In accordance with the requirements of the German Corporate Governance Code, the Board of Management ensures compliance with the statutory provisions and the Company’s internal policies and ensures compliance with them throughout the Group. The Volkswagen Group’s sense of obligation has always gone beyond statutory and internal requirements. Obligations undertaken and ethical principles accepted voluntarily form an integral part of our corporate culture and are at the same time the guiding principle on which decisions are based. The Group Chief Compliance Officer reports directly to the Chairman of the Board of Management. His task is to advise the Board of Management on all compliance issues, to introduce, control and supervise preventive measures, and to ensure that the rules are complied with.

The basis of our compliance activities is the Group-wide compliance strategy, which embraces a preventive approach. The central Compliance Office is currently building a compliance organization throughout the Group. Our existing compliance expertise has already been pooled in a Core Compliance Team. A global network of compliance officers and representatives is gradually being established to support the other Group companies, locations and business units in promoting and ensuring compliance. In 2009, the Group senior executives around the world were informed of the introduction of the compliance organization, alerted to the issue and invited to participate. As part of compliance programs, relevant and topical issues are discussed each year at all levels within the Group. In 2009, anti-corruption measures were among the issues in focus.

Since January 2006, Volkswagen AG has had a global anti-corruption system with independent lawyers as ombudsmen and an internal Anti-Corruption Officer. All of them are additional points of contact for persons wishing to provide information on suspected instances of corruption within the Group. In 2009, the ombudsmen passed on information provided by persons, whose details remained confidential, to Volkswagen AG’s internal Anti-Corruption Officer in 30 cases. All information is followed up.

To avoid and prevent conflicts of interest and corruption, Volkswagen uses an online learning program to provide targeted information to employees. Initially, the program was addressed to senior managers of Volkswagen AG, who were required to complete the program by the end of 2009. Participation is to be extended to other groups of Volkswagen AG employees and to other Group companies in the future.

To discharge our global and local responsibility even more systematically, we developed a Code of Conduct in 2009 for Group-wide application, which will be rolled out in stages throughout the Group starting in 2010. It will act as a guiding principle for employees that summarizes the key principles of our actions and supports them in dealing with the legal and ethical challenges they face in their daily work.

Moreover, the Volkswagen Group was the first company in 2009 to approve a “Labor Relations Charter” that is applicable worldwide. This Charter sets binding minimum standards for the entire Group for the involvement of employee representatives at company level on the basis of information, consultation and co-determination rights.

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