Volkswagen Bank GmbH trading as Volkswagen Bank United Kingdom Branch anti-slavery and human trafficking statement for the financial year ended 31st December 2023
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 Bank United Kingdom Branch (“VW Bank UK”) has taken, for the financial year ended 31st December 2023 (covering the period 1st January 2023 - 31st December 2023), 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.
Organisation
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 and fleet funding for vehicle rental businesses based 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 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 embodies the ethical principles of the Volkswagen Group and is based on shared values. It focuses on honesty, integrity, compliance and ethical behaviour as well as responsibility. 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 helps employees observe existing company rules at their workplace, as business partners and as members of society, providing them with practical guidance, assistance and advice. The rejection of all forms of modern slavery and human trafficking is an integral part of the Code of Conduct. In addition, we base our actions on the principles of the UN Global Compact, the OECD Guidelines for Multinational Enterprises and the requirements of the International Labour Organisation (ILO).
The Code of Conduct is available at all times to all employees on the Intranet and also to third parties and the public via the Volkswagen AG website (The Code of Conduct of the Volkswagen Group | Volkswagen Group (volkswagen-group.com)) and is continuously communicated in digital and print media as well as at internal company events. Regular training on the Code of Conduct is mandatory for all employees, regardless of their hierarchical level. Additionally, members of senior management confirm their knowledge and responsibility with regard to the Code of Conduct each year, based on the risks that affect them.
The Volkswagen Group has also specially formulated the Code of Conduct for Business Partners. This details the Group’s expectations regarding the attitude and conduct of business partners in their corporate activities, particularly with regard to suppliers and sales partners. The requirements are regarded as the basis for successfully shaping the business relationship between the Volkswagen Group and its partners. They include observance of human rights, such as the prohibition of child labour, human trafficking and slavery, as well as ensuring environmental protection and preventing corruption. The requirements for business partners were revised in 2022 and amended to include the requirements of the German Act on Corporate Due Diligence Obligations in Supply Chains.
In addition to the Code of Conduct for Business Partners, there are further product-specific requirements to which suppliers must adhere. These are set out in specifications and prescribe how certain products are to be produced. For example, the specifications state that there has to be full disclosure of the supply chain for cobalt for battery cells. Such requirements are also binding for the affected suppliers.
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 at all times.
No forced labour
The Volkswagen Group completely rejects forced labour and all forms of modern slavery including human trafficking. In particular, this includes work performed involuntarily by people under threat or penalties or other disadvantages (such as debt bondage or involuntary prison labour). Employment relationships must be voluntary and employees are able to give notice to leave their employment at any time in observance of reasonable notice periods.
Volkswagen Group Whistleblower System
The Whistleblower System is responsible for reporting Serious Regulatory Violations. The violation of human rights is an example of circumstances that, in principle, constitute a Serious Regulatory Violation. Potential violations of the Code of Conduct for Business Partners (including reports on serious risks and violations regarding human rights and the environment) whether occurring within the Volkswagen Group or at direct and indirect suppliers, can also be reported to the Whistleblower System.
Employees, as well as business partners and customers, have the opportunity to report misconduct by employees or suppliers around the clock, 365 days a year. Written reports can be submitted in all languages in a specially protected online reporting channel and by e-mail. Information can be reported in a total of 8 languages via an international 24-hour telephone hotline. In addition, information can also be submitted in person or through commissioned external lawyers (ombudsmen). If desired, reports can be made anonymously in all channels. Strict confidentiality and secrecy apply throughout the process. The Whistleblower System guarantees the highest possible protection both for whistleblowers and all persons who contribute to investigating and remedying misconduct and violations of the rules. Discrimination against whistleblowers and contributors is in principle a Serious Regulatory Violation and will not be tolerated. At the same time, the Whistleblower System safeguards the interests of the persons implicated and the presumption of innocence applies to the persons implicated as long as a violation is not proven.
Details of the Volkswagen Group whistleblowing system are publicly available via the Volkswagen AG website at Ethics, Risk Management & Compliance | Volkswagen Group (volkswagen-group.com).
Risk analysis
Matters such as risk assessments regarding human rights can be recorded in the established Risk Management and Internal Control System (ICS) processes.
Material business risks are regularly recorded, assessed and followed up with the required countermeasures as part of the quarterly risk process. Control activities are carried out within the annual standard ICS process to minimise litigation risks in material business processes within the Volkswagen Group and are tested for their effectiveness. A standardised risk catalogue is used for this which includes clearly defined control targets. These activities include checks on the specific content of agreements in the supply chain (incl. requirements regarding human rights) and compliance with legal and in-house specifications regarding human rights in the standard ICS. Reports are sent to the applicable boards of management and the Audit Committee on a quarterly and annual basis or when the need arises. These reports can also contain risks and material weaknesses in the area of human rights if the degree of materiality for reporting is met.
The Volkswagen Group has sustainably integrated the topic of business and human rights into its established compliance management system. All active controlled Volkswagen Group companies with their own employees take part in the standardized internal compliance risk management process. Group Compliance made risk assessments in the field of human rights for 805 companies around the world. This means that 100% of the Volkswagen Group controlled companies within the scope of compliance in a total of 82 countries were audited. This risk analysis incorporates the results and risk assessments of the previous year. In the reporting year itself, 51 risk assessments were made of companies that were added to the scope of compliance from a total of 18 countries. This analysis assessed business units’ human-rights risk situation and, as a result, these are allocated to either low, medium or high categories. These companies were then given risk-specific measures. The measures must be implemented for all companies in the scope on the basis of their risk profile. The status of implementation of the respective measures is continuously monitored within the Volkswagen Group. In the reporting year, adjustments to the compliance risk management process were prepared in order to fully comply with the requirements of the German Supply Chain Due Diligence Act (LkSG), which entered into force on 1 January 2023. These adjustments were applied in 2023.
Qualification of employees
Preventive measures promote compliance within the Volkswagen Group and raise compliance awareness among employees. Target group-oriented communication and training for employees at all hierarchical levels plays a key role in this. The Volkswagen Group reported on the Code of Conduct, anti-corruption and the Whistleblower System throughout the entire reporting year. Correspondingly, obligatory training courses on these topics rolled out across the Volkswagen Group were implemented in line with the defined repetitive cycles for the specific employee groups (such as employees in procurement, members of local management). In addition, the Volkswagen Group also trains its business partners in procurement and sales on key aspects of compliance and anti-corruption. The Volkswagen Group also continues to pursue the communication strategy it developed the previous year in order to increase transparency in human rights. 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 suppliers 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 at Integrity & Compliance | Volkswagen Group (volkswagen-group.com) which formulates VW Bank UK’s expectations towards the conduct of business partners in relation to central environment, social and compliance standards to ensure compliance with VW Bank UK’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. We review and develop our suppliers’ sustainability performance on an ongoing basis. This includes various measures such as the SAQ self-assessment questionnaire developed by the Initiative DRIVE Sustainability, sustainability as part of quality audits and focused sustainability audits of suppliers.
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 enforceable 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 and business suppliers.
Sustainability requirements for our suppliers
In the reporting year, we also adjusted our management approach in procurement to meet the requirements of the new German Supply Chain Due Diligence Act (LkSG). The previous approach of “prevent, detect, react” was replaced by the responsible supply chain system (ReSC system). The new approach has the aim of avoiding and minimizing human-rights, social or environmental risks along the Volkswagen Group’s supply chain based on a systemic risk analysis. It should also help to mitigate breaches and continuously improve suppliers’ sustainability performance. The ReSC system includes the following elements, which build on each other:
• Risk Analysis: A regular risk analysis serves to identify risks in the Volkswagen Group’s supply chain in advance. The analysis is made on the basis of the suppliers’ business models and takes account of internal and external data on human-rights and environmental risks. Based on the assessment of the risks, each supplier is allocated a low, medium or high sustainability risk. For suppliers with a low sustainability risk, a country risk score is additionally used. If the supplier has an increased country risk, it is upgraded to the medium risk category. The risk analysis is updated once a year and/or as required by Group Procurement Sustainability in consultation with relevant parent companies of the Volkswagen Group.
• Standard measures: These proactive and reactive measures include the Code of Conduct for Business Partners, the supply chain grievance mechanism, media screenings, the sustainability rating and training suppliers and employees.
• Deep Dive measures: These encompass the human rights focus system in the supply chain, the raw material due diligence management system and collaboration with external partners to develop the concept of sustainability in the supply chain.
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 regularly 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 13.06.2024, who will review and update it as necessary on an annual basis.
