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 to avoid or minimize potential risks due to regulatory violations, it is crucial that potential regulatory violations by employees or external partners are identified at an early stage, clarified, and stopped, and that disciplinary measures are applied where necessary. To encourage a speak-up culture and to detect potential wrongdoings, the TRATON GROUP operates a global independent, impartial, and confidential whistleblowing system managed in collaboration between the Brands and the TRATON Investigation Office. Besides the TRATON Investigation Office as central contact point for whistleblowers, some TRATON brands provide an Investigation Office Hub as brand contact point for whistleblowers.
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 such as the protection of whistleblowers and persons concerned of or supporting the investigation. We respect whistleblowers’ right to confidentiality, 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 serious regulatory violation.
Dedicated functions of concerned TRATON brands within Governance, Risk & Compliance, Security, 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 brand departments involved in whistleblowing and internal investigations work closely with colleagues at the TRATON Investigation Office, especially regarding potential serious regulatory violations.
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.
Whistleblowers worldwide can use the TRATON Speak up! tool, which is available around the clock in several languages to report hints on potential violations regarding white-collar crime such as corruption or antitrust law, 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 name 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 hints to us on an anonymous, non-traceable basis.
Speak up! is accessible from every Internet-enabled computer. Click here.At all times and in all languages, internal and external whistleblowers can report potential regulatory violations or risks related human rights or environmental obligations directly and confidentially to colleagues at the TRATON Investigation Office:
TRATON SE
Investigation Office
Hanauer Strasse 26
80992 Munich
Germany
E-mail: investigation-office@traton.com
The relevant teams are available to talk to you in person, on the phone, or via email.
Whistleblowers always have the possibility to adress their concerns to the following internal functions:
• Direct manager
• Human Resources/People and Culture function (local or central)
• Group Internal Audit
• Group Security
• Group Compliance/Local Compliance Officers
• Locally or regionally designated contact person for most of our legal entities based in the EU.
The receiving function will then forward the information to the dedicated whistleblowing functions, as set out in our internal procedures.
Regulatory violations can also be reported to the Volkswagen AG whistleblower hotline, where you can leave a voice message by phone 24 hours a day, 7 days a week.
After entering the phone number that is specific to the country you are in, you will be prompted to enter the organization code. You can then submit your report as a voice recording. Only a written transcript will be received by the Volkswagen Investigation Office. Dial back in to listen to the reply or further questions by the team.
Select a phone number from this list for your country or region and have the corresponding organizational code “122203” ready.
Volkswagen AG has authorized two external lawyers (Ombudspersons) who can assist or ensure that hints are forwarded to the TRATON Investigation Office – per request also anonymously.
Please find information on the Ombudspersons of Volkswagen AG here.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 also accept reports on misconduct as external reporting channels.
Check on the following countries you are reporting from the following linkAt our Company, hints regarding potential regulatory violations can be reported by employees, business partners/counter parties, customers, and other third parties through various channels, at any time, and in any language. Hints are then received by the TRATON Investigation Office, which ensure that thorough and appropriate investigations are carried out in a confidential and timely manner.
The qualified and experienced colleagues at the TRATON 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 TRATON 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 within the concerned TRATON brand will be started. Afterwards, the results of the investigation will be legally assessed by the TRATON 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 within the concerned TRATON brand to investigate and assess on their own, but with the chance to receive guidance from the TRATON Investigation Office. Whistleblowers or involved employees can always contact the TRATON 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 Investigation Office. The TRATON 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, 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.
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 customer care centers.
Please contact the TRATON Investigation Office in case of any questions or suggestions for improvement concerning the whistleblowing system at any time.
You can contact us at investigation-office@traton.com
