Volkswagen Group of America Code of Conduct Table of Contents Introduction by the Group Board of Management 1 Foreword by Volkswagen Group of America Management 5 Our responsibility for compliance . .9 Our responsibility as a member of society . 13 Human rights 15 Equal opportunity and equal treatment 16 Product conformity and product safety 17 Environmental protection 18 Donations, sponsorships and charity 19 Communication and marketing 20 Political lobbying 21 Our responsibility as a business partner . 23 Conflicts of interest 25 Gifts, hospitality and invitations 26 Prohibition of corruption 27 Dealings with officials and holders of political office 28 Prohibition of money laundering and terrorism financing 29 Accounting and financial reporting 31 Taxes and customs 32 Fair and free competition 33 Procurement 35 Export control 36 Prohibition of insider trading 37 Our responsibility in the workplace . 39 Occupational safety and healthcare 41 Data protection 42 Security and protection of information, know-how and intellectual property 43 IT security 44 Handling company assets 45 Support . 47 Employee representation 49 Help / contacts / whistleblower system 50 Self-test for decision guidance 51 Dear colleagues, The trust of customers and stakeholders Our Group is very diverse: today, in our Company and its products is our twelve brands from seven European 1 most valuable asset. We can only countries, some 664,000 employees, strengthen public trust and protect the 123 production sites and customers Volkswagen Group, its employees and in over 150 countries are all part of our environment by conducting the Group world. Irrespective of the ourselves with integrity and honesty. differences between us, our origins, That includes being familiar with the our tasks and our responsibilities, applicable statutory regulations and we all share responsibility for our internal rules, and complying with them. company’s success and our The Code of Conduct is the basis for our contribution to sustainable actions. development through our conduct and our actions. 1 Volkswagen Group of America: Code of Conduct Introduction by the Group Board of Management 2 Our shared values determine how We, the Volkswagen Group Board of we work, how we make decisions, Management, are convinced that our and how we interact with one Code of Conduct is one key to the another and all living creatures. success of our Group and its brands. We therefore ask you to use the Code The Volkswagen Group Code of of Conduct in your workplace and to Conduct supports ethical and seek advice if you are in doubt. Let us responsible conduct. It contains join together to make the rele-vant and practical examples Volkswagen Group a responsible that offer guidance, assistance and employer that is a byword not only advice in our daily work. And it helps for excellent products and services, us identify mistakes and respond but also for integrity and fairness. appropriately. Because in the Volkswagen Group, turning a blind eye can never be the right solution. We speak up – even if doing so is awkward and uncomfortable. When in doubt, we seek competent advice and support. 3 Volkswagen Group of America: Code of Conduct Introduction by the Group Board of Management 4 Foreword by Volkswagen 2 Group of America Management 5 Volkswagen Group of America: Code of Conduct Foreword by Volkswagen Group of America Management 6 September 2019 Dear VWGoA employees, Compliance and ethics form the Sincerely, principles that underpin our business This Code of Conduct is a set of and will help make us the model of expectations for how we operate as a integrity that we aspire to be. Mike Beamish business. Volkswagen is a huge, Executive Vice President, Human Resources complex organization, so the code Thank you for all you continue to do to covers 51 pages and it's worth the make this an organization that puts read. But for those of you pressed for integrity, honesty, and responsibility time, here's the takeaway: go about first. your business with integrity and honesty. Take responsibility. Do the right thing. In the meantime, if you ever have questions about anything related to anyone's ethical behavior, say something. Start by talking to your manager. If that's difficult, for Scott Keogh Stefan Baier Stephanie Davis whatever reason, call the ethics hotline at 1-888-228-7317. Someone will always take the call and you can remain anonymous. Your concerns will be considered seriously and whistleblowers will be protected. 7 Volkswagen Group of America: Code of Conduct Foreword by Volkswagen Group of America Management 8 One decisive factor for the success of Our shared goal is to fulfill our Our responsibility our Company is that all employees – responsibility to our Company and to for compliance from Board members and managers protect the reputation of our Group 3 to each individual member of staff brands Sustainability requires of us an – must act with honesty and integrity awareness of our responsibility for the and in an ethical manner This also economic, social and ecological impact means that our internal and external of our actions Such conduct also reporting and communications must means that we all respect and observe be truthful, comprehensive and timely the rules in force in the Company everywhere and at all times Our Board members and managers bear a special responsibility in this context: they are role models and must prevent non-compliant behavior within the Company, protect their employees and conduct themselves with integrity both within the Company and externally 9 Volkswagen Group of America: Code of Conduct Our responsibility for compliance 10 This Code of Conduct helps us by Failure to observe the Code of Conduct highlighting potential areas of risk can result in considerable damage, and conflict, explaining their not only to our Company, but also to significance for our Company and us as employees and to our business illustrating them using case studies partners and other stakeholders That is why the Code of Conduct is binding The information contained in this on all of us, irrespective of whether Code of Conduct is divided into three our role is that of a staff member, a main sections: manager or a Board member We do not tolerate violations of the Code Our responsibility as a of Conduct Anyone who violates member of society the Code of Conduct must expect Our responsibility as consequences, which, depending on a business partner the seriousness of the violation, can range from corrective action or claims Our responsibility in the workplace for damages under civil law, and may even extend to penalties under The Code of Conduct serves as a criminal law binding guideline in our day-to-day business It is supplemented by To make sure that does not happen, internal guidelines and policies It also it is up to each and every one of us to goes without saying that we all comply familiarize ourselves with this Code with national and international law of Conduct, to integrate the Code of This also means that we never take any Conduct into our own behavior, and part in any activity that involves fraud, to bear the Code of Conduct in mind misappropriation, extortion, theft, when making decisions When in embezzlement or any other deliberate doubt, we seek competent advice damage to the assets of our customers or any third party 11 Volkswagen Group of America: Code of Conduct Our responsibility for compliance 12 Our social responsibility means that Our responsibility as observing and complying with the a member of society law is a matter of course We have a 4 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: 13 Volkswagen Group of America: Code of Conduct Our responsibility as a member of society 14 Human Rights Equal opportunity and equal treatment BACKGROUND BACKGROUND We embrace diversity, actively The Declaration of Human Rights MY CONTRIBUTION Equal opportunities and equal encourage inclusion and create adopted by the United Nations and treatment are key cornerstones of a an environment that fosters each As an employee, I can also make my the European Convention for the fair, unprejudiced and open approach employee’s individuality in the contribution to respecting human Protection of Human Rights and The Volkswagen Group encourages interests of the Company rights I regard human rights as a Fundamental Freedoms state what respectful cooperation in a spirit of fundamental guideline and I am is required and expected of the partnership, diversity and tolerance As a matter of principle, our employees vigilant against human rights international community when it That is how we achieve a maximum are chosen, hired and supported based abuse happening around me comes to observing and respecting degree of productivity, competitive on their qualifications and skills human rights If I am concerned about human and innovative capability, creativity rights abuse in my professional and efficiency MY CONTRIBUTION CORPORATE PRINCIPLE surroundings, I take reasonable We respect, protect and promote CORPORATE PRINCIPLE I observe the principles of equal steps to prevent it and/or stop it, all regulations in force to protect We offer equal opportunities