Reporting system - whistleblowing system
The whistleblower system has been set up to deal with serious violations of regulations or laws. It is a key element of good corporate governance. In the context of a fair and transparent procedure, the whistleblower system protects the company, the persons implicated and the whistleblowers. The new system is founded on standardized and swifter processes along with the confidential and professional processing of reports by internal experts.
Complying with statutory regulations and internal rules has top priority at Volkswagen. We can only avoid damage to our company, our employees and business partners if rules and standards are respected. Consequently, misconduct must be recognized swiftly, processed and immediately remedied. That calls for vigilance on the part of everyone along with a willingness to draw attention to possible serious regulatory violations on the basis of concrete evidence. We also value information of this nature from business partners, customers and other third parties. We must all make every effort to create an atmosphere in our company where we feel comfortable talking about misconduct. In many cases that can take place in teams, with superiors or with colleagues. The revised and restructured whistleblower system is designed to help in situations where such issues cannot be clarified in the team due to their relevance or the seriousness of the misconduct.
Why is it important to report regulatory violations?
Reporting misconduct can avoid damages or other legal disadvantages for our company and for us as employees. In the event of serious regulatory violations, recognizing such violations swiftly, taking immediate action and remedying them promptly is crucial. In addition, we can learn from regulatory violations, and further improve and optimize the processes and structures in our company.
What is a "serious regulatory violation"?
The term "serious regulatory violation" is used to describe a violation when the reputational or financial interests of the Volkswagen Group or of one of its Group companies are severely affected. Group Policy 3: Volkswagen Group Whistleblower System gives concrete examples of such violations (LINK).
What changes have been made to the existing whistleblower system?
The revised version of Group Policy 3: Whistleblower System (GR 03) optimizes the whistleblower process. Tried-and-tested channels such as the ombudspersons (confidential lawyers) remain in place. All information received is treated as confidential and whistleblowers decide for themselves whether they wish to remain anonymous vis-à-vis the company. A specially-protected online channel for reports and the appointed ombudspersons make sure that reports from whistleblowers who do not wish to be identified by the company are forwarded to the Investigation Office in anonymous form.
Complete protection for whistleblowers and persons implicated
The whistleblower system guarantees the greatest possible protection for whistleblowers and persons implicated. An investigation is only initiated after very careful examination of the facts and concrete evidence of a regulatory violation. The presumption of innocence applies for persons implicated for as long as a regulatory violation is not proven. Persons implicated will be treated fairly, heard in a timely manner and rehabilitated insofar as they have been unjustly accused. There will be strict confidentiality and secrecy throughout the investigative process. Information will be reviewed fairly, promptly and in a sensitive manner.
Whistleblowers will be protected. The information they provide will be treated as confidential. If they so wish and insofar as permitted by law, their identity will not be disclosed. Discrimination against whistleblowers is a serious regulatory offence and will not be tolerated.
Role of the Investigation Office in the whistleblower system
Dr. Matthias Haas leads a team of specialized, experienced lawyers working in the Investigation Office. These colleagues receive reports and check the information for concrete evidence of a serious regulatory violation. They only initiate an investigation is there is concrete evidence of serious misconduct. If that is the case, a department (Corporate Audit, Corporate Security, Corporate Legal) will be appointed to investigate. Once the investigation has been concluded the Investigation Office will ensure that appropriate measures are taken by the responsible bodies in the event of a serious regulatory violation.
Role of employees
Anyone reporting concrete evidence of a serious regulatory violation in good faith helps the company and all employees because they prevent serious damages and other legal consequences from affecting the company and us as employees. In addition, such information helps us to further improve and optimize the processes and structures in our company.
Important note for executives / management
Executives are expected to fulfil their function as a role model, conduct themselves in an ethically correct manner and to support and encourage their employees to behave with integrity. Regulatory violations, in particular serious regulatory violations, will not be tolerated. This must be communicated clearly by every executive. Under the revised Group Policy, managers are obliged to report information concerning concrete evidence of a serious regulatory violation via the whistleblower system.
If an employees from the Higher Management Circle violates the law or company regulations - such as the Code of Conduct - that may be interpreted as a "serious regulatory violation" as defined by the Whistleblower System Group Policy. Click here for the text of Whistleblower System Group Policy.
Where can I make a report?
Click here for contact details and for further information on the whistleblower system.
Contact details Investigation Office
In person: Investigation Office
Porschestraße 26-30, 38440 Wolfsburg (DOWNTOWN), Gjermani
Postal address: Investigation Office, Box 1717, 38436 Wolfsburg, Germany
Phone +800 444 46300/ +49 5361 946300
Online channel for reports:: https://www.bkms-system.com/vw
Obudsman contact :
Dr. Rainer Buchert (Avokat)
+49 6105 921 355/+49 69 71033330, dr-buchert(kwfat)dr-buchert(kwfdot)de
Thomas Rohrbrach (Avokat)
+ 49 69 65300356, rohrbach(kwfat)ra-rohrbach(kwfdot)de
You can make a report using the international toll-free number: +800 444 46300* **.
If your local telephone provider does not support the toll-free service, you can
call the following chargeable number:
+49 5361 946300*.
* Please note that the + needs to be replaced by the international access code.
** If there occur technical problems with the availability of the hotline, please use the other listed reporting channels to report your concern to the Investigation Office.