In the TOGETHER 2025+ Group strategy, we have set a major objective: to act as a model of integrity. Through the implementation of the Together4Integrity (T4I) program, we want to consistently achieve this goal throughout the Group across all brands and companies and to strengthen corporate governance on integrity and compliance . We have set ourselves the objective of the key performance indicators of integrity and compliance having the same strategic and operational priority as, for example, sales revenue, profit, product quality or employer attractiveness. T4I is thus one of the most extensive change programs in the history of the Group. The Integrity and Legal Affairs function of the Board of Management, under the leadership of Hiltrud D. Werner, is responsible for designing and implementing the program.
T4I WITH FOCUS ON GOVERNANCE AND CULTURE CHANGE
The program serves to provide the regulatory framework for acting with integrity and in compliance with the rules – that is T4I’s governance dimension. In addition, T4I also has the dimension of culture change: to reach people and strengthen their own drive to act with integrity. For our employees, there is thus a stable framework in which they can act responsibly, purposefully and entrepreneurially and contribute to Volkswagen having integrity through and through and being a respectable company in the best sense of the word.
The seven Group Essentials are the foundation of the culture change. These essentials define how we at Volkswagen want to work together and they supplement the Code of Conduct, which lays down the general rules of conduct, particularly with respect to compliance with the law and with internal guidelines.
T4I’s methodological design follows the five fundamental and widely acknowledged principles of the international Ethics & Compliance Initiative (ECI). The principles relate to strategy, risk management, acting with integrity, a culture of open discussion and taking on responsibility, including in the case of misconduct.
T4I specifically will put integrity and compliance in concrete terms for all five principles, with the intention of sustainably anchoring them in corporate practice.
As a consistent umbrella program T4I combines the content of all the Group’s initiatives and its departments with respect to integrity and compliance.
An important factor for the success of T4I is a strong tone from the top, with which members of the Board of Management and top managers provide direction, reveal objectives and explain the reasons for and advantages of the program. The protagonists here are both the members of the Group Board of Management and the members of the boards of management or managing directors of the individual companies who put the individual initiatives in the local frame of reference and authentically champion T4I as a project of their company’s own.
Further support is provided by numerous dialog-oriented communication measures and event formats, for example, perception workshops, which actively involve employees across hierarchies and which employees can help shape. However, T4I not only has an impact internally, but also beyond the Group: through the revision of the Code of Conduct for Business Partners, through which we also commit our suppliers and sales partners to the principles of integrity and compliance.
Furthermore, the increasing focus on integrity and compliance, particularly in the Code of Conduct, also determines every employee’s interaction with customers, representatives of civil society, government bodies, authorities and other stakeholders.
IMPLEMENTING T4I THROUGHOUT THE GROUP
The program is to be rolled out to the roughly 700 operating business units (legal entities) in which our more than 670,000 employees work by 2025. From the start in spring 2018 to the end of the 2019 reporting period, the program has initially been rolled out to more than 200 business units, prioritized by size and risk profile, in order to achieve a far-reaching impact as quickly as possible. With around 491,000 employees, these business units represent more than two thirds of all the Volkswagen Group’s employees. The core content of T4I is more than 100 packages of measures that must be independently implemented by every business unit. This is intended to create consistently robust systems and processes for avoiding compliance and integrity risks in all areas of activity – and should thus also eliminate the causes that fostered serious misconduct in the past. The packages of measures are grouped by topic into 11 key initiatives, for example on product compliance, on HR compliance and processes, on the whistleblower system or on Business Partner Due Diligence.
One key initiative – the integrity program – is particularly focused on the topic of integrity. Regular reporting on how implementation of the particular key initiative is progressing ensures transparency about the progress made in implementation in the individual companies and thus creates the basis for quality assurance. The focus in the reporting year was on reaching people, raising their awareness and motivating them.
To this end, we held T4I launch events and subsequently held T4I perception workshops. Both events are held in every business unit at the start of the implementation of T4I and involve both employees and managers across hierarchies as players in the change process. The joint design and implementation of these events increases awareness of each individual’s valuable contribution to the success of the change among participants. In addition, they offer the opportunity to ask openly critical questions and name problems.
The perception workshops are primarily about the actual practice of integrity and compliance – measured by the perception of employees. Here, representatively selected employees and managers give their assessment and discuss opportunities for improvement.
In the reporting year, it became apparent that employees predominantly speak positively about the practice of integrity and compliance at each site: on average, more than 80% of survey respondents know the corporate values, for example. They know where they can report wrongdoing and agree with the statement that how managers behave is important to the Group. The workshops are repeated after around one year, partly in order to measure progress and identify any existing need for action.