Volkswagen Financial Services is bound not only by legal and internal requirements. Commitments that the Company has made voluntarily as well as ethical standards are likewise an integral part of our corporate culture and serve at the same time as the guidin principle for our decision making.

Compliance is a basic requirement for sustainable business. The Board of Management of Volkswagen Financial Services AG therefore ensures that both legal requirements and internal guidelines within the Volkswagen Financial Services AG subgroup are complied with. This is monitored by Supervisory Board.

Our compliance activities are based on a Group-wide compliance strategy, which follows a preventive approach. This means that we make our employees and business partners aware of the relevant topics, train them and, where necessary, make them give contractual undertakings.

Code of Conduct 

The Volkswagen Group’s Code of Conduct, which also applies throughout the Volkswagen Financial Services subgroup, is a key document in this context. Employees receive the relevant training by attending events or completing online training programs; printed and digital copies of the Code of Conduct are distributed to them. Suppliers are obligated to meet the Volkswagen Group’s sustainability requirements in their relationships with business partners (Code of Conduct for Business Partners).

The Volkswagen Group has a worldwide anti-corruption system with independent attorneys acting as ombudsmen and an internal anticorruption officer. Volkswagen Financial Services AG has joined this system. The ombudsman system is a worldwide platform through which employees and third parties can report breaches of legal provisions – in particular corruption and other criminal activities. Two external lawyers ensure that any reported case is investigated further and guarantee the anonymity of the whistleblower.

In order to combat corruption risks, Volkswagen Financial Services AG also has a set of framework instructions to guide employees. Articles are published on the intranet and special information events are held on a regular basis to raise awareness.

To minimize compliance risks, clear rules are provided in the form of written instructions – for example on the issue of antitrust law. The departments concerned have an obligation to raise awareness among their employees, specifically about the provisions of antitrust law. In case of doubt or queries, employees have the opportunity to obtain advice on compliance by contacting Compliance employees by phone or by e-mail.

Within the subgroup, regular exchanges with the local compliance officers in the foreign branches and subsidiaries are becoming an increasingly important aspect of compliance work. Risk-based on-site checks support the local colleagues in the implementation of Groupwide standards (especially on the prevention of money laundering and other criminal activities as well as the compliance function).