What kind of information can be reported through the Ombudsman System & Vigil Mechanism Committee?
One can confidentially report any information on acts of economic crime, corruption or any other serious non-compliance in terms of code of conduct or compliance policies (hereinafter referred to as “information”) of the Volkswagen Group or one of its brands.
Can customer complaints or complaints/correspondence/information on Sales, After Sales or service related queries also be reported to the Ombudsman System & Vigil Mechanism Committee?
Please note that instances of customer complaints are not to be reported in this system as another mechanism for this already exists. For any Sales or After Sales service related queries, please email at email@example.com. Any communications on above mentioned topics shall not be acknowledged, attended or replied by the Ombudsman or Vigil Mechanism Committee.
How can whistle-blower contact the Ombudsmen?
There are various ways for the whistle-blower to contact the ombudsmen. They can be contacted either by telephone or fax or email or letter. Furthermore, it is also possible to set up confidential one-on-one meetings.
The contact details of the Ombudsmen and Volkswagen Group’s Anti-Corruption Officer are as follows:
Dr. Rainer Buchert (Lawyer)
Phone: +49 (0) 61 05 92 13 55 or
+49 (0) 69 71 03 33 30
Fax: +49(0) 69 71 03 44 44
Thomas Rohrbach (Lawyer)
Phone: +49 (0) 69 65 30 03 56
Fax: +49(0) 69 65 00 95 23
Link to Online Platform: www.ombudsmen-of-volkswagen.com
VOLKSWAGEN GROUP ANTI-CORRUPTION OFFICER
Mrs. Hiltrud Werner
Phone: +49 (0) 5361-923488
The Chief Audit Executive of Volkswagen Group India can also be contacted for sharing such information.
Mr. Ferdenain Sauls
Vice President - Internal Audit
Volkswagen India Private Limited
Phone: +91(0) 3566 1008
In addition to the above, the Board of Directors of Volkswagen Group Sales India Private Limited, in their Board meeting held on September 14, 2016, have confirmed that the Vigil Mechanism Committee will be headed by Mr. Thierry Lespiaucq, Managing Director for the purpose of looking into and addressing all concerns pertaining to corruption and fraud related topics, including those reported by any employee. Mr. Vijay Kamath (Legal & GRC) shall be the Committee Member alongside Mr. Lespiaucq.
The contact details of the Committee Members are as follows:-
Mr. Thierry Lespiaucq
Tel: 022 – 3313 7300
Mr. Vijay Kamath
Head of Legal & GRC
Tel: 022 – 3313 7014
All information provided to the above personnel shall be treated as strictly confidential.
Employees may please note that the above policy provides for adequate safeguards against victimization of Employees who avail of the vigil mechanism. However, false and frivolous complaints will entail firm disciplinary action against the concerned persons.
How does the information exchange with the Ombudsman work?
After receiving the information, the Ombudsmen will record every indication of corruption, white collar crime, etc. Ombudsmen will transfer the confidential information / evidence to the Anti-Corruption Officer after examination only if explicitly authorized by the whistle-blower. If requested, the whistle-blower’s identity will be kept anonymous. If members of executive bodies or the Head of Group Internal Audit are alleged, the ombudsmen will forward the indication to the Chairman of the Audit Committee of the Volkswagen AG, Supervisory Board. As a lawyer, the Ombudsmen are bound by client confidentiality and identity of the whistle-blower is reliably protected and not disclosed to Volkswagen or to third parties.
What happens to the information that has been passed on?
The Anti-Corruption Committee assumes responsibility for the necessary investigation involving Group Internal Audit or Group Security. If internal investigations confirm the allegations then the relevant personnel are appropriately punished and may lead to severe consequences, including dismissal.
Will the whistle-blower be given feedback on further procedure of the investigation?
Wherever legally tenable, the ombudsmen are informed of the internal investigator’s findings and can forward this information to the whistle-blower. In this way, everyone is kept informed.
What happens if the whistle-blower / informant are personally involved in the corruption?
If the whistle-blower / informant are personally involved in the corruption, the Ombudsmen can advise him and help breaking the vicious circle. By speaking, assisting during the investigation, the whistle-blower / informant will generally be handled more leniently by the legal system.
Is there any other additional communication channel for reporting such information?
Yes, there is Business Platform Monitoring System which is a secured electronic platform for submitting confidential information. The system makes it possible to structurally and anonymously process information entered by the public and employees of a company. Whistle-blower can set up a mailbox within the application for written communication and the exchange of documents with the ombudsmen.