Volkswagen AG is in full transformation mode, pushing forward on our strategy with full force.
Parallel to the transformation of our industry we are seeing the rising importance of ESG in investment decisions, which no one will argue has become mainstream and will continue to grow at a rapid pace.
The importance of ESG is also growing continuously within our organization and is fully embedded in our decision making processes. We believe we have made significant progress amongst others in the areas stated below.
Nevertheless we are fully aware that much more needs to be done.
We have learned that the area of controversies is a reoccurring concern.
This website addresses relevant current and ongoing controversies in a factual manner with the aim of increasing transparency for you our stakeholders.
We invite you to browse this content, welcome any feedback from your side, also on suggestions
of further topics that require clarity, and we look forward to our increased dialogue.
Please feel free to send a mail to (firstname.lastname@example.org) or contact
email@example.com, +49 5361 947 420 or
firstname.lastname@example.org, +49 5361 942224
who are responsible for ESG within the IR Team.
End of Independent Compliance Monitorship
Volkswagen AG successfully completed the Independent Compliance Monitorship under Agreements with U.S. Authorities.
During the Monitorship, Volkswagen implemented nearly 300 new or revised internal regulations and policies in the relevant legal entities to accelerate the rollout of new processes. These include:
- Establishing a Group Compliance Committee, HR Steering Committee within the Group and new role for Environment, Health & Safety at Volkswagen Group of America
- Launching Together4Integrity, a global framework to oversee Volkswagen’s integrity and compliance program as well as its cultural change activities;
- The introduction of a group-wide uniform Code of Conduct for all 12 brands and all other companies;
- Expanding the whistle-blower system by investing in processes, staffing and in IT infrastructure;
- Publishing an employee survey conducted by the Ethics and Compliance Initiative (ECI)
- The T4I program has been determined in April 2018 by the Volkswagen Group’s Board of Management. It is the Group-wide program for implementing the Volkswagen Group's holistic and comprehensive integrity and compliance management system. It is firmly anchored in the Group's NEW AUTO strategy. The standards for ensuring integrity and compliance (I&C) are uniformly rolled out and implemented by T4I throughout the Group in more than 100 packages of measures, which are summarized in eleven so-called Key Initiatives.
- Since the launch of T4I, almost 750 Group Entities have been onboarded, thus more than half a million employees of the Volkswagen Group have been involved in our Integrity and Compliance programme.
- As part of T4I, we want to inspire and motivate employees, particularly through Launch- and Perception workshops. These are part of every local T4I implementation and involve representatively selected employees and managers across hierarchies as players in the change process. As of today, we have conducted over 600 across the involved entities.
- The Workshops have enabled us to make further progress: By repeating the events, we measure the progress of the company in question. 83% of those surveyed saw the anchoring of I&C as part of the T4I program in the companies as progressing successfully (as of end of Q1/2022). This is an increase, compared with the year 2020 (78%) and a significant increase compared with the first measurement point in 2019 (71%).
- Each member of the board of management is clearly committed in Integrity & Compliance and pursue I&C projects in their executive responsibilities. T4I program was assigned to steer these I&C projects in the executive responsibilities.
Link to the Website:
2022.03.24: Speech Dr. Döss (Member of the Group Board of Management for “Integrity and Legal Affairs”): Integrity as a key factor for the future success of the Volkswagen Group
Ethics & Compliance Initiative (ECI) https://www.ethics.org/
At Volkswagen Group, human rights, tolerance and respect for one another are the yardstick for our cooperation. This is what we stand for – developed to reflect the UN Guiding Principles for Business and Human Rights - also in China.
The respect of human rights is embedded in our Volkswagen Group-wide binding Code of Conduct.
We represent and live our standards and values in China and ensure that our work with all Volkswagen Groups factories, distribution companies and suppliers is based on our principles: for example, respect for minorities, employee representation, social and labor standards.
Volkswagen and its joint ventures strictly oppose any form of forced labor in our operations anywhere in the world, including China.
We have no evidence that forced labor is being used in our direct supply chain or at any of our production plants. At the SAIC VOLKSWAGEN Joint Venture plant in Urumqi, all employees have a direct labor contract with SAIC Volkswagen with equal pay for equal jobs.
Our joint ventures have an own Code of Conduct, a whistleblower and an external ombudsmen system to prevent or detect possible wrong doings or violations.
Volkswagen has built a long history with China and will remain firmly committed to its presence in China.
Link to the Website:
United Nations Human Rights Special Procedures: Communication with the “Working Group on the issue of human rights and transnational corporations and other business enterprises”:
Supply Chain / Sustainable Procurement, Code of Conduct
Volkswagen is convinced that a sustainable supplier network guarantees long term business success. All suppliers must accept the code of conduct which has been published under www.vwgroupsupply.com. The code of conduct defines legally compliant, sustainable and responsible business behavior under environmental, social and ethical aspects. Compliance with the code of conduct is evaluated by us for every relevant supplier on the basis of self-assessment questionnaires as well as possible local on site inspections. The sustainability index is directly relevant for the contract award: when a supplier does not meet our requirement for sustainability compliance standards, they are not entitled to a contract award. Therefore, there is a direct incentive for all suppliers to improve their sustainability performance.
Link to website:
Supply Chain / Lithium – Cobalt
As a one of the forerunners of e-mobility, the Volkswagen Group is ensuring intends to ensure greater transparency and responsibility in its raw material supply chains for batteries. To that end, the company has entered a strategic partnership with RCS Global, an agency specializing in supply chain analysis. The focus is on auditing suppliers for conformance with human rights, safe working conditions and environmental protection along the supply chain all the way back to the mines.
The Group introduced a sustainability rating for direct suppliers and a comprehensive system developed by RCS Global also tracks adherence to sustainability criteria at sub-suppliers, refineries, smelters, mines and recyclers. New guidelines for improvements issued to suppliers make an active contribution to achieving improvements when risks and shortcomings are identified. Serious audit violations may even lead to the disqualification of suppliers from the supply chain. That applies, for example, to small-scale mining operators when child labor cannot be ruled out. The approach builds on the Due Diligence Guidelines of the Organization for Economic Co-operation and Development (OECD).
Link to the website:
Supply Chain / Leather
AIt can be excluded that the Volkswagen Group together with all its brands is sourcing or has ever sourced leather from Paraguay. All our leather suppliers are working at a high level of sustainability. The general sustainability requirements of the Volkswagen Code of Conduct, which apply to all suppliers, are currently being adapted to leather. In order to improve the sustainability in the supply chain, we are currently working on leather specific mandatory requirement document for sustainable purchasing. This list has a mandatory leather specific external audit , the disclosure of the sub-suppliers of the vendors as well as the exclusion of leather and other primary material related to illegal deforestation. Volkswagen is
therefore proactively improving transparency and responsibility in the leather supply chain. Volkswagen is convinced that a sustainable supplier network guarantees long term business success. All suppliers must accept the code of conduct which has been published under www.vwgroupsupply.com. The code of conduct defines legally compliant, sustainable and responsible business behavior under environmental, social and ethical aspects. Compliance with the code of conduct is evaluated by us for
every relevant supplier on the basis of self-assessment questionnaires as well as possible local on site inspections. The sustainability index is directly relevant for the contract award: when a supplier does not meet our requirement for sustainability compliance standards, they are not entitled to a contract award. Therefore, there is a direct incentive for all suppliers to improve their sustainability performance.
European Commisson - Antitrust (08.07.2021)
With today's decision, the European Commission has ended a long-running administrative procedure. In these proceedings, it had investigated various forms of cooperation between auto manufacturers and classified them for the most part as not relevant under antitrust law.
The Commission is breaking new legal ground with this decision, because it is the first time it has prosecuted technical cooperation as an antitrust violation. It is also imposing fines even though the contents of the talks were never implemented and customers were therefore never harmed. In fact, the tank sizes and ranges of the SCR vehicles at all the OEMs involved were two to three times higher than discussed in the talks.
In addition, the Commission expressly points out that there is no classic cartel in the form of price fixing, customer agreements or market sharing.
VW has cooperated fully with the European Commission throughout the proceedings.
Instead of a fine, it would have been more expedient for the automotive industry to issue clear guidelines on how cooperations in the context of research and development can be structured in accordance with antitrust law in the view of the European Commission. The existing Commission guidelines on horizontal cooperation agreements date from 2011 and no longer do justice to the complex challenges facing the automotive industry in particular in the area of necessary technical cooperation. The large fines imposed in this case underscore the need for more comprehensive practical guidance from the Commission to ensure that legal uncertainties do not become a stumbling block to innovation in Europe.
VW will carefully review today's decision once served and then decide whether to appeal, if necessary. The latter would be possible until mid-September by bringing actions before the European Court in Luxembourg.
Volkswagen AG - Works Council Remuneration Scheme (28.09.2021)
Volkswagen AG sees its understanding vindicated that there was no criminal misconduct on the part of the accused relating to the determination of remuneration of individual works council members.
The remuneration system for Volkswagen AG works council members was developed and reviewed with external legal experts.
Nevertheless, there were open legal issues relating to long standing works council members’ remuneration.
The current court case was not directed at Volkswagen AG, but against individual persons.
Volkwagen Chattanooga (21.12.2021)
No matters involving Volkswagen Chattanooga are currently pending before the National Labor Relations Board (NLRB)
The UAW revoked its prior certification of a maintenance unit, filed for an election for both production and maintenance employees, and an election took place on June 12, 13, and 14, 2019. The employees voted against UAW representation, the UAW did not file any objections to the election.
End of EPA Auditorship (15.08.2022)
The Independent EPA Auditor retained pursuant to the EPA Administrative Agreement completed his three-year term on August 15, 2022.
During the EPA Auditorship, Volkswagen further strengthened its Code of Conduct and its policies and procedures related to the Whistleblower System. In particular,
- The Group amended whistleblower policies and Code of Conduct to state clearly that retaliation against whistleblowers and investigation participants is prohibited, and
- MAN ES implemented further communication and training measures to continue to increase awareness and acceptance of the Whistleblower System, and to continue to encourage employees to utilize the Whistleblower System.
In addition, Volkswagen maintained the commitment to integrity and compliance that led to Volkswagen’s successful completion of the Independent Compliance Monitorship under Agreements with U.S. Authorities in September 2020. Specifically, during the EPA Auditorship, Volkswagen
- Maintained an updated Code of Conduct to establish a baseline of principles and guidelines for the entire Group;
- Maintained an effective Whistleblower System based on the principles and standards established in the Group Policy for Volkswagen Group Whistleblower System;
- Communicated with employees to promote awareness of significant ethics and compliance topics and especially the Code of Conduct; and
- Utilized the System for Award Management database to ensure that certain employees with management or supervisory responsibility for business affairs related to U.S. federal procurement and nonprocurement programs had not been suspended or debarred by U.S. authorities.
Volkswagen remains committed to the continuous improvement of its organization and culture. This mindset continues to be essential to its ambition of making safer and more intelligent zero emission vehicles for today’s customers and for generations to come.