Corruption and Bribery

Material impacts and their interaction with strategy and business model

Interaction with strategy and business model

Our impacts identified in the materiality assessment have an effect on the Group’s strategy, business model and value chain. Integrity and compliance are cornerstones of regenerate+. The Code of Conduct forms the ethical and values-based foundation for integrity and compliance in the Volkswagen Group.

The Volkswagen Group uses the instruments of the compliance management system in its work to combat corruption to emphasize the influence of its material impacts on its business model, strategy and value chain. Here, particular focus is placed on ethical business practices as well as on tackling corruption and bribery – also along the value chain – in order to maintain and reinforce positive impacts.

Actions to combat corruption and bribery are part of regenerate+ and may in turn have an effect on the value chain.

Management policies: Prevention of corruption and bribery

The Volkswagen Group is fully committed to acting lawfully and responsibly and pursues a strict zero-tolerance policy against corruption. This principle is firmly anchored in the corporate values. This is also reflected in the Code of Conduct for Employees and the Code of Conduct for Business Partners, and thus forms the guiding principle for the Volkswagen Group’s actions. The relevant documents can be viewed on the Group website at https://www.volkswagen-group.com/en/integrity-and-compliance-15705. Further Group policies set out how to deal with conflicts of interest, donations and sponsorship or benefits, particularly in the form of gifts or invitations.

The Volkswagen Group follows up on reports of potential violations against legal provisions or its own corporate values and regulations, with the aim of ensuring compliant and lawful conduct within the Volkswagen Group. The handling of potentially serious breaches of rules falls within the remit of the investigation offices. Appropriate individuals and departments, in particular managers and Human Resources, are responsible for dealing with other breaches of rules. Employees who are involved in unfair business practices are sanctioned.

The Group Integrity & Compliance department is responsible for anti-corruption and the prevention of bribery and money laundering. It belongs to the Integrity and Legal Affairs function of the Board of Management.

Actions: Prevention of corruption and bribery

Written guidelines

The Code of Conduct is available to all Volkswagen Group employees and third parties on the Group website https://www.volkswagen-group.com/en/integrity-and-compliance-15705. In addition, the Group Integrity & Compliance communication team organizes information and communication activities such as campaigns, film and dialogue formats, newsletters and interactive games, with the aim of raising awareness of integrity and compliance topics.

Activities in the area of corruption prevention are based on the Group-wide policy on benefits and gifts, which sets out clear rules for dealing with gifts, invitations, and other benefits. It also contributes to preventing conflicts of interest and avoiding even the appearance of undue influence. The aim of these activities is to ensure that the Volkswagen Group’s business practices are as transparent as possible and comply with the applicable regulations.

Advice

The Integrity & Compliance Information Point has established itself as a central advisory office at Volkswagen AG. The team can be contacted in person, by email or by app (including the Volkswagen 360° app). It answers questions on integrity and compliance, particularly on the Code of Conduct and the topic of anti-corruption, and is in close communication with other advisory bodies in the Group.

Training activities and certification

To avoid corruption risks, risk-based communication and training activities on the topic of anti-corruption are carried out regularly. These actions not only cover the prohibition of corruption and how to deal with officeholders and mandate holders in this regard, but also cover topics related to the prevention of money laundering. A detailed description of the Volkswagen Group’s compliance training is provided in “Training programs”.

Employees from senior management upwards are certified on the Code of Conduct every two years. By signing the certificate, they confirm their knowledge of the Code of Conduct, and of their obligation to report potential conflicts of interest and serious breaches of regulations.

Business partner due diligence

As part of the Business Partner Due Diligence (BPDD) process, the integrity of sales partners is reviewed using a risk-based approach with a focus on anti-corruption. The due diligence is carried out prior to entering into a business relationship and continued for the entire business relationship. Early identification of potential risks enables preventive or reactive mitigating actions to be taken to ensure the reliability and stability of business relationships. Automated daily integrity monitoring of business partners is another key component of this. Sales partners are also subjected to additional risk-based checks, such as audits. Business partners receive support in various formats, such as compliance dialogues, so that they meet the necessary standards. Group Integrity & Compliance supports the sales entities with operational responsibility in conducting the Business Partner Due Diligence process. The process includes regular media screenings, risk assessments, sanction list checks and identifying warning signs with regard to business partners. The Volkswagen Group checks whether business partners have a compliance management system (CMS) or have implemented any compliance actions. The aim is to identify risks for breaches of the law and disregard of ethical standards at an early stage, avoid high-risk business partners and, where possible, define actions to minimize risk and implement these jointly with business partners. In individual cases, business partners are contacted directly to resolve potential violations. If this is not possible, the Group refrains from entering the business relationship or terminates it as the law allows. The business partner in question may be blacklisted from doing business with the Volkswagen Group, its brands and its companies.

In addition to automated, continuous integrity monitoring of the business partner in the BPDD tool, the implementation of any mitigation actions potentially agreed with the business partner prior to the conclusion of the contract is also monitored. Furthermore, the business partners are regularly assessed to determine whether further actions such as, in particular compliance dialogues, on-site visits or external audits are required to ensure a compliant and lawful business relationship. If necessary, these actions are taken in collaboration with the responsible compliance officers as part of a risk-based approach.

Handling breaches

In the case of breaches by employees, a systematic investigation is carried out and – if required – sanctions are imposed on the employees in question. Reports can be made confidentially and also anonymously through the Group-wide whistleblower system at any time. These cases are thoroughly investigated by the competent departments (for example, investigation offices in cases of potentially serious misconduct).

The Volkswagen Group conducts investigations with the utmost confidentiality after a thorough review and in cases where there are firm indications of rule-breaking. There is a presumption of innocence. Those involved are interviewed as soon as possible, and their names are cleared if they have been wrongly accused. Proven misconduct may, depending on its severity, be sanctioned by a warning, a reprimand, or dismissal.

Training programs

The Volkswagen Group offers its employees and suppliers the following training programs on the topic of preventing corruption and bribery:

Training for employees in the Volkswagen Group

The Volkswagen Group has a strict zero-tolerance policy toward any form of active or passive corruption. Companies with high exposure to risk pursuant to the ICRA are obliged to conduct anti-corruption and anti-money-laundering training for their employees. The training includes special modules on dealing with officeholders and mandate holders, handling benefits/contributions, and the prevention of money laundering. It is directed at all employees in non-production areas and must be repeated every three years. In 2025, the training was redesigned and subsequently rolled out in ICRA companies with a high-risk profile. Companies who have already introduced the new training course on anti-corruption and anti-money laundering report a training rate based on this course. Companies that have not introduced the new training – but use two separate training courses for anti-corruption and anti-money laundering – report two separate training rates based on the individual courses. A qualification on the topics of anti-corruption and anti-money laundering is generally available for all those who are eligible. At the end of fiscal year 2025, 87,620 employees of ICRA high-risk companies had a valid qualification (new training) in anti-corruption and anti-money laundering. This is equivalent to 69% of indirect employees eligible for training. At the end of fiscal year 2025, 29,288 employees of ICRA high-risk companies had a valid qualification in anti-corruption. This is equivalent to 85% of indirect employees eligible for training. At the end of fiscal year 2025, 14,577 employees of ICRA high-risk companies had a valid qualification in the prevention of money laundering. This is equivalent to 83% of indirect workers eligible for training. In the ICRA high-risk companies, the training was implemented based on various rollout scenarios. Within the Porsche AG Group, the functions at increased risk of corruption and bribery in the context of the ESRS as a result of their tasks and responsibilities are defined at company level. In 2025, the proportion of trained indirect employees in companies with an increased risk was 82%, which corresponds to 18,961 qualified employees. The companies of the Porsche AG Group at increased risk of corruption and bribery are identified via the compliance risk analysis. These companies conduct training on the Porsche Code of Conduct for their indirect workers, covering topics such as anti-corruption and the prevention of money laundering.

The Group-wide implementation of the mandatory training on anti-corruption and the prevention of money laundering is reported to the Group Board of Management on an ad hoc basis and at least once a year.

As a rule, members of the Board of Management are part of the target group for the mandatory integrity & compliance training. In addition, after being appointed they receive one-off, in-depth, and personal training on the Code of Conduct, anti-corruption, and the prevention of money laundering. In future, members of the Group Board of Management will also receive in-depth, target-group-specific training on anti-corruption and the prevention of money laundering. Carrying out these two training courses is the responsibility of the competent integrity & compliance officer.

A deep-dive training session on corruption prevention was organized for members of the Supervisory Board in the 2024 fiscal year.

Training for suppliers

Training on the Code of Conduct for Business Partners on anti-corruption and the prevention of money laundering is also made available to business partners from Sales and Procurement. The Code of Conduct for Business Partners has been a contractual component of agreements with suppliers and service providers since 2020.

Targets: Prevention of corruption and bribery

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 defined in relation to corruption and bribery. The effectiveness of the management policies and actions related to the positive impacts identified in the materiality assessment, which was performed in the reporting year, is currently not monitored. An internal compliance risk assessment of the companies in the Volkswagen Group’s own business area is conducted with the aim of achieving risk-based management of prevention actions. The ICRA serves to systematically identify, assess, and minimize compliance risks – particularly corruption and money laundering risks. Actions for targeted prevention are rolled out to the companies using a risk-based approach following an analysis of the risks which takes account of various factors such as geographic risks, sector-specific characteristics and past incidents. In the case of Group companies with a high level of risk exposure, external audits are conducted on the implementation and effectiveness of the prevention actions.

Metrics: Corruption and bribery

In 2025, the investigation offices received a total of 4,214 (3,555) reports, most of which were either not anonymous, or anonymous with the option to contact the whistleblower. The total number and type of identified cases of corruption are also determined by the Volkswagen Group’s investigation offices. The types of cases include corruption, bribery, fraud, extortion, collusion and money laundering. Convictions of Group employees for violations of anti-corruption and anti-bribery laws committed in the course of their work for the Group are taken into account if and to the extent that the Group is aware of the convictions. Fines are reported if they are directly related to the conviction. In the year under review, three final judgments for fraud are known to have been handed down. These are described in more detail in the “Report on Risks and Opportunities” chapter in the “Litigation” section of the Group management report.