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  3. Integrity & Compliance


  1. Principle and Code of Conduct
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      Porsche Holding Salzburg (hereinafter referred to as Porsche Holding) has worked to achieve its outstanding reputation during the 70 years of its existence in over 20 European countries, in China, South America, Malaysia, Singapore, etc. Social responsibility and a high standard of ethics have made Porsche Holding what it is today: the largest automotive distributor in Europe.

      As a company with operations around the globe, to Porsche Holding compliance means that its employees not only abide by current law but also adhere to a set of moral principles that go beyond merely observing the law. These principles have been set down in the company's own Code of Conduct. Naturally they apply to all levels of the Group and to all countries where Porsche Holding operates. This includes the important member of Porsche Holding, PAIG (China) Automobile Investment Co., Ltd. and its affiliated dealers (hereinafter jointly referred to as “PAIG China”). PAIG China firmly believes that compliance and integrity have always been the cornerstone of our road to success, and should also be the basic principles to be observed in all future decisions.

      Attachment: Code of Counduct.pdf  
  1. Integrity
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      Integrity means acting out of conviction with responsibility and steadfastness. A company can only have integrity when its people conduct themselves with integrity. Thus PAIG China is committed to fostering a strong and sincere culture of integrity through wide-ranging measures and activities. Integrity describes our inner attitude towards regulations, guidelines and values. Such values of integrity apply to every one of us, regardless of our function, division, role and task.
  2. Compliance 
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      Compliance means complying with laws, regulations, internal rules and policies, as well as ensuring implementation of aforesaid. Compliance is not just a matter for management, but the responsibility of all employees. Key topics of compliance include anti-trust law, conflict of interest, money laundering, data protection, product liability, fraud by employees, corruption, securities law/insider trading, etc. Among others, anti-corruption is the top priority in the integrity work.

      Corruption is not a trivial matter as it damages the interests of the company and employees. Porsche Holding attaches great importance to the issue of corruption and hopes to continuously improve its understanding of fighting against corruption. PAIG China adheres to the attitude of Porsche Holding to crack down on corruption, upholds anti-corruption spirit, and has formulated corresponding anti-corruption policies and reporting systems. Any person, including ordinary employees, senior executives, partners, can report potential corruption through the reporting channels provided by the ombudsman or reporting system.

      In addition to anti-corruption, PAIG China is also committed to creating an anti-trust and anti-money laundering compliance environment. We are fully aware that a fair market competition environment is beneficial to society, companies, industries and consumption. Therefore, we strive to make our own behavior conform to the relevant laws, regulations and policies. We have also promulgated and implemented corresponding anti-trust and anti-money laundering compliance policies within the Group, and are trying to help create a fair and transparent market competition environment.

       
  3. Whistleblower System
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      Complying with statutory regulations and internal rules has top priority at PAIG China. We can only avoid damage to our company, our employees and business partners if rules and standards are respected. Consequently, misconduct must be recognized swiftly, processed and immediately remedied. That calls for vigilance on the part of everyone along with a willingness to draw attention to possible Serious Regulatory Violations on the basis of Reasonable Suspicion. We also value information of this nature from business partners, customers and other third parties. Reports to the Investigation Office via mail or email can be made at any time and in any language. The Whistleblower System guarantees the greatest possible protection for whistleblowers and Persons Implicated subject to the applicable laws and regulations. An investigation is only initiated after very careful examination of the facts and Reasonable Suspicion of a Regulatory Violation. There will be strict confidentiality and secrecy throughout the investigative process. Information will be reviewed fairly, promptly and in a sensitive manner.

      To better implement the whistleblower policy, the Central Investigation Office was established, and Ombudspersons were appointed, to receive and process reports of Regulatory Violations affecting the Volkswagen Group. PAIG China has also established its local investigation office to receive and process reports.

       
    2. Intake Channels
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        Group Hints Intake Channels

         
        Central Investigation Office
        Email: io@volkswagen.de
        Hotline (24/7):
        International toll-free number:
        +800 444 46300
        If your local telephone provider does not support the toll-free service, you can call the following chargeable number:
        +49 5361 946300


        Mailbox:
        Post Box 1717, 38436 Wolfsburg (downtown), Germany

        Address:
        Porschestraße 26–30, 38440 Wolfsburg (downtown), Germany

        BKMS System:
        You have the option of using this internet-based communication platform to contact the Investigation Office, exchange documents and conduct a dialog with the lawyers via a separate mailbox. This system is confidential and protected. Whistleblowers can decide for themselves whether they wish to give their names. If you would like to send a confidential report to the lawyers in the Investigation Office, you can use the below channel to submit a report:
        http://www.bkms-system.com/vw
        Important Notice: 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.
         
           
        Ombudspersons: (“Ombudsman” is a term taken from the Swedish word for mediator or legal representative. Dr. Rainer Buchertand Thomas Rohrbach, the external ombudspersons appointed by the Volkswagen Group, act as special counsel to accept reports of potential statutory or internal violation of regulations or any other kind of harmful conduct in the Group, and to review these with respect to plausibility and substantiality. They consult with the whistleblower if necessary and if the identity of the whistleblower is known. Finally, they forward all the information that has been agreed with the whistleblower to the Investigation Office for further processing.)

        Dr. Rainer Buchert:
        • Phone: +49-69-71033330 or
        +49-6105-921355
        • Fax: +49-69-71034444
        • E-mail: dr-buchert@dr-buchert.de
        • Postal address: Bleidenstraße 1, 60311 Frankfurt am Main, Germany

        Thomas Rohrbach:
        • Phone: +49-69-65300356
        • Fax: +49-69-65009523
        • E-mail: rohrbach@ra-rohrbach.de
        • Postal address: Wildgäßchen 4, 60599 Frankfurt am Main, Germany




        You can also find their contact point on the following homepage:
        http://www.ombudsmen-of-volkswagen.com/
        All information is treated as confidential and it is the whistleblower who decides whether he or she wishes to protect his or her identity vis-àvis the Group. The ombudspersons appointed by the Group ensure that reports from whistleblowers who do not wish to be identified by the Company are forwarded to the Investigation Office anonymously.
        Local Hints Intake Channels
         
        PAIG China Investigation Office
        Email: compliance@paig.com.cn
        Hotline: +86-571 2882 8791 (Chinese and English)
        Post:
        2333 Xixing Road
        Sei Ran Ri, Building No. 4, 19F
        Binjiang District
        310051 Hangzhou
        P. R. China