In accordance with the requirements of the German Corporate Governance Code, the Board of Management of the Volkswagen Group ensures that the statutory requirements and the Company’s internal policies are complied with and respected throughout the Group. Volkswagen’s sense of duty has always gone beyond statutory and internal requirements; obligations undertaken and ethical principles accepted voluntarily also form an integral part of our corporate culture and are at the same time the guiding principle on which we base our decisions. Our compliance activities are based on a Group-wide strategy, which embraces a preventive approach. These activities were driven forward in the Volkswagen Group during the reporting period.
The Code of Conduct introduced by the Volkswagen Group in 2010 was not only successfully integrated into many existing processes in the past year, but also implemented in a large number of companies. At the same time, the comprehensive, Group-wide compliance organization was further developed to support Group companies, locations and business units in promoting and ensuring compliance. We have appointed further chief compliance officers, compliance officers and compliance representatives at the brands and companies worldwide who are responsible for the implementation of measures and thus support the Group Chief Compliance Officer in his task of initiating, controlling and supervising preventive measures and ensuring that the rules are complied with. The Group Chief Compliance Officer reports directly to the Chairman of the Board of Management of Volkswagen AG.
Our compliance work is further supported by the existing compliance expertise in our corporate units: the Core Compliance Team, which comprises experts from Group Internal Audit, Security and Data Protection among others, meets regularly, and the Compliance Board started its work as a committee of opinion leaders at senior executive level during the reporting period.
In 2011, the compliance program activities were largely focused on preventive measures in the area of competition and anti trust law. Key measures included the direct call by the Chairman of the Board of Management, Prof. Dr. Martin Winterkorn, on management to internalize compliance, as well as the preparation of a large number of written information documents distributed to the senior managers and Group senior executives of Volkswagen AG, among others. During the second half of the year, target group-specific information events were held at which more than 1,800 employees in key areas received training. The compliance program was reinforced through the simultaneous use of internal communication channels.
In addition, information on compliance was provided to around 6,000 employees at close to 200 in-depth, on-site seminars in 2011. Participants ranged from new hires through vocational trainees, employees in direct and indirect areas of the Group and management trainees, up to members of senior management. In addition to these events, employees also regularly receive the latest information on all compliance-relevant issues through the internal communication channels. The information can also be downloaded from the intranet at any time.
Our compliance activities during the reporting period also focused on the implementation of measures to prevent corruption. The e-learning offering to help avoid conflicts of interest and corruption was made available to additional employee groups, after being offered to members of the senior management in an initial stage. More than 40,000 employees of Volkswagen AG and the Group brands have so far received training in this way. The implementation of online training programs to provide targeted education to employees is progressing in many Group companies and is a core component of our compliance work.
To ensure that persons wishing to provide information on suspected instances of corruption within the Group have a point of contact, in January 2006 Volkswagen AG established a global anti-corruption system with independent lawyers as ombudsmen and an internal Anti-Corruption Officer. In 2011, the ombudsmen passed on information provided by persons, whose details remained confidential, to Volkswagen AG’s internal Anti-Corruption Officer in 36 cases. All information is followed up.
Moreover, employees have the option to contact the compliance organization via an e-mail address. In addition to the line managers and contacts in the individual departments, this e-mail address is a further point of contact for all issues relating to compliance. This facility has been used to obtain advice and assistance more than 400 times.
The assessment and early identification of risks are part of the Group-wide, integrated approach consisting of governance, risk & compliance. As in the previous years, all relevant and current compliance issues underwent an internal risk assessment in 2011 in order to determine the themes for the 2012 compliance program. In view of the Group’s global growth, preventing corruption will be the key issue. A variety of preventive measures will be implemented, a cornerstone of which will remain employee education and information.