Compliance & Risk Management

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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.

The Code of Conduct focuses in particular on the responsibilities that each employee bears towards the respect of ethical rules and principles.

The Volkswagen Group Code of Conduct brings to the attention three main elements:

Our responsibility as members of society
Our responsibility as business partners
Our responsibility in the workplace

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 13 December 2017	Download
Antitrust guidelines.pdf 13 December 2017	Download

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Whistleblower System
Compliance with statutory regulations and internal rules and Integrity are top priorities at Volkswagen Group Italia and in the entire Volkswagen Group, since they represents the basis of our reputation and the fundamental elements in order not to betray the trust of our Customers and our Business Partners.

Every Volkswagen Group Italia employee is asked to behave in compliance with laws, applicable regulations and the Company’s principles, in particular those stated in our Code of Conduct, and a Whistleblower System has been established for the reporting of any irregularities and misconducts by Volkswagen Group Italia employees when performing their daily duties.

The Whistleblower System allows employees, Business Partners and other third parties to make a report regarding suspected regulatory violations committed by Volkswagen Group Italia employees without fear of retaliation.

The Whistleblower System ensures protection, fairness and trust.

Protection for the Company, for people making a report (the so-called Whistleblower) and for persons implicated.
Fairness in the handling of reports.
Trust as the fundamental value of our work and the functioning of the Whistleblower System.

Through the Whistleblower System:

anyone who has a reasonable suspicion that a Volkswagen Group Italia employee committed a regulatory violation when performing his or her daily duties can make a report;
the Whistleblower can make a report confidentially and enjoys protection against all forms of discrimination and retaliation;
knowingly making false accusations is a sanctioned behavior;
reports of suspected regulatory violations are carefully examined before initiating an investigation;
reported information are investigated internally in a neutral and objective manner and in compliance with the principle of the presumption of innocence.

The Company provides several channels to contact to report suspected regulatory violations.

It is helpful if your report includes elements to answer these five fundamental questions:

Who: Who is involved? Who is concerned with the issue?
What: What happened? Detailed description of the events.
When: When did the issue happen? How often has this occurred?
How: How was the issue possible?
Where: Where did the issue occur?

Whistleblower System

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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

Code of Conduct

Whistleblower System

Organizational Model 231/01

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