Whistleblower System

Complying with statutory regulations and internal rules is top priority at Volkswagen Bank and we are committed to the highest standards of openness, propriety and accountability. In line with that commitment we encourage our employees to come forward with any serious regulatory concerns on the basis of having reasonable suspicion.

It is important to Volkswagen Bank that any fraud, misconduct or wrongdoing is reported and is properly dealt with.

Whistle-blowing is where legitimate concerns are raised which are considered to be in the public interest and relates to the following types of concerns:

• A criminal offence;
• A miscarriage of justice;
• An act which presents a risk to health and safety;
• An act causing damage to the environment;
• A breach of internal regulation e.g. Code of Conduct or contractual obligations
• A breach of other legal/ regulatory obligation;
• Concealment of any of the above

It is not necessary for the person raising the issue to have proof that the act is being, has been or is likely to be committed – a reasonable belief is sufficient. Once the issue has been raised, Volkswagen Bank will investigate the matter fully and take appropriate action where required.

Volkswagen Bank therefore encourages all individuals to raise any concerns that they may have about the conduct of others in the company, or the way in which the business is run.

It is understandable that Whistle-blowers, persons implicated and employees contributing to an investigation may be worried about possible repercussions.  Volkswagen Bank can provide assurance that an investigation is only initiated after very careful examination of the facts and reasonable suspicion of a regulatory violation. There will be strict confidentiality and secrecy throughout the investigative process. Information will be reviewed fairly, promptly and in a sensitive manner.  Whistle-blowers who raise a genuine concern will not receive any detrimental treatment as a result of raising a concern in good faith and will be supported even if they turn out to be mistaken.

Anyone raising a whistle-blowing concern can report this anonymously as well as have their personal information removed at a later date, if the request is accepted. We can only remove any reference to your personal data and will not delete the submission in its entirety where it relates to other individuals. Volkswagen Bank has a regulatory obligation to investigate any allegations of wrongdoing and must maintain our records in order to do so.

Please be advised that the Whistle-blower System cannot be used to process customer complaints.