Integrity & Compliance
The principles of governance at Quest One
As a company Quest One has a corporate responsibility to its customers, employees, investors, and the public. This corporate responsibility includes complying with laws everywhere and always, respecting ethical values and acting sustainably. Integrity and compliance are a fundamental part of the Quest One strategy and are practiced at all levels of the company and by all employees — the management, executives and all other employees.
Quest One GmbH is integrated into an Integrity & Compliance Management System. The integrity and compliance program addresses integrity as well as white collar crime, in particular anti-corruption, anti-money laundering, and antitrust law. The group-wide Integrity and Compliance Program is designed to
- prevent compliance violations (prevention),
- detect as early as possible compliance violations that may arise despite preventative measures (detection),
- and respond quickly and efficiently to any compliance violations (response).
Prevention
The Compliance Organization aims to further establish and promote awareness and understanding of responsible and ethical conduct among all Quest One employees, suppliers, and business partners. To prevent compliance violations, a wide range of measures has been implemented:
Code of Conduct
The Quest One Code of Conduct applies to all Quest One employees — the management, executives and all other employees. The Code of Conduct is at the heart of Quest One’s corporate culture and sets forth specific and binding guidelines for situations in which managers and employees should pay particular attention to acting responsibly. The Code of Conduct uses examples to describe how conflict situations can be addressed in everyday business.
Code of Conduct for Business Partners
Quest One expects its business partners and their employees to respect laws and behave responsibly and with integrity, everywhere and always. That is why Quest One has a Code of Conduct for Business Partners, which communicates the ethical standards that Quest One requires suppliers and business partners to uphold.
Communication
The Compliance Organization continuously communicates across all levels of the organization. Integrity and compliance topics are regularly featured in Quest One’s company media, such as the intranet. In addition, the Compliance Organization informs and advises managers and other employees through trainings, a helpdesk service, and internal conferences and meetings.
Compliance policies
Quest One has compliance policies, which establish requirements related to anticorruption, antitrust law, the prevention of money laundering and terrorism financing, and Business Partner Integrity. These policies contain binding rules for all employees throughout the Group.
Training program
Quest One has a robust Integrity and Compliance training program that covers all operations and employees worldwide. Key content includes information about the Code of Conduct and the Compliance Organization.
Exchange of experiences with experts
The functions responsible for integrity and compliance regularly participate in exchange formats on integrity and compliance topics with experts from industry and academia. By participating in external compliance initiatives, Quest One supports and promotes integrity and compliance initiatives both independently and in partnership with other companies.
Helpdesk
Employees can contact the Compliance Organization at any time by phone or email with questions related to integrity and compliance. Insights gained from inquiries help identify risks, trends, and the need for preventive measures.
Monitoring
To ensure the sustainability of the program, the Compliance Organization continuously reviews the Program’s effectiveness and efficiency, by tracking the implementation of measures and projects.
Tone from the Top
The Executive Board of the Quest One is aware of its responsibility for integrity and compliance and is committed to fulfilling this responsibility. Quest One’s management and executives consider integrity and compliance to be an integral part of the corporate strategy.
Detection
The occurrence of legal violations within Quest One can lead to considerable risks for the Quest One GmbH and the affected employees. Integrity and compliance with the law therefore have the highest priority within the Quest One GmbH. In order to guarantee these values, Quest One has created clear and transparent processes that ensure that violations of the law are identified, clarified and immediately remedied internally.
Compliance Risk Analyses
The Compliance Organization carries out periodic group-wide compliance risk analysis. The risk analysis takes into account information such as the number and size of individual Group companies, the business model, the customer and sales structure, country risk, and the structure of competition in the local market. In addition, the implementation of compliance measures and controls in the reviewed companies are audited internally.
Mergers and acquisitions (M&A)
To identify, prevent, and mitigate compliance risks that may arise for Quest One from the acquisition or divestiture of equity interests in companies at an early stage, the compliance organization is involved in M&A projects. As part of these projects, compliance due diligence reviews are conducted on the companies involved in order to systematically identify and assess potential compliance risks.
Whistleblower system
Quest One offers a secure whistleblower system for providing information on potential compliance violations, which is accessible to all, employees, customers, suppliers and other business partners. This allows anonymous, safe, and confidential sharing of such information at any time and from anywhere in the world. Tip-offs are forwarded to an independent unit for investigation. All whistleblowers who acted in good faith are protected against discrimination and retaliation. You can find more information about the whistleblowing system here:
www.volkswagenag.com/hint
Response and resolute accountability
Quest One has zero tolerance for compliance breaches. The right response to compliance violations and misconduct is essential for minimizing the negative impact of any breach, by holding those responsible accountable, and ensuring that our commitment to doing business with integrity remains firm.
Investigations by authorities
Quest One is also committed to cooperating closely with the responsible authorities. Quest One has a guideline for employees which emphasizes the importance of openness, transparency, and cooperation with authorities.
Continuous improvement of the Integrity and Compliance Program
The Compliance Organization of Quest One continuously develops and improves the Integrity and Compliance Program.
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 Quest One. The success of our company is based on Integrity and Compliance. To meet this standard, it is important to learn about potential employee or supplier misconduct and to put a stop to it. Therefore, we entrusted the Central Investigation Office of Volkswagen AG 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 Quest One 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 Central 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 Central 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 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 Central 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.
More information on the respective procedural principles can be found here.
*The processing time varies depending on the subject of the procedure.
What kind of report do you want to submit?
A report of potential misconduct to our Whistleblower System
hThe Whistleblower System offers various channels for reporting potential misconduct by Quest One employees, violations of the Code of Conduct for Business Partners or serious risks and violations of human rights and environment in our Supply Chain. However, this does not affect the statutory right to contact designated authorities as described below.
E-Mail
The Central Investigation Office of Quest One can be reached via E-mail (in any language): io@volkswagen.de.
POSTAL ADRESS/IN PERSON
Postal address:
Volkswagen AG, Central Investigation Office
Box 1717
Berliner Ring 2
38436 Wolfsburg
Germany
In person:
Please make an appointment in advance by writing an email to: io@volkswagen.de.
OMBUDSPERSONS
Volkswagen AG 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 Central Investigation Office if desired.
If you want to get in contact with the Ombudsperson you can find their contact details here: http://www.ombudsmen-of-volkswagen.com/
ONLINE REPORTING CHANNEL
You have the option of using a web-based communication platform to contact the Investigation Office in more than 65 languages. This system is confidential and technically secured and allows you to submit reports anonymously.
You can find detailed instructions on how to make reports online, by app or by phone here.
Voice intake by phone
You can leave us a voice message by phone 24 hours a day, 7 days a week. After entering the phone number (specific to the country you are in), you will be prompted to enter the organization code. Then, you can submit your report as a voice recording. Only a written transcript will be received by the Central Investigation Office. Dial back in to listen to the reply or further questions by our team.
Select a phone number from this list for your country or region and have the corresponding organizational code 122203 ready.
App “SpeakUp – Listen for a change”
You can also download the app “SpeakUp“ by People Intouch (personal devices only) to access the secure reporting system. To download the app, you can scan the following QR code.
Through this app, you can submit your report in writing or leave a voice message (also anonymously). You will need the organization code 122203. Alternatively, you can scan the following QR code:
Log back in to see our team’s reply or answer 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 Central Investigation Office. In addition, a central compliance contact point is available at compliance@questone.com for all matters related to the whistleblower system.
External Reporting Channels
We encourage reporting of misconduct via the internal reporting channels. 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.
An overview of these external reporting channels is available under this link.
External Reporting Channels for Germany
The German government has defined a designated authority, that also accepts reports on misconduct as external reporting channel. The external reporting channel is the Federal Office of Justice (Bundesamt für Justiz) (BfJ - Hinweisgeberstelle (bundesjustizamt.de).
