Compliance with international rules and the fair treatment of our business partners and competitors are among the guiding principles followed by our Company. Volkswagen’s commitment has always gone beyond statutory and internal requirements; voluntary obligations and ethical principles also form an integral part of our corporate culture.
The Volkswagen Group is also active in the fight against corruption and other illegal economic activity outside of the Company. Since 2002, we have been a member of the United Nations Global Compact, working with over 12,000 participants from more than 145 countries to create a more sustainable and fairer global economy.
Commitment to compliance at the highest level
Compliance is a cornerstone of sustainable business – a view expressly shared by the Company’s management. In the reporting period, the Group Board of Management member for marketing and sales and the Group Board of Management member for procurement, among others, stressed the importance of compliance to employees, both for their own departments and for the Company as a whole.
Preventive compliance management system
Compliance is an important part of the Governance, Risk and Compliance (GRC) organization in the Volkswagen Group (see the Report on Risks and Opportunities). As part of this, Volkswagen adopts a preventive compliance approach and aims to create a corporate culture that stops potential breaches before they occur by raising awareness and educating employees. Group Internal Audit and Group Security regularly perform the necessary investigative activities, systematically monitor compliance and perform random checks regardless of any suspicion of infringements, as well as investigating specific suspected breaches. Responses are implemented by the Human Resources and Group Legal departments. These processes are closely interrelated, in line with the concept of a comprehensive compliance management system. Nevertheless, we are aware that even the best compliance management system can never entirely prevent the criminal actions of individuals.
Various bodies support the work of the compliance organization at Group and brand company level. These include the Compliance Board at senior management level and the core Compliance team, which ensures coordination with the functional areas.
Focal points in 2014
Each year, detailed compliance risk assessments are carried out across the Group as part of the standard GRC process. The results are factored into the risk analyses performed by the Volkswagen Group, the brands and the companies, and into the Compliance Program planning.
Compliance activities in 2014 focused on further developing compliance standards for the sales organization and dealings with suppliers, among other things. The subject of “human rights and the Code of Conduct in the supplier chain” was driven forward in close cooperation with Group Procurement.
The Group Chief Compliance Officer is supported by 14 Chief Compliance Officers or compliance contact persons (staff who are responsible at the brands, the Financial Services Division and Porsche Holding GmbH, Salzburg). They are supported by compliance officers in the Group companies. In total, staff in 66 countries are employed in the GRC function.
The GRC organization provided information on various compliance issues to the Group’s brands and companies over the year, using a wide range of traditional communication channels. These include reports in various employee magazines produced by the brands, companies and locations. Digital media such as intranet portals, smartphone apps and tablets, blogs and newsletters are also frequently used to provide compliance information. On International Anti-Corruption Day in early December 2014, a global internal communications campaign was launched in the Volkswagen Passenger Cars brand with a compliance film produced specially for Volkswagen. At the same time, poster campaigns also highlighted the topic of preventing corruption.
Building on its Code of Conduct, Volkswagen has produced guidelines on various compliance topics. These cover anti-corruption – including checklists and the express prohibition of facilitation payments – and competition and antitrust law. These information documents were provided to employees either in paper form or electronically (on the intranet and the employee portal, for example) and made available to all brands to be adapted to their respective specific requirements.
Directives on dealing with gifts and invitations, as well as on making donations apply across the Group.
We have communicated the Code of Conduct to all consolidated brand companies and established it as a fundamental part of our corporate culture. It is also increasingly being integrated into our operational processes. For example, since 2010, all new employment contracts entered into between Volkswagen AG on the one part and both management staff and employees covered by collective agreements on the other have included a reference to the Code of Conduct and the obligation to comply with it.
Learning programs, training and advice
Providing information to employees at all levels continues to be a core component of our compliance work. In 2014, over 185,000 employees across the Group participated in a variety of different events on the topics of compliance, the Code of Conduct, anti-corruption, human rights, anti-money laundering, and competition and antitrust law in 2014. In addition to traditional lectures and e-learning programs, case studies, role playing formats and a GRC board game form an integral part of the training provided to employees. A compliance app for smartphones and tablets, among other things, is available for employee information. In addition, since 2012, all new Volkswagen AG employees have been required to complete an e-learning program on the Group’s Code of Conduct. The subject of human rights is an integral part of this training program. Training on competition and antitrust law is provided for specific target groups. For example, it is a core component of the training provided to sales and procurement employees.
Employees of all brand companies and a large number of Group companies are able to obtain personal advice about compliance issues, usually by contacting the compliance organization via a dedicated e-mail address. An IT-based information and advisory tool is available at Volkswagen AG’s German locations.
Business partner check
The Company considers the excellent reputation enjoyed by the Volkswagen Group in the business world and among the public to be a precious asset. To safeguard its reputation, Volkswagen verifies the integrity of its business partners (business partner check) in a risk-oriented approach. This check allows us to find out about potential business partners before entering into a relationship with them, reducing the risk of starting a cooperation that could be damaging to the Company or its business.
The Group-wide ombudsman system can be used to report any breaches or suspicions (particularly regarding corruption) in ten different languages to two external lawyers appointed by the Group. Since 2014, employees providing information have had the option of communicating with the ombudsmen via another online channel; any breaches can be reported using a technically highly secure electronic mailbox. Naturally, the people providing the information need not fear being sanctioned by the Company for doing this. In 2014, the ombudsmen passed on 51 reports by people – whose details remained confidential if requested – to Volkswagen AG’s Anti-Corruption Officer. In addition, the Anti-Corruption Officer and the head of Group Internal Audit received information on a further 89 cases directly. During local internal audits of the brands and Group companies, 365 reports of suspected fraud were submitted. All information is followed up. All breaches of the law or internal regulations are appropriately punished and may lead to consequences under employment law, including dismissal.
We review the effectiveness of the compliance measures taken at the Volkswagen Group’s brands and companies annually using an integrated survey, which forms part of the standardized GRC process. We check the effectiveness of selected countermeasures as well as management controls used to manage compliance risks. In addition, the continuous improvement of the compliance management system is ensured through independent reviews by the Group Internal Audit function at the corporate units and the regular exchange of information with external bodies, for example.