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.
Compliance and Risk Management contribute to the Together4Integrity Programme.

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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 5 October 2021 - PDF, 21 pages, 1,060 KB	Download
Antitrust guidelines.pdf 13 December 2017	Download

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Whistleblower System

Whistleblower System of the Volkswagen Group

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 this standard, 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 of Volkswagen AG 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.

Do you have any concern or feedback regarding a Volkswagen Group product or service?

If you have any questions or inquiries regarding your new or old vehicle, feedback or complaints about services provided by the Volkswagen Group or our business partners (e.g. car dealerships, workshops), please contact the Customer Care as described in the brand websites.

We kindly ask for your understanding that the whistleblower system unfortunately cannot accept, process and, in particular, forward customer complaints or concerns.

Making a report to our Whistleblower System

The Whistleblower System offers various channels to report potential employee and supplier misconduct that allow a swift review and reaction by our company if necessary. Reports can be made 24/7 in every language.

However, this does not affect the statutory right to contact designated authorities as described below.

ONLINE REPORTING CHANNEL
You have the option of using an internet-based communication platform BKMS o 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 you report. You can also contact the Central Investigation Office in any language via e-mail or mail.

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

24/7 HOTLINE
You can make a report at any time 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

POSTAL ADDRESS AND IN PERSON
Postal address:
Central Investigation Office
Box 1717, 38436 Wolfsburg (downtown)
Germany
In person:
Central Investigation Office
Porschestraße 1, 38440 Wolfsburg (downtown)
Germany

Please make an appointment in advance by writing an e-mail to: io@volkswagen.de

OMBUDSPERSONS IN THE VOLKSWAGEN GROUP
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.

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.

Declaration of data protection

Please find the declaration of data protection for reports here: Declaration of data protection for the Whistleblower System of the Volkwagen Group.

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

Please direct questions or suggestions for improvement concerning the Whistleblower System to the Investigation Office.
Furthermore, our local Compliance Officer can also be adressed in all matters of the Whistleblower System via compliance@volkswagengroup.it.

How do I make a report?
It is important to make sure the information contained in the report is as concrete as possible so that it can be processed and investigated in an appropriate manner.
It is helpful if the report covers the following five questions: Who? What? When? How? Where?

Please make sure that the descriptions contained in your report can be easily understood by persons who are not specialists in your field. It would be helpful if you are available to answer further questions. If you would be willing to do so, but wish to remain anonymous to the company, please contact the ombudspersons or use the Online Reporting Channel to make your report.

For any information or questions regarding the processing of personal data, you can also contact the local DPO at the following e-mail address privacy@volkswagengroup.it.

For more information on the Volkswagen Group’s Whistleblower System, please visit Whistleblower System (volkswagenag.com)

Whistleblower System

Download

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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

Whistleblower System of the Volkswagen Group

How do we process your report?

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

Do you have any concern or feedback regarding a Volkswagen Group product or service?

Making a report to our Whistleblower System

Declaration of data protection

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

How do I make a report?

Organizational Model 231/01

Data Transmission