Volkswagen Group Rus Code of Conduct Table of Contents
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Volkswagen Group Rus Code of Conduct Table of Contents 1 3 Foreword 3 Our 9 by the Group Board responsibility of Management as a member Foreword by VOLKSWAGEN Group Rus 5 of society Board of Management Human rights 12 2 8 Equal opportunity and equal treatment 13 Product conformity and product safety 16 Our Environmental protection 17 Donations, sponsorships and charity 20 responsibility Communication and marketing 21 for compliance Political lobbying 24 4 5 Our 25 Our 49 responsibility responsibility as a business partner in the workplace Conflicts of interest 28 Occupational safety and healthcare 52 Gifts, hospitality and invitations 29 Data protection 53 Prohibition of corruption 32 Security and protection of information, Dealings with officials and holders know-how and intellectual property 56 of political office 33 IT security 57 Prohibition of money laundering Handling Company assets 60 and terrorism financing 35 Accounting and financial reporting 37 Taxes and customs 40 6 Fair and free competition 41 Procurement 44 Support 62 Export control 45 Prohibition of insider trading 47 Employee representation 63 Help / Contacts 65 Whistleblower system 67 Self-test for decision guidance 72 1 Foreword by the Group Board of Management Dear colleagues, The trust of customers and stakeholders in our Company and its products is our most valuable asset. We can only strengthen public trust and protect the Volkswagen Group, its employees and our environment by conducting ourselves with integrity and honesty. That includes being familiar with the applicable statutory regulations and internal rules, and complying with them. The Code of Conduct is the basis for our actions. Our Group is very diverse: today, twelve brands a blind eye can never be the right solution. We from seven European countries, some speak up – even if doing so is awkward and 664,000 employees, 123 production sites and cus- uncomfortable. When in doubt, we seek compe- tomers in over 150 countries are all part of the tent advice and support. Group world. Irrespective of the differences between us, our origins, our tasks and our respon- We, the Volkswagen Group Board of Management, sibilities, we all share responsibility for our com- are convinced that our Code of Conduct is one key pany’s success and our contribution to sustainable to the success of our Group and its brands. We development through our conduct and our therefore ask you to use the Code of Conduct in actions. Our shared values determine how we your workplace and to seek advice if you are in work, how we make decisions, and how we interact doubt. Let us join together to make the Volk- with one another and all living creatures. swagen Group a responsible employer that is a byword not only for excellent products and ser- The Volkswagen Group Code of Conduct supports vices, but also for integrity and fairness. ethical and responsible conduct. It contains rele- vant and practical examples that offer guidance, assistance and advice in our daily work. And it helps us identify mistakes and respond appropri- ately. Because in the Volkswagen Group, turning 3 1 Foreword by the Group Board of Management Dr.-Ing. Herbert Diess Oliver Blume Markus Duesmann Chairman of the Board of Management of Chairman of the Board of Management of Premium Volkswagen Aktiengesellschaft and Chair- Dr. Ing. h.c. F. Porsche AG, Sport & Luxury man of the Brand Board of Management brand group of Volkswagen Passenger Cars, Volume brand group, China Gunnar Kilian Andreas Renschler Dr. Stefan Sommer Human Resources Chairman of the Board of Management Components & Procurement of TRATON SE, Truck & Bus brand group Hiltrud Dorothea Werner Frank Witter Integrity and Legal Affairs Finance & IT 4 Foreword by the Volkswagen Group Rus Board of Management Dear Colleagues, This Code of Conduct is a result of joint work of Volkswagen Group and each of the brands in particular. It includes the most important and valuable principles and rules that constitute an integral part of our daily work. We all and every single one of us shall demonstrate a fair and honest conduct, acting with integrity and in compliance with the norms specified in this Code of Conduct. It is designed in order to put the most important principles in a transparent and clear manner to reach their uniform understanding and bring the trust within and towards the company to even a higher level. The Code of Conduct is binding on all of us: staff members, managers as well as Board members. The Volkswagen Group Rus Board of Management encourages you to study this document fully and thoroughly and follow these norms with shared responsibility and integrity. 5 Marcus Osegowitsch Lars Himmer Patrik Andreas Mayer General Director Managing Director NSO Board Member for Finance Dieter Neuhäeusser Stefan Depka Thomas Milz Board Member for HR & Board Member for Production & Brand Director VW PC Russia Organizations Logistics, Plant Manager Kaluga Ksenia Komyagina Jan Prochazka Board Member for Procurement Brand Director ŠKODA Russia 6 7 2 Our responsibility for compliance One decisive factor for the success of our Com- The Code of Conduct serves as a binding guideline pany is that all employees – from Board members in our day-to-day business. It is supplemented by and managers to each individual member of staff internal guidelines and provisions in employ- – must act with honesty and integrity and in an ment contracts. It also goes without saying that ethical manner. This also means that our internal we all comply with the national and international and external reporting and communications statutory provisions. This also means that we must be truthful, comprehensive and timely. never take any part in any activity that involves Our shared goal is to fulfill our responsibility to fraud, misappropriation, extortion, theft, embez- our Company and to protect the reputation of our zlement or any other deliberate damage to the Group brands. Sustainability requires of us an assets of our customers or any third party. awareness of our responsibility for the economic, Failure to observe the Code of Conduct can result social and ecological impact of our actions. Such in considerable damage, not only to our Com- conduct also means that we all respect and pany, but also to us as employees and to our busi- observe the rules in force in the Company every- ness partners and other stakeholders. That is why where and at all times. Our Board members and the Code of Conduct is binding on all of us, irre- managers bear a special responsibility in this con- spective of whether our role is that of a staff text: they are role models and must prevent non member, a manager or a Board member. We do -compliant behavior within the Company, protect not tolerate violations of the Code of Conduct. their employees and conduct themselves with Anyone who violates the Code of Conduct must integrity both within the Company and expect consequences, which, depending on the externally. seriousness of the violation, can range from This Code of Conduct helps us by highlighting action under labor law to claims for damages potential areas of risk and conflict, explaining under civil law, and may even extend to penalties their significance for our Company and illustrat- under criminal law. ing them using examples. To make sure that does not happen, it is up to The information contained in this Code of Con- each and every one of us to familiarize ourselves duct is divided into three main sections: with this Code of Conduct, to integrate the Code → Our responsibility as a member of society of Conduct into our own behavior, and to bear the → Our responsibility as a business partner Code of Conduct in mind when making decisions. → Our responsibility in the workplace. When in doubt, we seek competent advice. 8 3 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 outlined in this chapter. 9 10 Our responsibilitY AS A member OF sociETY 11 Our responsibilitY AS A member OF societY Human rights BACKGROUND MY CONTRIBUTION The Declaration of Human Rights adopted by the As an employee, I can also make my contribution United Nations and the Convention for the to respecting human rights. I regard human rights Protection of Human Rights and Fundamental as a fundamental guideline and I am vigilant Freedoms state what is required and expected of against human rights abuse happening around me. the international community when it comes to observing and respecting human rights. If I have concerns regarding human rights abuse in CORPORATE PRINCIPLE my professional surroundings, I prevent it and/or We respect, protect and promote all regulations stop it. If necessary, I inform my superior or get in in force to protect human rights and children’s touch with any of the contacts listed in chapter 6. rights (hereinafter called human rights) as a fundamental and general requirement EXamplE throughout the world. We reject all use of child You are responsible for purchasing specific labor and forced or compulsory labor as well as goods. You receive information that a all forms of modern slavery and human supplier with which you do business uses children trafficking. This applies not only to cooperation in their production process, or that employees are within our Company but also as a matter of made to work in inhumane conditions (e.g.