Lobbying activities
MATERIAL IMPACT AND RISK AND THEIR INTERACTION WITH STRATEGY AND BUSINESS MODEL
Impact in the area of lobbying activities
The Volkswagen Group is an active participant in various networks of experts and decision-makers who have a significant influence on economic conditions and the sociopolitical agenda.
The Volkswagen Group’s political engagement was identified as material via an actual positive impact in the materiality assessment conducted in fiscal year 2024. The Volkswagen Group has a positive impact on the focus on sustainable mobility through lobbying activities, particularly in the upstream and downstream value chain, but also in its own operations.
Financial risk in the area of lobbying activities
In connection with the Volkswagen Group’s lobbying, the material risk of reduced influence on political decision-making processes was identified. A decline in the social significance of the automotive industry or legal restrictions on lobbying activities in the coming years could lead to a reduction in the Volkswagen Group’s influence on political decision-making processes.
As a result, the Volkswagen Group may be negatively impacted by political decisions without the opportunity to actively influence them (in good time). This may result in negative regulatory consequences that impact the Group’s long-term business operations and profitability due to factors such as cost increases to comply with new legal requirements.
Interaction with strategy and business model
The positive impact and the risk identified in the materiality assessment have an influence on the Group’s business model, strategy and value chain. The Volkswagen Group uses various actions in the area of lobbying to emphasize the influence of the material positive impact and respond to the effect of its material risk on its business model, strategy and value chain. For instance, in addition to the one-voice policy, we carry out lobbying as well as risk assessment and strategic forecasts.
Strategic business decisions can affect the opportunities for lobbying. The Volkswagen Group represents its interests worldwide; these are listened to in the context of political decisions and have 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.
An in-depth description of all actions in the area of lobbying activities is provided in “Actions: Lobbying activities”.
POLICIES: LOBBYING ACTIVITIES
As part of society, the Volkswagen Group can strategically integrate the positions of the Group into decision-making processes through lobbying – for example, on legislative proposals. 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 conflicts with the Volkswagen Group’s Code of Conduct and is not permitted.
Lobbying is defined in various documents, including the internal Public Affairs Group Policy and the publicly available “Principles and Guidelines (including Annex) 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 messages of the Group’s lobbying. In their function as the chair of a cross-brand public affairs steering committee, 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 messages 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 lobbying 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 noncompliance 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 the social environment, 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 uniformity of behavior 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 these measures within the framework of an authorization process.
In addition, it supports scientific, charitable or 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 if climate-related targets are to be achieved, and that this requires a well-maintained 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. - Regulated trade
As a multinational enterprise, the Volkswagen Group relies on open regulated international trade. In the Group’s view, measures that restrict trade, such as the introduction of countervailing duties/protective tariffs are generally inappropriate for strengthening the long-term competitiveness of the automotive industry. Instead, the transformation of the automotive industry needs to be underpinned through a suitable regulatory environment and the creation of competitive structures. The conclusion of both previously negotiated and new trade agreements and partnerships may help to minimize trade barriers and the distortion of competition. 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 champions responsible handling of all types of data and advocates for 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’s goal is to develop sustainable, environmentally friendly and resource-efficient products and production facilities, which is why it is committed 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 strengthening the economy and reducing red tape in the EU’s automotive sector. The aim is to not only accelerate innovations but also scale them up for industrial production. 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 (R006923), AUDI AG (R001702), MAN Truck & Bus SE (R001638), Cariad (R006271), MOIA (R000349), MAN Energy Solutions 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), MAN Energy Solutions SE (REG number: 101247832736-33) and MAN Truck & Bus SE (REG number: 06093891220-52) are registered in the EU Transparency Register.
ACTIONS: LOBBYING ACTIVITIES
In the reporting year, the Volkswagen Group introduced various measures that will continue to be implemented in the future. These serve the purpose of managing and ensuring consistency in the Group’s lobbying.
Lobbying
In order to support the Volkswagen Group’s strategy, the Public Affairs department influences the political framework. Active lobbying is reinforced 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 external lobbying.
Risk assessment and strategic forecast
In its risk assessment, the Volkswagen Group has identified and assessed relevant political developments and regulatory measures. Recommendations for action for Group management were derived with the involvement of a network of policymakers, external networks, and through association work, topic responsibilities, and priority markets.
One-voice policy
An in-depth description of the one-voice policy is provided in “Policies: Lobbying activities”.
The Volkswagen Group’s one-voice policy is organized through Group and brand guidelines, the Group Public Affairs steering committee, lobby guidelines, and information and voting cascades (group calls, regular conference calls). 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.
With regard to the Group policy, all controlled companies are required to implement it within a set period of time. If a company is unable to implement the policy, it must report this.
TARGETS: LOBBYING ACTIVITIES
No measurable, outcome-oriented targets within the meaning of the ESRS are defined in relation to lobbying activities. The effectiveness of the policies and actions in relation to the positive impact and the risk identified through the materiality assessment performed this year for the first time is currently not monitored.
The objectives in the Public Affairs department are shaped by internal management tasks and supporting activities for the Group. The management and consistency of lobbying 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 official processes in special cases, ensuring targeted and efficient handling.
METRICS: 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 fully consolidated companies amounted to €92 thousand in 2024.