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Volkswagen Group Code of Conduct Table of Contents

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Volkswagen Group Code of Conduct Table of Contents Volkswagen Group Code of Conduct Table of Contents 1 3 5 6 Foreword by the Our responsibility Our responsibility Our responsibility Group Board of for compliance 9 as a business in the workplace 50 Management 4 partner 26 Occupational safety and healthcare 53 Data protection 54 4 Conflicts of interest 29 Security and protection of information, Gifts, hospitality and invitations 30 2 Our responsibility know-how and intellectual property 57 Prohibition of corruption 33 IT security 58 as a member of Dealings with officials and holders of Handling company assets 61 Foreword by political office 34 the Board of society 10 Prohibition of money laundering and terrorism financing 36 Human rights 13 Management of Accounting and financial reporting 38 7 Equal opportunity and equal treatment 14 Taxes and customs 41 Volkswagen Group Product conformity and product safety 17 Support 63 Fair and free competition 42 Environmental protection 18 Employee representation 64 China 6 Procurement 45 Donations, sponsorships and charity 21 Help / contacts 66 Export control 46 Communication and marketing 22 Self-test for decision guidance 69 Prohibition of insider trading 48 Lobbying 25 1 Foreword by the Group Matthias Müller Dr. rer. soc. Karlheinz Blessing Dr.-Ing. Herbert Diess Chairman of the Board of Human Resources and Chairman of the Brand Board Management of Volkswagen AG Organization of Management of Board of Management Volkswagen Passenger Cars Dear colleagues, The trust of customers and stakeholders in our Company and its products is our most precious asset. It therefore follows that we have a shared responsibility to live up to this trust every day by conducting ourselves with honesty and integrity. That includes being familiar with the applicable internal rules and statutory regulations and complying with them. A new, expanded version of the Volkswagen If we notice that something is going wrong, Group Code of Conduct is now available. It of- if we make a mistake ourselves or we see a Prof. Dr. rer. pol. Dr.-Ing. E.h. Andreas Renschler Dr. rer. pol. h.c. Francisco Javier Garcia Sanz fers guidance on proper conduct by providing mistake being made elsewhere, we must speak Jochem Heizmann Commercial Vehicles China Procurement orientation and support in our daily work. up and respond appropriately – even if doing It is precisely in times like these, when the so is awkward and uncomfortable. Turning a automotive industry is undergoing fundamen- blind eye can never be the right solution. When tal change, that a solid foundation of values is in doubt, we must seek competent advice and indispensable for sustained success. support. Our Group is very diverse – with today twelve We, the Board of Management of the Volkswa- brands from seven European countries, some gen Group, are convinced that our Code of 630,000 employees, 120 production sites, and Conduct is an essential key to making the with customers in over 150 countries are all Volkswagen Group and its brands even more part of the Group’s world. Irrespective of the successful in the future. The clear and transpar- differences between us, our origins, our tasks, ent rules and very specific practical examples our responsibilities, it is shared values that are a useful guide. determine how we go about our duties, how we make decisions and how we interact with We therefore encourage you to read the con- one another and with people from outside our tents carefully. And we hope you will join us Company. Regardless of our position in the in working together to make the Volkswagen Prof. Rupert Stadler Hiltrud Dorothea Werner Frank Witter company, we all share responsibility for the Group a byword not only for excellent products Chairman of the Board of Integrity and Legal Affairs Finance and Controlling reputation, and thus the success, of our Com- and services, but also reinforced for integrity Management of AUDI AG pany through our attitude and our conduct. and fairness. 4 5 2 Foreword by the Board of Management of Volkswagen Group China Dear colleagues, Millions of Chinese customers and stakeholders/business partners put their precious trust in our Company and its products. It is down to all of us to live up to this trust every day with honesty and respect, in order to maintain and expand our leading position in this dynamically changing market. Prof. Dr. Jochem Heizmann Stephan Beyse Juergen Franke In order to support you, we have jointly And Integrity is the key to ensure our success President & CEO of Volkswagen Purchasing Quality Assurance defined a new, advanced version of the for the future – of this, we, the Board of Man- Group China Volkswagen Group Code of Conduct, which will agement of the Volkswagen Group China are be valid for all Volkswagen Group employees convinced. worldwide: This also means that you should be attentive towards potential wrong-doings and we as • It offers guidance by giving us orientation Dr. Ralf Hanschen Rolf Hueber Carsten Isensee management encourage you to speak up in for our daily work President ŠKODA China Human Resources, Finance order to allow for an appropriate and timely Organization & ITP • It clearly outlines our responsibilities response. You can be sure of our support! • o As a member of society We kindly ask you to familiarize yourself with the new Code of Conduct. These clear guide- • o As a business partner lines and practical examples will be a good Joerg Mueller Sven Patuschka Weiming Soh • o In the workplace guide for all of us. Production & Logistics Research & Development Group Strategy and Sales & Marketing • It defines the solid foundation of our We, the whole management team, want to set a shared values good example of reliability. Join us in working together so that in the future Volkswagen It is the behavior of each and every one of us Group stands for excellent products and servic- that counts – our honest conduct in daily life. es as well as for integrity and fairness. Joachim Wedler Dr. Stephan Woellenstein Dr. Suixin Zhang President of Audi China CEO of Volkswagen China Corporate Affairs Passenger Cars Brand 6 7 3 Our responsibility for compliance One decisive factor for the success of our The Code of Conduct serves as a binding guide- Company is that all employees – from Board line in our day-to-day business. It is supple- members and managers to each individual mented by internal guidelines and provisions member of staff – must act with honesty and in employment contracts. It also goes without integrity and in an ethical manner. This also saying that we all comply with the national means that our internal and external reporting and international statutory provisions. This and communications must be truthful, com- also means that we never take part in any prehensive and timely. activity that involves fraud, misappropriation, extortion, theft, embezzlement or any other Our shared goal is to fulfill our responsibility deliberate damage to the assets of our custom- to our Company and to protect the reputation ers or any third party. of our Group brands. Sustainability requires of us an awareness of our responsibility for Failure to observe the Code of Conduct can the economic, social and ecological impact result in considerable damage, not only to our of our actions. Such conduct also means that Company, but also to us as employees and to we all respect and observe the rules in force our business partners and other stakeholders. in the Company everywhere and at all times. That is why the Code of Conduct is binding Our Board members and managers bear a on all of us, irrespective of whether our role is special responsibility in this context: they are that of a staff member, a manager or a Board role models and must prevent non-compliant member. We do not tolerate violations of the behavior within the Company, protect their Code of Conduct. Anyone who violates the employees and conduct themselves with integ- Code of Conduct must expect consequences, rity both within the Company and externally. which, depending on the seriousness of the vi- olation, can range from action under labor law This Code of Conduct helps us by highlighting to claims for damages under civil law, and may potential areas of risk and conflict, explaining even extend to penalties under criminal law. their significance for our Company and illus- trating them using case studies. To make sure that does not happen, it is up to each and every one of us to familiarize our- The information contained in this Code of Con- selves with this Code of Conduct, to integrate duct is divided into three main sections: the Code of Conduct into our own behavior, and to bear the Code of Conduct in mind when g Our responsibility as a member of society making decisions. When in doubt, we seek g Our responsibility as a business partner competent advice. g Our responsibility in the workplace. 8 9 4 Our responsibility as a member of society Our social responsibility means that observing and complying with the law is a matter of course. We have a duty to observe the law under which we operate in all business decisions we make. Every employee in the Volkswagen Group must be aware of his/her social responsibility, particularly as regards the wellbeing of people and the environment, and ensure that our Company contributes to sustainable development. The Volkswagen Group’s responsibility as a member of society specifically gives rise to the following principles: 10 11 OUR RESPONSIBILITY AS A MEMBER OF SOCIETY OUR RESPONSIBILITY AS A MEMBER OF SOCIETY Human rights BACKGROUND MY CONTRIBUTION The Declaration of Human Rights adopted by As an employee, I can also make my contri- the United Nations and the European Conven- bution to respecting human rights.
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