Compliance

For the Volkswagen Group Charging GmbH, sustainability means pursuing economic, social and ecological objectives simultaneously and with equal energy. It is our aim to create lasting values, offer good working conditions, and conserve resources and the environment.

With our sustainability concept we want to ensure that opportunities and risks associated with our environmental, social and governance activities are identified as early as possible at every stage of the value creation process. In keeping with this aim, we are determined that our corporate social responsibility (CSR) activities will have a lasting, positive impact on the Company’s value and reputation.

Therefore Elli combines all topics regarding compliance, integrity and information security with a very holistic and sustainable mindset.

  1. Code of Conduct
  2. Compliance
  3. Integrity statement
  4. How we handle Risk Management
  5. Whistleblower System
  6. The Volkswagen Group Sustainability Report 2020
  7. Information Security
  8. Slavery and Human Trafficking Statement

1. Code of conduct

The Code of Conduct sums up fundamental principles underlying the conduct of Volkswagen Group Charging GmbH employees and is instrumental in responding to legal and ethical challenges.  The Volkswagen Group Charging GmbH´s reputation is a core value relying on the resolve shown by employees around the world to act in keeping with our Code of Conduct and all laws. The “Code of Conduct at Volkswagen Group Charging GmbH” has become part and parcel of our corporate culture. Download the Code of Conduct and the Code of Conduct for Business Partners for further information

2. Compliance

The Volkswagen Group Charging GmbH is rigorous in its duty of adherence to legislation, internal regulations, ethical principles and other voluntary commitments. Corporate Compliance reaches beyond business relations to embrace activities both within and outside the group. This is the Volkswagen Group Charging GmbH's way of signalling loudly an clearly that its conduct will echo the requirements of legal and ethical rules on competition, finances and taxes, environmental protection and employee relations, including the safeguarding of equal opportunities.

2.1 The aim of  compliance within Volkswagen Group Charging GmbH

Our corporate Goal to enable the Volkswagen Group for electric life makes an active contribution to the Group strategy. Therefore, it’s even more important that we keep in mind that our business can only be successful if we act with integrity and compliance and pay attention to the worldwide applicable laws and regulations as well as ethical principles. To ensure this, we developed together with the Group a Compliance Management System (CMS). The central focus of our compliance  work lies in the prevention of active and passive corruption, embezzlement, fraud and money laundering. In general, the compliance organization aims at setting up the business of Elli in a clearly defined and lawful manner.

Basic outline of the Compliance Management System of the Volkswagen Group and Strategic set up of Elli’s CMS Complying with international regulations and dealing fairly with business partners and competitors are among the most important principles of our company. Elli does not merely abide by legal and internal rules. Voluntary commitments and ethical principles also form an integral part of our corporate culture which are based on our corporate values.

3. Integrity statement

Commitments of the executive management of Volkswagen Group Charging GmbH – Integrity & Compliance

As the executive management of Volkswagen Group Charging GmbH we believe that Integrity & Compliance are fundamental building blocks of sustainable success. Therefore, we make the following commitments:

  1. We will act with honesty at all times and adhere to the highest standards of moral and ethical values and principles through our professional behavior.
  2. We will demonstrate our understanding of these values and principles and uphold them in every action and decision to sustain a culture that is based on ethical conduct.
  3. We will hold ourselves and one another accountable for our words and our actions, and for consistency of same.
  4. We accept our responsibilities and subject ourselves to the highest standards of trust
  5. We will embrace human diversity and inclusiveness and we will uphold the highest standards of fairness, act as responsible citizens, respect equality and the rights of others, and treat all individuals with dignity.
  6. We will operate within the letter and spirit of the law and prescribed policies, and will strive to avoid impropriety or conflict of interest.
  7. We will promote, protect and value the reporting of concerns and suspected wrongdoing, and will take action when wrongdoing occurs.
  8. If you have concerns we encourage you to speak up as our Whistleblowing Policy allows you to do so without fear of victimization, subsequent discrimination or disadvantage.

4. Risk Management

The Volkswagen Group Charging GmbH’s risk management structure is built on a common principle of risk management within the Volkswagen Group complying with German legislative requirements. Risk management, as an operational component of the corporate process, must pinpoint individual risks down to the last detail, assess how great they are, take action to eliminate them, and document how effective the response has been.

5. Our Whistleblower System

Complying with statutory regulations and internal rules and the principles laid down in our Code of Conduct and the Code of Conduct for Business Partners, has top priority at Elli. The success of our company is based on Integrity and Compliance. To meet this standard, it is important to learn of potential employee 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 offering opportunities for anonymous reporting and communication. We assure not to perform any steps in order to identify anonymous whistleblowers, who do not misuse our Whistleblower System. Retaliation of whistleblowers and all persons who contribute to investigations at Elli 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.

How do we process your report?

The qualified and experienced colleagues at the Investigation Office examine every report for potential misconduct by a Volkswagen Group employee thoroughly and follow it up systematically.  First, you will get a confirmation of  receipt. The Investigation Office then assesses 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 be started. Afterwards, the results of the investigation will be assessed by the 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. The processing time varies dependingon the subject of the procedure.

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 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 minimize or end violations and/or risks.

Find more information on the procedural principles of the Volkswagen Group Complaints Procedure here.

Do you have any concern or feedback regarding an Elli product or service?

If you have any questions or inquiries regarding our products, feedback or complaints about services provided by Elli or our business partners (e.g. car dealerships, workshops), please contact our Customer Care Contact via EMAIL. We kindly ask for your understanding that the Whistleblower System unfortunately cannot process customer complaints.

Making a report to our Whistleblower System

The Whistleblower System offers various channels to report potential employee misconduct that allow a swift review and reaction by our company if necessary. However, this does not affect the statutory right to contact designated authorities as described below.

Online Reporting Channel

You have the option of using an internet-based communication platform to contact the Investigation Office in many languages. This system is confidential and tecnically secured.

Even if your preferred language is not offered in the reporting channel, you can use any language to submit your report. You can also contact the Investigation Office in any language via e-mail or mail. For Access click here.

24/7 Hotline

You can make a report at 365 days, 24 hours, using the international toll-free number: +800 444 46300. 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.

If your local telephone provider does not support the toll-free service, you can call the following chargeable number: +49 5361 946300.

Country
Toll Free Number
Local Number
Brazil
0800-5912743
021-23911381
Mexico
001-800-4610242
0155-71000355
Slovak Republic
0800-002576
02-33325602
USA
833-6571574
908-2198092
South Africa
0800-994983
021-1003533
Malaysia
1-800-819523
0154-600099
Argentina
0800-6662992
011-52528632
Germany
0800 444 46300
05361-946300

E-Mail

You can get in contact with the Investigation Office of the Volkswagen Group via E-Mail. io@volkswagen.de

Ombudspersons of the Volkswagen Group

The Volkswagen Group has appointed external lawyers to act as Ombudspersons. They advise on the Whistleblower System or ensure that reports from whistleblowers are forwarded anonymously to the Investigation Office if desired.

If you want to get in contact with the Ombudspersons you can find their contact details here: http://www.ombudsmen-of-volkswagen.com/

Postaladdress and in person​​​​​​​

Postal address:

Central Investigation Office
Box 1717
38436 Wolfsburg
Germany

In person:

Please make an appointment in advance writing an e-mail to io---AT---volkswagen.de

External Reporting Channel for Germany

The following German government-appointed agency also accepts tips about potential misconduct as an external reporting channel: Federal Office of Justice BfJ - Hinweisgeberstelle (Bundesjustizamt)

Do you have further questions?

Do you have further questions or do you need a local contact?

Questions or suggestions for improvement concerning the Whistleblower System can also be addressed to the Investigation Office.

If you have been interviewed in terms of an investigation, you have the possibility to givefeedback to the Ombudsperson as independent body.

Furthermore, our local Compliance Officer can also be addressed in all matters of the Whistleblower System via  compliances@elli.eco.

6. Sustainability

The Volkswagen Group Sustainability Report

7. Information Security

Elli is serious on information security. Since 2020 we have been certified according to the ISO 27001 standard. This year we will migrate to the latest release ISO 27001:2022 to further strengthen our measures to ensure availability, integrity and confidentiality of information.

To view the official certificate click here. To learn more about our infosec activities contact us.

8. Slavery and Human Trafficking Statement

This statement has been prepared in accordance with section 54 of the United Kingdom Modern Slavery Act 2015. In particular, it sets out the measures implemented across the Group to prevent forms of modern slavery and human trafficking.

Slavery and Human Trafficking Statement Volkswagen Group Charging GmbH