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Integrity, Compliance and Risk Management


We have anchored Integrity and Compliance in our NEW AUTO China Group Strategy 2030.

For us, integrity means acting out of conviction, with responsibility and steadfastness. Integrity serves as our moral compass for doing the right thing in gray areas, in the absence of explicit rules or in the event of conflicting objectives. Complying with our Group principles and the ethical values established therein and behaving correctly in accordance with the rules, regardless of economic and social pressure, is expected from all of our employees.

We firmly believe that only by a comprehensive and sustainable integration of integrity in our corporate culture, we will be able to strengthen the trust of the general public, our customers, staff, shareholders, business partners in our company.


Together4Integrity: Establishing processes and engaging with people


As a central part of achieving the goal of becoming a role model for integrity and compliance, Volkswagen Group has launched the Together4Integrity (T4I) program – one of the most extensive transformation programs in the history of the Group.

Through the implementation of the Together4Integrity (T4I) program, we want to continuously enhance our corporate governance on integrity and compliance. With T4I, integrity and compliance are given the same priority as other parameters such as economic targets, sales figures and product quality.

T4I is based on the five principles of the internationally recognized Ethics & Compliance Initiative (ECI), which relate to strategy, risk management, a culture of integrity, a speak-up environment and resolute accountability.

The program serves to implement processes and structures that create a regulatory framework for acting with integrity and in accordance with the law. Furthermore, T4I aims to engage with people, creating a corporate culture that enables them to work together as equals, inspiring creativity, allows diversity to flourish and encourages people to act in line with their values.

Through T4I, corporate governance at Volkswagen Group China will be geared towards integrity and compliance. This will provide a stable framework in which the whole workforce can act responsibly, with purpose and entrepreneurial spirit.


In the long term, a company can only be successful if it acts with integrity, complies with statutory provisions worldwide and stands by its voluntary undertakings and ethical principles, even when this is the harder choice. We are committed to this principle. Compliance must be second nature to all Group employees. This standard is also expected to be followed by our business partners. They are expected to act responsibly and to agree to comply with the requirements defined in the Code of Conduct for Business Partners.

The Volkswagen Group takes a preventive approach to compliance which heightens employee awareness and knowledge in order to prevent potential rule breaches before they happen. Compliance at Volkswagen Group China is practiced through activities whose overall aim is to ensure that all employees – including members of the Board of Management, Management and Tariff Personnel act in accordance with internal regulations and all legal requirements and prohibitions. Internal Audit and Security complete systematic compliance checks, conduct necessary investigations on a regular basis, perform spot checks in the absence of suspicion, and examine the circumstances in cases of alleged misconduct. Human Resources and Legal respond by applying the relevant measures. These processes are closely integrated to form a holistic compliance management system. However, we are aware that even the best compliance management system can never fully exclude the possibility of criminal action by individual employees.

Risk Management

In Regional Risk management, our goal is to ensure an effective Risk Management System and Internal Control System (RMS/ICS) for Volkswagen Group China. To protect our business from potential threats, we need to analyze all kinds of risks so we could properly identify, assess and control them following the defined requirements from Volkswagen AG.

"Managing risk is managing success" is our slogan. We aim to cover all areas of risk as comprehensively as possible. Risk management is a crucial step in designing the strategic plan as it provides a solid foundation for the overall business. The significant business risks are collected via Quarterly Risk Process (RQP) so they could be addressed early and monitored with appropriate measures. On the other hand, we also keep an eye on related the significant process risks that might affect our major processes; we call this the Standard Internal Control System process (Standard ICS). Besides, we have implemented a comprehensive business continuity management system to ensure the uninterrupted flow of our business.

Code of Conduct

The Code of Conduct is a common set of binding guidelines for all employees in the Volkswagen Group China. It helps in complying with existing rules and regulations and offers guidance, advice and support in everyday work situations and decision-making. The focus is on the responsibility of each individual employee to comply with the rules of ethical conduct.

The information contained in the Code of Conduct is divided into four main sections:
• We are committed individuals
• We are reliable colleagues
• We are responsible partners
• We are good corporate citizens

Volkswagen Group China Code of Conduct_English

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

Whistleblower System

Our Whistleblower System

Complying with relevant 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. The success of our company is based on Integrity and Compliance. To meet these standards, it is important to learn of potential misconduct and to put a stop to it. Therefore, we entrusted Regional 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 lays out the possible and legally-allowed 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 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 VGC will not be tolerated. Investigations upon reasonable suspicion will be conducted with the utmost confidentiality. The information will be processed in a fair and protected process. Other applicable principles for Whistleblower System will be also applied during the handling of reporting.

How does the company process reports received?

The qualified and experienced colleagues at the Investigation Office examine the received report for (potential) misconduct by a Volkswagen Group employee thoroughly and follow it up systematically.  First, upon the reported information, 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 sufficient grounds for reasonable suspicion of a violation an investigation by a dedicated Investigating Unit (and/or competent function) will be started. Afterwards, the results of the investigation will be assessed by the Investigation Office and appropriate measures will be recommended (if applicable).

When Investigation Office receives (potential) violations of the Code of Conduct for Business Partners -  as well as reports including otherwise action, the Investigation Office will inform the responsible departments, who will process the issue accordingly. This particularly includes taking the necessary/applicable measures to minimize or end violations and/or risks.

Do you have any concern or feedback regarding the product or service?

If you have any questions or inquiries regarding [your new or used vehicle | feedback or complaints about services provided by 4S Shops/dealers, please contact Applicable Customer Care Contact(s). We kindly ask for your understanding that the Whistleblower System unfortunately cannot process customer complaints.

Whistleblower System Reporting Channel


*Please note: 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 channels managed by Central Investigation Office in Germany (the reporting channels such as io@volkswagen.de, BKMS, Ombudespersons locate overseas), 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 information is treated as confidential and it is the whistleblower who decides whether he or she wishes to protect his or her identity when sending the report. The reports from whistleblowers who do not wish to be identified by the Company are forwarded by the Investigation Office anonymously.

How to report violations through the Whistleblower System?

Keep the following advice in mind for your report to be properly handled and verified:

You can report violations of the statutory and internal regulations (e.g. applicable law, internal policies) by Volkswagen employees to the Regional Investigation Office.

Make sure your descriptions as detailed/concrete/objective as possible, including these elements:

• Who?

• What?

• When?

• How?

• Where?

In order to effectively proceed the next step, it is helpful if you are available for further questions and could provide concrete materials/supporting documents.

(Please note, this system is NOT a designated channel to resolve workplace conflicts, personnel matters, or work mistakes, etc.; it is also NOT an advice center for general questions about rule-compliant behavior or compliance.)

Rules of Procedure

© Volkswagen China 2018
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