OUR
CODETABLE OF
CONTENTSWE ARE ONE
WE ARECOMMITTED INDIVIDUALSWE ARERESPONSIBLE PARTNERS

1.1

Human rights

3.1

Conflicts of interest

1.2

Ethical leadership3.2

Benefits

1.3

Diversity, equal opportunities

3.3

Prohibition of corruption

and equal participation

3.4

Prohibition of insider trading

1.4

Speak Up

3.5

Prohibition of money laundering

1.5

Employee representationand terrorism financing

WE ARERELIABLE COLLEAGUES

3.6

Fair and free competition

3.7

Business partners, procurement
and sales

3.8

Accounting and financial

Occupational health and safety

2.2

Handling Company assets

2.3

Security and protection of

3.9

Export control

WE AREGOOD CORPORATE CITIZENS

information, know-how andintellectual property
4.1

Communication and marketing

4.2

Political lobbying

4.3

Dealings with public officials

4.4

Donations and social sponsorship

4.5

Taxes and customs

4.6

Data protection

4.7

IT security

4.8

Product Compliance

4.9

Environmental protection

SUPPORT

2

TABLE OF CONTENTS

reporting
2.1

GROUPESSENTIALS

We take on responsibility forthe environment and society.

We are honest
and speak up whensomething is wrong.

We break new ground.

3

We live diversity.

We are proud of
the work we do.

We not me.

We keep our word.

4

GROUP ESSENTIALSThe Group Essentials are our Group’s foundation of values
that connects all people in all brands and companies.
They form the basis of our corporate culture.

WE ARE ONE

We are one

Our fundamentals for
Integrity and Compliance

The Porsche Holding Code of Conduct,

intelligence. Transparency is important to us

OUR CODE, is the ethical and values-based

and our approach to innovative technologies

foundation for acting with integrity andensures that users‘ rights and security arein compliance with the rules in our Group.

respected.

It serves as a binding guideline for all
employees in all brands and companies

We do not tolerate violations of the Code– all over the world.

of Conduct. Anyone who violates our rules
make sure that does not happen we seek

collaboration, our workplace, the environment,

advice and support so that together, wesustainability, and society. We approach one

protect our Company, its values, and theanother and everyone else with respect andreputation of all the brands.

fairness, as equals. We take a stance, we are
steadfast and courageous in standing up

Each of us is personally responsible forfor our values and principles – regardless ofcomplying with OUR CODE. It is up to all of

time, economic or social pressure.

us to familiarize ourselves with the Code’s
principles and to be guided by them in our

We are firmly convinced it is essential for

day-to-day decision-making. For a Group oneach and every one of us – employees,

the move, for the protection of people andmembers of the Board of Management andthe environment, and for future generations.

managers – to act with honesty in order tofoster trust in our Company, our products,
services, and innovations. That is why thedecisions we take in all areas of work andin all roles must be in accordance with our
corporate values, and comply with valid
national and international laws, regulations,and internal voluntary commitments. This
also holds true for the continued evolutionof our Company as well as the choice,procurement, development, and use ofinnovative technologies such as artificial

6

WE ARE ONE

must expect appropriate consequences. To
Together, we bear responsibility for ourWE ARE COMMITTEDINDIVIDUALS
We embrace our corporate values, principles and rules,
thus promoting trustful, sincere and fair interaction with
one another. We are all role models.

1.1 Human rights
1.2 Ethical leadership
1.3 Diversity, equal opportunities
and equal participation
1.4 Speak Up
1.5 Employee representation8

1.1 Human rights

We take responsibility forhuman rights
CORPORATE PRINCIPLE

MY CONTRIBUTION

Respect for human rights is of paramountAs an employee, I can also make myimportance. We are convinced that

contribution to respecting human rights.

sustainable economic activity is only

I regard human rights as a fundamental

possible by acting ethically and withguideline, and I am vigilant against humanintegrity. Within the framework ofrights abuse that is happening around me

our entrepreneurial activities, we areor of which I become aware.

regarding human rights. The GroupIf I have concerns regarding human rights

Board of Management, the Volkswagen

abuse in my professional surroundings,

Group European Works Council and the

I prevent it or stop it immediately. If

Volkswagen Group Global Works Council

necessary, I inform my supervisor or gethave fulfilled this responsibility in thein touch with any of the contacts listed inGroup’s Declaration on Social Rights,

the chapter on “Support”.

WE ARE COMMITTED INDIVIDUALS

fully committed to our responsibility

Industrial Relations and Business andHuman Rights, known as the Social
Charter.
We confirm our commitment to majorinternational agreements and declarations,in particular the International Bill of Human
Rights and the core labor standards of theInternational Labour Organization (ILO).
EXAMPLEOur entrepreneurial activities follow theUN Guiding Principles on Business andHuman Rights (UN Global Compact), which

Someone has written to you with information

Inform your superior and the Whistleblower

determine the most important cornerstones

that one of our suppliers is not paying their

System of your concerns about human rights

for our actions.

employees their correct wages and is violating

abuse. Our Company will examine the allegations

labor law by tolerating 80-hour weeks. In

in greater detail and take the necessary

addition, the pay of some of the supplier’s

measures. This may include terminating businessemployees is below the minimum wage.

relations with the supplier in question.

910

1.3 Diversity, equal opportunities and equal participation

We lead based on our values

We live diversity

CORPORATE PRINCIPLE

EXAMPLECORPORATE PRINCIPLE

MY CONTRIBUTION

We embrace our corporate values,

In order to complete a project to schedule,

Diversity, equal opportunities, and equal

I observe the principles of diversity, equal

principles, and rules, take responsibility foryour team would like to skip one step in theparticipation are important principles foropportunities and equal participation andboth personal and corporate growth, andprocess. They say the step is unnecessary.

fair, non-discriminatory, and respectful

encourage people around me to do thelead by example. We perform our duties,

You point out that the valid rules mustcoexistence. We believe in cooperation insame.

and manage our powers and roles in an

be followed, regardless of any pressure.

a spirit of partnership, in tolerance and in

appropriate, fair and responsible manner.

Together, you search for a solution thatmutual respect. We foster diversity in the

If I see any violations of the principles ofThat also applies for personal relationships

complies with the requirements and ourworkforce and support an inclusive work

equal opportunities and equal participation,in the workplace, in particular insofar as

values. You undertake to revise the processenvironment.

such as unequal treatment, harassment, andexisting employment or hierarchicalin collaboration with everyone involved

dependencies may be exploited. Our

and, where possible, to make it leaner. You

We offer equal opportunities for everyoneof their misconduct. If I am not in a position

decisions are always transparent, showcommit to that as a manager and teamand reject all forms of discrimination.

to directly influence events, I notify the HR

good judgment, are guided by integrity,

member.

This applies in particular to unequal

department of the incident immediately or

and are taken in the best interests of thetreatment due to ethnic or social origin,get in touch with the contacts listed in the

Company and its employees, businessskin color, biological sex, nationality,

chapter on “Support”.

partners and shareholders. We strengthen

language, religion, ideology, age, physicaltrust and shape change in the Company

or mental disabilities, gender identity,

through our values-based leadership.

sexual orientation, political views, or any

bullying, I make the persons involved aware

EXAMPLEother characteristics protected by law. We

You hear some of the people you work withlive diversity, actively support inclusion,

making disrespectful comments about people

and create an environment that noton account of their nationality, gender, sexual

I am aware of my function as a role

only encourages the engagement of allorientation, or skin color.

model both within the Company and in aemployees, but also fosters each employee’s

broader context. My conduct and actionsindividuality in the interests of the Company.

MY CONTRIBUTION

Either speak up straight away about thisdiscrimination or get in touch immediately

are always guided by integrity and a senseof responsibility, and are based on this CodeOur employees are selected, hired, andwith one of the contacts listed in the chapterof Conduct, our corporate values, principles

developed based on their qualifications

on “Support”.

and rules. I advocate interaction with one

and their skills.

another in a spirit of trust, honesty, andfairness, and I am open to different pointsof view.

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12

WE ARE COMMITTED INDIVIDUALS

1.2 Ethical leadership1.4 Speak Up

CORPORATE PRINCIPLE

MY CONTRIBUTION

We want to learn from mistakes andMy first point of contact for questions,continuously improve. That is why weconcerns, or the reasonable suspicion of a

speak up about wrongdoings, or as soon

violation of internal or external regulations

as something doesn’t feel right, even if

is my supervisor, or alternatively I can seekthat is awkward and uncomfortable. To

advice from the relevant subject matterdo that, we promote a culture of integrity

experts. The HR department and employee

and actively seek a dialog within our

representatives as well as Compliance areteam and with our supervisors. We seek

also available to provide support. In addition,

advice and support if we have questions

I should report any reasonable suspicion

and problems. We protect everyone whoof Serious Regulatory Violations via thecontributes to this culture.

Whistleblower System. As a Management
Level employee, I am obliged to report any

For us, compliance with external andsuch suspicion.

internal rules at all times is a given. We do
EXAMPLEnot tolerate misconduct. We believe thatturning a blind eye can never be the rightsolution. That is why we react immediately

The deadline for a decision proposal

and appropriately to misconduct andsubmitted to a committee has expired andviolations of our rules.

you notice that you and your team havemade a mistake. You know it is not possible

Managers always lead by example throughto take a meaningful decision on the basis

conduct that is in accordance with our rulesof the data submitted.

and regulations. They perform this importantfunction by supporting employees to comply

Inform your supervisor and the departmentswith the rules, promoting an error culture,

responsible for the committee immediately.

and following up on violations.

Jointly find a way to correct the document.
In addition, you and your team discuss how
such errors can be avoided in future.

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WE ARE COMMITTED INDIVIDUALS

We speak up when somethingis wrong

1.5 Employee representation

We work together in close
partnership – constructive,
cooperative and fair
We recognize the basic right of all employees
to establish trade unions and employee
representations.
We are committed to working with
employee representatives in candor andtrust, to conducting a constructive andcooperative dialog, and to striving for a fairbalance of interests. Professional dealings
with employee representatives are part ofour corporate culture.
Safeguarding the future of the Groupand its employees is achieved in a spirit ofcooperative conflict management and social
commitment, on the basis and with the goalof ensuring economic and technologicalcompetitiveness. Economic efficiency andjob protection are equal-ranking and sharedgoals.

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16

WE ARE RELIABLE
COLLEAGUES
We take our responsibility in the workplaceseriously and protect what is valuable for our
team, our Company, and our customers.

2.1 Occupational health and safety
2.2 Handling Company assets
2.3 Security and protection of information,
know-how and intellectual property
18

2.1 Occupational health and safety

2.2 Handling Company assets

We respect and promotehealth and safety

We protect our assets –whether visible or invisible

CORPORATE PRINCIPLECORPORATE PRINCIPLE

EXAMPLEI make an active contribution to maintaining

We respect the Company’s tangible andYour daughter asks you if you could bringhealth of our employees very seriously. We

and promoting my health by voluntarily

intangible assets and do not use themhome index cards and pens from the officepromote occupational health and safety

participating in preventive healthcare

for non-business purposes, but solely tofor her to use in a school project.

in line with the provisions of national laws

and health promotion activities. I follow

achieve the Company‘s business objectives.

and regulations and with the occupational

instructions, attend training, and align myExceptions are possible if internal policies

You explain that you aren’t allowed to use

health and safety policy of the Company.

daily actions with them.

and guidelines permit private use.

office equipment for private purposes.

Occupational health and safety for all

EXAMPLEMY CONTRIBUTION

sustainable future for our Company and to

You notice that a device in your department

I adhere to the Company’s rules and exercise

positioning our Company as an attractive

appears to have an electrical defect.

care when handling Company assets.

employer. All accidents at work and work-

Do not activate the device and notify the

related illnesses are generally preventable.

responsible supervisor to coordinate further

We therefore aim to ensure the protection

measures. It is not permitted to repair

and promotion of physical and mental

electrical equipment yourself because thishealth. This requires the cooperation andmight be dangerous.

WE ARE RELIABLE COLLEAGUES

We take our responsibility for the safety andemployees is fundamental to ensuring aparticipation of all.
MY CONTRIBUTION
I comply with occupational health andsafety regulations and instructions. I do notendanger my own health and safety or thatof my team or third parties. I support them,
do not look the other way, and accept help.
Within my area of responsibility, I take allappropriate and statutory measures toensure a safe working environment. I draw
attention to unsafe actions or conditions.

1920

2.3 Security and protection of information, know-how
and intellectual property

We protect information andintellectual property
CORPORATE PRINCIPLE

EXAMPLEWe are aware of the value of Company

Your technical invention is about to go into

know-how and take great care to protect

series production. You think about telling ait. We respect the intellectual property ofcolleague about this when you meet in thecompetitors, business partners and othertrain on the way home.
WE ARE RELIABLE COLLEAGUES

third parties.
Be aware that ideas and patents are also
MY CONTRIBUTION

intellectual property belonging to theCompany and do not discuss them in public.

I handle all Company information carefully

If you have any concerns, contact yourand do not disclose it to unauthorized

supervisor or the relevant department.

persons. I take particular care with regard
to information relating to technical knowhow, patents, and trade and businesssecrets.

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22

WE ARE RESPONSIBLE
PARTNERS
Trust is our greatest asset. That is why we rely on honest,
reliable, transparent, and fair business relationships.

3.1 Conflicts of interest
3.2 Benefits
3.3 Prohibition of corruption
3.4 Prohibition of insider trading
3.5 Prohibition of money launderingand terrorism financing
3.6 Fair and free competition
3.7 Business partners, procurement
and sales
3.8 Accounting and financial reporting
3.9 Export control
24

3.1 Conflicts of interest

CORPORATE PRINCIPLE

MY CONTRIBUTION

We act with integrity. That is why it

If I identify that I face or suspect that I

is especially important for us to avoid

may face a potential conflict of interest,

creating potential conflicts of interest when

I immediately notify my supervisor and theperforming our job responsibilities and to

relevant HR and Compliance departments

recognize and disclose possible conflicts

and disclose the facts. If a conflict exists,that we face or that we observe. A potential

we jointly seek a solution that safeguards

conflict of interest already exists if private

the interests of the Company.

or personal financial interests of employees
EXAMPLE

influence or could influence their businessdecisions. This also applies for personal
relationships in the workplace, in particular

You work in purchasing and you have issued

with regard to existing employment

a call for tenders. You find out that your best

relationships or hierarchical dependence.

friend holds a stake in one of the companies
making a bid.

Conflicts of interest may arise both from
employees themselves or through persons

Inform your supervisor of the situation,

related to them, in particular as a result of

document the possible conflict of interest,

involvement in other companies, throughand withdraw from the decision-making

secondary employment, in connection withprocess to avoid any appearance of amemberships or with regard to employees’

conflict of interest.

personal financial circumstances. In thiscontext, business relations with third
parties, such as other companies in theGroup or suppliers, may also be relevant.

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26

WE ARE RESPONSIBLE PARTNERS

We take decisions based on facts,
thus avoiding conflicts of interest

3.2 Benefits

We carefully check all Benefits

CORPORATE PRINCIPLE

EXAMPLE

Our products and services define who we

Employees from a business partner giveare. Therefore, benefits in the form of gifts

you Bluetooth headphones as a birthday

and invitations are only permitted if they are

gift. Even if you are sure that accepting thisappropriate.

gift does not affect business relations, you
its appropriateness critically on the basis ofinvitations and business meals set out what

the valid policy on benefits.
WE ARE RESPONSIBLE PARTNERS

should nevertheless review the benefit andOur internal policies on handling gifts,
benefits are appropriate and what steps
must be taken when accepting and / or

If in doubt seek advice from your supervisor

granting them.

and jointly decide whether to accept or
decline the gift.

MY CONTRIBUTION
I familiarize myself with the policies on
handling gifts, invitations and businessmeals, and strictly abide by them.
I check whether my behavior is appropriate
and whether it might influence my businessdecisions.

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3.4 Prohibition of insider trading

We do not bribe others and do
not accept bribes ourselves

We do not share insider knowledge

CORPORATE PRINCIPLE

EXAMPLECORPORATE PRINCIPLE

Corruption is prohibited worldwide.

You work in software development, and you

We handle information pertaining to share

If I have access to inside information, I

Corruption means that someone abuses

are asked to award a major sub-project to an

Company performance in accordance

do not purchase or sell any financial

their professional position to gain an

external service provider. One of the service

with capital market requirements and do

instruments based on this information. Thisadvantage for themself or a third party

providers that have been invited to submit

not tolerate any insider trading. Insider

applies not only to trading with shares ofand thereby harm others.

a bid offers you a large sum of money if you

information is information of a precise

listed companies belonging to the Group or

make sure their company gets the order.

nature that has not been made publicderivatives thereof, but also to trading withand that, if it were made public, would be

financial instruments in general, i.e., also
those of suppliers.

Benefits such as invitations and gifts,
especially when dealing with public

The conduct of the service provider

likely to have a significant effect on theofficials, can be evidence of corruption.

constitutes attempted corruption. Contact

price of the relevant financial instrument,

Therefore, benefits should be exceptions inyour supervisor or the relevant Compliancee.g., stocks and shares. We may only use

business transactions. Benefits may only be

department immediately.

knowledge relating to insider-relevant

EXAMPLE

granted or accepted within the framework

projects and processes internally in

You learn through your work that theof internal policies and applicable laws.

accordance with the applicable internalacquisition of a large company well-known

policies and may not divulge suchworldwide is going to be announced soon. As

knowledge to any outside party, including

part of your job, you have been informed thatfamily members, e.g., a spouse.

the Company‘s share price will rise significantly

MY CONTRIBUTION
I do not bribe others and I do not accept

once this transaction has been announced. You
MY CONTRIBUTION

a bribe myself, and I avoid even theknow that a good friend is currently considering

appearance of improper influence. I keep

whether to sell their shares in our Company. You

myself informed by consulting the internal

I do not engage in insider trading, nor do

consider telling your friend that he should hold

rules before I give or accept gifts and issue

I make any such recommendations to any

off on selling his shares.

or accept invitations.

third party or induce any third party toengage in insider trading. Furthermore, I do

Do not tip your friend off for any reasons

If I receive any corruption-related hints,

not divulge inside information unless thiswhatsoever. Since the information of which

I immediately inform one of the contacts

is required during the course of my normal

you are aware is not public, but insider

listed in the chapter on “Support”.

work, and I comply with the relevant internal

knowledge, you are not permitted under any

policies. I undertake to familiarize myself

circumstances to share this knowledge with

with the applicable internal rules.

others. Transmitting this knowledge directly or
indirectly would make you liable to prosecution.

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WE ARE RESPONSIBLE PARTNERS

3.3 Prohibition of corruption

3.5 Prohibition of money laundering and terrorism financing

CORPORATE PRINCIPLE

MY CONTRIBUTION

Money laundering occurs when funds

I take no action whatsoever that may violate

or other assets originating directly ormoney laundering provisions at homeindirectly from criminal offenses are putor abroad. I am vigilant and immediately

into circulation in the legal economy,

assess any suspicious conduct on themaking their source appear legal. Terrorism

part of customers, business partners andfinancing occurs when money or other

other third parties. If there is information

resources are made available to commit

providing sufficient grounds for suspicion,

criminal acts of terrorism or to support

I immediately get in touch with the contact

terrorist organizations. Liability does not

person responsible for money laundering

require the person involved to be aware

prevention.

WE ARE RESPONSIBLE PARTNERS

We are committed to clean
business practices

that money is being laundered throughthe relevant transaction. Inadvertent

I abide by all applicable provisions for

involvement in money laundering may

recording and posting transactions andalready be a criminal offense for thecontracts within my area of responsibility

parties involved.

in the accounting system.

We carefully check the identity ofcustomers, business partners and otherthird parties with whom we wish to do
EXAMPLEbusiness. It is our declared aim to conductbusiness solely with reputable partners who
operate in line with legal provisions andA customer would like to conclude apresented, then this particular agreement

who use resources from legitimate sources.

financing agreement but refuses to handcannot be concluded.

over some of the usual documents that
We assign incoming payments to theare necessary to complete the financing

corresponding services without delay

paperwork.

and post them accordingly. We ensure

You need the documents in order totransparent and open cash flows.

conclude the financing agreement. If
documents such as the self-disclosure are
not handed over or an identity card is not

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3.6 Fair and free competition

We are committed to fair andfree competition

Free and fair competition is protected by

We conduct business solely on the basis

antitrust legislation valid throughout theof merit and market economy principles

world. Complying with this legislation

as well as free and open competition.

ensures that there is no undue distortion

We like to measure ourselves against ourof competition in the relevant markets

competitors, always abiding by laws and– to the benefit of all market players.

regulations and observing ethical principles.

In particular, agreements and concerted

We do not enter into any anti-competitive

practices between competitors intended

agreements with competitors, suppliers,

to achieve or effect the prevention oror customers. If our Company holds a

restriction of free competition are prohibited.

dominant market position, we do not abuse

WE ARE RESPONSIBLE PARTNERSCORPORATE PRINCIPLE

this position.
This includes in particular exchanges on
prices and price components, terms andWe comply with the specific antitrust

conditions, carving up customer groupings

provisions for distribution systems in ourand territories, and restrictions on

dealings with our authorized distribution

innovations. In addition, the exchange

partners.

of competitively sensitive information is
MY CONTRIBUTION

prohibited. The abuse of a dominant market
position is also prohibited. Furthermore, theproper implementation of merger control

Whenever I come into contact withprocedures is required with regard tocompetitors, I make sure that no informationcooperations and transactions.

is given or received that would allow
conclusions to be drawn about current or

EXAMPLE

future business conduct.

Anti-competitive conduct has the potential
not only to significantly damage the good

You meet with competitors’ employees at awith details that could impact free and fair

reputation of the Company, but can also

In discussions or any other contacts withtrade conference. You exchange ideas withcompetition. Such information includes

incur severe fines, penalties, and financial

competitors, I avoid issues that could be ofthem. Make very sure you do not betraythe pricing of products and services, pay orcompensation for damages.

relevance for competition among each other.

any trade secrets – especially information

strategic details.

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34

3.8 Accounting and financial reporting

We carefully check who we
do business withWe are committed to correct
financial accounting and reporting

CORPORATE PRINCIPLECORPORATE PRINCIPLE

EXAMPLEWe carefully select suppliers, service

I do not purchase any products or services

We strictly comply with the statutory

You urgently need new equipment. However,providers and partner companies based

without having first gathered information on

provisions for proper accounting andyour department’s budget for the current fiscal

on objective criteria and make use of

the market and alternative suppliers. I follow

financial reporting. Transparency andyear has already been used up. You consider

competition. We only cooperate withthe applicable procurement guidelines andcorrectness are our top priorities, because

acquiring the equipment nevertheless andbusiness partners in line with statutory

involve the relevant purchasing department

any irregularities may have serious

posting the cost in the next fiscal year whenrequirements, internal rules and guidelines.

at an early stage before the planned delivery

consequences for the Company as wellyour budget has been refreshed.

and performance of services in line with

as for the persons responsible. To thatvalid purchasing processes.

end, we regularly inform all capital market

Do not take any action of the kind. Entries

players of our financial position andmust always be assigned correctly. Posting

We check the integrity of potential business
partners carefully before entering intobusiness relations and follow the processes

I make sure that remuneration is only paidbusiness developments. We publish our

entries inaccurately may have serious

and contact procedures set out in the rules

for services that are actually rendered andperiodic financial statements punctually inconsequences for the Company and theand policies.

that the payments are commensurate withaccordance with national and international

individual employee.

the services rendered.

accounting regulations.

and services, we involve the relevant

I also comply with the relevant policies

MY CONTRIBUTION

departments in the process in good time inbefore commissioning Group companies.

When purchasing or selling products

accordance with the applicable policies.

I organize processes in such a manner as
EXAMPLEMY CONTRIBUTION

to ensure all business financial data areentered correctly and promptly in the

It comes to your attention that a supplier,accounting system. If I have any questions

I make myself familiar, that the integrity

service provider or partner company is toabout the correct recording of data, Iof potential business partners has been

be commissioned without involving thecontact my supervisor or the appropriate

checked before entering into businessrelevant purchasing department.

finance department.

relations and follow the processes andcontact procedures set out in the rules and

Get in touch with the relevant purchasing

policies. I show no bias in favor of a supplier,department or one of the contacts listed

service provider or partner company

in the chapter on “Support”, to make surewithout an objective reason, and I promote

the bid that is most cost-effective for thecompetition.

Company is given consideration.

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WE ARE RESPONSIBLE PARTNERS

3.7 Business partners, procurement and sales3.9 Export control

We ensure compliance with all
regulations in cross-border trade
CORPORATE PRINCIPLE
We are aware of our social responsibility

Should I become aware that export control

to fulfill export control and sanctions

regulations are being violated in my area

obligations and expressly commit toof responsibility, I immediately take every

complying with the relevant legislation.

possible action to prevent or remedy such
violations.

transactions may be subject to prohibitions,

If in doubt, I seek advice from the relevant

restrictions, approval requirements orexport control contact.

other supervisory measures under export
EXAMPLE

control regulations. These may relate to therelevant business partners, goods, countries,
financial resources, or intended use. This

You would like to enter into businessapplies to technologies and software as

relations with a potential customer who

well as goods and products. In addition, it

might be on a sanctions list.

applies to temporary cross-border transfer
and technical transmissions, for example, by

Make sure you comply with valid legislation.

e-mail or cloud. Furthermore, certain imports

Contact the relevant export control unit to

may be subject to export control regulations.

coordinate the next steps.

We ensure compliance with applicable
export control regulations and the relevantinternal policies.
MY CONTRIBUTION
I am responsible for regularly checking that
I am familiar with internal information andpolicies on export control. That is how I keep
up to date on whether my day-to-day work
is subject to export control regulations.

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WE ARE RESPONSIBLE PARTNERS

Cross-border business processes andWE ARE GOOD
CORPORATE CITIZENSWe bear responsibility for society and ensure that our
Company contributes to sustainable development.

4.1 Communication and marketing
4.2 Political lobbying
4.3 Dealings with public officials
4.4 Donations and social sponsorship
4.5 Taxes and customs
4.6 Data protection
4.7 IT security
4.8 Product Compliance
4.9 Environmental protection40

4.2 Political lobbying

We communicate clearly
and respectfully

We represent our Company’s
positions in a responsible andclear way

CORPORATE PRINCIPLE

EXAMPLECORPORATE PRINCIPLE

EXAMPLEWe ensure that our communication is

A Group employee has made comments to

As a member of society, we can specificallyYou have a relative who works for theclear and consistent in order to maintainthe media about product sales from anotherpromote the Company’s positions duringtransport ministry and who asks for yourthe confidence of customers, investors

Group brand. This gives the impression thatdecision-making processes, such as those for

opinion on draft legislation that will impact

and other stakeholders. Before committing

the employee is speaking for the brand in an

legislation plans through political lobbying.

the automotive industry. They also ask you

to and / or executing any communication

official capacity.

We conduct political lobbying centrally

for the Group’s position on this legislation.

and in line with the principles of openness,

Do not comment.

or marketing measures, such measures
must first be coordinated with the relevantContact the employee and explain that

accountability, and responsibility. It goesdepartment. Thoughtfulness and respectful

official comments about the company andwithout saying that our interaction with

Political lobbying in the Company isinteraction with one another are second

its products can only be made by authorized

political parties and interest groups is

exclusively coordinated centrally andnature to us.

units. Forward the comments to the relevant

based on the principle of neutrality. Undue

conducted openly and transparently. The

unit with a request to check whether ainfluence in politics or legislation is not

authorized contact for such lobbying

public response is necessary.

permitted.

activities is the External Relations

MY CONTRIBUTION

department.
MY CONTRIBUTION

I do not issue any public statement onbehalf of my Company and always referany requests to the Communications

I do not attempt to intervene in political

department. If I make any comments at

decisions on behalf of the Company if I am

public, trade or cultural events or on the

not authorized to do so. If I am authorized tointernet, I make it clear that I am voicing

do so, I observe the relevant internal policies

solely my own personal opinion. I consultin the performance of my duties.

the Company’s social media guidelines
for advice on proper conduct in social
networks.

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WE ARE GOOD CORPORATE CITIZENS

4.1 Communication and marketing4.3 Dealings with public officials

We exercise caution when
dealing with public officials
CORPORATE PRINCIPLE

EXAMPLEIn view of national and international

As part of an external audit conducted bylegislation, there is an increased risk ofa technical audit organization to obtaincorruption when dealing with public

a compulsory certification you would

officials. This is taken into account inlike to invite the auditors from the audit

our internal policies, which lay down theorganization to lunch.

particular, we do not make any facilitation

Audit organization employees must be

or expediting payments, i.e., payments toconsidered as public officials as they

public officials that facilitate or expedite

perform sovereign functions on behalf ofregular or routine official acts.

the state by conducting the certification.

WE ARE GOOD CORPORATE CITIZENS

framework with regard to benefits. In

For this reason, you have a mandatory
MY CONTRIBUTION

obligation to involve the relevantCompliance department in advance. They

I am aware that there is an increased risk

also help you to assess whether the personsof corruption when dealing with publicconcerned are considered to be public

officials. Therefore, I familiarize myself with

officials.

the applicable special rules. I understandthat I have a binding obligation to consult
the Compliance department in this regard.

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4.5 Taxes and customs

We commit to society in many ways

We meticulously observe tax
and customs regulations

CORPORATE PRINCIPLE

MY CONTRIBUTIONCORPORATE PRINCIPLE

EXAMPLEWe make donations, i.e., voluntary

If I consider a particular sponsorship measure

As a global company, we are aware of

You are responsible for posting certain

contributions without a return service

to be worthy of support, I make initial contact

our social responsibility to meet ourbusiness transactions, for example generalby the recipient, and grant sponsorships,with the appropriate departments in the

obligations with regard to foreign trade,overheads such as maintenance expenses,

i.e., contributions based on a contractually

Company, e.g., Communications, External

taxes and customs, and we explicitly

and production costs, in the statutory

agreed return service for social objectives,

Relations, and Human Resources.

endorse compliance with national andfinancial statements. One project exceeds

international legislation.

certain controlling parameters early into achieve a positive impact in terms ofour reputation and public perception. In

The granting of donations must beorder to avoid conflicts of interest andtransparent, i.e., the purpose, the recipient of

to ensure standard conduct within thethe donation, and the financial management

Company, donations and sponsorshipmust be documented and verifiable. I

I design internal structures and processes

transaction unquestionably relates to anmeasures are permitted only in the context

comply with internal processes and generalin such a manner as to ensure that the taxes

investment and must therefore be treated asof the respective legal framework and in

conditions and do not initiate any donationand customs to be paid by the respective

capitalized production costs.

accordance with the applicable internalthat could damage the reputation of ourGroup companies are calculated correctly,

Post the entry in line with legal

rules of the Group brands and companies.

Company.

promptly and in full, are disclosed inrequirements. All business transactions

reporting, and are paid to the relevant

must be correctly reported pursuant to

EXAMPLE

fiscal authorities.

commercial law and tax regulations because

transparent approval process. We grant

You are a fan of a particular soccer club and

If I have information concerning a violation

for tax returns. Accounting errors could

payments and/or non-cash benefits forwould like to provide financial support in theof tax and customs regulations in my area of

therefore result in incorrect tax returns andscientific, charitable, cultural or religious

form of corporate sponsorship.

responsibility, I undertake every action I canlead to serious consequences under tax

purposes. In addition, we grant donations

Sponsoring decisions are taken in

to prevent or stop this violation. If that is notand customs law for the Company and theexclusively to institutions which areaccordance with all applicable processes, inpossible, I get in touch with the appropriate

employees responsible.

recognized as charitable and/or tax-

consultation with all relevant departments

contact person in the tax and customs

privileged.

and are based on objective criteria. If you

department.

Donations and sponsorship measures

the financial year. You therefore receive
MY CONTRIBUTION

instructions to make an entry under
maintenance expenses even though theare only granted in accordance with athese accounting records form the basis

have concerns that your club or othersponsoring recipient does not meet theCompany’s criteria for social sponsoring,
make your concerns transparent to yourCompliance department.

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WE ARE GOOD CORPORATE CITIZENS

4.4 Donations and social sponsorship4.6 Data protection

CORPORATE PRINCIPLE

EXAMPLEWe attach great importance to handling

You have organized a seminar with external

data responsibly, securely and transparently.

participants and receive personal data in

We collect, process, use, and store personalconnection with the seminar. A colleague

data solely in accordance with statutory

asks you to pass on the addresses inrequirements. We protect the personal data

order to send the participants commercial

of customers, employees – including former

communications on our products andemployees and applicants – and partners

services.

such as suppliers and development partners.
Do not pass this data on without
MY CONTRIBUTION

first consulting your data protection
organization. As a general principle, data

I handle personal data confidentially and mymay only be processed for the purpose foractions are clear and transparent. I integrate

which it was collected.

data protection in my actions and processes
and ensure the security of all data in myarea of responsibility. I take responsibility
and pay attention to secure data exchange
throughout the value chain. If in doubt, I
contact my supervisor or the relevant dataprotection department.

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WE ARE GOOD CORPORATE CITIZENSWe handle data carefully4.8 Product Compliance

We secure our IT systems

We inspire the world with
our products

CORPORATE PRINCIPLE

EXAMPLECORPORATE PRINCIPLE

MY CONTRIBUTION

We respect IT security and abide by the

You receive an e-mail from someone

Our products inspire countless people all

I carefully comply with all relevant

applicable information security regulations.

claiming to be a business partner asking forover the world. We give high priority to theprovisions in my day-to-day work. I set

The information security regulations provide

certain confidential information on a current

conformity and safety of our products. We

realistic goals. If there is a conflict of goals,

guidelines for different employment groups

project. You feel the tone of the email ishave a responsibility to ensure that risks

the conformity of our products always

and are relevant for all employees.

unusual and the inquiry itself would appear

to health, safety, the environment, and thehas top priority, regardless of time or costto be false.

assets of our customers or third parties

pressure. That is why I embrace our defined

resulting from the use of these products

processes and continuously improveare excluded where possible.

them. We jointly identify and close gaps

MY CONTRIBUTION
Contact the relevant IT security department
I familiarize myself with the applicable IT

to clarify whether your suspicion is correct.

security regulations and observe the rules

Check with your supervisor whether

In compliance with statutory provisions,obligations. I contact my supervisor or

therein. As part of the IT security chain,confidential information may be passed on

we develop our products in accordance

the PCMS team if I have any questions or

I make my active contribution by being

to third parties.

with state-of-the-art technology, taking

concerns about product compliance.

in processes in order to meet all binding

vigilant at all times and ensuring my basic

account of other binding obligations such

IT security skills are always up-to-date.

as additional safety requirements resulting

EXAMPLE

from the state of scientific knowledge.
This is systematically ensured by means

A customer contacts you to report technicalof established structures and stableproblems with a vehicle. You are not sureprocesses. Once they have been put on

whether these problems are due to an

the market, our products are constantly

operating error on the part of the customer

monitored in the field so that appropriate

or due to a manufacturing or construction

measures may be promptly initiated in thedefect.

event of possible discrepancies. We do notmake any compromises in this regard.

Clarify the matter immediately. It is essential
to make sure our Company remedies any
problem for which it is responsible. In
addition, errors on the part of the customer
may also require a response from ourCompany, such as amendments to operating
instructions or application training.

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WE ARE GOOD CORPORATE CITIZENS

4.7 IT security

4.9 Environmental protection

CORPORATE PRINCIPLE

MY CONTRIBUTION

As a global commercial enterprise, we

I am mindful of environmental protection

bear responsibility for the environmental

in my work and use resources and energy

compatibility and sustainability of oureconomically and efficiently. I make sure myproducts, locations, and services. Our

activities have the smallest possible impact

Company aspires to be a global provider

on the environment and that they complyof sustainable mobility and a role modelwith environmental protection laws andfor protecting the environment. We focus

regulations.

on environmentally friendly, advanced,
EXAMPLEand efficient technologies, which we
implement throughout the entire lifecycleof our products. From the very early

You notice a constant drip on the water tap

phases of development and production

fitted to a washbasin in the office; this could

onward, we make sure we manage natural

waste large quantities of water if it is notresources carefully, continuously reduce

repaired.

the environmental impact, and comply
with environmental protection laws andReport the dripping tap immediately toregulations.

the colleagues in charge and draw theirattention to the problem.

Furthermore, we constantly reassess theenvironmental compatibility of products andmanufacturing processes, optimizing thesewhere necessary. We are a responsible
member of society and a partner for politics.
We seek a dialog with these players on
future mobility concepts and on shaping
ecologically sustainable development.

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WE ARE GOOD CORPORATE CITIZENSWe bear responsibility for theenvironment and sustainability

SUPPORT
We offer support in dealing with the Code of Conduct.

PREVENTING MISCONDUCT, CONTACTPOINTS AND WHISTLEBLOWER SYSTEM
Our Code of Conduct provides the binding

give our name, or we can make the reportframework for acting with integrity andanonymously. We are aware that thein compliance with the rules within our

Volkswagen Group Whistleblower System

Group. As Group employees, we have a

has responsibility for investigating reports

responsibility to respect the principles ofregarding Serious Regulatory Violations.

Violations and thus avoid damage to the

A Serious Regulatory Violation is aCompany. Violations of laws and internalsignificant violation of our ethical values

policies are immediately investigated.

as set out in the Code of Conduct. Equally,

Depending on the seriousness of theviolations of statutory laws or regulations

violation, this can have disciplinary, civil, orthat may significantly affect the reputation

criminal consequences for the employees

or financial interests of the Company areconcerned. Proven misconduct can also

also considered to be Serious Regulatory

have an impact on remuneration. That

Violations. In all other cases we should firstis why we talk to our supervisor or seek

seek advice from our supervisor, the HR

expert advice immediately if we have any

department or Compliance.

SUPPORT

our Code in order to prevent Regulatory

questions or concerns, or if we suspect
there has been a violation of internal orManagers have a special function as role

external regulations. The HR department

models. The decisions they make for theand employee representatives are there

Company must always take account ofDiscrimination against them is itself

reports. Abuse of the Whistleblower System

to provide support. We can also contact

values and regulations. This includes

considered a Serious Regulatory Violation.

is not tolerated and will be disciplined

the Company’s Compliance Officer or theimmediately reporting Reasonable

Compliance advice service at any time at:

Suspicion of the concrete indication of a

At the same time, the Whistleblower

Serious Regulatory Violation.

System protects the interests of Persons

Potential violations of the Code of

Implicated. For them, the presumption of

Conduct for Business Partners, including

The purpose of the Whistleblower System is toinnocence applies as long as a violation isserious risks, violations of human rights

In addition, we can submit reports regarding

protect our Company, the whistleblower, andnot proven. The work of the Whistleblower

and environmental violations by direct andRegulatory Violations via the Volkswagen

all persons who contribute to the investigation

System is based on uniform processes andindirect suppliers, can also be reported toGroup Whistleblower System. We canand the termination of misconduct.

the confidential, professional processing of

the Central Investigation Office.

E-mail: compliance@porsche.co.at53

accordingly.

54

We can access the Whistleblower
System through the following
channels:
Contact details for the Investigation Office:In addition, experienced external lawyers act as neutral mediators (ombudspersons) for us.

Postal address:

Central Investigation OfficeBox 1717
38436 Wolfsburg, Germany

As legal counsel, they are tasked with receiving reports about possible infringements oflaws, internal rules or other conduct damaging to the Porsche Holding. If necessary, andif the identity of the whistleblower is known, they make direct contact should they require
feedback. Once the preparations are complete, the ombudspersons forward all informationagreed with the whistleblower – anonymously if the whistleblower so wishes – to our

24/7 hotline:

E-mail:+800 444 46300+49 5361 946300

Contact details for the ombudspersons:

io@volkswagen.deInternet:

Online reporting channel: https://www.bkms-system.com/vw(this channel can also be used
for making anonymous reports)

https://www.ombudsmen-of-volkswagen.com

Further information on the Volkswagen Group Whistleblower System, the ombudspersons
and the relevant external reporting channel (if applicable) is available on the internet athttps://www.volkswagenag.com/en/group/compliance-and-risk-management/
whistleblowersystem.html

In person:

Please make an appointment inadvance by writing an e-mail to
io@volkswagen.de

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SUPPORT

Whistleblower System for further processing.

If at any time I am unsure whether my behavior complies
with the principles set out in our Code of Conduct, I should
ask myself the following questions:

1.

Did I take all relevant matters into consideration andweigh them properly? (content test)

2.

Am I confident that my decision is within theconstraints of legal and company requirements?
(legality test)3.

Do I stand by my decision when it is revealed?
(supervisor test)

4.

Am I in favor of all such cases being decided the same
way company-wide? (universality test)

5.

Do I still think my decision is right when my company
has to justify it in public? (public test)

6.

Would I accept my own decision if I were affected?
(involvement test)

7.

What would my family say about my decision?
(second opinion)

If my answer to questions 1– 6 is “yes” and the answer to question 7 is positive, my behavior
is very likely to be compliant with our principles. If questions remain unanswered or if I haveany doubts, I should get in touch with any of the points of contact listed in this chapter.

58

SUPPORTSELF-TEST FOR
DECISION GUIDANCE© VOLKSWAGEN AKTIENGESELLSCHAFTGroup Integrity & Compliance
Letterbox 1717
38436 Wolfsburg
Germany
Version 3.0 | January 2024