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Whistleblower System

Welcome to the homepage of the Volkswagen China Whistleblower System.

Integrity and compliance with statutory and other requirements lay the foundation of a good reputation for Volkswagen and for the trust of our customers. They also contribute to the wellbeing of Group employees as well as to sustainable economic success, which should not be undermined by the risk of significant financial losses or criminal prosecution.

Making sure these goals are not jeopardized requires the establishment of a corporate culture based on integrity, as well as vigilance by all employees and their willingness to report potential irregularities and violations if reasonable suspicion exists. We must work together to achieve this. And that means we need your support. In order to live up to our aspirations even more effectively and to learn the right lessons from past events, the ombudsman system set up in 2006 has been developed further. We continue to do everything we can to process reports received quickly and objectively, and to offer whistleblowers a protected space.

We use the term “whistleblower system” to describe both internal and external contact points for persons wishing to report violations of regulations in connection with the Volkswagen Group together with the committees that support and monitor the work of these contact points. The Regional Investigation Office is the central contact point within the Company.

What should I report?

You can report violations of all statutory and internal regulations (e.g. Employment Contract, Code of Conduct, Guidelines) by Volkswagen employees to the Regional Investigation Office.

Please note that the whistleblower system includes contact points to report violations of statutory and internal regulations. If you have questions or complaints regarding your vehicle / car, please contact the customer care.

You can make a report on the following violations:
• actual and possible violations of the laws and regulations in China;
• actual and possible violations of the Code of Conduct, and internal policies and processes;
• actual and possible violations related to internal controls and auditing matters, including but not limited to all rules and procedures set forth in the “Golden Rules” Handbook; and,
• conduct involving the development of a potential or known defeat device, or any other actual or possible violation of U.S. environmental protection laws and regulations.

Where do I make a report?

In an open corporate culture, employees should be able to talk about mistakes openly and early. The direct superior should be the first point of contact in regard to problems or process improvements. If for any reason you do not feel you can tell your superior of your suspicions regarding a violation, then the Volkswagen whistleblower system offers you various options for communicating your information.

The central internal contact point is the Central Investigation Office in Volkswagen AG, while the local internal contact point is the Regional Investigation Office in VGC. Should you decide to communicate your information to experts outside the Company, you can also contact two external lawyers who act as neutral mediators (ombudspersons). They are tasked with accepting reports of potential statutory or internal violations of regulations, reviewing this information, consulting with the whistleblower where applicable, and forwarding the information to the Company for further processing – protecting the identity of the whistleblower if so wished.

Making a report to the Central Investigation Office

The Central Investigation Office, which is your internal contact partner in Volkswagen AG, can be accessed as follows:
• E-mail: io@volkswagen.de
• 24/7: +49 5361 946300
• Online channel: http://www.bkms-system.com/vw
• Post: Central Investigation Office, Box 1717, 38436 Wolfsburg (downtown), Germany
• In person: Central Investigation Office, Porschestraße 1, 38440 Wolfsburg (downtown), Germany

Making a report to the Regional Investigation Office

The Regional Investigation Office, which is your internal contact partner in Region China, can be accessed as follows:
• Email: io@volkswagen.com.cn
• Hotline: +86 10 6531 4794
• Post / In person: Regional Investigation Office,7F, Building 1, 12 Qisheng Mid Street, Beijing, P.R. China

Please note that data may be transmitted indirectly if you select one of these electronic contact options. For example, your phone number may be transmitted during a phone call or your IP address may be transmitted when you send an email even if you create a new, anonymous e-mail address. If you wish to use a non-traceable electronic contact option to make your report, thus avoiding the indirect transmission of personal data, please use the internet-based communication platform of the ombudspersons.

Making a report to the ombudspersons

Two external lawyers act as neutral mediators (ombudspersons) for the Volkswagen Group: they are Dr. Rainer Buchert and Thomas Rohrbach. You can contact the ombudspersons via the following channels:

Dr. Rainer Buchert:
• Phone: +49-69-71033330 or +49-6105-921355
• Fax: +49-69-71034444
• Email: dr-buchert@dr-buchert.de
• Post: Dr. Rainer Buchert,Bleidenstraße 160311 Frankfurt am Main,Germany

Dr. Rainer Buchert:
• Phone: +49-69-65300356
• Fax: +49-69-65009523
• Email: rohrbach@ra-rohrbach.de
• Post: Thomas Rohrbach,Wildgäßchen 460599 Frankfurt am Main,Germany

In addition to the contact options listed above, you may also use an internet-based communication platform to contact the ombudspersons, exchange documents and conduct a dialog with the ombudspersons via a separate mailbox. This set-up is confidential and protected. Whistleblowers can decide for themselves whether they wish to give their names. To access the communication platform, please click here.

How do I make a report?

It is important to make sure the information contained in the report you submit to the Regional Investigation Office is as concrete as possible, so that it can be processed and investigated in the appropriate manner.

It is helpful if your report covers the following five questions:
• Who?
• What?
• When?
• How?
• Where?

It is also helpful if the descriptions contained in your report can be easily understood by persons who are not specialists in your field. It is also very much appreciated, although not required, that you will be available to answer further questions. If you would be willing to do so, but do not wish your name to be disclosed to the Company, please contact the ombudspersons to make your report (see Where do I make a report?

My role as a superior

As a senior manager you have a special duty to comply with laws and internal regulations because in addition to taking responsibility for your own actions, you are also a role model for your employees. This duty also includes regular checks and critical reviews of the processes for which you are responsible, as well as eliminating any weaknesses in these processes. Please encourage your employees to draw attention to irregularities and potential for improvements, and do everything you can to create an atmosphere in your team that enables your employees to feel comfortable about expressing both praise and criticism.

Obviously, situations may arise which cannot be clarified in the team due to their relevance or their severity. That is where the whistleblower system comes in. The system thrives on the fact that employees are aware of its existence. They must grasp that their information on possible violations is welcome. At Volkswagen, whistleblowers are seen as people who have the Company’s welfare at heart. This is not about blackening someone’s name, but is about objective information that prevents damage to the Company. In your function as a senior manager, you are an important multiplier. Please take this responsibility very seriously.

In addition, all members of management are required to pass on any report received to the Regional Investigation Office as set out in VGC Policy No. 37 Whistleblower System. If managers fail to fulfil the obligation to report in the event of proven knowledge of regulatory violations will also be considered as a serious regulatory violation.

Further Information

Please read on for more information about the Volkswagen Group China whistleblower system.

If you have any further questions you can contact Central Investigation Office by:
• Calling: +49 5361 946300 (chargeable number)
• Sending an email to: io@volkswagen.de

Or contact the Regional Investigation Office by:
• Calling: +86 (0)10 6531 4794 (Hotline) or
• Sending an email to: io@volkswagen.com.cn

Warning

Please note that Chinese laws and regulations limit or prohibit cross-border transfer from mainland China of certain “Sensitive Information”, including “Personal Information”, “Important Data” and “Chinese State Secrets”. By submitting such information via Group reporting channels managed by Central Investigation Office in Germany, you might risk violating the applicable Chinese laws and regulations and may also bear the risk of being sanctioned by the competent Chinese authorities.

Anonymous hints are always possible unless expressly prohibited by the applicable laws. We recommend you disclose your identity to the Whistleblower System to allow further inquiries. It might be helpful to the following investigation. Personal data would be only processed within the scope of the processing of the hint as well as for the protection of Whistleblowers and the rights of the Persons Implicated.

Instead of using Group reporting channels, you may contact the Whistleblower System via local reporting channels handled by the Regional Investigation Office.

For managers (personal grade MK and above) of Volkswagen Group in region China, you are obliged to report Reasonable Suspicion concerning Serious Regulatory Violations via local reporting channels to the Regional Investigation Office.

If you have any questions related to reporting whistleblower hints, please contact the Regional Investigation Office at io@volkswagen.com.cn

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    What is a whistleblower case?

    A whistleblower is a person who exposes any kind of information or activity that is deemed illegal, unethical, or not correct within an organization that is either private or public. Whistleblower cases are the information and suspicions reported by whistleblowers that flag potential violations of statutory or internal regulations by Volkswagen employees.

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    What is a violation?

    Violations are all violations of statutory and internal regulations (e.g. local laws, Code of Conduct, Group Guidelines, process specifications) by Volkswagen employees. Volkswagen Group China Regional Investigation Office makes a distinction between serious regulatory violations and other regulatory violations.

    Serious Regulatory Violation is a Regulatory Violation that significantly affects the interests of the Volkswagen Group or one of its group companies, in particular the reputational or financial interests, or that significantly violates the ethical values of the Volkswagen Group.

    Examples for a Serious Regulatory Violation are as follows:
    • Corruption, white-collar and tax criminal offences
    • Environmental criminal offences
    • Violations of human rights (e.g. prohibition of child labor)
    • Violations of anti-trust law and competition law
    • Money laundering and terrorism financing
    • Violations of product safety and technical requirements regulations
    • Substantial violations of data protection laws
    • Violations committed by Employees from the level of upper management (personal OMK level) and above which contradicts its role model function for compliance and integrity as defined in the Code of Conduct
    • High risk of company sanctions (for example, fines and levies, ban on business transactions with authorities, loss of licenses for business operations)
    • Conspiracy to commit a violation involving several people
    • Systematic exploitation of company structures to commit violations

    The following cases are always processed as reports of Serious Regulatory Violations:
    • Violations of regulations prohibiting the discrimination of whistleblowers
    • Failure of managers to fulfil the obligation to report
    • Abuse of the Whistleblower System by knowingly making false accusations
    • Violations of US environmental regulations

    An Other Regulatory Violation is any Regulatory Violation, which is not a Serious Regulatory Violation. Proven Other Regulatory Violations may also be sanctioned appropriately and may lead to termination of employment.

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    When is information deemed to be substantiated?

    Substantiated information is the suspicion of violation of statutory or internal regulations based on actual concrete evidence. If the report only contains random allegations or suspicion of a violation of statutory or internal regulations without any concrete facts that can be used to initiate investigative measures, then the information is deemed to be unsubstantiated.

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    How does the company process reports received?

    The Regional Investigation Office is responsible for documenting and reviewing every report received. Substantiated information must be investigated without delay. The employees responsible for handling and investigating the reports must treat the information as confidential and may not disclose it to other parties. This applies in particular to personal data. They may only inform other persons on a strictly need-to-know basis. Applicable legislation, the internal policies and, in particular, data protection and cyber security laws must be observed when processing whistleblower cases.