Corporate Culture

Sustainable, responsible and transparent corporate governance is a top priority for the Volkswagen Group.

Material impacts and their interaction with strategy and business model

Interaction with strategy and business model

The impact in the area of corporate culture identified in the materiality assessment has an effect on the Volkswagen Group’s strategy and business model. The topic of corporate culture is anchored at an overarching level in the Group sustainability strategy regenerate+. The Volkswagen Group uses various actions in the area of corporate culture to emphasize the influence of its material impact on its business model and strategy. In this respect, the focus of this chapter is on topics relating to integrity and compliance (I&C), such as the Code of Conduct and risk-based packages of actions, e.g. awareness and training initiatives, tone-from-the-top actions, the Group Essentials in conjunction with the Role Model Programme and myVOICE (formerly known as the Stimmungsbarometer).

Policies: Corporate culture

Code of Conduct and Volkswagen Group Essentials

Integrity and compliance are the basis for correct and value-oriented conduct at the Volkswagen Group. We have set out the relevant guidelines in the Code of Conduct and the Group Essentials. The Code of Conduct forms the ethical and values-based foundation for acting with integrity and in a compliant manner in the Volkswagen Group. It serves as the main tool for promoting awareness of responsible conduct and decision-making, can be used as an aid in forming opinions and names contact persons. It is binding for all Group brands and companies. The Code of Conduct is based on international conventions and declarations, particularly the International Bill of Human Rights, the Fundamental Conventions of the International Labour Organization (ILO), and the United Nations Convention against Corruption.

As part of the Code of Conduct, the Volkswagen Group Essentials define the shared underlying values across all of the Volkswagen Group’s brands and companies. They are the basis of the corporate culture and describe what the Volkswagen Group stands for around the world: we take on responsibility for the environment and society; we are honest and speak up when something is wrong; we break new ground; we live diversity; we are proud of the work we do; we not me; we keep our word. These statements are a promise to customers, shareholders, business partners and employees. The Code of Conduct and the Group Essentials can be found on the Volkswagen Group website.

In cooperation with the relevant departments, the Group Chief Integrity & Compliance Officer is responsible for the content of the Code of Conduct. The Group Chief Integrity & Compliance Officer heads the Group-wide Integrity & Compliance organization, which is part of the Integrity and Legal Affairs function of the Board of Management. The brands and companies are responsible for local implementation throughout the workforce.

The Group Integrity & Compliance organization helps the Group and brand companies to comply with the rules when conducting their business activities and to comply with the relevant legislation and internal regulations. The focus of its work includes anti-corruption, the prevention of financial losses due to fraud and breaches of trust, and the prevention of money laundering. The internal compliance risk assessment (ICRA) serves as a starting point.

Internal compliance risk assessment

As part of the operational implementation of integrity and compliance, potential risks in the Group are identified through actions including the ICRA and relevant focus areas are defined. The active and controlled companies of the Volkswagen Group that employ personnel or carry out procurement activities are assigned risk profiles – categorized as low, medium, or high – and associated packages of actions including training and communication requirements. On this basis, actions such as increasing awareness and providing training must be put in place for the Group’s employees to promote integrity in day-to-day business, enable responsible conduct and prevent misconduct. Through this risk-based approach, employees, members of management and relevant stakeholder groups receive regular training on integrity and compliance topics, processes and conduct requirements specific to their field of work. Auditors also assess the effectiveness of the Integrity & Compliance actions as part of a monitoring and improvement process. Moreover, the integrity and compliance management system (ICMS) is optimized on a continuous basis.

The Porsche AG Group conducts an independent internal compliance risk assessment in its main departments to identify risk potential, determine focus areas, and derive preventive actions.

Minimum standards for integrity and compliance training and communication

In addition to the ICRA packages of actions, the minimum standards provide a more detailed framework for designing and implementing Integrity & Compliance training and are provided centrally by Group Integrity & Compliance. They are intended to provide the brands and companies with guidance on the training topics, their target groups and the minimum content. These Group-wide minimum standards ensure a defined level of homogeneity in Group-wide Integrity & Compliance training. The respective brands and companies are responsible for developing an effective training program and organizing and implementing training courses, such as Code of Conduct training, taking account of the minimum standards.

Code of Conduct training is aimed at all employees in the controlled companies, including company management. The training course must be repeated every three years for employees in non-production areas (full-time and part-time employees and managers). Participation is recorded in the system. Interns, student workers and doctoral candidates, for example, are exempt. At the end of fiscal year 2025, 280,865 (261,707) employees had a valid qualification on the Code of Conduct. This is equivalent to 94% (97%) of the active workforce eligible for training. A total of 14,980 employees of Porsche AG (86% of the relevant Porsche AG employees) completed the digital training module on the Porsche AG Code of Conduct in fiscal year 2025. The training module introduces the guidelines for conduct and provides information on the whistleblower system and contact details for the Compliance Helpdesk. Content on the prevention of conflicts of interest and corruption, as well as human rights, are also part of the training module.

The Group-wide implementation of the mandatory training measures on the Code of Conduct is reported to the Group Board of Management on an ad hoc basis and at least once a year.

Employees in production-related areas receive the relevant training every four years. The training course is based on the principles of the Code of Conduct brochure and includes topics such as environmental compliance, product compliance and the prohibition of corruption. The content is updated regularly.

Actions: Corporate culture

Code of Conduct training

Code of Conduct training educates Volkswagen Group employees on the topics of integrity and compliant conduct, the prohibition and, specifically, the prevention of corruption. An in-depth description of Code of Conduct training is provided in “Policies: Corporate culture”.

Employees from senior management upwards are certified on the Code of Conduct every two years, with the aim of recognizing their function as role models, raising their employees’ awareness accordingly and making it easier for them to find relevant information in the Code of Conduct. As part of the certification, participants are made aware of their reporting obligation in the event of serious compliance breaches as set out in their employment contract and the disclosure of any conflicts of interest.

Code of Conduct brochure

The Code of Conduct brochure is used to communicate the Code of Conduct to all employees and external stakeholders. It aims to create a consistent understanding of the Code of Conduct throughout the Volkswagen Group.

All employees receive the brochure when they start working for the company. It can also be accessed online, both internally and externally. The document is published across the Group, regularly updated, and supported by relevant communication campaigns. In September 2025, the Code of Conduct was updated with respect to the reporting channels for the whistleblower system.

Tone from the top

Tone-from-the-top communication conveys the stance of both company management and top management on integrity and compliant conduct to employees and external stakeholders. It serves as a model for all employees and so has a substantial influence on integrity and compliance in the corporate culture. Through regular Integrity & Compliance communication, consistent action, and by exemplifying values, both top management and company management signal that integrity and compliant conduct are not only expected but actively promoted. This is how the tone from the top creates trust and provides guidance in everyday working life. Tone-from-the-top communications are documented in a risk-specific manner.

Role Model Programme

Encouraging and empowering managers to actively contribute a successful transformation and act as role models is an important part of the Volkswagen Group’s philosophy. Managers who lead by example, motivate their teams, encourage resilience in the face of change, bolster their teams’ effectiveness and create trust. These are key factors for successful teamwork. The Role Model Programme helps managers to reinforce these factors.

A toolbox of easy-to-follow clear activities gives managers suggestions and instructions that can be implemented easily, without any additional budget and that are easy to integrate into day-to-day work. In all activities, it is about making management dynamic and engaging, dismantling distances between hierarchy levels, promoting innovation, and reinforcing mutual trust and interaction. The methods and instructions contained in the toolbox are assigned to the seven Group Essentials. In addition to the centrally suggested methods and instructions, the managers have the option to develop their own methods and tools and to implement them as actions in the program using wild cards.

The binding framework, with its minimum requirements for managers, supports the implementation of this program to improve the corporate culture. The Role Model Programme is run annually across the Group. It is targeted at all employees with management or team leadership functions in the Group.

myVOICE

The employee survey myVOICE (formerly Stimmungsbarometer) is a positive action for promoting corporate culture. Regularly gathering opinions, assessments and criticism strengthens the ongoing dialogue between employees and managers. This helps to foster transparency, trust, and a culture of open communication. The survey gives managers insights into potential improvements in their areas of responsibility and supports them in identifying and implementing appropriate actions using various tools and instruments. In 2024, the opinion survey was suspended in the Group to allow it to be revised. Following its revision, the opinion survey was relaunched under the name of myVOICE, initially to four companies in 2025. The tool will be rolled out in other Group companies starting in 2026.

The principles and response rates of myVOICE are described under “Processes: Engaging with employees and workers’ representatives about impacts” in the “Employees and Non-Employees” chapter. Further information, including on the actions based on myVOICE, is provided in the section on “Actions related to working conditions”.

Targets: Corporate culture

The Volkswagen Group generally develops targets where there is a connection to its strategies. No measurable, outcome-oriented targets within the meaning of the ESRS are currently defined in relation to corporate culture. The effectiveness of the management policies and actions related to the positive impact identified in the materiality assessment, which was performed in the reporting year, is currently not monitored. The Code of Conduct and the related training courses are an important expression of the corporate culture.

An update of the Code of Conduct was publicized throughout the Group on January 1, 2024. In September 2025, a further update was made regarding the reporting channels of the whistleblower system. Relevant additional content and an overarching, Group-wide narrative convey a clear, values-oriented attitude and ensure ease of integration of future developments. The topics of integrity and compliant conduct are also covered in the myVOICE employee survey.