Anti-slavery and human trafficking statement
This statement is made pursuant to s.54 of the Modern Slavery Act 2015. It sets out the steps that Volkswagen Financial Services (UK) Limited (“VWFS”) has taken, for the financial year ended 31st December 2022 (covering the period 1st January 2021 – 31st December 2022), to ensure that modern slavery and human trafficking is not taking place within its business or supply chain.
VWFS has a zero-tolerance approach to any form of modern slavery. VWFS is committed to acting in an ethical manner, with integrity and transparency in all business dealings and is committed to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within its business or supply chain.
As part of the Volkswagen group of companies, VWFS adheres to the Volkswagen Group Code of Conduct (“Code of Conduct”). The Code of Conduct offers VWFS employees guidance on proper conduct and support in overcoming legal and ethical challenges. Compliance with internationally recognised human rights is part of this and VWFS attaches great importance to ensuring that its corporate activities are in keeping with values set out in such international conventions and guidelines on human rights.
The Volkswagen Group Code of Conduct
The Code of Conduct helps employees observe existing company rules at their workplace, as business partners and as members of society, providing them with practical guidance, assistance and advice. The rejection of all forms of modern slavery and human trafficking is an integral part of the Code of Conduct. In addition, we base our actions on the principles of the UN Global Compact, the OECD Guidelines for Multinational Enterprises and the requirements of the International Labour Organisation (ILO).
The Code of Conduct is available at all times to all employees on the Intranet and also to third parties and the public via the Volkswagen AG website, and is continuously communicated in digital and print media as well as at internal company events. Regular training on the Code of Conduct is mandatory for all employees. Additionally, members of the senior management confirm their knowledge and responsibility with regard to the Code of Conduct each year following a risk based approach.
The Volkswagen Group has also specially formulated the Code of Conduct for Business Partners. This details the Group’s expectations regarding the attitude and conduct of business partners in their corporate activities, particularly with regard to suppliers and sales partners. The requirements are regarded as the basis for successfully shaping the business relationship between the Volkswagen Group and its partners. They include observance of human rights, such as the prohibition of child labour, human trafficking and slavery, as well as ensuring environmental protection and preventing corruption.
VWFS expects its employees, retailers, suppliers and business partners and each of their employees to act responsibly and comply with the requirements of the Code of Conduct.
VWFS has a whistleblowing policy intended to encourage and enable staff to report suspected wrongdoing and raise serious concerns within the workplace. VWFS employees, business partners and other third parties are provided with internal and external contact points to report on legal and regulatory violations, including suspicions of human rights violations, in connection with the Volkswagen Group. VWFS is committed to ensuring that any staff concerns are taken seriously and properly investigated.
Details of the Volkswagen Group whistleblowing system are publicly available via the Volkswagen AG website.
Qualification of employees
VWFS treats its employees with respect and dignity and operates internal policies to ensure that it is conducting its business in an ethical and transparent manner. VWFS’s policies and procedures are reviewed and updated on an annual basis and are available to staff and on-site contractors via its internal policy and procedure hub.
VWFS’s recruitment policies ensure that employee screening checks are carried out to ensure that the individual is legally entitled to work in the UK to safeguard against human trafficking or individuals being forced to work against their will, and expects the same of each of its retailers, suppliers and business partners. Employees are free to leave their employment after reasonable notice and are not required to lodge deposits of money or identity papers with their employer. The compensation and benefits paid to employees for a normal working week comply at least with guaranteed minimum legal requirements, including minimum wage legislation and working hours comply at least with the national legal standards and are not excessive.
VWFS does not act as a producer or manufacturer of physical goods and has no supply chain in relation to such activities. The majority of VWFS’s suppliers are located in the UK.
VWFS requires its suppliers to comply with the Volkswagen Group requirements regarding sustainability in its relationships with business partners (Code of Conduct for Business Partners) available via the Volkswagen Group website which formulates VWFS’s expectations towards the conduct of business partners in relation to the central environment, social and compliance standards to ensure compliance with VWFS’s sustainability standards along the entire supply chain. The bases for these requirements are the principles of the UN Global Compact, the OECD Guidelines for Multinational Enterprises, as well as the conventions of the International Labour Organisation (ILO). We review and develop our suppliers’ sustainability performance on an ongoing basis. This includes various measures such as the SAQ self-assessment questionnaire developed by the Initiative DRIVE Sustainability, sustainability as part of quality audits and focused sustainability audits of suppliers.
All procurement is based on objective and fair criteria that reflect the principles of non-discrimination, equal treatment, transparency, procedural fairness, mutual recognition and proportionality. In addition to carrying out due diligence on prospective suppliers, as part of the tender process prospective suppliers are expected to confirm they are aware of VWFS’s sustainability requirements, their agreement to VWFS’s contractual terms and conditions, and that they will comply with VWFS’s policies and procedures and provide the services in accordance with all applicable laws and regulations. VWFS expects its suppliers to exercise due diligence along their supply chains.
VWFS considers compliance with the Code of Conduct to be essential to its contractual relationships with suppliers and business partners.
Monitoring and audit
VWFS conducts routine risk assessments of its retailer network to identify risks presented in different segments and an escalation procedure is in place if serious issues are identified, which may include referral to VWFS’s compliance function.
VWFS regularly monitors key suppliers at supplier performance review meetings and any necessary actions and issues, including non-compliance with the Code of Conduct or laws or regulations, are tracked by the relevant operational area and reviewed at the next performance review meeting. VWFS will work to remedy any areas in which suppliers do not meet VWFS standards or do not comply with relevant laws or regulations. In addition, VWFS has the right to audit suppliers for compliance with applicable laws, including the supplier’s obligations to comply with all laws relating to slavery and human trafficking.
VWFS has an autonomous and independent internal audit function which has an unrestricted right to obtain information and to conduct audits within VWFS to determine whether statutory obligations are being fulfilled and reports its findings to the senior managers and directors of VWFS. If there is any specific suspicion of violations of laws, employees are expected to inform internal audit.
This statement has been approved by the board of directors of VWFS on 9th June 2023, who will review and update it as necessary on an annual basis.
Chief Financial Officer
Volkswagen Financial Services (UK) Limited
9th June 2023