Integrity and Compliance at CUPRA

For the Volkswagen Group, compliance is adherence to legal requirements, internal corporate policies, ethical principles, and self-imposed values for the protection of the company. In the long term, a company can only be successful if it acts with integrity, complies with statutory provisions worldwide, and stands by its voluntary undertakings and ethical principles, even when this is the harder choice.  We remain committed to this principle and compliance must be second nature to all Volkswagen Group employees.  

This section further explores the following compliance topics:

• The Modern Slavery Reporting Requirements
  
• The Code of Conduct for Employees
• The Code of Conduct for Business Partners
• The Whistleblower System

Complying with statutory regulations and internal rules, and the principles laid down in our Code of Conduct and Code of Conduct for Business Partners, has top priority at CUPRA Australia. The success of our company is based on Integrity & Compliance. To meet these standards, it is important to learn of potential employee or supplier misconduct and to put a stop to it. Therefore, we entrusted the Central Investigation Office to operate an independent, impartial and confidential Whistleblower System on our behalf.

A key pillar of our Whistleblower System is the principle of procedural fairness. It also guarantees the greatest possible protection for whistleblowers, persons implicated and employees contributing to the investigation of reported misconduct.

This also includes the option of anonymous reporting and communication. As part of our investigation, we will not perform any steps that may identify anonymous whistleblowers. Retaliation against whistleblowers and any persons who contribute to investigations at CUPRA Australia will not be tolerated. Persons implicated are presumed innocent until the violation is proven. Investigations will be conducted with the utmost confidentiality. The information will be processed in a fair, fast and protected process.

Our qualified and experienced colleagues at the Central Investigation Office examine every report for potential misconduct by an employee thoroughly and follow it up systematically.  First, you will get a confirmation of receipt. The Central Investigation Office will then assess your report. This includes gathering facts particularly from the whistleblower. Only if this initial evaluation shows grounds for suspicion of a violation, an investigation by a dedicated Investigating Unit will commence. Afterwards, the results of the investigation will be assessed by the Central Investigation Office and appropriate measures will be recommended. Information about the status* and the outcome of the procedure will be given to you without undue delay.

Potential violations of the Code of Conduct for Business Partners by suppliers, including serious risks and violations of human rights and environment by direct and indirect suppliers, can also be reported to the Central Investigation Office - as well as reports requiring otherwise immediate action. The Investigation Office will inform the responsible departments, who will process the issue accordingly. This particularly includes taking the necessary measures to minimise or end violations and/or risks.

Further information on the procedural principles of the Volkswagen Group Complaints Procedure can be viewed here.

_{*The processing time varies depending on the subject of the procedure.}