WHISTLEBLOWING

Integrity and compliance with laws and regulations are top priorities and cornerstones of Traton Financial Services’ corporate culture. To encourage a speak-up culture and detect potential wrongdoings, we provide a global whistleblowing system. The whistleblowing system and procedures for conducting internal investigations are governed by our internal policies and procedures and always in accordance with our values. 

Traton Financial Services’ whistleblowing system is based on fundamental principles such as protection of the whistleblower and the whistleblower’s right to anonymity, as well as presumption of innocence and fairness of investigations towards persons implicated. Information received via the whistleblowing system will be treated with the highest level of confidentiality. Dedicated functions within Traton Financial Services and TRATON Group handle incoming hints and internal investigations. An investigation is only initiated after very careful examination of the facts and reasonable suspicion of a regulatory violation. 
 
Persons who are aware of potential misconduct, in particular violations of laws and our Code of Conduct, committed by Traton Financial Services employees in connection with performing their duties at Traton Financial Services, are encouraged to speak up and report at any time and in any language. There are several reporting channels available:
 

Traton Financial Services reporting channels

• Direct manager
• HR function (local or central)
• Traton Financial Services Compliance Function (whistleblower@tratonfs.com)
• Group Internal Audit

If a manager or an HR function receives a whistleblowing hint, the information must be escalated to the dedicated whistleblowing functions, as set out in our internal procedures.

TRATON/VW reporting channels

• TRATON Investigation Office (Investigation-Office@traton.com).  Whistleblowers can also contact the TRATON Investigation Office in any language via mail on its address below.
• Speak up! portal: https://www.bkms-system.net/TRATON. The portal is available in several languages, and even if a preferred language is not offered in the portal, the whistleblower can use any language to submit its report. The whistleblower can also choose to submit the hint via Speak up! anonymously. Files related to the incident can be uploaded on the secure portal. The TRATON Investigation Office will contact the whistleblower for further actions or questions via the Speak up! portal, which guarantee anonymity if requested.
• VW whistleblower hotline: suspected regulatory violations can also be reported via the Volkswagen AG whistleblower hotline. The hotline is available around the clock and accepts tip-offs from all brands of the Volkswagen Group — if desired also anonymously. All tip-offs concerning Traton Financial Services received via the hotline are forwarded to the TRATON Investigation Office.

This is how the whistleblower hotline can be reached:

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

Additionally, at all times in all languages, internal and external whistleblowers can report potential regulatory violations directly and confidentially to colleagues at the TRATON Investigation Office or to Traton Financial Services Compliance Function:

It is also possible to contact the  Ombudspersons of the Volkswagen Group. Further information about the Ombudspersons is available here. 
 
As regards whistleblowing in Sweden, certain limitations apply regarding reporting through specifically established reporting channels, such as direct reporting to the Investigation Office at TRATON, the Speak Up! portal and the 24/7 Volkswagen Whistleblower hotline numbers. The TRATON/VW Reporting Channels may only be used for reporting if the information relates to persons in key-positions or management positions within Traton Financial Services or VW and the information includes suspicions that the person in question has been participating in serious irregularities relating to accounting, internal accounting controls, auditing matters, fight against bribery, anti-money laundering and terrorist financing, banking and financial crime or other serious irregularities relating to Traton Financial Services’ vital interest or individuals life and health. The Traton Financial Services Reporting Channels can always be used for reporting in Sweden.
 
Traton Financial Services will treat all reports on potential misconduct seriously. However, reports in bad faith containing knowingly false and untrue allegations against Traton Financial Services’ employees are not tolerated. Making such reports are potential misconduct, which can be subject to internal investigations and potential sanctions against the person making them.