Whistleblower System

1. Our Whistleblower System

Complying with statutory regulations and internal rules, and the principles laid down in our Code of Conduct and the Code of Conduct for Business Partners, has top priority at Volkswagen Digital Solutions (“VWDS”). The success of our company is based on Integrity and Compliance. To meet these standards, it is important to learn of potential employee or supplier misconduct and to put a stop to it. Therefore, we entrusted the Central Investigation Office to operate an independent, impartial and confidential Whistleblower System on our behalf.

A key pillar of our Whistleblower System is the principle of procedural fairness. It also guarantees the greatest possible protection for whistleblowers, persons implicated and employees contributing to the investigation of reported misconduct.

This also includes offering opportunities for anonymous reporting and communication.

We assure not to perform any steps in order to identify anonymous whistleblowers who do not misuse our Whistleblower System.

Retaliation of whistleblowers and all persons who contribute to investigations at VWDS will not be tolerated.

Persons implicated are presumed innocent until the violation is proven.

Investigations will be conducted with the utmost confidentiality.

The information will be processed in a fair, fast and protected process.

How do we process your report?

The qualified and experienced colleagues at the Investigation Office examine every report for potential misconduct by a Volkswagen Group employee thoroughly and follow it up systematically.

First, you will get a confirmation of receipt. The Investigation Office then assesses your report. This includes gathering facts particularly from the whistleblower. Only if this initial evaluation shows grounds for suspicion of a violation an investigation by a dedicated Investigating Unit will be started.

Afterwards, the results of the investigation will be assessed by the Investigation Office and appropriate measures will be recommended.

Information about the status* and the outcome of the procedure will be given to you without undue delay.

Potential violations of the Code of Conduct for Business Partners by suppliers, including serious risks and violations of human rights and environment by direct and indirect suppliers, can also be reported to the Investigation Office – as well as reports requiring otherwise immediate action.

The Investigation Office will inform the responsible departments, who will process the issue accordingly. This particularly includes taking the necessary measures to minimize or end violations and/or risks.

More information on the respective procedural principles can be found here.

*The processing time varies depending on the subject of the procedure.

2. What kind of report do you want to submit?

A complaint about products or services to our customer service:

For complaints or feedback about services of  VWDS or our business partners (e.g. car dealerships, workshops), please contact SIVA Customer Care:


Please understand that we will not be able to forward your request or take any action for reasons of responsibility.

A report of potential misconduct to our Whistleblower System:

The Whistleblower System offers various channels for reporting potential misconduct by VWDS’ employees, violations of the Code of Conduct for Business Partners or serious risks and violations of human rights and environment in our Supply Chain.

However, this does not affect the statutory right to contact designated authorities, as described further (“External Reporting Channel”).

E-mail

The Investigation Office of VWDS can be reached via e-mail (in any language): io@volkswagen.de 

For customer complaints, please contact the channels listed under “A complaint about products or services to our customer service”.

Postal address

Central Investigation Office Volkswagen AG

Central Investigation Office
Mailbox 1717

Berliner Ring 2, 38436 Wolfsburg, Germany

In person            

Please make an appointment in advance by writing an e-mail to io@volkswagen.de.                                       

Ombudspersons

VWDS has appointed external lawyers to act as Ombudspersons. They advise on the Whistleblower System or ensure that reports from whistleblowers are forwarded anonymously to the Investigation Office if desired.

If you want to get in contact with the Ombudsperson you can find their contact details here.

Online Reporting Channel

You have the option of using a web-based communication platform to contact the Investigation Office in more than 65 languages.

This system is confidential and technically secured and allows you to submit reports anonymously.

You can access the online reporting channel through the following link: https://goto.speakup.report/volkswagen 

You can find instructions on how to make reports online, by app or by phone here.

Voice Intake by phone

You can leave us a voice message by phone 24 hours a day, 7 days a week.

After entering the phone number (specific to the country you are in), you will be prompted to enter the organization code. Then, you can submit your report as a voice recording.

Only a written transcript will be received by the Investigation Office.

Dial back in to listen to the reply or further questions by our team.

1. Please call 800 831 302

2. Have the organizational code 122203 ready

ATTENTION: If you are outside of Portugal, you can select a phone number from this list for the country or region you are in.

Speak Up App

You can also download the Speak Up App “SpeakUp – Listen for a change“ by People Intouch (personal devices only) to access the secure reporting system. Through this app, you can submit your report in writing or leave a voice message (also anonymously). You will need the organization code 122203. Log back in to see our team’s reply or answer further questions.

To download the app, you can also scan the QR code:

3. Do you have any questions, or do you need a local contact?

Questions or suggestions for improvement concerning the Whistleblower System can also be addressed to the Investigation Office.

Furthermore, our local Compliance function ​can also be addressed in all matters of the Whistleblower System via compliance@vwds.pt.

4. External Reporting Channel

Protection of Whistleblowers – Portuguese legal landscape – Law No. 93/2021 of December 2021 (General Regime for the Protection of Whistleblowers – “RGPDI”).

    1. Legal Framework

    1.1 Offences Covered

    Offences include acts or omissions that violate:

    • Acts or omissions contrary to Directive (EU) 2019/1937, to national rules implementing, transposing or complying with it, in areas such as public procurement; services, financial services; product and transport safety and compliance; environmental protection; radiation protection and nuclear safety; food and animal safety; public health; consumer protection; protection of privacy and personal data and security of network and information systems;
    • Acts or omissions contrary to and detrimental to the financial interests of the European Union;
    • Acts or omissions contrary to internal market rules, including competition and state aid rules, and corporate tax rules
    • Failure to comply with rules on violent, especially violent and highly organised crime, including measures to combat organised and economic and financial crime.

    1.2 Object of Report or Public Disclosure

    Reports can cover offences that have occurred, are occurring, or are likely to occur, including attempts to conceal such offences.

    1.3 Definition of Whistleblower

    A whistleblower is any natural person who reports or publicly discloses an infringement on the basis of information obtained in the course of his or her professional activity, regardless of the nature of that activity and the sector in which it is carried out.

    This includes:

    • Employees (private, social, or public sector)
    • Service providers, contractors, subcontractors and suppliers, as well as any persons acting under their supervision and direction;
    • Shareholders and persons belonging to administrative or management bodies or to tax or supervisory bodies of legal persons, including non-executive members;
    • Volunteers and interns, paid or unpaid.

    Whistleblowers are protected if they report in good faith, believing the information to be true. Anonymous whistleblowers who are later identified also receive protection.

    1.4 Rights and Warranties

    • The identity of the whistleblower, as well as the information that, directly or indirectly, allows his or her identity to be deduced, is confidential and is only disclosed by legal obligation or court decision.
    • Personal data irrelevant to the report is deleted immediately.
    • Whistleblowers are protected from retaliation. The concept of retaliation includes threats and attempts.
    • Acts of retaliation are considered to be changes in working conditions, suspension, non-conversion of a fixed-term employment contract into an open-ended contract, non-renewal of a fixed-term employment contract, dismissal and negative performance evaluations, etc.

    1.5 Protection of the Whistleblower

    Protection measures include:

    • Prohibition of retaliation
    • Legal support

    2. Submission of a Report

    2.1 Anonymity

    Internal reporting channels ensure the confidentiality and integrity of complaints, protecting the identity of whistleblowers and third parties.

    2.2 Reporting Channels

    Reports can be made internally, externally, or publicly disclosed under certain conditions:

    • Internal Reporting: Preferred method, unless specific conditions justify external or public reporting.
    • External Reporting: Used if internal channels are unavailable, ineffective, or if there is a risk of retaliation.
    • Public Disclosure: Allowed if there is an imminent danger to the public interest or if previous reports have not led to appropriate measures.

    2.3 Internal Reporting Channels

    VWDS offers multiple internal channels – please see point 2 of “Whistleblower System” (“What kind of report do you want to submit?”).

    2.4 Internal Reporting Channels – Guarantees

    Although we entrusted the Central Investigation Office to operate our internal whistleblowing channel, this is still of the responsibility of the Compliance department of VWDS. This department ensures the existence of an independent, impartial, and confidential reporting system.

    3. Handling Reports

    3.1 Handling Internal Reports

    Required steps:

    • Acknowledge receipt within seven days.
    • Inform the whistleblower of the process and potential external authorities.
    • Investigate and take appropriate actions.
    • Communicate measures taken within three months.

    3.2 Handling External Reports

    External complaints are submitted to authorities which, in accordance with their tasks and competences, must handle the matter at issue in the report, including:

    • The Public Prosecutor’s Office;
    • Criminal police bodies;
    • Banco de Portugal;
    • Independent administrative authorities;
    • Public institutes;
    • General inspections and similar entities and other central services of the direct administration of the State with administrative autonomy;
    • Local authorities; and
    • Public associations.
    Whistleblower System Explanation – PTDownload