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The TRATON Financial Services Group Whistleblowing Systems

Integrity and compliance with laws and regulations as well as the principles laid down in the Code of
Conduct and the Code of Conduct for Suppliers and Business Partners are top priorities and
cornerstones of our corporate culture. To meet these values and avoid or minimize potential risks due
to regulatory violations, it is crucial that potential regulatory violations of employees or external
partners are identified at an early stage, clarified, stopped and that disciplinary measures are applied
when necessary. To encourage a speak-up culture and to detect potential wrongdoings, TRATON
Financial Services operated a global independent, impartial and confidential whistleblowing system 
managed in collaboration with the TRATON Investigations Office.

The Group-wide whistleblowing system and procedures for conducting internal investigations are
governed by an internal Group Policy.

Our whistleblowing system is based on fundamental principles as the protection of whistleblowers
and persons concerned of or supporting the investigations
. We respect whistleblowers’ right to
, and we uphold the presumption of innocence and fairness of investigations towards
any persons concerned
. Information received via the whistleblowing system will be reviewed fairly,
promptly, and in a sensitive manner and will be treated with the highest level of confidentiality. No
actions are taken to identify anonymous whistleblowers. However, any report in bad faith will be
treated as a serious regulatory violation.

Dedicated persons within Governance, Risk and Compliance, Security, Internal Audit, Legal and
HR/People and Culture support the investigations. An investigation is only initiated after a careful
examination of the facts and reasonable suspicion of a regulatory violation. The TRATON Financial
Services Investigations Office work closely with colleagues at the TRATON Investigations Office,
especially regarding potential serious regulatory violations.

Our whistleblowing channels

Our whistleblowing system provides the following channels to report potential violations committed
by employees or external partners to enable a fast investigation and appropriate reaction by our
company. However, that does not limit legally protected rights to contact relevant authorities

Speak up! The 24/7 TRATON Group whistleblower portal

Whistleblowers worldwide can use the TRATON Speak up! tool to address the TRATON Financial
Services Investigations Office, which is available around the clock in several languages to report hints
on potential violations regarding white-collar crime such as corruption, antitrust, data protection
issues as well as risks and violations regarding human rights and environmental obligations, or other
internal and statutory regulations. Whistleblowers can register on Speak up! with their names or stay
anonymous. All hints are treated as confidential. Even if their preferred language is not offered in the
reporting channel, whistleblowers can use any language to submit their report. Our whistleblowing
portal is operated by a third-party, who is hosting the portal on external, certified servers (located in
Germany) allowing whistleblowers to address hint to us on an anonymous, non-traceable basis.

Speak up! is accessible from every internet-enabled computer. Click here.

Contact the Investigations Office (post & e-mail)

At all times and in all languages, internal and external whistleblowers can report potential regulatory
violations, or risks related to human rights or environmental obligations, directly and confidentially to
colleagues at the TRATON Financial Services Investigations Office or to the TRATON Group’s
Investigations Office. The relevant teams are available to talk to you in person, on the phone or via

TRATON Financial Services
Investigations Office – Compliance Function
Kvarnbergagatan 14a
151 87 Södertälje, Sweden

Investigations Office
Hanauer Strasse 26
80992 Munich, Germany

Additional internal reporting channels
Whistleblowers always have the possibility to address their concerns to the following internal

  •  Direct manager
  •  Human resources/People and Culture function (local or central)
  •  Internal Audit
  •  Security
  •  Compliance Function (local or central)

The receiving function will forward the information to the dedicated whistleblowing functions, as set
out in our internal procedures.

24/7 Volkswagen whistleblower portal

Regulatory violations can also be reported via the 24/7 Whistleblower Hotline provided by
Volkswagen AG. The hotline is available around the clock and accepts hints concerning all brands of
the Volkswagen Group – if desired also anonymously. All hints concerning companies within the
TRATON Group received via the hotline are forwarded to the TRATON Investigation Office directly and
may in turn be forwarded to the TRATON Financial Services Investigations Office.

This is how you can reach the Whistleblower Hotline:

+ 800 444 46300* (international toll-free number)
+ 49 5361 946300 (chargeable number, if your local telephone provider does not support the toll-free

* Depending on the country you are calling from it is possible that the international toll-free hotline is not available since
some telephone network providers do not support the service. If so, please use the offered chargeable number or your
country specific number.


Toll-free number

Local telephone number







Slovak Republic






South Africa










0800 444 46300


Volkswagen ombudspersons

Volkswagen AG has authorized two external lawyers (Ombudspersons) who can assist to ensure that
hints are forwarded to the TRATON Investigation Office or TRATON Financial Services Investigations
Office – per request also anonymously.

Please find information on the Ombudspersons of Volkswagen AG here.

External reporting channels

We encourage reporting of misconduct via the internal reporting channels as described above.
However, in view of the EU Whistleblowing Directive, EU member states have defined (or will soon
define) designated authorities that accept reports on misconduct as external reporting channels.

Check on the following countries you are reporting from the following link

How we process your report?

At our Company, hints regarding potential regulatory violations can be reported by employees,
business partners, customers and other third parties through various channels, at any time, and in
any language. TRATON Financial Services Investigations Office ensure that the hints it receives are
appropriately investigated in a thorough, confidential and timely manner.

The qualified and experienced colleagues at the Investigation Office examine every report on
potential misconduct thoroughly and follow the process according to the applicable Group Policy
systematically. First, whistleblowers will get a confirmation of receipt from the Investigation Office,
which will then assess your report for potential legal risks. This includes clarifying questions about the
reported matter and gathering available facts particularly from the whistleblowers. If this initial
evaluation shows grounds for suspicion of a serious violation, an investigation by a dedicated
investigating unit will be started. Afterwards, the results of the investigation will be legally assessed
by the Investigation Office and appropriate measures will be recommended. If the hint points to a
less serious regulatory violation, the case may be handed over to a suitable body to investigate and
assess on their own, but with the chance to receive guidance from the Investigation Office.
Whistleblowers or involved employees can always contact the Investigation Office about the status
and the outcome of the procedure. The outcome will also be shared as far as legally possible
considering the need-to-know-principle. However, the processing time varies depending on the
subject of the procedure.

Potential violations of the Code of Conduct for Suppliers and Business Partners by business
partners/counter parties, suppliers, and other third parties, including risks and violations regarding
human rights and environmental obligations, can also be reported to the TRATON Financial Services
Investigation Office. The Investigation Office will inform the responsible departments, who will
process the reported matter accordingly. This particularly includes taking the necessary measures to
minimize or end violations and/or risks.

Find more information on the Rules of Procedure for the TRATON GROUP Complaints Procedure here. In addition to this, TRATON GROUP has published a Policy Statement on Human Rights here,
describing the expectations on the organization and suppliers to protect and respect human rights.

Data Protection for Whistleblowers: The TRATON Investigation Office collects and processes the
personal data you provide for the purpose of assessing and processing your reported hint. Further
information on data protection and the rights to which you are entitled can be found here.

Do you have any concern or feedback regarding our products or services?

If you have any questions or inquiries regarding our products or your vehicle, feedback or complaints
about services provided by us or our business partners (such as car dealerships or workshops), please
contact our local commercial teams.

Do you have further questions?

Please contact TRATON Financial Services Investigations Office in case of any questions or suggestions
for improvement concerning the whistleblowing system at any time. You can contact us at