department.

WE ARE GOOD CORPORATE CITIZENS

We handle data carefully

4.8 Product Compliance

We secure our IT systems

We inspire the world with our products

CORPORATE PRINCIPLE

EXAMPLE

CORPORATE PRINCIPLE

MY CONTRIBUTION

We respect IT security and abide by the

You are on a business trip. The SIM card

Our products inspire countless people all

I carefully comply with all relevant

applicable information security regulations.

you have been given by your company has

over the world. We give high priority to the

provisions in my day-to-day work. I set

The information security regulations provide

no reception, but you need to send a

conformity and safety of our products. We

realistic goals. If there is a conflict of goals,

guidelines for different employment groups

confidential document to your supervisor.

have a responsibility to ensure that risks

the conformity of our products always

and are relevant for all employees.

The café you are sitting in offers free,

to health, safety, the environment, and the

has top priority, regardless of time or cost

unencrypted Wi-Fi.

assets of our customers or third parties

pressure. That is why I embrace our defined

resulting from the use of these products

processes and continuously improve them. We jointly identify and close gaps

MY CONTRIBUTION Be very careful when you use public Wi-Fi. There is data leak risk when using

are excluded where possible.

I familiarize myself with the applicable IT security regulations and observe the rules

unprotected connections, even though our

In compliance with statutory provisions,

obligations. I contact my supervisor or

therein. As part of the IT security chain,

data transmissions are protected via VPN,

we develop our products in accordance

the PCMS team if I have any questions or

I make my active contribution by being

a virtual private network.

with state-of-the-art technology, taking

concerns about product compliance.

in processes in order to meet all binding

vigilant at all times and ensuring my basic

account of other binding obligations such

IT security skills are always up-to-date.

as additional safety requirements resulting

EXAMPLE

from the state of scientific knowledge. This is systematically ensured by means

A customer reports that the operating

of established structures and stable

system in their vehicle has crashed. You are

processes. Once they have been put on

not sure whether this is due to an operating

the market, our products are constantly

error on the part of the customer or a

monitored in the field so that appropriate

software malfunction.

measures may be promptly initiated in the event of possible discrepancies. We do not

Follow the applicable processes and report

make any compromises in this regard.

the problem immediately to the employees in charge so that the issue can be clarified and in order to initiate the steps that may be necessary based on the known facts.

WE ARE GOOD CORPORATE CITIZENS

4.7 IT security

4.9 Environmental protection

CORPORATE PRINCIPLE

MY CONTRIBUTION

As a global commercial enterprise, we

I am mindful of environmental protection

bear responsibility for the environmental

in my work and use resources and energy

compatibility and sustainability of our

economically and efficiently. I make sure my

products, locations, and services. Our

activities have the smallest possible impact

Company aspires to be a global provider

on the environment and that they comply

of sustainable mobility and a role model

with environmental protection laws and

for protecting the environment. We focus

regulations.

on environmentally friendly, advanced, and efficient technologies, which we

EXAMPLE

implement throughout the entire lifecycle of our products. From the very early

You notice that a tank in one of the halls

phases of development and production

is leaking and that large quantities of fluid

onward, we make sure we manage natural

used in the production process are spilling

resources carefully, continuously reduce

onto the floor. No one else seems to have

the environmental impact, and comply

noticed the leak and you are concerned that

with environmental protection laws and

the entire tank could drain off.

regulations. Inform one of the employees in charge Furthermore, we constantly reassess the

immediately and draw attention to the

environmental compatibility of products and

problem. Do not count on anyone else

manufacturing processes, optimizing these

reporting the leak.

where necessary. We are a responsible member of society and a partner for politics. We seek a dialog with these players on future mobility concepts and on shaping ecologically sustainable development.

WE ARE GOOD CORPORATE CITIZENS

We bear responsibility for the environment and sustainability

SUPPORT We offer support in dealing with the Code of Conduct.

PREVENTING MISCONDUCT, CONTACT POINTS AND WHISTLEBLOWER SYSTEM Our Code of Conduct provides the binding

give our name, or we can make the report

framework for acting with integrity and

anonymously. We are aware that the

in compliance with the rules within our

Volkswagen Group Whistleblower System

Group. As Group employees, we have a

has responsibility for investigating reports

responsibility to respect the principles of

regarding Serious Regulatory Violations.

Violations and thus avoid damage to the

A Serious Regulatory Violation is a

Company. Violations of laws and internal

significant violation of our ethical values

policies are immediately investigated.

as set out in the Code of Conduct. Equally,

Depending on the seriousness of the

violations of statutory laws or regulations

violation, this can have disciplinary, civil, or

that may significantly affect the reputation

criminal consequences for the employees

or financial interests of the Company are

concerned. Proven misconduct can also

also considered to be Serious Regulatory

have an impact on remuneration. That

Violations. In all other cases we should first

is why we talk to our supervisor or seek

seek advice from our supervisor, the HR

expert advice immediately if we have any

department or Compliance.

SUPPORT

our Code in order to prevent Regulatory

questions or concerns, or if we suspect there has been a violation of internal or

Managers have a special function as role

external regulations. The HR department

models. The decisions they make for the

and employee representatives are there

Company must always take account of

Discrimination against them is itself

reports. Abuse of the Whistleblower System

to provide support. We can also contact

values and regulations. This includes

considered a Serious Regulatory Violation.

is not tolerated and will be disciplined

the Company’s Compliance Officer or the

immediately reporting Reasonable

Compliance advice service at any time at:

Suspicion of the concrete indication of a

At the same time, the Whistleblower

Serious Regulatory Violation.

System protects the interests of Persons

Potential violations of the Code of

Implicated. For them, the presumption of

Conduct for Business Partners, including

The purpose of the Whistleblower System is to

innocence applies as long as a violation is

serious risks, violations of human rights

In addition, we can submit reports regarding

protect our Company, the whistleblower, and

not proven. The work of the Whistleblower

and environmental violations by direct and

Regulatory Violations via the Volkswagen

all persons who contribute to the investigation

System is based on uniform processes and

indirect suppliers, can also be reported to

Group Whistleblower System. We can

and the termination of misconduct.

the confidential, professional processing of

the Central Investigation Office.

E-mail: compliance@vwfs.com

INTERNAL

accordingly.

We can access the Whistleblower System through the following channels: Contact details for the Investigation Office: VW FS (ED-ELC) Gifhorner Str. 57 38112 Braunschweig Germany

24/7 hotline :

VW AG (Investigation Office) Brieffach 1717 38436 Wolfsburg Germany + 800 444 46300 + 49 5361 946300 + 49 531 212 899786 io@volkswagen.de investigation@vwfs.com indication@vwfs.com

E-mail:

In addition, experienced external lawyers act as neutral mediators (ombudspersons) for us. As legal counsel, they are tasked with receiving reports about possible infringements of laws, internal rules or other conduct damaging to the Volkswagen Group. If necessary, and if the identity of the whistleblower is known, they make direct contact should they require feedback. Once the preparations are complete, the ombudspersons forward all information agreed with the whistleblower – anonymously if the whistleblower so wishes – to our Whistleblower System for further processing.

Contact details for the ombudspersons: Internet:

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

Further information on the Volkswagen Group Whistleblower System, the ombudspersons

Online reporting channel:

https://www.bkms-system.com/vw

(this channel can also be used for making anonymous reports)

https://www.volkswagenag.com/en/group/compliance-and-risk-management/ whistleblowersystem.html.

Office Space, ED-ELC Käferweg 3, Building B7 EG

In person:

INTERNAL

and the relevant external reporting channel (if applicable) is available on the internet at

SUPPORT

Postal adress:

If at any time I am unsure whether my behavior complies with the principles set out in our Code of Conduct, I should ask myself the following questions:

Did I take all relevant matters into consideration and weigh them properly? (content test)

Am I confident that my decision is within the constraints of legal and company requirements? (legality test)

Do I stand by my decision when it is revealed? (supervisor test)

Am I in favor of all such cases being decided the same way company-wide? (universality test)

Do I still think my decision is right when my company has to justify it in public? (public test)

Would I accept my own decision if I were affected? (involvement test)

What would my family say about my decision? (second opinion)

If my answer to questions 1– 6 is “yes” and the answer to question 7 is positive, my behavior is very likely to be compliant with our principles. If questions remain unanswered or if I have any doubts, I should get in touch with any of the points of contact listed in this chapter.

SUPPORT

SELF-TEST FOR DECISION GUIDANCE