There is no place for corruption at Volkswagen!
We are fully committed to lawful and responsible action and follow a clear zero-tolerance policy towards active and passive corruption.
This commitment isfirmlyanchored in the Groups’s Code of Conduct. The Code of Conduct applies worldwide to all employees of the Volkswagen Group.
We actively counteract corruption, white-collar crime and other violations of the law with additional binding guidelines that apply Group-wide and locally.
Corruption is prohibited worldwide. It involves the offering, promising, granting, demanding or accepting benefits with the intention unduly influence business or official decisions.
The following applies: even the appearance of undue influence can undermine trust in integrity.
A distinction is generally made between interactions in business transactions and dealing with public officials and elected officials. Particularly strict legal requirements apply to dealing with public officials.
Additional risk areas may arise, for example, in the case of commissions in consultancy contracts, where services and considerations are not clearly described or are not in line with market practices. This can encourage illicit business practices, such as creating slush funds or the payment of kickback to supporting third parties.
Corruption risks can also occur in everyday business activities—especially if benefits are likely to unduly influence business or official decisions.
This includes in particular the following types of benefits: gifts, invitations to business lunches or corporate events, vehicle rentals, discounts, sponsorship and donation projects as well as memberships in institutions such as clubs or associations.
The principle for all types of benefits is: they must be transparent, appropriate and lawful.
When dealing with public officials and elected representatives, significantly lower orientation values and stricter approval processes apply.
We take our responsibility to protect the company and our employees from corruption risks very seriously. A fundamental part of our Compliance Management System is the continuous communication and training measures for corruption prevention.
Web-based trainings, face-to-face trainings and a wide diverse range of film and dialogue formats are used to raise awareness for the internal regulations and applicable laws and train employees in dealing with corruption risks appropriately. For example, throughout the Group, all employees in the salaried areas complete mandatory trainings on corruption prevention.
The same high standards apply to our national and international business partners. We are convinced that ending corruption is a task best accomplished together. The Code of Conduct for Business Partners is generally an integral part of contractual agreements with our Business Partners- It formulates the expectations we have of our service providers, suppliers and sales partners when it comes to integrity and law-abiding behavior.
As part of the Business Partner Due Diligence (BPDD), we check the integrity of our business partners across the Group using a risk-based approach. Companies that do not meet the standards through this transparent review process are not considered as business partners of the Volkswagen Group.
The review is always carried out before a business relationship is entered into and continues throughout duration of the business relationship – for example through automated, continuous (24/7) integrity monitoring of the business partner. Even after contracts has been concluded, the business partners are regularly checked to determine whether further measures are required. We support them with various formats (e.g. compliance dialogues) to help them meet required standards.
Our central Whistleblower System is also part of the global compliance management system for ending corruption. Being aware of potential rule violationsby Volkswagen Group employees is just as crucial to us as responding to rule violations appropriately. The Whistleblower System is also the central point of contact for reporting potential violations of the Code of Conduct for Business Partners, including serious risks and violations of human rights or environmental by direct and indirect suppliers.
Multiple reporting channels and external ombudsmen are available for this purpose. We guarantee the greatest possible protection for Whistleblowers and affected individuals.
