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.