Whistleblower System > Integrity and Compliance > Audi China
Whistleblower System
Complying with statutory regulations and internal rules has top priority at Audi China. We can only avoid damage to our company, our employees and business partners if laws and legislations, rules and standards are respected. Consequently, misconduct must be recognized swiftly, processed and immediately remedied.
That calls for vigilance on the part of everyone along with a willingness to draw attention to possible serious regulatory violations on the basis of concrete evidence. We also value information of this nature from business partners, customers and other third parties.
The whistleblower system guarantees the greatest possible protection for whistleblowers and persons implicated. An investigation is only initiated after very careful examination of the facts and concrete evidence of a regulatory violation. There will be strict confidentiality and secrecy throughout the investigative process. Information will be reviewed fairly, promptly and in a sensitive manner.
How to report violations through the Whistleblower System?
Keep the following advice in mind for your report to be properly handled and investigated - It is important to be as specific as possible.
Make sure your descriptions can be understood by non-specialists as well. Include these elements:
• Who
• What
• When
• How
• Where
It is helpful if the descriptions contained in your report can be easily understood by persons who are not specialists in your field. It is also very much appreciated, although not required, that you will be available to answer further questions. If you would be willing to do so, but do not wish your name to be disclosed to the Company, please contact the ombudspersons to make your report.
Whistleblower system is NOT to resolve workplace conflicts, personnel matters, or work mistakes, etc. It is NOT an advice center for general questions about rule-compliant behavior or compliance. Audi China Whistleblower System does NOT process any complaint regarding the quality of vehicle. For this topic please contact customer service hotline of FAW-VW Audi at 400-817-1666.
Make sure your descriptions can be understood by non-specialists as well. Include these elements:
• Who
• What
• When
• How
• Where
It is helpful if the descriptions contained in your report can be easily understood by persons who are not specialists in your field. It is also very much appreciated, although not required, that you will be available to answer further questions. If you would be willing to do so, but do not wish your name to be disclosed to the Company, please contact the ombudspersons to make your report.
Whistleblower system is NOT to resolve workplace conflicts, personnel matters, or work mistakes, etc. It is NOT an advice center for general questions about rule-compliant behavior or compliance. Audi China Whistleblower System does NOT process any complaint regarding the quality of vehicle. For this topic please contact customer service hotline of FAW-VW Audi at 400-817-1666.
What is a Violation?
Violations are all violations of statutory and internal regulations (e.g. Code of Conduct, Group Guidelines, process specifications) by Audi China employees. Audi China Investigation Office makes a distinction between serious regulatory violations and other regulatory violations.
Serious Regulatory Violation is a Regulatory Violation that significantly affects the interests of Audi China, in particular the reputational or financial interests, or that significantly violates the ethical values of Audi China.
Examples for a Serious Regulatory Violation are as follows:
• Corruption, white-collar and tax criminal offences
• Environmental criminal offences
• Violations of human rights (e.g. prohibition of child labor)
• Violations of anti-trust law and competition law
• Money laundering and terrorism financing
• Violations of product safety and technical requirements regulations
• Substantial violations of data protection laws
• Violations committed by Employees from the level of upper management (personal OMK level) and above which contradicts its role model function for compliance and integrity as defined in the Code of Conduct
• High risk of company sanctions (for example, fines and levies, ban on business transactions with authorities, loss of licenses for business operations)
• Conspiracy to commit a violation involving several people
• Systematic exploitation of company structures to commit violations
The following cases are always processed as reports of Serious Regulatory Violations:
• Violations of regulations prohibiting the discrimination of whistleblowers
• Failure of managers to fulfil the obligation to report
• Abuse of the Whistleblower System by knowingly making false accusations
• Violations of US environmental regulations
An Other Regulatory Violation is any Regulatory Violation, which is not a Serious Regulatory Violation. Proven Other Regulatory Violations may also be sanctioned appropriately and may lead to termination of employment.
Serious Regulatory Violation is a Regulatory Violation that significantly affects the interests of Audi China, in particular the reputational or financial interests, or that significantly violates the ethical values of Audi China.
Examples for a Serious Regulatory Violation are as follows:
• Corruption, white-collar and tax criminal offences
• Environmental criminal offences
• Violations of human rights (e.g. prohibition of child labor)
• Violations of anti-trust law and competition law
• Money laundering and terrorism financing
• Violations of product safety and technical requirements regulations
• Substantial violations of data protection laws
• Violations committed by Employees from the level of upper management (personal OMK level) and above which contradicts its role model function for compliance and integrity as defined in the Code of Conduct
• High risk of company sanctions (for example, fines and levies, ban on business transactions with authorities, loss of licenses for business operations)
• Conspiracy to commit a violation involving several people
• Systematic exploitation of company structures to commit violations
The following cases are always processed as reports of Serious Regulatory Violations:
• Violations of regulations prohibiting the discrimination of whistleblowers
• Failure of managers to fulfil the obligation to report
• Abuse of the Whistleblower System by knowingly making false accusations
• Violations of US environmental regulations
An Other Regulatory Violation is any Regulatory Violation, which is not a Serious Regulatory Violation. Proven Other Regulatory Violations may also be sanctioned appropriately and may lead to termination of employment.
When is information deemed to be substantiated?
Substantiated information is the suspicion of violation of statutory or internal regulations based on actual concrete evidence. If the report only contains random allegations or suspicion of a violation of statutory or internal regulations without any concrete facts that can be used to initiate investigative measures, then the information is deemed to be unsubstantiated.
How does the company process reports received?
Audi China Investigation Office is responsible for documenting and reviewing every report received. Substantiated information must be investigated without delay. The employees responsible for handling and investigating the reports must treat the information as confidential and may not disclose it to other parties. This applies in particular to personal data. They may only inform other persons on a strictly need-to-know basis. Applicable legislation, the internal policies and, in particular, data protection and cyber security laws must be observed when processing whistleblower cases.