Code of Conduct Table of Contents Foreword 2 Our 10 responsibility as a member Our 9 of society responsibility Human rights 13 for compliance Equal opportunity and equal treatment 14 Product conformity and product safety 17 Environmental protection 18 Donations, sponsorships and charity 21 Communication and marketing 22 Political lobbying 25 Our 26 Our 50 responsibility responsibility in as a business the workplace partner Occupational safety and healthcare 53 Data protection 54 Conflicts of interest 29 Security and protection of information, Gifts, hospitality and invitations 30 know-how and intellectual property 57 Prohibition of corruption 33 IT security 58 Dealings with officials and Handling Company assets 61 holders of political office 34 Prohibition of money laundering and terrorism financing 36 Accounting and financial reporting 38 Taxes and customs 41 Support 63 Fair and free competition 42 Procurement 45 Employee representation 64 Export control 46 Help / contacts / whistleblower system 66 Prohibition of insider trading 48 Self-evaluation for decision guidance 71 For better readability, only the masculine form is used in the following text. This form is explicitly understood as gender-neutral. It is used for editorial purposes only and is entirely without prejudice. Foreword by the Volkswagen 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 from When in doubt, we seek competent advice and seven European countries, some 664.000 support. employees, 123 production sites and customers in We, the Volkswagen Group Board of Management, over 150 countries are all part of the Group world. are convinced that our Code of Conduct is one key Irrespective of the differences between us, our to the success of our Group and its brands. We origins, our tasks and our responsibilities, we all therefore ask you to use the Code of Conduct in share responsibility for our company’s success and your workplace and to seek advice if you are in our contribution to sustainable development doubt. Let us join together to make the Volkswagen through our conduct and our actions. Our shared Group a responsible employer that is a byword not values determine how we work, how we make only for excellent products and services, but also for decisions, and how we interact with one another integrity and fairness. and all living creatures. The Volkswagen Group Code of Conduct supports ethical and responsible conduct. It contains relevant and practical examples that offer guidance, assistance and advice in our daily work. And it helps us identify mistakes and respond 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. 2 Dr.-Ing. Herbert Diess Oliver Blume Gunnar Kilian Chairman of the Board of Management Chairman of the Board of Management Human Resources of Volkswagen Aktiengesellschaft of Dr. Ing. h.c. F. Porsche AG, Sport & and Chairman of the Brand Board of Luxury brand group Management of Volkswagen Passenger Cars, Volume brand group, China Andreas Renschler Bram Schot Dr. Stefan Sommer Chairman of the Board of Chairman of the Board of Components & Procurement Management of TRATON SE, Management of AUDI AG, Truck & Bus brand group Premium brand group Hiltrud Dorothea Werner Frank Witter Integrity and Legal Affairs Finance & IT 3 Foreword by the Executive Committee of SEAT, S.A. We, as SEAT Group1 and as part of the Volkswagen Group, express through our Code of Conduct our commitment to assume our global and local responsibility to act in our daily activities in accordance with our internal standards and comply with the current legislation. This is consistent with the aim of strengthening the confidence of customers and business partners in our Company and its products. Our brand has established ambitious goals and is ready knowing that we count on the support of the Board of to face the transformation challenges that the sector is Directors and the Executive Committee. currently experiencing. The Volkswagen Group’s Code of Conduct, in its We must develop innovative, sustainable, efficient and updated and extended version, provides guidance and safe products, including mobility services and new advice. It establishes which conduct would be the vehicles for urban mobility. most suitable within the company, as well as with SEAT’s Board of Directors and Executive Committee business partners and third parties. SEAT has decided are convinced that an integral and honest conduct will to adhere to it and for its compliance by all the increase our business success in a lasting basis, employees that form part of the SEAT Group. because “values create value”. It is up to all of us to We must take the required time to familiarize ourselves contribute to its achievement. with the current Code of Conduct and observe the Each and every one of us must comply with the guidelines thereof. current legislation and applicable standards in order to The management team and the entire staff share a safeguard the good reputation of our brand on a daily responsibility towards our SEAT brand and we pledge basis. All of us know what is right and wrong. In case we ourselves with this Code of Conduct to act in an do not feel comfortable with any decision or business honest and upright way. transaction, we should express it and seek for advice, 1 For the purpose of this document, SEAT Group is defined as the following group of companies: SEAT, S.A.; SEAT CUPRA, S.A.; SEAT Metropolis Lab Barcelona, S.A.; Connected Mobility Ventures, S.A.; Respiro, S.L.; SEAT Portugal Unipessoal, LDA; SEAT Center Arrábida-Automóveis, LDA; and SEAT Deutschland GmbH. 4 Luca de Meo Luis Comas Matias Carnero Chairman of the Executive Vice-President Chairman of Works Executive Committee for Legal Affairs and Council of SEAT, S.A. Governance of SEAT S.A of SEAT, S.A. 5 Foreword of CUPRA S.A SEAT CUPRA S.A is a company committed to compliance with ethical norms and principles, as well as with current legislation and regulations. Consequently, all members of SEAT CUPRA S.A want to show our total commitment and full will to respect the values and principles of conduct reflected in this Code. As part of the SEAT Group, in SEAT CUPRA S.A we or involuntarily. In this sense, if in a given case we share the vision that true business success is witness or we become aware of any action contrary to achieved through honesty, transparency and this Code of Conduct, it is our obligation to contact commitment to legality. the persons responsible for regulatory compliance The trust that our customers place in us every day through the means provided for that purpose. depends on all of us, with no exception, conforming It is of the utmost importance that we all bear in mind our conduct to the provisions of this Code. The good that each of us personally responds to compliance reputation enjoyed by SEAT CUPRA S.A is, in part, the with the rules contained in this Code, as well as with result of the good work of all the SEAT Group’s all the additional regulations that are applicable to us companies and any action contrary to our values in the performance of our work. would jeopardize the great image of all the brands We must support each other in complying with this that make up the Group. Code of Conduct. It is, therefore, of the utmost importance that we understand and assimilate these common rules and standards of conduct, without forgetting that, although this Code intends to cover many of the possible situations that may take place within the SEAT Group, it cannot foresee everything, so we should ask for clarification in case of having any doubt about the best course of action in a given situation. Likewise, we all know that, in the working environment of the company, as well as in the rest of society’s spheres, behaviours contrary to ethics that may even be considered a crime can occur voluntarily 6 Antonino Labate Jaime Puig COO Chief Operation Officer CUPRA Racing Director 7 8 Our responsibility for compliance One decisive factor for the success of our Company The Code of Conduct serves as a binding guideline is that all employees – from Board of Directors, in our day-to-day business. It is supplemented by Executive Committee members and managers to internal guidelines and provisions in employment each individual member of staff – must act with contracts. It also goes without saying that we all honesty and integrity and in an ethical manner. This comply with the national and international statutory also means that our internal and external reporting provisions. This also means that we never take any and communications must be truthful, part in any activity that involves fraud, comprehensive and timely. misappropriation, extortion, theft, embezzlement Our shared goal is to fulfill our responsibility to our or any other deliberate damage to the assets of our Company and to protect the reputation of customers or any third party. Volkswagen Group brands. Sustainability requires of Failure to observe the Code of Conduct can result in us an awareness of our responsibility for the considerable damage, not only to our Company, but economic, social and ecological impact of our also to us as employees and to our business partners actions.