Compliance with international rules and the fair treatment of our business partners and competitors are among the guiding principles followed by our Company. Volkswagen’s sense of commitment has always gone beyond statutory and internal requirements; obligations undertaken and ethical principles accepted voluntarily also form an integral part of our corporate culture.
The Volkswagen Group also endeavors to fight corruption and other illegal economic activity outside of the Company. Since 2002, we have been a member of the United Nations Global Compact, working with around 7,000 participating companies in more than 135 countries to create a more sustainable and fair global economy.
Consciously implementing core values like integrity and fairness, rather than simply defining them, has been and will continue to be actively promoted by our corporate governance. Speaking to more than 3,900 managers in March 2012, Chairman of the Board of Management of Volkswagen AG, Prof. Dr. Martin Winterkorn, stressed that there is no leeway when it comes to the issue of compliance to safeguard the Company’s reputation. Clear declarations of commitment to compliance were also made to the workforce by other members of the Group Board of Management and brand boards of management during the year.
Volkswagen embraces a preventive compliance approach and aims to create a corporate culture that stops potential breaches before they occur, through raising awareness and educating employees. The necessary investigative measures are regularly performed by Group Internal Audit and Group Security. Both departments systematically monitor compliance and perform reviews on a test basis irrespective of whether any breaches are suspected, as well as investigating specific suspected breaches. Responses are implemented by the Human Resources and Group Legal departments. These processes are closely interrelated as part of a comprehensive compliance management system. In addition, a large number of governing bodies belong to the compliance organization at Group and brand level. These include the Compliance Board at senior executive level and other expert committees, such as the Core Compliance Team.
The Group Chief Compliance Officer is currently supported by 13 Chief Compliance Officers, who are responsible for the brands. The number of Compliance Officers in the Group companies has risen by 35 to 100. In total, more than 400 employees are involved in the Governance, Risk and Compliance organization in some 39 countries.
The organization provided information on various compliance issues to the brands and companies over the year, using a wide range of traditional communication channels, such as reports in different employee magazines produced by the brands, companies and locations. Websites, smartphone applications, blogs and electronic newsletters are also frequently used to provide compliance information. The Compliance intranet site registered more than 17,000 clicks in the space of just three days following a works meeting at the Wolfsburg site, which clearly shows that initiatives like the series of films on compliance are generating a favorable response. The communication measures also include speaking to employees personally at information stands at works and other employee meetings. Our compliance communication has not only been well received internally, as the Volkswagen Group’s communication campaigns and media received numerous external awards during the year.
The prevention of active corruption was the main focus in 2012. In particular, we pushed ahead integration with the compliance organization in key strategic markets such as Brazil, Russia, India, China, Malaysia, Argentina and Mexico.
In November 2012, we also published anti-corruption guidelines and distributed them throughout the compliance organization, sending them to more than 5,700 Volkswagen AG managers. Prof. Dr. Martin Winterkorn took this opportunity to again emphasize the importance of compliance. The guidelines use real examples to raise awareness, provide corruption risk checklists and demonstrate measures for successfully avoiding corruption. Among other things, the guidelines expressly forbid facilitation payments. They are available to all Volkswagen AG employees in electronic form via the Volkswagen portal.
There are Group-wide directives on dealing with gifts and invitations, as well as making donations.
We have now provided the Code of Conduct to all consolidated brand companies and established it as a fundamental part of our corporate culture. Brochures on the Code of Conduct have been widely distributed and are available to employees via the Volkswagen portal, for example. The Code of Conduct has also been further integrated into operational processes. Since 2010, new employment contracts with Volkswagen AG make reference to the Code of Conduct and the requirement to comply with it.
Further progress was also made in the area of competition and antitrust law – the focal point of the 2011 compliance program – during the reporting period.
Information events for employees at all levels are still a core component of our compliance work. Across the Group, a total of 45,000 employees worldwide attended events on the topics of compliance, the Code of Conduct, competition and antitrust law, and anti-corruption in 2012. E-learning programs are also an established means of providing employee training. Around 20,000 employees successfully completed the e-learning program on avoiding conflicts of interest and corruption in 2012. A training program on the Group’s Code of Conduct was added to the e-learning offering in the year. Since July 1, 2012 participation has been compulsory for new Volkswagen AG employees. More than 70,000 employees have taken the opportunity to further their professional development by participating in e-learning programs on the subject of compliance since 2009.
For the Volkswagen Group, the excellent reputation enjoyed by the Company in the business world and among the public is a precious asset. To safeguard its reputation, Volkswagen verifies the integrity of new business partners. The aim is to find out about potential business partners before entering into a relationship with them, in order to reduce the risk of starting a cooperation that could be damaging to business or the Company.
In 2012, the compliance organization’s advisory services were significantly expanded. All brands and a large number of companies now offer their employees the opportunity to receive personal advice, usually by contacting the compliance organization via an e-mail address. At Volkswagen AG’s German sites, an IT-based information and advisory tool was launched in March 2012.
An anti-money laundering concept was also developed in 2012. This tool is based on the identified risks and is structured according to business area. It meets the new requirements of the Geldwäschegesetz (GwG – German Money Laundering Act) that came into force in the reporting period.
Any breaches or suspicions (particularly regarding corruption) can be reported to two external lawyers appointed by the Group via the ombudsman system in place since 2006. In 2012, the ombudsmen passed on 46 reports provided by persons, whose details remained confidential if requested, to Volkswagen AG’s Anti-Corruption Officer. Information on a further 64 cases was provided directly to the Anti-Corruption Officer or the head of Group Internal Audit. All information is followed up. All breaches of the law or internal regulations are appropriately punished and may lead to consequences under employment law, including dismissal.
We review the effectiveness of the compliance measures on an annual basis through an integrated survey of the Volkswagen Group’s brands and companies. The effectiveness of selected management controls to manage compliance risks is also checked. Detailed compliance risk assessments were carried out across the Group in 2012. The findings were factored into the risk analyses of the Volkswagen Group, the brands and the companies and are therefore subject to a continuous improvement process. Based on the risk analysis, the compliance activities in 2013 will focus on expanding the compliance organization within the Volkswagen Group and preventing corruption in China, in addition to strengthening the existing structures.
During the reporting period, independent experts were engaged to assess the compliance management system concept. They concluded that Volkswagen has established “an effective and efficient compliance management system”.