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  1. Principle and Code of Conduct
    1.    

      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  
    2. Code of Conduct for Business Partners
      1.    
        PAIG China expects compliance with applicable laws, respect for ethical values and sustainable action not only from its own employees, but also from its business partners. With this Code of Conduct for Business Partners, PAIG China defines the most essential principles to ensure compliance by business partners. We expect business partners to be responsible for their actions and agree to comply with the requirements of the Code of Conduct for Business Partners.   

         
        Attachment: Code of Conduct for Business Partners  
      2.    
        Attachment: Training Material for Code of Conduct for Business Partners  
  1. Integrity
    1.    
      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 
    1.    

      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
    1.    
      1. 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 PAIG China. The success of our company is based on Integrity and 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 PAIG China 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 PAIG China 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 and PAIG China 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.

       

      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.

       

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

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

      2. Do you have any concern or feedback regarding a PAIG China product or service?

      If you have any questions or inquiries regarding your new or used vehicle/feedback or complaints about services provided by PAIG China, please contact our dealers. [Locations - PAIG (China) Automobile Investment]. We kindly ask for your understanding that the Whistleblower System unfortunately cannot process customer complaints.

       

      3. 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. 

       
    2. Intake Channels
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        Local Hints Intake Channels
         

        PAIG China Investigation Office
        Email: compliance@paig.com.cn
        Hotline: +86-571 2827 2702 (Chinese and English)  
                    +86-571 2882 1125 (Chinese and English)
        Post:
        2333 Xixing Road
        Sei Ran Ri, Building No. 4, 19F
        Binjiang District
        310051 Hangzhou
        P. R. China

         
        Group Hints Intake Channels

         

        24/7 Hotline

        You can make a report at 365 days, 24 hours, using the 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.

         

        *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.

        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



        Online Reporting Channel

        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

        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 Ombudsperson you can find their contact details here: http://www.ombudsmen-of-volkswagen.com/

        E-mail

        You can get in contact with the Investigation Office of Volkswagen Group via e-mail:

        io@volkswagen.de

        Postal adress /in person 

        Central Investigation Office

        Postal address:

        Central Investigation Office

        Box 1717

        38436 Wolfsburg Germany

        In person:        

        Please make an appointment in advance writing an E-mail to io@volkswagen.de.

        Please note that Chinese laws and regulations limits or prohibits cross-border transfer from mainland China of certain Sensitive Information, including Personal Information, Important Data and Chinese State Secrets. Because the BKMS-Servers and Ombudspersons locate overseas, by submitting such information via the BKMS or Ombudspersons you might risk violating the applicable Chinese laws and regulations and may also bear the risk of being penalized by the competent Chinese authorities.

        Do you have further questions?

        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 give feedback to the Ombudsperson as independent body.
        Furthermore, our local Compliance Officer/responsible function can also be addressed in all matters of the Whistleblower System via compliance@paig.com.cn.

         

           
           
           
*Please visit the webpage of Porsche Holding Salzburg for more information: https://www.porsche-holding.com/en/company/compliance-integrity/principles