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  6. “We must root out and end serious misconduct”

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“We must root out and end serious misconduct”

An interview with Matthias Haas, Director of the Investigation Office

Last year, the Volkswagen Group began to restructure its whistleblower system as a way of better uncovering and ending serious violations of laws and internal codes of conduct. The Investigation Office plays a key role in the whistleblower system. In the following interview, Office Director Matthias Haas offers some insights into his team’s work.

What does the Investigation Office do?

Our main job is to follow up leads about serious violations of regulations. Such leads can be provided by employees, customers or suppliers of the Volkswagen Group. With a team of experienced lawyers, we review the information and analyze initial documents, among other things. We will initiate more extensive inquiries if further suspicions are raised.

How many disclosures do you get on average each month?

We currently get about 70 to 90 disclosures each month. Following our thorough review, only a relatively small number of disclosures actually produce suspicions of serious misconduct. Nonetheless, we are grateful for all such information because they help us identify and stop serious misconduct at an early stage. We define a serious violation of regulations as misconduct that causes far-reaching damage to the financial position or image of the company.

How can someone provide information to you?

We are receiving more and more disclosures through our online reporting channel. Every whistleblower can enter this highly secure room and provide information. All whistleblowers may use their name or submit information anonymously. Whistleblowers can also set up a mailbox there. This is helpful because we can then ask follow-up questions regarding anonymous information. The Investigation Office can also be reached in many other ways – by e-mail, letter or a personal appointment. We recently created a new way for whistleblowers to personally reach the Investigation Office. Beginning on August 1, information about possible serious misconduct can be reported to a 24/7 hotline in addition to the other reporting channels. People who call the global telephone number will speak to a specially trained contact partner. This individual can bring in an interpreter if necessary. The disclosures are handled confidentially and are transmitted to the Investigation Office for further review.

How do you determine that misconduct has indeed occurred?

We start by investigating the information. If we develop a reasonable suspicion of serious violation of regulations, we will pass the information to Group Security, Group Audit or Group Legal Affairs for further investigation. Our colleagues will collect additional information, conduct interviews and put together an investigation report. The Investigation Office will evaluate the results of the inquiry. If a serious violation of regulations is determined, a review will be conducted to determine what sort of punishment the affected employees should face.

How do you prevent unproven allegations from harming accused individuals?

In the interest of those implicated, we follow the rules of the whistleblower policy, which calls for a fair, transparent and speedy process. This includes the opportunity for the accused individuals to address each allegation. If they wish, they are welcome to have a member of the Works Council or a lawyer present at the time. And we bring in only those individuals whose cooperation is really needed. One particularly important aspect of our work is the need-to-know principle. That is, we conduct investigations as confidentiality as possible and do not want to unnecessarily drag employees’ names through the mud. One other thing is equally important: All employees identified by disclosures are presumed to be innocent until proven guilty.

What if a line manager or colleagues hear about the allegations in spite of your efforts to keep the matter confidential?

Anyone who is falsely accused has a right to rehabilitation. If the cleared individual so desires, his supervisor or another manager will announce at the end of the inquiry that the allegations were baseless. Incidentally: Anyone who abuses the system and intentionally makes false allegations against a colleague is violating company rules. This violation will be investigated and pursued.

And what about the whistleblowers – people who expose problems won’t always win popularity contests…

Protecting whistleblowers is also one of our top priorities. We will handle your name very confidentially. You can also provide information anonymously. Furthermore, discrimination against employees who provide disclosures is also considered to be a serious violation of regulations. The Investigation Office will immediately follow up on any evidence in this regard.

Why is it important to pass information about serious misconduct to the Investigation Office?

Whistleblowers help us prevent damage to the Volkswagen Group. They protect our company and, in the end, all employees. It takes courage and the willingness to assume responsibility to submit a disclosure. As a rule, this decision is not an easy one for whistleblowers to make. But it is an important one. After all, information provided by whistleblowers is the most frequent way to uncover illegal activity in organizations. In particular, we expect members of management to fulfill their role model function and report serious violations of regulations to us. Under our whistleblower policy, these colleagues are also obligated to report serious violations of rules.

What motivates you on the job?

I have always enjoyed working on behalf of others and preventing them from being harmed. I did this for years as a lawyer and later as an employee at MAN – I am now playing this role on behalf of Volkswagen, colleagues and our business partners. I also believe that a smoothly running whistleblower system is an element of our new corporate culture. It helps ensure that misconduct is addressed and not tolerated. We intend to and must root out and end serious misconduct. This is what I am working for.

How do I submit a disclosure?

To process a disclosure, the Investigation Office of the Volkswagen Group needs to have the most specific information possible about a potential violation. Whistleblowers can run down a list of five questions to determine whether they possess all of the important facts:

  • Who allegedly committed a serious violation of rules?
  • What happened?
  • When did the misconduct occur?
  • Where did it occur?
  • How did the misconduct occur?
The Investigation Office needs the most specific responses possible to these questions in order to conduct an effective inquiry. One other important point: Company outsiders should also be able to understand the information. This is not always the case when disclosures involve technical details.
 
Even when the five questions are answered, other questions frequently arise during an inquiry. Our job at the Investigation Office becomes easier if experienced and trained lawyers can ask follow-up questions during the inquiry. Whistleblowers who prefer to remain anonymous can set up a secure mailbox via the online reporting channel. The Investigation Office can then initiate a dialog with the individual, and the whistleblower does not have to reveal his or her identity. Potential supplemental documents can be transmitted via the online channel as well. During this process, it is impossible for us to learn the identity of a whistleblower if he or she does not want to reveal it.
  • One other point should be kept in mind:

    The whistleblower system is designed to uncover serious violations of regulations. It is not designed to solve things like everyday conflicts on the job. These types of issues should be discussed openly and resolved constructively in dialog with colleagues and managers,

    Disclosures can be made online, by phone, by letter, by fax, or in person. The central point of contact is the Investigation Office, which is part of Group Compliance. There are other investigation offices at Volkswagen Truck & Bus, Audi and Porsche. The four investigation offices collaborate closely.

    Every employee can make disclosures. But the information can also come from suppliers or sales partners.

  • You can reach the Investigation Office, a part of Group Compliance, in the following ways: