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?
AA 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:
- E-mail: apoio.clientes@siva.pt
- Website: https://www.siva.pt/#/
- Phone: 808 30 89 89
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”).
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.
After entering the telephone number and the organizational code, a report can be given as a voice recording via Voice Intake. 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.
Speak Up App
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 800 831 302, you will be prompted to enter the organization code (122203). 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.
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?
Do you have further 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:
- EU rules (as per Directive (EU) 2019/1937)
- National laws implementing these EU rules
- Areas such as public procurement, financial services, product safety, transport safety, environmental protection, radiation protection, food and animal safety, public health, consumer protection, data privacy, and IT security
- Financial interests of the EU
- Internal market rules, including competition and corporate taxation
- Organized crime and economic-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 anyone who reports an offence based on information obtained through their professional activities. This includes:
- Employees (private, social, or public sector)
- Service providers, contractors, subcontractors, and suppliers
- Shareholders, management, and supervisory bodies
- Volunteers and trainees (paid or unpaid)
- Individuals involved in recruitment or pre-contractual negotiations
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
- Whistleblower identity is confidential and only disclosed by legal obligation or judicial decision.
- Personal data irrelevant to the complaint is deleted immediately.
- Whistleblowers are protected from retaliation, including changes in work conditions, suspension, dismissal, and negative performance reviews.
1.5 Protection of the Whistleblower
Protection measures include:
- Prohibition of retaliation
- Legal support
Retaliation includes any unjustified harm in a professional context, presumed if occurring within two years of the report.
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
Internal channels are managed by the Compliance department, ensuring an independent, impartial, and confidential reporting system.
3. Handling Reports
3.1 Handling Internal Reports
- 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.