Compliance & Risk Management

In order to ensure the sustainable success of the Volkswagen Group, we rely on a Compliance Management System and on a Risk Management System which are based on principles and measures applied group-wide.

For the Volkswagen Group compliance is: adherence to legal requirements, internal corporate policies, ethical principles, and self-imposed values for the protection of the company and its brands. For us standing by these values is a priority. Volkswagen Group fully commits to its corporate human rights responsibility and to a zero-tolerance policy regarding active and passive corruption. An important part of this commitment also lies in responsible risk management, which is supported by an integrated system of risk management and control measures.
In the following sections you can find more information on our Code of Conduct, on our Whistleblower System and on our Organizational Model pursuant to Legislative Decree 231/01.

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Code of Conduct

Volkswagen Group Italia implements the Code of Conduct binding for all the Employees of the Volkswagen Group – all over the world, in every Brand and at all hierarchical levels. It contains the basic principles and guidelines for our behavior and it provides orientation, advice and support to all the employees.

Each employees is responsible to ensure that his or her conduct are honest, reliable and ethical. Such conduct is based on the knowledge of and the compliance with internal rules and statutory provisions in force.

In case of suspected violation of the Code of Conduct or other kinds of irregularities, it is possible to submit a hint through the channels of the Volkswagen Group Whistleblower System.

The Code is an essential part of the Organisation, Management and Control Model required by article 6 of the Legislative Decree 231/01 bearing the "Regulations on the administrative responsibility of legal persons and of bodies without legal personality, pursuant to article 11 of Italian Law 300 of 29 September 2000". Antitrust Guidelines represents an annex to the Code of Conduct.

Code of Conduct.pdf

2024 - PDF 33 pages - 8,68 MB

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Code of Conduct for Business Partners

The Code of Conduct for Business Partners makes clear which standards apply for business partners of the Volkswagen Group.

Code of Conduct for Business Partners

2023 - 27 Pages - 1 MB

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Human rights

Respect for human rights is of paramount importance to the Volkswagen Group. We are convinced that sustainable economic activity is only possible by acting ethically and with integrity towards people and the environment. In our activities, we are therefore fully committed to our responsibility regarding human rights.

In line with the main international agreements and conventions and with the German LkSG legislation, the defense of human rights is a central part of our Code of Conduct and of the Code of Conduct for Business Partners and, to further strengthen this commitment, Volkswagen Group Italia has adopted - in agreement with the Works Council the "Volkswagen Group Declaration on Social Rights, industrial relations, business and human rights" (so called Social Charta) available below.

The channel for reporting potential human rights violations and environmental risks related to our business activities or the activities of our direct and indirect suppliers or other business partners is the Whistleblower System.

Social charta

27.11.2020 - 9 Pages - 1,58 MB Social charta

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Our Whistleblower System

Complying with statutory regulations and internal rules, and the principles laid down in our Code of Conduct and the Code of Conduct for Business Partners, has top priority at Volkswagen Group Italia. The success of our company is based on Integrity and Compliance. To meet these standards, it is important to learn of potential employee or supplier misconduct and to put a stop to it. Therefore, we entrusted the Central Investigation Office to operate an independent, impartial, and confidential Whistleblower System on our behalf.

A key pillar of our Whistleblower System is the principle of procedural fairness. It also guarantees the greatest possible protection for whistleblowers, persons implicated and employees contributing to the investigation of reported misconduct.

This also includes offering opportunities for anonymous reporting and communication. We assure not to perform any steps in order to identify anonymous whistleblowers, who do not misuse our Whistleblower System. Retaliation of whistleblowers and all persons who contribute to investigations at Volkswagen Group Italia will not be tolerated. Persons implicated are presumed innocent until the violation is proven. Investigations will be conducted with the utmost confidentiality. The information will be processed in a fair, fast, and protected process.

How do we process your report?

The qualified and experienced colleagues at the Investigation Office examine every report for potential misconduct by a Volkswagen Group employee thoroughly and follow it up systematically. First, you will get a confirmation of receipt. The Investigation Office then assesses your report. This includes gathering facts particularly from the whistleblower. Only if this initial evaluation shows grounds for suspicion of a violation an investigation by a dedicated Investigating Unit will be started. Afterwards, the results of the investigation will be assessed by the Investigation Office and appropriate measures will be recommended. Information about the status* and the outcome of the procedure will be given to you without undue delay.

Potential violations of the Code of Conduct for Business Partners by suppliers, including serious risks and violations of human rights and environment by direct and indirect suppliers, can also be reported to the Investigation Office - as well as reports requiring otherwise immediate action. The Investigation Office will inform the responsible departments, who will process the issue accordingly. This particularly includes taking the necessary measures to minimize or end violations and/or risks.

Find more information on the procedural principles of the Volkswagen Group Complaints Procedure here.

* The processing time varies depending on the subject of the procedure.

Making a report to our Whistleblower System

The Whistleblower System offers various channels to report potential employee misconduct that allow a swift review and reaction by our company if necessary.
However, this does not affect the statutory right to contact designated authorities as described below.

24/7 voice intake via telephone
You can submit hints 24/7 by voice message:
· cost-free telephone number 800 147 694
· Porsche Holding Salzburg Code: 122333
If you call from countries other than Italy, please see the telephone numbers listed here and enter the organizational code of Porsche Holding Salzburg.

Online Reporting Channel
You have the option of using a web-based communication platform to contact the Investigation Office in many languages. This system is confidential and technically secured.
Even if your preferred language is not offered in the reporting channel, you can use any language to submit your report. You can also contact the Investigation Office in any language via e-mail or mail
Online Reporting Channel: https://goto.speakup.report/phs
Porsche Holding Salzburg Code: 122333
You can find detailed instructions on how to make reports online, by app or by phone here.

Ombudspersons
The Volkswagen Group has appointed external lawyers to act as Ombudspersons. They advise on the Whistleblower System or ensure that reports from whistleblowers are forwarded anonymously to the Investigation Office if desired.
If you want to get in contact with the Ombudsperson you can find their contact details here: http://www.ombudsmen-of-volkswagen.com

E-mail
You can get in contact with the Central Investigation Office via e-mail: io@volkswagen.de.

Central Investigation Office
Postal address
Volkswagen AG, Central Investigation Office
Mailbox 1717
Berliner Ring 2
38436 Wolfsburg, Germany
In person
Please make an appointment in advance by writing an e-mail to: io@volkswagen.de.

SpeakUp APP
You can easily download the SpeakUP app using the QR code below and submit your comments directly via the app. Please use the Porsche Holding Salzburg company code: 122333.
QRCode for downloading the SpeakUp App:

QRCode for automatically entering the PHS Organization Code (necessary when the App is opened for the first time):

Independent Body of Volkswagen Group Italia
In Volkswagen Group Italia the report of a violation of the Code of Conduct’s principles and values can be submitted also to the Independent Body (Organismo di Vigilanza) established by the Company pursuant to the requirements of the Legislative Decree 231/2001. The Independent Body ensures that the whistleblower is protected by any kind of repercussion.

The Independent Body can be contacted:
• via e-mail: odv@volkswagengroup.it,
• via postal address: Organismo di Vigilanza di Volkswagen Group Italia Spa - Via Gumpert n. 1 – 37137 – Verona,
• or via the anonymous e-mail odv-anonymous@volkswagengroup.it, which is available for whistleblowers who prefer to stay anonymous and which is accessible only to external members of the Independent Body.

Do you have further questions, or do you need a local contact?

Questions or suggestions for improvement concerning the Whistleblower System can also be addressed to the Investigation Office.
Furthermore, our local Compliance Department can also be addressed in all matters of the Whistleblower System via compliance@volkswagengroup.it.

External Reporting Channel in Italy

IAs part of the requirements set by Italian Legislative Decree 24/2023, the Italian government has defined a designated authority, that also accepts reports on misconduct as external reporting channels. The external reporting channel is managed by the National Anti-Corruption Authority (ANAC) is available at the following link: Whistleblowing - National Auti-Corruption Authority

Whistleblowers can use the ANAC channel if they consider:
· that a report of a violation in scope to Legislative Decree 24/2023 already made to internal channels has not been effectively followed up or
· that reporting to an internal channel may cause a risk of retaliation, or
· that the violation may constitute an imminent or manifest danger to the public interest.

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Organizational Model 231/01

Pursuant to the Legislative Decree 231/01 regarding the so called “administrative” responsibility of legal entities, corporations and organizations, Volkswagen Group Italia S.p.A. adopted an Organizational, Management and Control Model of which the Code of Conduct is an integral part as the document which defines the ethical values our Entity believes and respecting which allows, among other things, to prevent the commission of the crimes listed in the aforementioned Decree.

In this context, Volkswagen Group Italia S.p.A - traditionally careful to respect the principles of fairness, transparency and legality - undertook a thorough analysis in order to identify all the processes and activities where potentially a crime could be committed and consequently the development of control and prevention measures.

This analysis, which also aimed at verifying the correspondence of the behavioral principles and procedures adopted for the purposes set out in the Decree, led eventually to the drafting of the Model – a constantly evolving tool, thanks also to the contribution of all its recipients – which strongly and clearly identifies the guiding principle of corporate ethics in the compliance with the applicable legal provisions.

It is therefore primary interest of our Company that anyone who – in any capacity – works for or with Volkswagen Group Italia S.p.A. manage their duties in compliance with the principles and the values identified in the Model, which is the essential tool for guiding, promoting and spreading correct and linear behavior to assure the good management, the reliability and reputation of Volkswagen Group Italia S.p.A.

To oversee on the implementation and on the respect of the Organizational Model 231/01, the Board of Directors appointed an Independent Body intended to verify its effectiveness, efficiency and adaptation over time. Anyone, employees, business partners and third parties who would like to contact the Independent Body or making a report related to Model 231/01 or the Code of Conduct can use the following channels available:

- E-mail: odv@volkswagengroup.it

- E-mail: odv-anonymous@volkswagengroup.it (available only to the external members of the IB)

- Postal address: Organismo di Vigilanza, Volkswagen Group Italia S.p.A., Viale G.R. Gumpert, 1 - 37137 Verona

Model ex D.Lgs. 231

4^th December 2023 - File PDF - 1,26 MB

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Code of Conduct

Code of Conduct for Business Partners

Human rights

Our Whistleblower System

How do we process your report?

* The processing time varies depending on the subject of the procedure.

Making a report to our Whistleblower System

Do you have further questions, or do you need a local contact?

External Reporting Channel in Italy

Organizational Model 231/01

Data Transmission