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Annual Report

Compliance

In accordance with the requirements of the German Corporate Governance Code, the Board of Management of the Volkswagen Group ensures that the statutory requirements and the Company’s internal policies are complied with and respected throughout the Group. Volkswagen’s sense of duty has always gone beyond statutory and internal requirements; obligations undertaken and ethical principles accepted voluntarily also form an integral part of our corporate culture and are at the same time the guiding principle on which we base our decisions. Our compliance activities are based on a Group-wide compliance strategy, which embraces a preventive approach.

In the course of 2010, the convergence of risk management, internal control systems and compliance resulted in the creation of the new Governance, Risk & Compliance division. Its head is also the Group Chief Compliance Officer of the Volkswagen Group; he reports directly to the Chairman of the Board of Management. His tasks include advising the Board of Management on all compliance issues as well as initiating, controlling and supervising preventive measures and ensuring that the rules are complied with.

To discharge Volkswagen’s global and local responsibility even more systematically, we have developed a Code of Conduct for Group-wide application. It forms the basis for our actions in day-to-day business and is gradually being integrated into existing processes. In 2010, the introduction of the Code of Conduct of the Volkswagen Group was one of the focal points of compliance work. The Code acts as a guiding principle for employees: it summarizes the key action principles in the Group and therefore helps them deal with the legal and ethical challenges they face in daily work situations. In the first step, the Chairman of the Board of Management informed all the Company’s managers of the importance of the Code of Conduct and called on them to lead by good example. In addition, all managers of Volkswagen AG were tasked with familiarizing their units with the issue. Furthermore, each employee received a copy of the “Code of Conduct of the Volkswagen Group” brochure. At the same time, the message was driven home in on-site seminars conducted by the Governance, Risk & Compliance division and by members of the compliance organization. In addition to these events, employees also receive information on compliance through the internal communication channels. German and English versions of the Code of Conduct can also be downloaded from the Internet and intranet. Moreover, Volkswagen employees have the option to contact the compliance organization via an internal e-mail address.

The continuous implementation of measures to prevent corruption was another focal point of compliance work in 2010. 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 2010, the ombudsmen passed on information provided by persons, whose details remained confidential, to Volkswagen AG’s internal Anti-Corruption Officer in 34 cases. All information is followed up.

In addition, to prevent conflicts of interest and corruption, Volkswagen has since 2009 used an online learning program to provide targeted information to employees. Initially, the program was addressed to senior managers of Volkswagen AG. Since then, the program has been rolled out to other groups of employees of Volkswagen AG and other Group companies. In addition, target-group-specific attendance seminars on anti-corruption are organized.

The existing compliance expertise in our corporate units is 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.

Every year, relevant current compliance issues are discussed at all levels within the Group and new compliance programs are developed. In 2011, providing training and information to employees will again be a key component of preventive compliance measures at Volkswagen. We will continue to expand our compliance organization with undiminished commitment.

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