Minimum safeguards
The minimum safeguards consist of the OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights, the Fundamental Conventions of the International Labour Organization (ILO) and the International Bill of Human Rights. The assessments confirm that we meet the requirements of the minimum safeguards in the reporting year.
As a business with a global presence, the Volkswagen Group accepts its corporate responsibility for human rights, fully recognizes these conventions and declarations and reaffirms its agreement with the contents and principles stated therein. Compliance with legal requirements, internal rules and the principles enshrined in the Code of Conduct has top priority. This is why the Volkswagen Group appointed a Human Rights Officer, whose duties relate primarily to monitoring, checking and advising within the meaning of the Lieferkettensorgfaltspflichtengesetz (LkSG – German Supply Chain Due Diligence Act).
The LkSG imposes certain due diligence obligations designed to avoid risks associated with human rights and the environment. These obligations include the performance of risk analyses, the integration of preventive measures, remedial actions and the provision of a complaints mechanism. The whistleblower system is the central point of contact for reporting cases of breaches by employees of the Volkswagen Group or by suppliers. Employees can also contact the internal workers’ representatives with their concerns. Reports submitted to the Volkswagen Group are transferred to the whistleblower system and processed there. As soon as breaches are identified and remedial action is necessary, the department responsible immediately and autonomously initiates appropriate remedial action. Remedial action that results from risk analyses or is necessary for other reasons is also defined and implemented by the departments responsible.
The Volkswagen Group checks whether the actions taken are effective at avoiding or reducing negative impacts on a regular and ad hoc basis in what is known as compliance monitoring. This also includes checking whether the Code of Conduct is being complied with and whether complaints have been dealt with.
Furthermore, along with the Group policies developed by Group Occupational Safety and Group Security, the HR Compliance Group policy sets out the organizational framework conditions in the controlled companies of the Volkswagen Group with regard to integrity and compliance in HR tools, actions and processes and takes into account local legal, collective-bargaining and operational regulations when implementing these. The provisions of the Code of Conduct are an integral part of the Group policy in that they require employees’ human rights to be upheld.
Relationships with our business partners are based on agreements such as the Code of Conduct for Business Partners. Compliance with the requirements defined in the Code is contractually binding, and we review this with the aid of a sustainability rating in the case of relevant suppliers. We address existing sustainability risks and violations of sustainability principles by systematically defining and allocating packages of actions to correct the violations; we also apply this approach to the upstream supply chain. In addition, we also conducted training for suppliers and audits at suppliers with a high risk exposure in the reporting period. We implemented a Human Rights Focus System in 2022 to optimize our management system in line with international frameworks and requirements and specifically the LkSG. The system aims to identify particularly high risks in our supply chain in connection with human rights violations and the environment and to manage these appropriately.