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
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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.
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We live diversity.
We are proud of the work we do.
We not me.
We keep our word.
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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
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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
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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.
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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.
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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.
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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
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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
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.
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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.
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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.
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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.
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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.
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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
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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.
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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
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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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
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INTERNAL
accordingly.
54
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:
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INTERNAL
and the relevant external reporting channel (if applicable) is available on the internet at
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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:
1.
Did I take all relevant matters into consideration and weigh them properly? (content test)
2.
Am I confident that my decision is within the constraints of legal and company requirements? (legality test)
3.
Do I stand by my decision when it is revealed? (supervisor test)
4.
Am I in favor of all such cases being decided the same way company-wide? (universality test)
5.
Do I still think my decision is right when my company has to justify it in public? (public test)
6.
Would I accept my own decision if I were affected? (involvement test)
7.
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.
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SUPPORT
SELF-TEST FOR DECISION GUIDANCE
© VOLKSWAGEN AKTIENGESELLSCHAFT Group Integrity & Compliance Letterbox 1717 38436 Wolfsburg Germany Version 3.0 | January 2024