Lobbying activities

Material impact and risk and their interaction with strategy and business model

Interaction with strategy and business model

The positive impact and the risk identified in the materiality assessment affect the Group’s business model, strategy and value chain. The Volkswagen Group uses various actions in the area of political influence to both enhance the material positive impact on its business model, strategy and value chain, and respond to any material risks in this respect. In addition to the one voice policy and political lobbying, actions include strategic risk assessments and the development of corresponding strategic forecasts accompanied by recommendations for action.

Strategic business decisions can affect the opportunities for representing political interests. The Volkswagen Group represents its interests worldwide; these are heard in the political decision-making process, which in turn has an influence on the business model and the value chain.

What is more, the Volkswagen Group’s business model and the value chain are inherently influenced by structural change and geopolitical developments.

Policies: Political influence and lobbying activities

As part of society, the Volkswagen Group can integrate the positions of the Group into decision-making processes, for example, in legislative proposals, in a targeted manner through political influence, i.e. lobbying. Lobbying is organized centrally and in line with the principles of openness, transparency, and responsibility. Neutrality in dealing with political parties and stakeholder groups is standard practice for the Volkswagen Group. Any unfair influence on policy and legislation stands in contradiction to the Volkswagen Group’s Code of Conduct and is not tolerated.

Political influence is defined in various documents, including the internal Public Affairs Group Policy and the publicly available Principles and Guidelines for Public Affairs. This policy is aimed at the brands and companies of the Volkswagen Group and their political officers. The Group policy’s requirements must be implemented in each company’s own regulations. The Group External Relations department, particularly the Head of Public Affairs, has process responsibility for a one voice policy within the framework of the Public Affairs Group Policy. The Head of Public Affairs regularly informs the Board of Management on the status and messaging of the Group’s political engagement. With a direct reporting line to the Chair of the Board of Management, the Head of Public Affairs can escalate topics to the Board of Management if required, with the aim of establishing the Group’s position.

The aim of the one voice policy is to define a standardized, coordinated, and binding position for political issues relevant to the Group. This is communicated to the respective audiences worldwide with consistent messaging from the Group, brands, and companies. As a result, the Group’s interests are represented with the same, internally agreed content, objectives, and statements. The Group policy is intended to ensure transparent political influence activities in the political decision-making process. The policy communicates the fulfillment of statutory requirements and the inclusion of other external stakeholder expectations to all controlled companies, with the aim of avoiding financial and legal risks, erosion of confidence, and reputation risks. In addition, any exclusion from public orders due to strict regulations and/or non-compliance with political obligations is to be minimized or prevented.

With regard to dealing with officeholders and mandate holders, strict regulations apply nationally and internationally to prevent corruption. The internal policies on benefits take these fully into account.

As an active participant in society, the Volkswagen Group makes donations and provides sponsorship for social purposes. Donations are voluntary contributions for which nothing is received in return, whereas sponsorship money is provided in return for a contractually agreed service. To avoid conflicts of interest and ensure consistent conduct within the Group, donations and sponsorship measures are only permitted within the framework of the relevant legal system and in accordance with the current internal requirements. The Volkswagen Group only provides such actions within the framework of an authorization process.

In addition, the Volkswagen Group supports scientific, charitable and cultural causes with donations in cash and in kind. Furthermore, donations are only made to accredited non-profit organizations or organizations specifically endorsed to receive donations.

The Volkswagen Group strives to create sustainable, environmentally friendly, and resource-conserving products and production facilities. The Group is therefore committed to ambitious, yet economically feasible environmental and climate targets. This requires workable guidelines in various topic areas.

The Volkswagen Group currently focuses on the following issues:

• Promoting e-mobility
  The Volkswagen Group believes that promoting e-mobility is vital to achieving climate-related targets, and that this requires a well-developed charging infrastructure in particular. Its expansion must be accelerated and pursued with commitment.
  The Volkswagen Group believes that funding instruments in the early phases of the ramp-up are a critical element in the success of e-mobility in increasing the market acceptance of electric vehicles.
  In addition, alternative and lower-carbon fuels should be further developed and used to decarbonize the transport sector and specifically the vehicle fleet.
• Regulation of batteries
  Given its strategic orientation, battery-specific regulations are extremely important for the Volkswagen Group. These govern factors including the systems and methodologies for determining a battery’s carbon footprint, which should be flexible and fair.
• Regulations on CO₂ fleet legislation
  The Volkswagen Group is fundamentally committed to the goal of 100% decarbonization in the transport sector. We regard electric mobility as the technical solution for the future. However, given the reality of the current market, we also recognize the need for CO₂-related legislation to be made more flexible and to assume realistic timelines for implementation on the path towards decarbonization. Current legislation was developed at a time when forecasts concerning electrification were much more optimistic than the current realities of the market – despite all the efforts of the automotive industry and a stark rise in the number of electric vehicles on offer.
• Regulated trade
  The Volkswagen Group is a globally active company that advocates for fair, regulated international trade. For the automotive industry and its global networks of supply chains, a binding regulatory environment is essential for supporting the creation of competitive structures during the transformation process and for safeguarding planning reliability. European production and strategically important products need to be bolstered over the long term by improving local conditions within Europe. Here, the conclusion of already negotiated trade agreements and partnerships in strategic areas as well as the establishment of new ones can help with factors such as minimizing barriers to trade and the distortion of competition or establishing reliability. The Volkswagen Group supports this.
• Cybersecurity, data and digitalization
  Cybersecurity, digitalization and AI are major topics in the automotive industry at present. The Volkswagen Group supports responsible handling of all types of data and uses access to vehicle data as the bedrock for new value creation based on existing laws.
• Automated driving
  Automated driving will become an integral part of the development of future mobility. To advance its development activities in this area, the Volkswagen Group believes it is essential to create uniform regulations and remove restrictions.
• Climate policy and emissions
  The Volkswagen Group is committed to sustainable, environmentally friendly and resource-efficient products and production facilities, and therefore to ambitious yet economically viable environmental and climate targets. The Group believes that this requires, among other things, practicable guidelines in various topic areas such as recycling rates and end-of-life regulations.
• Competitiveness of the automotive industry
  The Volkswagen Group is committed to enhancing the economic strength of the EU’s automotive sector and reducing red tape in the sector. The aim is to not only accelerate innovations but also scale them up for industrial production. This is particularly true for battery cell production, with the aim here being to promote this process with output-based support. The industry needs access to cheaper energy. It is important to diversify the sources of raw materials and enter into partnerships with third countries. Furthermore, regulations or red tape must not put European companies at a disadvantage.

Volkswagen AG (R001681), Dr. Ing. h.c. F. Porsche AG (R001768), TRATON SE (R001565), VW Financial Services AG (R001704), PowerCo SE (R006923), AUDI AG (R001702), MAN Truck & Bus SE (R001638), Cariad SE (R006271), MOIA GmbH (R000349), Everllence SE (R001653), and Volkswagen Group Charging GmbH (R001890) are registered in the Lobbying Register of the German Bundestag.

Volkswagen Aktiengesellschaft (REG number: 6504541970-40), Scania AB (publ) (REG number: 3305029916-47), Everllence SE (REG number: 101247832736-33) and MAN Truck & Bus SE (REG number: 06093891220-52) are registered in the EU Transparency Register. The State of Lower Saxony appointed its Minister President Olaf Lies to the Volkswagen AG Supervisory Board on May 20, 2025. Prior to his appointment, Minister President Lies had been Lower Saxony’s Minister for Economic Affairs, Housing, Transport and Digitalization since November 2022. Apart from Minister President Lies, no further persons holding a similar position within public administration (including regulatory authorities) were appointed to the Supervisory Board in the two years preceding Minister President Lies’ appointment in financial year 2025.

Actions: Political influence and lobbying activities

The Volkswagen Group has introduced various actions that will continue to be implemented in the future. These serve the purpose of managing and establishing consistency in the Group’s political influence outside the Group’s lobbying.

Political influence

In order to support the Volkswagen Group’s strategy, the Public Affairs department influences the political framework. Active lobbying is supported primarily by regular association work and contact with policymakers via the headquarters or external offices. The department’s aim is to ensure standardized global management and consistency in the Group’s political influence outside the company.

Risk assessment and strategic forecast

In its risk assessment, the Volkswagen Group identifies and assesses relevant political developments and regulatory measures on an ongoing basis. Recommendations for action for Group management are derived with the involvement of a network of policymakers, external partners, associations, topic owners and priority markets.

One voice policy

The Volkswagen Group’s one voice policy is organized through Group and brand guidelines, lobby guidelines, and information and voting cascades (group calls, regular conference calls and coordination formats). This approach takes regulatory requirements into account, such as the Lobbying Register of the German Bundestag or EU regulations such as the CSRD or the EU Foreign Subsidies Regulation. In addition, requirements due to ESG ratings or from other processes are included.

All controlled companies are required to meet the targets defined in Group policies within a set period of time. If a company is unable to implement the policy, it is obligated to report this.

Targets: Political influence and lobbying activities

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 political influence and lobbying activities. The effectiveness of the management policies and actions related to the positive impact and the risk identified through the materiality assessment, which was performed in the reporting year, is currently not monitored.

The objectives in the Public Affairs department are shaped by management tasks within the Group and supporting activities for the Group. The management and consistency of political influence activities in the Group are decisive in ensuring uniform and strategic communication toward policymakers and non-governmental organizations (NGOs). The Group must, of course, ensure that all legal requirements are met. In addition, operational support is offered to all areas of the Group in special cases involving official processes, ensuring targeted and efficient handling.

Metrics: Political influence and lobbying activities

The Group’s total political contributions comprise the financial contributions made directly and indirectly by the Group and the monetary value of the in-kind contributions. Direct contributions are those made directly to political parties, their elected representatives or persons seeking political office. Indirect contributions are those made to parties such as lobbyists or associations that are linked to or support certain political parties or causes. The total amount of political contributions is not broken down by region as none were granted, except in the USA. Due to the specific definitions in the ESRS, the figures in this report differ from those entered in lobby registers. As such, this report does not include all the figures from entries in lobby registers.

The value of financial and in-kind political contributions made directly and indirectly by the consolidated companies amounted to €185 (92) thousand in 2025.