2.3.47.2, 2017-10-10 18:26:25

Ombudsmen System

Ombudsmen System & Vigil Mechanism Committee

The Volkswagen Group follows a stringent ethical system worldwide in order to create a secure environment where matters concerning corruption, fraud, viola-tion of policies and conflict of interest can be appropriately addressed. Corrup-tion / fraud can harm our company, the Volkswagen Group and its employees. The Volkswagen Group has therefore set up an Anti–Corruption System to maintain the core ethics of the Group.

In order to facilitate a platform to come forward and report genuine concerns and fight corruption, two highly respected lawyers act as independent Om-budsmen for the entire Volkswagen Group and can be contacted for reporting any information / concerns pertaining to Corruption related topics within the Group. All the information provided to the Ombudsmen is treated in the strictest confidence and the identity of anyone disclosing the information is also kept strictly anonymous.

FAQs

One can confidentially report any information on acts of economic crime, corruption or any other serious non-compliance in terms of code of conduct or compliance policies (hereinafter referred to as "information") of the Volkswagen Group or one of its brands.

Please note that instances of customer complaints are not to be reported in this system as another mechanism for this already exists. For any Sales or After Sales service related queries, please email at customercare@volkswagen.co.in or refer to this link. Any communications on above mentioned topics shall not be acknowledged, attended or replied by the Ombudsman or Vigil Mechanism Committee.

There are various ways for the whistle-blower to contact the ombudsmen. They can be contacted either by telephone or fax or email or letter. Furthermore, it is also possible to set up confidential one-on-one meetings.

The contact details of the Ombudsmen and Volkswagen Group's Anti-Corruption Officer are as follows:

Dr. Rainer Buchert (Lawyer)
Phone: +49 (0) 61 05 92 13 55 or
+49 (0) 69 71 03 33 30
Fax: +49(0) 69 71 03 44 44
dr-buchert@dr-buchert.de

Mr. Thomas Rohrbach (Lawyer)
Phone: +49 (0) 69 65 30 03 56
Fax: +49(0) 69 65 00 95 23
rohrbach@ra-rohrbach.de

Link to Online Platform: www.ombudsmen-of-volkswagen.com

VOLKSWAGEN GROUP ANTI-CORRUPTION OFFICER
Mrs. Hiltrud Werner 
Phone: +49 (0) 5361-923488
hiltrud.werner@volkswagen.de

The Chief Audit Executive of Volkswagen Group India can also be contacted for sharing such information.

Mr. Ferdenain Sauls
Vice President - Internal Audit 
Volkswagen India Private Limited
Phone: +91 (21) 3566 1008
internalaudit@volkswagen.co.in

In addition to the above, the Board of Directors of Volkswagen Group Sales In-dia Private Limited, in their Board meeting held on September 14, 2016, have con-firmed that the Vigil Mechanism Committee will be headed by Mr. Thierry Lespiaucq, Managing Director for the purpose of looking into and addressing all concerns pertaining to corruption and fraud related topics, including those re-ported by any employee. Mr. Vijay Kamath (Legal & GRC) shall be the Commit-tee Member alongside Mr. Lespiaucq.

The contact details of the Committee Members are as follows:-

Mr. Thierry Lespiaucq
Managing Director
Tel: 022 – 3313 7300
Email: thierry.lespiaucq@volkswagen.co.in

Mr. Vijay Kamath
Head of Legal & GRC
Tel: 022 – 3313 7014
Email: vijay.kamath@volkswagen.co.in

All information provided to the above personnel shall be treated as strictly confi-dential.
Employees may please note that the above policy provides for adequate safe-guards against victimization of Employees who avail of the vigil mechanism. However, false and frivolous complaints will entail firm disciplinary action against the concerned persons.

After receiving the information, the Ombudsmen will record every indication of corruption, white collar crime, etc. Ombudsmen will transfer the confidential information / evidence to the Anti-Corruption Officer after examination only if explicitly authorized by the whistle-blower. If requested, the whistle-blower's identity will be kept anonymous. If members of executive bodies or the Head of Group Internal Audit are alleged, the ombudsmen will forward the indication to the Chairman of the Audit Committee of the Volkswagen AG, Supervisory Board. As a lawyer, the Ombudsmen are bound by client confidentiality and identity of the whistle-blower is reliably protected and not disclosed to Volkswagen or to third parties.

The Anti-Corruption Committee assumes responsibility for the necessary investigation involving Group Internal Audit or Group Security. If internal investigations confirm the allegations then the relevant personnel are appropriately punished and may lead to severe consequences, including dismissal.

Wherever legally tenable, the ombudsmen are informed of the internal investigator's findings and can forward this information to the whistle-blower. In this way, everyone is kept informed.

If the whistle-blower / informant are personally involved in the corruption, the Ombudsmen can advise him and help breaking the vicious circle. By speaking, assisting during the investigation, the whistle-blower / informant will generally be handled more leniently by the legal system.

Yes, there is Business Platform Monitoring System which is a secured electronic platform for submitting confidential information. The system makes it possible to structurally and anonymously process information entered by the public and employees of a company. Whistle-blower can set up a mailbox within the application for written communication and the exchange of documents with the ombudsmen.