OUR  
CODE  
GROUP  
ESSENTIALS  
The Group Essentials are our Group’s foundation of values that  
connects all people in all brands and companies.  
They form the basis of our corporate culture.  
We live diversity.  
We take on responsibility for  
the environment and society.  
We are proud of  
the work we do.  
We are honest  
and speak up when  
something is wrong.  
We not me.  
We keep our word.  
We break new ground.  
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We are one  
WEAREONE  
Our fundamentals for  
Integrity and Compliance  
The Volkswagen Group Code of Conduct,  
OUR CODE, is the ethical and values-based  
foundation for acting with integrity and in  
compliance with the rules in our Group. It  
serves as a binding guideline for all  
employees in all brands and companies  
all over the world.  
intelligence. Transparency is important to us  
and our approach to innovative technologies  
ensures that users‘ rights and security are  
respected.  
We do not tolerate violations of the Code of  
Conduct. Anyone who violates our rules  
must expect appropriate consequences. To  
make sure that does not happen we seek  
advice and support so that together, we  
protect our Company, its values, and the  
reputation of all the brands.  
Together, we bear responsibility for our  
collaboration, our workplace, the environment,  
sustainability, and society. We approach one  
another and everyone else with respect and  
fairness, as equals. We take a stance, we are  
steadfast and courageous in standing up for  
our values and principles regardless of time,  
economic or social pressure.  
Each of us is personally responsible for  
complying with OUR CODE. It is up to all of us  
to familiarize ourselves with the Code’s  
principles and to be guided by them in our  
day-to-day decision-making. For a Group on  
the move, for the protection of people and the  
environment, and for future generations.  
We are firmly convinced it is essential for  
each and every one of us employees,  
members of the Board of Management and  
managers to act with honesty in order to  
foster trust in our Company, our products,  
services, and innovations. That is why the  
decisions we take in all areas of work and in  
all roles must be in accordance with our  
corporate values, and comply with valid  
national and international laws, regulations,  
and internal voluntary commitments. This also  
holds true for the continued evolution of our  
Company as well as the choice, procurement,  
development, and use of innovative  
technologies such as artificial  
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WEARECOMMITTED  
INDIVIDUALS  
We embrace our corporate values, principles and rules,  
thus promoting trustful, sincere and fair interaction with  
oneanother. We are all role models.  
1. Human rights  
2. Ethical leadership  
3. Diversity, equal opportunities  
and equal participation  
4. Speak Up  
5. Employeerepresentation  
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1.1 Human rights  
We take responsibility for  
human rights  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
Respect for human rights is of paramount  
importance. We are convinced that  
sustainable economic activity is only  
possible by acting ethically and with  
integrity. Within the framework of our  
entrepreneurial activities, we are fully  
committed to our responsibility regarding  
human rights. The Group Board of  
Management, the Volkswagen Group  
European Works Council and the  
Volkswagen Group Global Works Council  
have fulfilled this responsibility in the  
Group’s Declaration on Social Rights,  
Industrial Relations and Business and  
Human Rights, known as the Social  
Charter.  
As an employee, I can also make my  
contribution to respecting human rights.  
I regard human rights as a fundamental  
guideline, and I am vigilant against human  
rights abuse that is happening around me or  
of which I become aware.  
If I have concerns regarding human rights  
abuse in my professional surroundings,  
I prevent it or stop it immediately. If  
necessary, I inform my supervisor or get in  
touch with any of the contacts listed in the  
chapter on “Support”.  
We confirm our commitment to major  
international agreements and declarations, in  
particular the International Bill of Human  
Rights and the core labor standards of the  
International Labour Organization (ILO).  
Our entrepreneurial activities follow the UN  
Guiding Principles on Business and Human  
Rights (UN Global Compact), which  
determine the most important cornerstones  
for our actions.  
EXAMPLE  
Someone has written to you with information  
that one of our suppliers is not paying their  
Inform your superior and the Whistleblower  
System of your concerns about human rights  
employees their correct wages and is tolerating abuse. Our Company will examine the  
employees working beyond the maximum  
working hours regulated by relevant laws and  
regulations. In addition, the pay of some of the  
supplier’s employees is below the minimum  
wage.  
allegations in greater detail and take the  
necessary measures. This may include  
terminating business relations with the  
supplier in question.  
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1.3 Diversity, equal opportunities and equal participation  
1.2 Ethical leadership  
We lead based on our values  
Welivediversity  
CORPORATE PRINCIPLE  
EXAMPLE  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
We embrace our corporate values, principles,  
and rules, take responsibility for both  
In order to complete a project to schedule,  
your team would like to skip one step in the  
process. They say the step is unnecessary.  
You point out that the valid rules must be  
followed, regardless of any pressure.  
Together, you search for a solution that  
complies with the requirements and our  
values. You undertake to revise the process  
in collaboration with everyone involved and,  
where possible, to make it leaner. You  
commit to that as a manager and team  
member.  
Diversity, equal opportunities, and equal  
participation are important principles for  
fair, non-discriminatory, and respectful  
coexistence. We believe in cooperation in a  
spirit of partnership, in tolerance and in  
mutual respect. We foster diversity in the  
workforce and support an inclusive work  
environment.  
I observe the principles of diversity, equal  
opportunities and equal participation and  
encourage people around me to do the  
same.  
personal and corporate growth, and lead by  
example. We perform our duties, and manage  
our powers and roles in an appropriate, fair  
and responsible manner. That also applies for  
personal relationships in the workplace, in  
particular insofar as existing employment or  
hierarchical dependencies may be exploited.  
Our decisions are always transparent, show  
good judgment, are guided by integrity, and  
are taken in the best interests of the  
If I see any violations of the principles of equal  
opportunities and equal participation, such as  
unequal treatment, harassment, and bullying, I  
make the persons involved aware of their  
misconduct. If I am not in a position to directly  
influence events, I notify the HR department of  
the incident immediately or get in touch with  
the contacts listed in the chapter on  
We offer equal opportunities for everyone  
and reject all forms of discrimination.  
This applies in particular to unequal  
Company and its employees, business  
partners and shareholders. We strengthen  
trust and shape change in the Company  
through our values-based leadership.  
treatment due to ethnic or social origin, skin  
color, biological sex, nationality, language,  
religion, ideology, age, physical or mental  
disabilities, gender identity, sexual  
“Support”.  
EXAMPLE  
orientation, political views, or any other  
characteristics protected by law. We live  
diversity, actively support inclusion, and  
create an environment that not only  
You hear some of the people you work with  
making disrespectful comments about people  
on account of their nationality, gender, sexual  
orientation, or skin color.  
MYCONTRIBUTION  
encourages the engagement of all  
I am aware of my function as a role model  
both within the Company and in a broader  
context. My conduct and actions  
employees, but also fosters each employee’s  
individuality in the interests of the Company.  
Either speak up straight away about this  
discrimination or get in touch immediately  
with one of the contacts listed in the chapter  
on “Support”.  
are always guided by integrity and a sense of  
responsibility, and are based on this Code of  
Conduct, our corporate values, principles and  
rules. I advocate interaction with one another  
in a spirit of trust, honesty, and fairness, and I  
am open to different points of view.  
Our employees are selected, hired, and  
developed based on their qualifications  
and their skills.  
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1.4 Speak Up  
We speak up when something  
is wrong  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
We want to learn from mistakes and  
continuously improve. That is why we  
speak up about wrongdoings, or as soon as  
something doesn’t feel right, even if that is  
awkward and uncomfortable. To do that,  
we promote a culture of integrity and  
actively seek a dialog within our team and  
with our supervisors. We seek advice and  
support if we have questions and  
My first point of contact for questions,  
concerns, or the reasonable suspicion of a  
violation of internal or external regulations is  
my supervisor, or alternatively I can seek  
advice from the relevant subject matter  
experts. The HR department and employee  
representatives as well as Compliance are also  
available to provide support. In addition,  
I should report any reasonable suspicion of  
Serious Regulatory Violations via the  
Whistleblower System. As a Management  
Level employee, I am obliged to report any  
such suspicion.  
problems. We protect everyone who  
contributes to this culture.  
For us, compliance with external and internal  
rules at all times is a given. We do not  
tolerate misconduct. We believe that turning  
a blind eye can never be the right solution.  
That is why we react immediately and  
appropriately to misconduct and violations  
of our rules.  
EXAMPLE  
The deadline for a decision proposal  
submitted to a committee has expired and  
you notice that you and your team have made  
a mistake. You know it is not possible to take  
a meaningful decision on the basis of the data  
submitted.  
Managers always lead by example through  
conduct that is in accordance with our rules  
and regulations. They perform this important  
function by supporting employees to comply  
with the rules, promoting an error culture, and  
following up on violations.  
Inform your supervisor and the departments  
responsible for the committee immediately.  
Jointly find a way to correct the document. In  
addition, you and your team discuss how such  
errors can be avoided in future.  
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1.5 Employee representation  
We work together in close  
partnership constructive,  
cooperative and fair  
We recognize the basic right of all employees  
to establish trade unions and employee  
representations in compliance with local laws  
and regulations.  
We are committed to working with all  
employees and employee representatives in  
candor and trust, to conducting a  
constructive and cooperative dialogue, and  
to striving for a fair balance of interests.  
Professional dealings with all employees and  
employee representatives are part of our  
corporate culture.  
Safeguarding the future of Volkswagen and its  
employees is achieved in a spirit of cooperative  
conflict management and social commitment,  
on the basis and with the goal of ensuring  
economic and technological competitiveness.  
Economic efficiency and job protection are  
equal-ranking and shared goals.  
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WEARERELIABLE  
COLLEAGUES  
We take our responsibility in the workplace  
seriously and protect what is valuable for  
our team, our Company, and our customers.  
1. Occupational health and safety  
2. Handling Company assets  
3. Security and protection of information,  
know-how and intellectual property  
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2.1 Occupational health and safety  
2.2 Handling Company assets  
We respect and promote  
health and safety  
We protect our assets –  
whether visible or invisible  
CORPORATE PRINCIPLE  
CORPORATE PRINCIPLE  
EXAMPLE  
We take our responsibility for the safety and  
health of our employees very seriously. We  
promote occupational health and safety  
in line with the provisions of national laws  
and regulations and with the occupational  
health and safety policy of the Company.  
I make an active contribution to maintaining  
We respect the Company’s tangible and  
intangible assets and do not use them for  
non-business purposes, but solely to  
achieve the Company‘s business objectives.  
Exceptions are possible if internal policies and  
guidelines permit private use.  
High-end software is installed on your  
business laptop. A friend who knows this  
asks you to lend them your laptop so that  
they can use one of these programs for  
private purposes.  
and promoting my health by voluntarily  
participating in preventive healthcare  
and health promotion activities. I follow  
instructions, attend training, and align my  
daily actions with them.  
You say no, because you know that  
Company property and Company IT may  
not be made available to third parties.  
Occupational health and safety for all  
employees is fundamental to ensuring a  
sustainable future for our Company and to  
positioning our Company as an attractive  
employer. All accidents at work and work-  
related illnesses are generally preventable.  
We therefore aim to ensure the protection  
and promotion of physical and mental  
health. This requires the cooperation and  
participation of all.  
EXAMPLE  
MYCONTRIBUTION  
You notice that a device in your department  
appears to have an electrical defect.  
I adhere to the Company’s rules and exercise  
care when handling Company assets.  
Do not activate the device and notify the  
responsible supervisor to coordinate further  
measures. It is not permitted to repair  
electrical equipment yourself because this  
might be dangerous.  
MY CONTRIBUTION  
I comply with occupational health and safety  
regulations and instructions. I do not  
endanger my own health and safety or that of  
my team or third parties. I support them, do  
not look the other way, and accept help.  
Within my area of responsibility, I take all  
appropriate and statutory measures to  
ensure a safe working environment. I draw  
attention to unsafe actions or conditions.  
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2.3 Security and protection of information, know-how  
and intellectual property  
We protect information and  
intellectual property  
CORPORATE PRINCIPLE  
EXAMPLE  
We are aware of the value of Company  
know-how and take great care to protect it.  
We respect the intellectual property of  
competitors, business partners and other  
third parties.  
You are involved in the development of an  
innovative technology. You are to present  
your development at various Company sites  
and want to take your laptop, which you have  
used to store the relevant documents, with  
you for presentation purposes. You intend to  
go over these documents again on the plane  
or the train on the way to the various sites.  
MYCONTRIBUTION  
I handle all Company information carefully  
and do not disclose it to unauthorized  
persons. I take particular care with regard to  
information relating to technical know- how,  
patents, and trade and business secrets.  
You must make sure that no one obtains  
knowledge of sensitive information belonging  
to the Group, as this could lead to serious  
competitive disadvantages. Do not retrieve  
this type of information in places where third  
parties can access it or take note of it.  
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WE ARE RESPONSIBLE  
PARTNERS  
Trust is our greatest asset. That is why we rely on honest,  
reliable, transparent, and fair business relationships.  
1. Conflicts of interest  
2. Benefits  
3. Prohibition of corruption  
4. Prohibition of insider trading  
5. Prohibition of money  
laundering and terrorism  
financing  
6. Fair and free competition  
7. Business partners, procurement  
and sales  
8. Accounting and financial reporting  
9. Export control  
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3.1 Conflicts of interest  
We take decisions based on facts,  
thus avoiding conflicts of interest  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
If I identify that I face or suspect that I  
may face a potential conflict of interest,  
I immediately notify my supervisor and the  
relevant HR and Compliance departments  
and disclose the facts. If a conflict exists, we  
jointly seek a solution that safeguards the  
interests of the Company.  
We act with integrity. That is why it  
is especially important for us to avoid creating  
potential conflicts of interest when  
performing our job responsibilities and to  
recognize and disclose possible conflicts that  
we face or that we observe. A potential  
conflict of interest already exists if private or  
personal financial interests of employees  
influence or could influence their business  
decisions. This also applies for personal  
relationships in the workplace, in particular  
with regard to existing employment  
EXAMPLE  
Your boss asks you to review offers from  
several suppliers of plastic components and  
to pre-select potential candidates. You  
discover that one of the most favorable bids is  
from the company of a good friend.  
relationships or hierarchical dependence.  
Conflicts of interest may arise both from  
employees themselves or through persons  
related to them, in particular as a result of  
involvement in other companies, through  
secondary employment, in connection with  
memberships or with regard to employees’  
personal financial circumstances. In this  
context, business relations with third parties,  
such as other companies in the Group or  
suppliers, may also be relevant.  
Inform your supervisor of this personal  
connection that could be understood as  
personal bias. Withdraw from the decision-  
making process to avoid any appearance of a  
conflict of interest.  
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3.2 Benefits  
We carefully check all Benefits  
CORPORATE PRINCIPLE  
EXAMPLE  
Our products and services define who we are.  
Therefore, benefits in the form of gifts and  
invitations are only permitted if they are  
appropriate.  
You work in purchasing. A supplier sends you  
an invitation to a multi-day sports event. This  
supplier is one of the bidders in a current call  
for tender.  
Our internal policies on handling gifts,  
invitations and business meals set out what  
benefits are appropriate and what steps must  
be taken when accepting and / or granting  
them.  
Invitations and gifts from suppliers to  
purchasing employees must always be  
scrutinized very carefully. During a call for  
tenders in particular, the acceptance of  
benefits from participants is not permitted, as  
this could give the impression of undue  
influence. If you have any concerns, contact  
your supervisor and if necessary the relevant  
Compliance department.  
MYCONTRIBUTION  
I familiarize myself with the policies on  
handling gifts, invitations and business  
meals, and strictly abide by them.  
I check whether my behavior is appropriate  
and whether it might influence my business  
decisions.  
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3.3 Prohibition of corruption  
3.4 Prohibition of insider trading  
We do not share insider knowledge  
We do not bribe others and do  
not accept bribes ourselves  
CORPORATE PRINCIPLE  
EXAMPLE  
CORPORATE PRINCIPLE  
Corruption is prohibited worldwide.  
Corruption means that someone abuses  
their professional position to gain an  
advantage for themself or a third party  
and thereby harm others.  
You visit a supplier to inspect components for  
local production. During your visit it becomes  
obvious that the components have significant  
defects. Your contact at the supplier offers  
you a sum of money for ignoring the defects  
and to persuade you to accept the defective  
items.  
We handle information pertaining to share  
Company performance in accordance with  
capital market requirements and do not  
tolerate any insider trading. Insider  
If I have access to inside information, I  
do not purchase or sell any financial  
instruments based on this information. This  
applies not only to trading with shares of  
listed companies belonging to the Group or  
derivatives thereof, but also to trading with  
financial instruments in general, i.e., also  
those of suppliers.  
information is information of a precise  
nature that has not been made public  
and that, if it were made public, would be  
likely to have a significant effect on the  
price of the relevant financial instrument,  
e.g., stocks and shares. We may only use  
knowledge relating to insider-relevant  
projects and processes internally in  
accordance with the applicable internal  
policies and may not divulge such  
Benefits such as invitations and gifts,  
especially when dealing with public officials,  
can be evidence of corruption. Therefore,  
benefits should be exceptions in business  
transactions. Benefits may only be granted or  
accepted within the framework of internal  
policies and applicable laws.  
On no account accept the money. Contact  
your supervisor or the relevant Compliance  
department immediately. Any attempt  
at bribery is not tolerated under any  
circumstances.  
EXAMPLE  
You learn through your work that the acquisition  
of a large company well-known worldwide is  
going to be announced soon. As part of your job,  
you have been informed that the Company‘s  
share price will rise significantly once this  
transaction has been announced. You know that  
a good friend is currently considering whether  
to sell their shares in our Company. You  
consider telling your friend that he should hold  
off on selling his shares.  
knowledge to any outside party, including  
family members, e.g., a spouse.  
MYCONTRIBUTION  
I do not bribe others and I do not accept a  
bribe myself, and I avoid even the  
MYCONTRIBUTION  
appearance of improper influence. I keep  
myself informed by consulting the internal  
rules before I give or accept gifts and issue or  
accept invitations.  
I do not engage in insider trading, nor do I  
make any such recommendations to any  
third party or induce any third party to  
engage in insider trading. Furthermore, I do  
not divulge inside information unless this is  
required during the course of my normal  
work, and I comply with the relevant internal  
policies. I undertake to familiarize myself with  
the applicable internal rules.  
Do not tip your friend off for any reasons  
whatsoever. Since the information of which  
you are aware is not public, but insider  
knowledge, you are not permitted under any  
circumstances to share this knowledge with  
others. Transmitting this knowledge directly or  
indirectly would make you liable to  
prosecution.  
If I receive any corruption-related hints, I  
immediately inform one of the contacts  
listed in the chapter on “Support”.  
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3.5 Prohibition of money laundering and terrorism financing  
We are committed to clean  
business practices  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
Money laundering occurs when funds or  
other assets originating directly or  
indirectly from criminal offenses are put  
into circulation in the legal economy,  
making their source appear legal. Terrorism  
financing occurs when money or other  
resources are made available to commit  
criminal acts of terrorism or to support  
terrorist organizations. Liability does not  
require the person involved to be aware that  
money is being laundered through the  
relevant transaction. Inadvertent  
I take no action whatsoever that may violate  
money laundering provisions at home  
or abroad. I am vigilant and immediately  
assess any suspicious conduct on the part  
of customers, business partners and other  
third parties. If there is information  
providing sufficient grounds for suspicion,  
I immediately get in touch with the contact  
person responsible for money laundering  
prevention.  
I abide by all applicable provisions for  
recording and posting transactions and  
contracts within my area of responsibility  
in the accounting system.  
involvement in money laundering may  
already be a criminal offense for the parties  
involved.  
We carefully check the identity of customers,  
business partners and other third parties with  
whom we wish to do business. It is our  
declared aim to conduct business solely with  
reputable partners who operate in line with  
legal provisions and who use resources from  
legitimate sources.  
EXAMPLE  
A customer or business partner has overpaid  
and asks for the excess amount to be repaid  
by transferring it to a foreign account held in  
another country or by paying it in cash instead  
of via bank transfer to the original business  
account.  
the customer why the amount cannot be  
repaid through the same channel used for  
the original payment. Seek advice from the  
contact person responsible for money  
laundering prevention.  
We assign incoming payments to the  
corresponding services without delay  
and post them accordingly. We ensure  
transparent and open cash flows.  
This kind of request requires an explanation.  
Do not accept the suggestion readily but ask  
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3.6 Fair and free competition  
We are committed to fair and  
free competition  
CORPORATE PRINCIPLE  
Free and fair competition is protected by  
antitrust legislation valid throughout the  
world. Complying with this legislation  
ensures that there is no undue distortion  
of competition in the relevant markets  
to the benefit of all market players.  
We conduct business solely on the basis  
of merit and market economy principles as  
well as free and open competition.  
We like to measure ourselves against our  
competitors, always abiding by laws and  
regulations and observing ethical principles.  
In particular, agreements and concerted  
practices between competitors intended  
to achieve or effect the prevention or  
We do not enter into any anti-competitive  
agreements with competitors, suppliers, or  
customers. If our Company holds a  
dominant market position, we do not abuse  
this position.  
restriction of free competition are prohibited.  
This includes in particular exchanges on  
prices and price components, terms and  
conditions, carving up customer groupings  
and territories, and restrictions on  
We comply with the specific antitrust  
provisions for distribution systems in our  
dealings with our authorized distribution  
partners.  
innovations. In addition, the exchange  
of competitively sensitive information is  
prohibited. The abuse of a dominant market  
position is also prohibited. Furthermore, the  
proper implementation of merger control  
procedures is required with regard to  
cooperations and transactions.  
EXAMPLE  
MYCONTRIBUTION  
Whenever I come into contact with  
competitors, I make sure that no information is  
given or received that would allow  
conclusions to be drawn about current or  
future business conduct.  
You talk to a competitor’s employee at a  
trade fair. After a short while, you notice you  
are being sounded out for information about  
future business planning. In return, the  
employee offers to divulge the same  
information about his company.  
This type of conversation apart from the  
unauthorized disclosure of trade secrets is  
also a violation of valid competition and  
antitrust legislation and could have drastic  
consequences for you personally, our Group,  
and both the competitor’s employee and his  
company. Document this conversation and  
inform the relevant Legal and Compliance  
department immediately.  
Anti-competitive conduct has the potential  
not only to significantly damage the good  
reputation of the Company, but can also  
incur severe fines, penalties, and financial  
compensation for damages.  
In discussions or any other contacts with  
competitors, I avoid issues that could be of  
relevance for competition among each other.  
Immediately make it absolutely clear to the  
competitor’s employee that you will not talk  
to him about such issues.  
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3.7 Business partners, procurement and sales  
3.8 Accounting and financial reporting  
We carefully check who we do  
business with  
We are committed to correct  
financial accounting and reporting  
CORPORATE PRINCIPLE  
CORPORATE PRINCIPLE  
EXAMPLE  
We carefully select suppliers, service  
providers and partner companies based  
on objective criteria and make use of  
competition. We only cooperate with  
business partners in line with statutory  
requirements, internal rules and guidelines.  
I do not purchase any products or services  
We strictly comply with the statutory  
provisions for proper accounting and  
financial reporting. Transparency and  
correctness are our top priorities, because  
any irregularities may have serious  
consequences for the Company as well  
as for the persons responsible. To that end,  
we regularly inform all capital market  
players of our financial position and business  
developments. We publish our periodic  
financial statements punctually in  
You urgently need new equipment. However,  
your department’s budget for the current fiscal  
year has already been used up. You consider  
acquiring the equipment nevertheless and  
posting the cost in the next fiscal year when  
your budget has been refreshed.  
without having first gathered information on  
the market and alternative suppliers. I follow  
the applicable procurement guidelines and  
involve the relevant purchasing department at  
an early stage before the planned delivery and  
performance of services in line with valid  
purchasing processes.  
We check the integrity of potential business  
partners carefully before entering into  
business relations and follow the processes  
and contact procedures set out in the rules  
and policies.  
Do not take any action of the kind. Entries  
must always be assigned correctly. Posting  
entries inaccurately may have serious  
consequences for the Company and the  
individual employee.  
I make sure that remuneration is only paid  
for services that are actually rendered and  
that the payments are commensurate with  
the services rendered.  
accordance with national and international  
accounting regulations.  
When purchasing or selling products  
and services, we involve the relevant  
departments in the process in good time in  
accordance with the applicable policies.  
I also comply with the relevant policies  
before commissioning Group companies.  
MYCONTRIBUTION  
I organize processes in such a manner as to  
ensure all business financial data are  
entered correctly and promptly in the  
accounting system. If I have any questions  
about the correct recording of data, I  
contact my supervisor or the appropriate  
finance department.  
EXAMPLE  
MYCONTRIBUTION  
It comes to your attention that a supplier,  
service provider or partner company is to  
be commissioned without involving the  
relevant purchasing department.  
I make myself familiar, that the integrity  
of potential business partners has been  
checked before entering into business  
relations and follow the processes and  
contact procedures set out in the rules and  
policies. I show no bias in favor of a supplier,  
service provider or partner company without  
an objective reason, and I promote  
competition.  
Get in touch with the relevant purchasing  
department or one of the contacts listed in  
the chapter on “Support”, to make sure the  
bid that is most cost-effective for the  
Company is given consideration.  
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3.9 Export control  
We ensure compliance with all  
regulations in cross-border trade  
CORPORATE PRINCIPLE  
We are aware of our social responsibility to  
fulfill export control and sanctions  
That is how I keep up to date on whether  
my day-to-day work is subject to export  
control regulations.  
obligations and expressly commit to  
complying with the relevant legislation.  
Should I become aware that export control  
regulations are being violated in my area of  
responsibility, I immediately take every  
possible action to prevent or remedy such  
violations.  
Cross-border business processes and  
transactions may be subject to prohibitions,  
restrictions, approval requirements or  
other supervisory measures under export  
control regulations. These may relate to the  
relevant business partners, controlled items  
(including goods, technologies, and services),  
countries, financial resources, or intended use.  
This applies to goods, products, service,  
technologies and software as well as relevant  
technical information and data. Except for  
export per se, it also applies to temporary  
cross-border transfer and technical  
If in doubt, I seek advice from the relevant  
export control contact.  
EXAMPLE  
You receive an inquiry from a potential  
customer wishing to place an order with the  
Group to supply products to a country that the  
Group has listed as an embargoed country.  
Contact the relevant export control unit to  
coordinate the next steps and to clarify what  
export restrictions apply to the country to be  
supplied. Do not conclude any contracts that  
commit the Company to export to this country  
until the issue has been fully clarified.  
transmissions, for example, by e-mail or cloud  
or removable memory. Furthermore, certain  
imports may be subject to export control  
regulations.  
We ensure compliance with applicable  
export control regulations and the relevant  
internal policies.  
MYCONTRIBUTION  
I am responsible for regularly checking that I  
am familiar with internal information and  
policies on export control.  
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WEAREGOOD  
CORPORATE CITIZENS  
We bear responsibility for society and ensure that our  
Company contributes to sustainable development.  
1. Communication and marketing  
2. Communication with governmental  
authorities  
3. Dealings with public officials  
4. Donations and social sponsorship  
5. Taxes and customs  
6. Data protection  
7. IT security  
8. Product Compliance  
9. Environmental protection  
40  
4.2 Communication with governmental authorities  
4.1 Communication and marketing  
We represent our Company’s  
positions in a responsible and  
clear way  
We communicate clearly  
and respectfully  
CORPORATE PRINCIPLE  
EXAMPLE  
CORPORATE PRINCIPLE  
EXAMPLE  
We ensure that our communication is  
clear and consistent in order to maintain  
the confidence of customers, investors  
and other stakeholders. Before committing  
to and / or executing any communication or  
marketing measures, such measures must  
first be coordinated with the relevant  
department. Thoughtfulness and respectful  
interaction with one another are second  
nature to us.  
You read comments on the internet from  
someone criticizing production methods  
in Asia and you know the comments are  
completely unfounded.  
As a member of society, we can specifically  
promote the Company’s positions during  
decision-making processes, such as those for  
legislation plans through communication with  
governmental authorities.  
You have a relative who works for the  
transport ministry and who asks for your  
opinion on draft legislation that will impact  
the automotive industry. They also ask you  
for the Group’s position on this legislation.  
We conduct communication with  
Even if you would like to put the facts right  
straight away, contact the relevant  
department first, because they are in a  
position to respond comprehensively and  
appropriately to these comments.  
governmental authorities centrally and in  
line with the principles of compliance,  
openness, accountability, and responsibility.  
Influence in politics or legislation is not  
permitted.  
Do not comment. Communication with  
governmental authorities in the Company  
is exclusively coordinated centrally and  
conducted openly and transparently.  
Please seek advice of Corporate & JV  
Affairs division.  
MYCONTRIBUTION  
I do not issue any public statement on  
behalf of my Company and always refer  
any requests to the Communications  
department. If I make any comments at  
public, trade or cultural events or on the  
internet, I make it clear that I am voicing  
solely my own personal opinion. I consult  
the Company’s social media guidelines for  
advice on proper conduct in social  
networks.  
MYCONTRIBUTION  
I do not attempt to intervene in political  
decisions on behalf of the Company if I am not  
authorized to do so. If I am authorized to do so,  
I observe the relevant internal policies in the  
performance of my duties.  
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42  
4.3 Dealings with public officials  
We exercise caution when  
dealing with public officials  
CORPORATE PRINCIPLE  
EXAMPLE  
In view of national and international  
legislation, there is an increased risk of  
corruption when dealing with public  
officials. This is taken into account in our  
internal policies, which lay down the  
framework with regard to benefits. In  
particular, we do not make any facilitation  
or expediting payments, i.e., payments to  
public officials that facilitate or expedite  
regular or routine official acts.  
The guests invited to a full-day event include a  
university professor, who has been asked to  
give a lecture. You are considering what you  
need to keep in mind. Among other things,  
your department would like to invite the  
guests to lunch.  
Because the rules governing dealings with  
public officials this also includes  
academic staff at state universities are  
especially strict, seek the advice of the  
relevant Compliance department in  
advance.  
MYCONTRIBUTION  
I am aware that there is an increased risk of  
corruption when dealing with public officials.  
Therefore, I familiarize myself with the  
applicable special rules. I understand that I  
have a binding obligation to consult the  
Compliance department in this regard.  
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44  
4.4 Donations and social sponsorship  
4.5 Taxes and customs  
We commit to society in many ways  
We meticulously observe tax  
and customs regulations  
CORPORATE PRINCIPLE  
MYCONTRIBUTION  
CORPORATE PRINCIPLE  
EXAMPLE  
We make donations, i.e., voluntary  
If I consider a particular sponsorship measure  
to be worthy of support, I make initial contact  
with the appropriate departments in the  
Company, e.g., Communications, External  
Relations, and Human Resources.  
As a global company, we are aware of our  
social responsibility to meet our  
You are responsible for posting certain  
business transactions, for example general  
overheads such as maintenance expenses,  
and production costs, in the statutory  
financial statements. One project exceeds  
certain controlling parameters early in  
the financial year. You therefore receive  
instructions to make an entry under  
contributions without a return service by  
the recipient, and grant sponsorships and  
brand ambassador agreements,  
obligations with regard to foreign trade,  
taxes and customs, and we explicitly  
endorse compliance with national and  
international legislation.  
i.e., contributions based on a contractually  
agreed return service for social objectives, to  
achieve a positive impact in terms of our  
reputation and public perception. In order to  
avoid conflicts of interest and  
The granting of donations must be  
transparent, i.e., the purpose, the recipient of  
the donation, and the financial management  
must be documented and verifiable. I comply  
with internal processes and general conditions  
and do not initiate any donation that could  
damage the reputation of our Company.  
MYCONTRIBUTION  
maintenance expenses even though the  
transaction unquestionably relates to an  
investment and must therefore be treated  
as capitalized production costs.  
to ensure standard conduct within the  
Company, donations and sponsorship and  
brand ambassador agreements measures  
are permitted only in the context of the  
respective legal framework and in  
I design internal structures and processes in  
such a manner as to ensure that the taxes and  
customs to be paid by the respective Group  
companies are calculated correctly, promptly  
and in full, are disclosed in reporting, and are  
paid to the relevant fiscal authorities.  
Post the entry in line with legal requirements.  
All business transactions must be correctly  
reported pursuant to commercial law and tax  
regulations because these accounting records  
form the basis for tax returns.  
accordance with the applicable internal rules  
of the Group brands and companies.  
EXAMPLE  
A local politician asks you for a cash donation or  
sponsorship from your Company for a  
government project/event.  
If I have information concerning a violation of  
tax and customs regulations in my area of  
responsibility, I undertake every action I can to  
prevent or stop this violation. If that is not  
possible, I get in touch with the appropriate  
contact person in the tax and customs  
department.  
Donations and sponsorship and brand  
ambassador agreements measures are  
only granted in accordance with a  
transparent approval process. We grant  
Payments and/or non-cash benefits for  
scientific, charitable, cultural or religious  
purposes. In addition, we grant donations  
exclusively to institutions which are  
recognized as charitable and / or tax-  
privileged.  
Accounting errors could therefore result in  
incorrect tax returns and lead to serious  
consequences under tax and customs  
law for the Company and the employees  
responsible.  
Turn down the request. Donations and  
sponsorships may only be granted after going  
through the required approval process. In this  
specific case, the donation or sponsorship  
cannot be approved because an internal  
guideline prohibits donations and  
sponsorships to political parties, related  
institutions, and politicians.  
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46  
4.6 Data protection  
We handle data carefully  
CORPORATE PRINCIPLE  
EXAMPLE  
We attach great importance to handling data  
responsibly, securely and transparently. We  
collect, process, use, and store personal data  
solely in accordance with statutory  
You are planning a market analysis for the  
Company. The analysis involves the  
collection and evaluation of customers’  
personal data. Another department would  
also like to use this data at a later point.  
Valid data protection legislation states  
that data may only be collected and  
processed on a specific legal basis and  
that the customers concerned must  
always be adequately informed. In addition,  
as a general principle data may only be  
processed for the purpose for which it was  
collected.  
requirements. We protect the personal data of  
customers, employees including former  
employees and applicants and partners such  
as suppliers and development partners.  
MYCONTRIBUTION  
I handle personal data confidentially and my  
actions are clear and transparent. I integrate  
data protection in my actions and processes  
and ensure the security of all data in my area  
of responsibility. I take responsibility and pay  
attention to secure data exchange throughout  
the value chain. If in doubt, I contact my  
supervisor or the relevant data protection  
department.  
Please clarify with your supervisor or the  
relevant data protection unit whether the  
customers’ consent must be obtained prior  
to collection, how the customers are to be  
informed, and the terms on which the data  
could be used by another department.  
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48  
4.8 Product Compliance  
4.7 IT security  
We secure our IT systems  
We inspire the world with  
our products  
CORPORATE PRINCIPLE  
EXAMPLE  
CORPORATE PRINCIPLE  
MY CONTRIBUTION  
We respect IT security and abide by the  
applicable information security regulations.  
The information security regulations provide  
guidelines for different employment groups  
and are relevant for all employees.  
You are on a business trip. The SIM card you  
have been given by your company has no  
reception, but you need to send a  
confidential document to your supervisor.  
The café you are sitting in offers free,  
unencrypted Wi-Fi.  
Our products inspire countless people all  
over the world. We give high priority to the  
conformity and safety of our products. We  
have a responsibility to ensure that risks to  
health, safety, the environment, and the  
assets of our customers or third parties  
resulting from the use of these products are  
excluded where possible.  
I carefully comply with all relevant provisions  
in my day-to-day work. I set realistic goals. If  
there is a conflict of goals, the conformity of  
our products always has top priority,  
regardless of time or cost pressure. That is  
why I embrace our defined processes and  
continuously improve them. We jointly  
identify and close gaps in processes in order  
to meet all binding obligations. I contact my  
supervisor or the PCMS team if I have any  
questions or concerns about product  
compliance.  
MY CONTRIBUTION  
Be very careful when you use public  
Wi-Fi. There is data leak risk when using  
unprotected connections even though our  
data transmissions are protected via VPN, a-  
virtual private network.  
I familiarize myself with the applicable IT  
security regulations and observe the rules  
therein. As part of the IT security chain,  
I make my active contribution by being  
vigilant at all times and ensuring my basic IT  
security skills are always up-to-date.  
In compliance with statutory provisions, we  
develop our products in accordance with  
state-of-the-art technology, taking account  
of other binding obligations such as  
additional safety requirements resulting  
from the state of scientific knowledge.  
This is systematically ensured by means of  
established structures and stable  
EXAMPLE  
While developing a software update you  
notice that a safety mechanism in vehicle  
software that is already on the market does  
not function correctly in a specific  
application. Further investigation is required  
to understand the scope and impact of the  
error and to establish how it may be  
remedied.  
processes. Once they have been put on the  
market, our products are constantly  
monitored in the field so that appropriate  
measures may be promptly initiated in the  
event of possible discrepancies. We do not  
make any compromises in this regard.  
Follow the applicable processes and report  
the problem immediately to the employees in  
charge so that the issue can be clarified and in  
order to initiate the steps that may be  
necessary based on the known facts.  
49  
50  
4.9 Environmental protection  
We bear responsibility for the  
environment and sustainability  
CORPORATE PRINCIPLE  
MY CONTRIBUTION  
As a global commercial enterprise, we bear  
responsibility for the environmental  
compatibility and sustainability of our  
products, locations, and services. Our  
Company aspires to be a global provider of  
sustainable mobility and a role model for  
protecting the environment. We focus on  
environmentally friendly, advanced, and  
efficient technologies, which we implement  
throughout the entire lifecycle of our  
products. From the very early phases of  
development and production onward, we  
make sure we manage natural resources  
carefully, continuously reduce the  
I am mindful of environmental protection in  
my work and use resources and energy  
economically and efficiently. I make sure my  
activities have the smallest possible impact on  
the environment and that they comply with  
environmental protection laws and  
regulations.  
EXAMPLE  
You notice that fluid is leaking from the  
engine compartment of a vehicle in one of  
the vehicle halls and flowing towards the  
drainage system.  
environmental impact, and comply with  
environmental protection laws and  
regulations.  
Inform one of the employees in charge  
immediately and draw attention to the  
problem. Do not count on anyone else  
reporting the leak.  
Furthermore, we constantly reassess the  
environmental compatibility of products and  
manufacturing processes, optimizing these  
where necessary. We are a responsible  
member of society and a partner for politics.  
We seek a dialog with these players on future  
mobility concepts and on shaping ecologically  
sustainable development.  
51  
52  
SUPPORT  
We offer support in dealing with the Code of Conduct.  
PREVENTING MISCONDUCT, CONTACT  
POINTS AND WHISTLEBLOWER SYSTEM  
In addition, we can submit reports regarding  
Regulatory Violations via the Volkswagen  
Group Whistleblower System. We can give our  
name, or we can make the report  
The purpose of the Whistleblower System is to  
protect our Company, the whistleblower, and  
all persons who contribute to the investigation  
and the termination of misconduct.  
That is why we talk to our supervisor or seek  
Our Code of Conduct provides the binding  
framework for acting with integrity and  
in compliance with the rules within our  
Group. As Group employees, we have a  
responsibility to respect the principles of our  
Code in order to prevent Regulatory  
expert advice immediately if we have any  
questions or concerns, or if we suspect there  
has been a violation of internal or external  
regulations. The HR department and  
employee representatives are there to  
provide support. We can also contact the  
Company’s Compliance Officer or the  
Compliance advice service at any time at  
below channels:  
anonymously. We are aware that the  
Discrimination against them is itself  
Volkswagen Group Whistleblower System has  
responsibility for investigating reports  
regarding Serious Regulatory Violations.  
considered a Serious Regulatory Violation.  
At the same time, the Whistleblower System  
protects the interests of Persons Implicated.  
For them, the presumption of innocence  
applies as long as a violation is not proven.  
The work of the Whistleblower System is  
based on uniform processes and the  
confidential, professional processing of  
reports. Abuse of the Whistleblower System  
is not tolerated and will be disciplined  
accordingly.  
Violations and thus avoid damage to the  
Company. Violations of laws and internal  
policies are immediately investigated.  
Depending on the seriousness of the violation,  
this can have disciplinary, civil, or criminal  
consequences for the employees concerned  
Proven misconduct can also have an impact on  
remuneration.  
A Serious Regulatory Violation is a  
significant violation of our ethical values as  
set out in the Code of Conduct. Equally,  
violations of statutory laws or regulations  
that may significantly affect the reputation  
or financial interests of the Company are  
also considered to be Serious Regulatory  
Violations. In all other cases we should first  
seek advice from our supervisor, the HR  
department or Compliance.  
Volkswagen (China) Investment Co., Ltd.  
Volkswagen (China) Investment Co., Ltd. Anhui Branch  
Volkswagen Group Import Co., Ltd.  
Potential violations of the Code of Conduct  
for Business Partners, including serious risks,  
violations of human rights and  
CARIAD (China) Co., Ltd.  
Audi China Enterprise Management Co., Ltd.  
Volkswagen Automatic Transmission (Dalian) Co., Ltd.  
Volkswagen Automatic Transmission (Tianjin) Co., Ltd.  
Volkswagen (Anhui) Automotive Co., Ltd.  
Volkswagen (Anhui) Digital Sales and Service Co., Ltd.  
Volkswagen (Anhui) Components Co., Ltd.  
Volkswagen Group (China) Technology Co., Ltd.  
Managers have a special function as role  
models. The decisions they make for the  
Company must always take account of  
values and regulations. This includes  
immediately reporting Reasonable  
Suspicion of the concrete indication of a  
Serious Regulatory Violation.  
environmental violations by direct and  
indirect suppliers, can also be reported to  
the Competent Investigation Office(s).  
53  
54  
WecanaccesstheWhistleblower  
Systemthroughthefollowing  
channels:  
Contact details forthe Investigation Office:  
Regional Investigation Office  
Ombudspersons*  
In addition, experienced external lawyers act as neutral mediators (ombudspersons) for us. As legal counsel,  
they are tasked with receiving reports about possible infringements of laws, internal rules or other conduct  
damaging to the Volkswagen Group. If necessary, and if the identity of the whistleblower is known, they make  
direct contact should they require feedback. Once the preparations are complete, the ombudspersons forward all  
information agreed with the whistleblower anonymously if the whistleblower so wishes to our Whistleblower  
System for further processing.  
The Regional Investigation Office (contact channel in Region China):  
• Hotline: +86 10 6531 4794  
Contact details for the ombudspersons: https://www.ombudsmen-of-  
volkswagen.com  
• Regional Investigation Office: Building 1, 12 Qisheng Mid Street, Beijing, P.R. China  
Central Investigation Office*  
* Please note that Chinese laws and regulations limit or prohibit cross-border transfer  
from mainland China of certain “Sensitive Information”, including “Important Data”,  
“Chinese State Secrets” and “Personal Information”. By submitting such information via  
Group reporting channel(s) managed by Central Investigation Office and  
Ombudspersons in Germany, you might risk violating the applicable Chinese laws and  
regulations and may also bear the risk of being penalized by the competent Chinese  
authorities.  
The Central Investigation Office (contact channel in Volkswagen AG, Germany):  
• E-mail: io@volkswagen.de  
• 24/7 hotline: +800 444 46300 / +49 5361 946300  
• Online reporting channel: http://www.bkms-system.com/vw (this channel can also be  
used for making anonymous reports)  
Further information on the Volkswagen Group Whistleblower System and the ombudspersons (if applicable) is  
available on the internet at  
• Postal address: Central Investigation Office, Box 1717, 38436 Wolfsburg, Germany  
• Central Investigation Office: 38436 Wolfsburg, Germany  
SELF-TEST FOR  
Did I take all relevant matters into consideration  
and weigh them properly? (content test)  
1.  
2.  
DECISION GUIDANCE  
If at any time I am unsure whether my behavior complies with the  
principles set out in our Code of Conduct, I should ask myself the  
following questions:  
Am I confident that my decision is within the  
constraints of legal and company requirements?  
(legality test)  
3.  
4.  
5.  
6.  
7.  
Do I stand by my decision when it is revealed?  
(supervisor test)  
Am I in favor of all such cases being decided the  
same way company-wide? (universality test)  
Do I still think my decision is right when my  
company has to justify it in public? (public test)  
Would I accept my own decision if I were affected?  
(involvement test)  
What would my family say about my decision?  
(second opinion)  
If my answer to questions 16 is “yes” and the answer to question 7 is positive, my  
behavior is very likely to be compliant with our principles. If questions remain unanswered  
or if I have any doubts, I should get in touch with any of the points of contact listed in this  
chapter.  
58  
© VOLKSWAGEN GROUP CHINA  
Integrity & Compliance  
Building 1, 12 Qisheng Mid Street  
Chaoyang District  
100028 Beijing P.R. China  
Version 3.0 | January 2024  
In case of any discrepancy between the international conventions or standards mentioned in this Code of Conduct  
and Chinese laws, regulations and standards, the latter shall prevail.