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Volkswagen Bank GmbH trading as Volkswagen Bank United Kingdom Branch anti-slavery and human trafficking statement for the financial year ended 31st December 2018
This statement is made pursuant to s.54 of the Modern Slavery Act 2015. It sets out the steps that Volkswagen Bank GmbH trading as Volkswagen United Kingdom Branch (“VW Bank UK”) has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within its business and supply chain.
VW Bank UK has a zero tolerance approach to any form of modern slavery. VW Bank UK is committed to acting in an ethical manner, with integrity and transparency in all business dealings and is committed to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within its business and supply chain.
VW Bank UK is the UK branch of Volkswagen Bank GmbH (registered as a branch at Companies House in England and Wales under branch number BR007842). Volkswagen Bank GmbH is part of the Volkswagen Group and its ultimate parent company is Volkswagen AG. VW Bank UK provides wholesale vehicle and corporate funding to the retailer network of Volkswagen Group United Kingdom Limited in the United Kingdom. VW Bank UK’s core business is the wholesale funding of Audi, Volkswagen passenger cars, Volkswagen Commercial vehicles, SEAT and Škoda vehicles. Wholesale funding is also available for MAN, Porsche, Bentley and Lamborghini vehicles.
The Volkswagen Group Code of Conduct
As part of the Volkswagen AG group of companies (the “Volkswagen Group”), VW Bank UK adheres to the Volkswagen Group Code of Conduct (“Code of Conduct”). The Code of Conduct is provided to VW Bank UK employees and provides guidance on proper conduct and support in overcoming legal and ethical challenges. Compliance with internationally recognised human rights is part of this and VW Bank UK attaches great importance to ensuring that its corporate activities and the activity of its employees are in keeping with values set out in such international conventions and guidelines on human rights.
The Code of Conduct is publicly available via the Volkswagen AG website here.
VW Bank UK expects its employees, retailers, suppliers and business partners and each of their employees to act responsibly and comply with the requirements of the Code of Conduct.
VW Bank UK has a whistleblowing policy intended to encourage and enable staff to report suspected wrongdoing and raise serious concerns within the workplace. VW Bank UK employees, business partners and other third parties are provided with internal and external contact points to report on legal and regulatory violations, including suspicions of human rights violations, in connection with the Volkswagen Group. VW Bank UK is committed to ensuring that any staff concerns are taken seriously and properly investigated.
Volkswagen Group has a whistleblowing system which is publicly available via the Volkswagen AG website (www.volkswagenag.com)
Qualification of employees
VW Bank UK treats it employees with respect and dignity and operates internal policies to ensure that it is conducting its business in an ethical and transparent manner. VW Bank UK policies and procedures are reviewed and updated on an annual basis and are available to staff and on-site contractors via its internal policy and procedure hub.
VW Bank UK’s recruitment policies ensure that employee screening checks are carried out to ensure that the individual is legally entitled to work in the United Kingdom to safeguard against human trafficking or individuals being forced to work against their will, and expects the same of each of its retailers, suppliers and business partners. Employees are free to leave their employment after reasonable notice and are not required to lodge deposits of money or identity papers with their employer. The compensation and benefits paid to employees for a normal working week comply at least with guaranteed minimum legal requirements, including minimum wage legislation and working hours comply at least with the national legal standards and are not excessive.
VW Bank UK suppliers
VW Bank UK does not act as a producer or manufacturer of physical goods and has no supply chain in relation to such activities. The majority of VW Bank UK’s business partners are located in the United Kingdom.
VW Bank UK requires its suppliers to comply with the Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for Business Partners) available via the Volkswagen Group website (www.vwgroupsupply.com) which formulates Volkswagen Group’s expectations towards the conduct of business partners in relation to central environment, social and compliance standards to ensure compliance with Volkswagen Group’s sustainability standards along the entire supply chain. The bases for these requirements are the principles of the UN Global Compact, the charter of the International Chamber of Commerce for viable long-term development, as well as the conventions of the International Labour Organisation.
All procurement is based on objective and fair criteria that reflect the principles of non-discrimination, equal treatment, transparency, procedural fairness, mutual recognition and proportionality. In addition to carrying out due diligence on prospective suppliers, as part of the tender process prospective suppliers are expected to confirm they are aware of Volkswagen Group’s sustainability requirements, their agreement to VW Bank UK’s contractual terms and conditions, and that they will comply with VW Bank UK’s policies and procedures and provide the services in accordance with all applicable laws and regulations. VW Bank UK expects its suppliers to exercise due diligence along their supply chains.
VW Bank UK considers compliance with the Code of Conduct to be essential to its contractual relationships with suppliers. VW Bank UK may end its relationship with a business partner if the business partner does not comply with these requirements or take alternative action if the business partner is able to prove to VW Bank UK’s satisfaction that it has implemented immediate countermeasures to prevent comparable violations occurring in future.
VW Bank UK has obligations in its agreements with suppliers requiring suppliers to comply with all laws including those relating to slavery and human trafficking to ensure that there is no trafficked, bonded, child or forced labour within their supply chain. VW Bank UK may terminate the relevant contract immediately if the business partner does not comply with these requirements.
Monitoring and audit
VW Bank UK conducts routine risk assessments of its business partners to identify risks presented in different segments and an escalation procedure is in place if serious issues are identified, which may include referral to VW Bank UK’s compliance function.
VW Bank UK monitors key suppliers at supplier performance review meetings and any necessary actions and issues, including non-compliance with the Code of Conduct or laws or regulations are tracked by the relevant operational area and reviewed at the next performance review meeting. VW Bank UK will work to remedy any areas in which suppliers do not meet VW Bank UK standards or do not comply with relevant laws or regulations. In addition, VW Bank UK has the right to audit suppliers for compliance with applicable laws, including the supplier’s obligations to comply with all laws relating to slavery and human trafficking.
Volkswagen Bank GmbH has an autonomous and independent internal audit function which has an unrestricted right to obtain information and to conduct audits within VW Bank UK to determine whether statutory obligations are being fulfilled and reports its findings to senior managers at VW Bank UK and Volkswagen Bank GmbH, and to directors of Volkswagen Bank GmbH. If there is any specific suspicion of violations of laws, employees are expected to inform internal audit.
This statement has been approved by Members of the Board of Management for Volkswagen Bank GmbH on 17th June 2019, who will review and update it as necessary on an annual basis.
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