Responding department: Sustainability and Political Communication
Stock Exchange Symbol: (VOW:GR)
Does your company have a publicly available commitment to respect human rights?
Yes, the Volkswagen Group publicly states its commitment to respect human rights within its Code of Conduct:[link].
References to Volkswagen's human rights commitment are also included in its supplier relations: [link].
The Group Guiding principles lay down the fundamental convictions and attitudes towards life: [link]
In addition to the Code of Conduct, the Volkswagen Group is committed to the United Nations Global Compact and has given a worldwide undertaking to uphold human rights, foster good working conditions and combat corruption. This also applies to all business relations of the Group and is stated within the Group sustainability report: [link].
In the “Declaration on Social Rights and Industrial Relations at Volkswagen” (Volkswagen Social Charter), the Charter on Labour Relations and the Charter on Temporary Work, Volkswagen professes its commitment to fundamental social rights and principles: [link] [link] [link].
New guideline on conflict minerals (German only): http://www.volkswagenag.com/content/vwcorp/info_center/de/publications/2016/06/konfliktrohstoffe-volkswagen-leitlinie-2016.bin.html/binarystorageitem/file/16-06-21_Leitlinie_Konfliktrohstoffe.pdf
How are human rights governed in your company?
To coordinate sustainability and corporate responsibility, including human rights, Volkswagen has put in place a clear structure. The Group Board of Management (Sustainability Board) is also the highest ranking sustainability body in the company. It is informed about corporate responsibility, sustainability and human rights issues by the Group CSR & Sustainability Steering Group and takes central decisions. Since 2006, the CSR & Sustainability Office is coordinating all sustainability-related activities within the Group and the brands. The activities of the Volkswagen Group are governed not only by strategic objectives, but also by own principles and values as well as voluntary undertakings, also with respect to human rights. The Volkswagen Group makes sure that its activities are in line with the Declarations of the International Labour Organization (ILO), the Guidelines and conventions of the Organization for Economic Cooperation and Development (OECD) and the UN international pacts on fundamental human rights and freedoms. For this purpose, Volkswagen has created its own framework in the Volkswagen Social Charter, the Charter on Labour Relations and the Charter on Temporary Work, all of which apply throughout the Group. For Volkswagen, the observance of internationally recognized human rights forms the basis of all business relations. Volkswagen also attaches great importance to ensuring that our corporate activities are in keeping with international conventions and guidelines. The main conventions of this kind are:
• The Universal Declaration of Human Rights, dating from 1948 (UNO)
• European Convention on Human Rights, 1950
• International Covenant on Economic, Social and Cultural Rights, 1966
• International Covenant on Civil and Political Rights, 1966
• Tripartite Declaration on Principles Concerning Multinational Enterprises and Social Policy, ILO (International Labour Organisation), 1977
• ILO Declaration on Fundamental Principles and Rights at Work, 1998 (especially the following topics: abolition of child labour, elimination of forced or compulsory labour, ban on discrimination, freedom of association and the right to collective bargaining)
• OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, 1997
• “Agenda 21” on sustainable development (final document of the ground-breaking United Nations Conference on Environment and Development, Rio de Janeiro 1992)
• Principles of the Global Compact for more social and more ecological globalisation, 1999
• OECD Guidelines for Multinational Enterprises, 2000
How are human rights managed within your company?
Volkswagen Group Internal Audit and Group Security regularly and systematically monitor compliance with the rules, carrying out random checks irrespective of any suspicion of non-compliance and investigating whenever breaches are actually suspected. The worldwide ombudsman system in place since 2006, can be used to report any breaches or suspicions in nine different languages to two external lawyers appointed by the Group. Prevention takes place through information and training. The requirements in the Code of Conduct for business partners set out the Group´s expectations concerning its business partners’ conduct with regard to central environmental and social standards and are based on documents such as the Principles of the UN Global Compact, the International Chamber of Commerce’s Business Charter for Sustainable Development and the relevant conventions of the International Labour Organization. The sustainability requirements for suppliers are binding. To raise employee awareness of compliance-related issues Volkswagen uses both, traditional communication channels such as employee magazines and information stands, and electronic media such as intranet portals, apps, blogs, audio-podcasts and online newsletters.
In 2013, over 200.000 employees across the Group took part in classroom and online courses on the topics of compliance in general, but also the Code of Conduct, human rights and combatting corruption. Online E-Learning programs and classroom training are firmly anchored in existing corporate processes. At Volkswagen, the completion of the online training module on the Code of Conduct is mandatory for all new employees. Since 2013, the Volkswagen Group’s E-Learning tool has also been available to suppliers to raise awareness among an unlimited number of employees. When Volkswagen receives information or the early warning system gives reason to suspect that tier 1 suppliers or their suppliers are failing to comply with Volkswagen's sustainability requirements or the answers to the sustainability questionnaire are not satisfactory, the party concerned is asked for a written statement using a standardized 6D Report. If the answers again prove unsatisfactory, Volkswagen takes further steps, such as the examination of documents, visits to the suppliers premises or other customized supplier development activities. These measures are coordinated by an ad-hoc expert team in Wolfsburg together with expert teams from the relevant brands and regions. The Volkswagen Group reserves the right to have compliance with the sustainability requirements verified by experts at the supplier´s premises during regular business hours. In the event of non-compliance with the sustainability requirements, however, Volkswagen will terminate business relations particularly if the supplier shows no interest in long-term improvement.
In 2014 the compliance agenda focused on the continuing expansion of the GRC organization, tightening compliance standards for the sales organization, international money-laundering prevention, and the handling of contracts for work or services. In addition, based on the “Volkswagen Group requirements regarding sustainability in its relationships with business partners” (Code of Conduct for Business Partners), supplier awareness of topics including human rights was increased. Business partners of the Volkswagen Group are subject to a Business Partner Check, a risk-oriented assessment of their integrity, also based on the “Volkswagen Group requirements regarding sustainability in its relationships with business partners” (Code of Conduct for Business Partners). To raise awareness of the importance of compliance, since 2010 all new employment contracts entered into between Volkswagen AG on the one part and both management staff and employees covered by collective agreements on the other have included a reference to the Code of Conduct and the obligation to comply with it. Completion of the online training module on the Code of Conduct is mandatory for all new employees. As of 2014, compliance with the Code of Conduct is one factor in calculating the variable, performance-based pay component.
By means of appropriate preventive measures integrated in our existing management system, we foster compliance with the rules within our organization and sharpen our employees’ awareness. However, we are also aware that the risk of individual misconduct can never be completely eliminated. To raise employee awareness of compliance-related issues we use both traditional communication channels such as employee magazines and information stands, and electronic media such as intranet portals, apps, blogs, audio-podcasts and online newsletters and guidelines. For example, our Anti-Corruption Guidelines are available to all employees, business partners and members of our governance bodies on the Volkswagen portal as well as the Internet.
Across all regions, 5,728 managers participated in classroom training and E-Learning programs on the topic of anti-corruption.
On the topic of human rights, more than 6,000 employees worldwide received in 128 hours of training distributed across 329 classroom training courses. In addition, employees can learn more about this topic using our online E-Learning programs.
On United Nations International Anti-Corruption Day, many Volkswagen locations held a variety of multi-channel activities related to corruption prevention. A film was also made for the event and shown internationally. In 2014 over 185,000 employees across the Group took part in 4,444 classroom and online courses on the topics of compliance in general, money laundering, the Code of Conduct, competition and antitrust legislation, human rights and combatting corruption. Online E-Learning programs and classroom training are firmly anchored in existing corporate processes. Employees of all brand companies and a large number of Group companies are able to obtain personal advice about compliance issues, usually by contacting the compliance organization via a dedicated e-mail address. In the fall of 2014, a letter specifically addressed to all employees of Group Security and Plant Security at Volkswagen AG once again called attention to the Group Code of Conduct, including its human rights requirements.
What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?
In cooperation with the Institute for Market, Environment and Society (imug) Volkswagen established a stakeholder panel, which has now been running for over 17 years. It follows the companies’ activities, especially our environmental and sustainability reporting activities, and produces a critical commentary every year. To this end, imug holds detailed interviews with a total of 33 representatives of different stakeholder groups. This evaluation helps to critically scrutinize and improve the reporting on sustainability and human rights, and also provides information about weaknesses in our Group-wide sustainability coordination. The brands Audi, MAN Volkswagen and Porsche have carried out their own – mostly very extensive – online surveys of their stakeholders, as have Volkswagen do Brasil and Volkswagen Financial services. Moreover, in 2013 all companies in the Volkswagen Group took part in the “Stimmungsbarometer” – an opinion survey for employees of the Volkswagen Group. This was the first Group-wide investigation of employee needs and interests. The Group also has a standardized procedure for communication with customers. Both the Volkswagen Group and the brands maintain an intensive dialogue with their stakeholders – their own employees, customers, suppliers, business partners and their local neighbors. This also includes a constructive exchange with public authorities and in most cases intensive long-term cooperation with organizations representing social and environmental interests. This is prompted by a desire not only to be a responsible corporate citizen but also to obtain insight into external perceptions of Volkswagen's own activities.
Priority human rights issues: What are some of the priority human rights issues for your company?
The company selected the following from a check list:
- Health (including environmental health, workplace health & safety)
- Workplace diversity / non-discrimination
- Forced labour and human trafficking (including in supply chains)
- Sexual harassment
- Access to water
- Freedom of association and trade union rights
- Freedom of expression and/or right to privacy / digital rights
- Conflict minerals
- Transparency in payments to governments / responsible tax practices
- Children (including child labour)
- Migrant workers
Actions on 'other' issues
Volkswagen's Global Works Council, Volkswagen's Board of Management, and the International Metalworkers' Federation signed the "The Declaration of Social Rights and Industrial Relations" in June 2002. The Declaration is a commitment by the company to improving workers' conditions across the supply chain. The Declaration covers ILO's four fundamental principles and rights at work: (1) Freedom of association and the effective recognition of the right to collective bargaining; (2) Elimination of all forms of forced or compulsory labour; (3) Effective abolition of child labour; and, (4) Elimination of discrimination in respect of employment and occupation.
In application of the Declaration's stipulations, Volkswagen has raised the awareness of its employees to the rights of migrant workers by developing programmes and training modules on diversity, equal opportunity and human rights. The Volkswagen Group attaches great importance to health protection and promotion for all our staff. This involves far more than simply preventing accidents at work and precautions against occupational sickness. Comprehensive health management ensures that employees remain fit and healthy. Prevention and provision are given a high priority. Various early diagnosis examinations, health promotion programmes and individual health coaching are available for the well-being of the workforce. Detailed information is provided about potential accident hazards at the workplace. With the declaration of social rights and industrial relations at Volkswagen, the company has expressly committed itself to the Group objective of guaranteeing healthy working conditions at all its site.
How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?
Group Sustainability Report: [link]
Annual Report 2013: Sustainable Value Enhancement [link]
Newsletter and Employee Magazines
Sustainability Report 2014: http://www.volkswagenag.com/content/vwcorp/info_center/en/publications/2015/04/group-sustainability-report-2014.bin.html/binarystorageitem/file/Volkswagen_Sustainability_Report_2014.pdf
Microsite Sustainability: http://sustainabilityreport2014.volkswagenag.com/node/2048
What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?
Two highly-respected lawyers act as independent ombudsmen. Any employee, business partner or third party who suspects corrupt practices can send their complaint to the ombudsmen. All information is treated in the strictest confidence and the identity of anyone disclosing information is kept strictly anonymous, the ombudsmen are bound by the oath of professional secrecy. Since 2014, the ombudsmen system has also an online contact channel. In this way, any employee, business partner or third party can contact the ombudsmen and inform about any breaches or their suspicions regarding corruption and other economic crimes, which includes possible breaches of human rights. In addition, Volkswagen has set up a central email address for complaints regarding actual or suspected violations of human rights in the supply chain.
Group Internal Audit regularly and systematically reviews processes within the Company, using approaches such as the internationally recognized COSO Enterprise Risk Management framework. It also carries out random checks irrespective of any suspicion of non-compliance and investigates whenever breaches are actually suspected.
The worldwide ombudsman system in place since 2006 can be used to confidentially report corruption, fraudulent activities, or other serious irregularities (such as human rights violations or ethical misconduct) in ten different languages to two external lawyers appointed by the Group. Naturally, the people providing the information need not fear being punished by the Company for doing so. As of December 2014, there is also the option of using an additional online channel to communicate with the ombudsmen. A technically secure digital mailbox allows suspected breaches to be reported – anonymously, if so desired. In 2014, the ombudsmen passed on 51 reports by people – whose details remained confidential if requested – to the Volkswagen Group’s Anti-Corruption Officer, the Head of Group Internal Audit. In addition, the Anti-Corruption Officer received information on a further 89 cases directly. One case was identified by the person reporting it as a possible human rights violation. During local internal audits of the brands and Group companies, 365 reports of suspected fraud were submitted. All information is followed up. All breaches of the law or internal regulations are appropriately punished. In 2014 action was taken against a total of 132 employees across the Volkswagen Group as a result of findings of investigations based on information received. In 72 of these cases worldwide, the employee’s contract was terminated. Moreover, during the reporting year, 16 contracts with business partners were terminated or not renewed because of infringements related to corruption.
The basis for the auditing program of Group Internal Audit and of 19 other local audit functions at the brands and affiliated companies is provided by a risk-oriented assessment of the Group’s core business processes. The business processes of all Volkswagen Group companies are systematically classified in terms of risks which, from the point of view of the auditors, are relevant to the audit. The topics with the highest risk levels are integrated into the auditing programs. In 2014 a total of 1,723 audits were conducted at 304 companies. Among other things, the audits also examine internal control mechanisms for the prevention of corruption (four-eye principle, segregation of functions), the existence of compliance guidelines and preventive measures.
Another aspect of the audit function is advising the specialist areas of the Volkswagen Group. In particular, this helps define processes and ensures they are designed in compliance with internal standards and can be applied worldwide.
In addition, Group Internal Audit has set up a Continuous Monitoring unit. It is tasked not least with supporting the effectiveness of the internal control system, based on structured data analysis of the financial systems. This allows potential weak spots to be discovered quickly, preventing major damage from occurring.
Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?
Since 2002, the Volkswagen Group is an active participant of the United Nations Global Compact with a GC Advanced level. With the aim to promote good governance in mineral-producing countries by disclosing information relating to payment flows, Volkswagen signed up to the Extractive Industries Transparency Initiative (EITI). Furthermore, Volkswagen is a member of CSR Europe, the European Business Network for Corporate Social Responsibility. Within CSR Europe, Volkswagen is one of the project leaders on Business & Human Rights. The project focuses on practical guidance on how to embed human rights throughout departments, and how companies can effectively address internal and external human rights complaints. On the local level, the Volkswagen Group is for example a member of the Forum for Sustainable Development of German Business (econsense). econsense also works on the topic of Business and Human Rights, discussing practical questions regarding the responsibility to respect and collectively developing management approaches with the member companies.
Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.
In the long term, a company can only be successful if it acts with integrity, complies with statutory provisions worldwide and stands by its voluntary undertakings and ethical principles. At Volkswagen, compliance means playing by the rules. It is a cornerstone of sustainable business – a view expressly shared by the Company’s management. Volkswagen adopts a preventive compliance approach and fosters a corporate culture that stops potential breaches before they occur. Group Internal Audit and Group Security as well as the Human Resources and Group Legal departments are responsible for the necessary investigative measures and responses. The guidelines laid down in the Volkswagen Group’s Code of Conduct are of essential importance here. These have been communicated at all consolidated brand companies and can be accessed by all Group employees via the Volkswagen portal. By now, 14 Chief Compliance Officers, 175 Compliance Officers and 500 employees in 49 countries safeguard Volkswagen's integrity.
Since 2010, all new employment contracts entered into between Volkswagen AG on the one part and both management staff and employees covered by collective agreements on the other have included a reference to the Code of Conduct and the obligation to comply with it. The integrity of Volkswagen Group suppliers is systematically examined through a Business Partner Check based on the Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for business partners). These requirements were revised in 2013.
What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?
The year 2015 will be politically and economically challenging. Political changes in for Volkswagen relevant markets lead to considerable challenges, also regarding the management of human rights issues.
The year 2016/17 will be politically and economically challenging, also regarding the management of human rights issues