BKMS System
Volkswagen Aktiengesellschaft
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Protection. Fairness. Trust.

You want to report a violation. The following pages provide a technical area which only you and Volkswagen can access for submitting a report. You can submit your information to Volkswagen AG’s Investigation Office in confidence. Your report will be handled by a team of specialist and experienced lawyers.

We respect your decision if you do not wish to provide your name. If this is the case, you can set up a special secured postbox in order to communicate with us. This is important because questions often arise which we will need your help to clarify, and which may prove decisive in how the report is handled.

You can report all violations committed by employees of the Volkswagen Group in connection with their employment.

Such violations can be breaches of legislation or internal regulations. Please note that we cannot handle any questions you may have about customer service in relation to your vehicle. Please direct any such queries to Customer Care.

In case of violations in the context of data protection regulations, we would like to ask you to contact the Data-Breach-Hotline (05361-9-28479) of Volkswagen AG.

Volkswagen AG is committed to protecting whistleblowers. We do not tolerate any bullying or discrimination against whistleblowers. The suspected person is presumed innocent until convicted of a violation.

If you would like to send your first report, please click here:
If you have already set up a postbox, you may login here:
  • Why should I submit a report?

    The aim is to avert damage to the company. Regulatory violations damage the company, and individual misconduct comes at a price for the entire workforce. Volkswagen’s good reputation and the trust of our customers and business partners are all based on integrity and compliance with legislation and regulations. At the same time, compliance has a considerable impact on the wellbeing of the company’s employees and on achieving long-term economic success. Everyone must play their part in achieving this, and in recognising any legal or regulatory violations as quickly as possible, and ensuring that they are rectified or punished. We are reliant on your willingness to report possible irregularities and violations wherever reasonable suspicion exists. It is vital to ensure that our company is able to investigate such reports in a rapid and objective fashion.

  • What can I report?

    You can report information about any violations of legislation and internal regulations (e.g. employment contracts, Code of Conduct, guidelines) committed by Volkswagen employees to the Investigation Office.

    As a result of the agreements concluded between Volkswagen and the US government in relation to the diesel issue, the following violations are of particular interest to the Investigation Office:

    • Actual and potential violations of the segregation of duties of production development and the official registration of motor vehicles
    • Actual and potential violations in portable emissions measurement system (PEMS) testing
    • Actual and potential violations of the Code of Conduct
    • Actual and potential violations of internal controls and in relation to audit issues, including but not limited to the rules and procedures listed in the Manual of Golden Rules
    • Activities which aid the development of potential or known defeat devices, or other actual or potential violations of US environmental protection legislation and regulations.
  • What is the process of submitting a report? How do I set up a postbox?

    To submit an anonymous or personalised report, start by clicking the ”Submit report“ button located on the top left side of our introduction page.

    There are 4 steps to the reporting process:

    1. First, you will be asked to read an information text about protecting your anonymity and then respond to a security query.
    2. On the following page, you will be asked about the category of your report.
    3. On the report page, you write the information in your own words and answer questions about the incident by simply selecting responses. The free text can be a maximum of 4,096 characters in length, which corresponds to a full page of text. You can also submit a file of up to 10 MB to support your report. Remember that documents may contain information about the author. After sending your report, you will receive a reference number as confirmation that the report has been submitted.
    4. Finally, please set up your own secured postbox. This is where you will receive responses from us, answer questions, and be kept up-to-date about the progress of your report.

    If you already have set-up a secured postbox, click the “Login” button to access it directly. First, you will have to answer a security query.

    As long as you do not enter any data which can identify you, the technology of the BKMS® System will protect your anonymity.

    We assure you that we are only interested in the report you submit. The aim is to discover any abuse and to avert financial damage.

    We kindly ask you to check your postbox regularly. Via this postbox, we will send you the confirmation for the report and, if necessary, ask questions that are important to solve the case.

  • How do I receive feedback and remain anonymous at the same time?

    Protection of the whistleblower is the overriding principle of the BKMS® process used here. The anonymity protection function has been verified independently.

    When setting up your secured postbox, you select your own pseudonym/user name and password. Your report is anonymised using encryption and other special security measures. At no point in the reporting process you will be asked for personal details. Do not enter any data that may reveal your identity. Please do not use a PC provided by your employer to submit a report.

    An examiner will provide feedback via the secured postbox as to what is happening with your information, or will ask questions if any details are still unclear. You also remain anonymous during the dialogue. We are interested in reports which help us to avert damage, not in your identity as a whistleblower.

  • I seek advice

    If you decide to pass your hint on to the experts outside the company, there are two external lawyers who will accept hints as neutral mediators (ombudsmen). The ombudspersons task is to accept hints about potential violations of legislation or internal regulations, review it and, if necessary, discuss it with the whistleblower and then submit the information to the company for further processing – without your identity being revealed, if so requested and if legally permissible.

    The Volkswagen Group uses two external lawyers as neutral mediators (ombudsmen): Dr Rainer Buchert and Thomas Rohrbach. The ombudsmen can be contacted as follows:

    • Dr. Rainer Buchert
    • Telephone: +49-69-710 33 330 oder +49-6105-92 13 55
    • Fax: +49-69-710 34 444
    • Email: dr-buchert@dr-buchert.de

    • Post:
    • Dr. Rainer Buchert
    • Bleidenstraße 1
    • 60311 Frankfurt am Main

    • Personal:
    • Bleidenstraße 1
    • 60311 Frankfurt am Main

    • Please arrange an appointment in advance on the above telephone numbers.
    • Thomas Rohrbach
    • Telephone: +49-69-65 30 03 56
    • Fax: +49-69-65 00 95 23
    • Email: rohrbach@ra-rohrbach.de

    • Post:
    • Thomas Rohrbach
    • Wildgäßchen 4
    • 60599 Frankfurt am Main

    • Personal:
    • Wildgäßchen 4
    • 60599 Frankfurt am Main

    • Please arrange an appointment in advance on the above telephone numbers.

    Compliance

    If you have any queries or require advice on the issue of compliance, please contact compliance@volkswagen.de

    Not for complaints

    Please note that our whistleblowing system is not intended for complaints. If you are dissatisfied with the customer service in relation to your car or a service provided by Volkswagen AG, please get in touch with the contact person listed in your contract documents, or our Dialog Center https://www.volkswagen.de/de/dialog-center.html.

  • What does protection of the whistleblower and affected parties entail?

    Whistleblowers are protected. Statements made by the whistleblower are handled confidentially. Your identity will not be disclosed if you so wish, and insofar as this is permitted by law. Discrimination or harassment of whistleblowers and reprisals against whistleblowers will not be tolerated and may be punished by law. Whistleblowers should disclose their identity in order to allow questions which may be useful for any investigations. If you request that your identity is not shared with other offices in the Volkswagen Group, this will be guaranteed. Anonymous reports are also possible – unless expressly prohibited by applicable law.

    The principle of fairness also applies to the person who is suspected of the violation, and the suspected violation must be handled carefully. The principle of the presumption of innocence until proven otherwise always applies, and investigators will look for circumstances that may exonerate the suspect. However, the punishment of legal infringements follows the principle of proportionality and takes into account the gravity of the violation and the employee’s previous merits, their responsibility within the Volkswagen Group, and the other circumstances of the individual case. Anyone who falsely accuses another person of a regulatory violation is also committing a violation, which will be investigated and punished as required.

    If the investigation finds no evidence of a regulatory violation, the person suspected of the violation can request assistance with clarifying the situation in his/her working environment in an appropriate and adequate fashion, in order to avert any damage to his/her reputation.

  • Information about Cookies

    For the duration of the use of this website, a so-called session ID is assigned, which is stored on your computer in a so-called cookie. This only serves to ensure that the BKMS® System can correctly link your entries even during a longer stay. By closing the website or your browser, the cookie becomes inoperative. The cookie is not used, as on some other websites, for cross website tracking or optimization of advertising. The cookie can not be used technically to reveal your identity.

  • Information about data protection

    The following section contains information about the collection, processing and use of personal data in the context of the whistleblowing system. Please read this privacy information carefully before submitting a report.

    Purpose of the whistleblowing system

    The whistleblowing system (BKMS® System) is used to accept and process information relating to (alleged) violations of legislation or breaches of internal regulations to the detriment of the Volkswagen Group in a secure and confidential way.

    The processing of personal data within the BKMS® System is based on the legitimate interest of Volkswagen AG in the detection and prevention of grievances and the associated prevention of damage and liability risks for the Volkswagen Group (Art. 6 Para. 1 lit. f DSGVO in conjunction with Sections 30, 130 OWiG). Point 4.1.3 of the German Corporate Governance Code also requires the establishment of a whistleblowing system in order to give employees and third parties the appropriate opportunity to provide protected information on legal infringements within the company.

    If a report received concerns an employee of Volkswagen AG, the processing also serves to prevent criminal offences or other legal infringements in connection with the employment relationship (§ 26 Para. 1 BDSG).

    Responsible office and data security

    The office responsible for the data protection aspect of the whistleblowing system is Volkswagen AG, Berliner Ring 2, 38440 Wolfsburg. The whistleblowing system is operated by a specialised company, Business Keeper AG, Bayreuther Str. 35, 10789 Berlin, Germany, on behalf of Volkswagen AG.

    Personal data and information entered in the whistleblowing system are stored in a database operated by Business Keeper AG in a high-security data centre. Only Volkswagen AG can access the data. Business Keeper AG and other third parties do not have access to the data. This is ensured by a certified procedure involving comprehensive technical and organisational measures.

    All data are encrypted and stored behind multi-level password protection, which means that access is restricted to a very small group of persons authorised expressly by Volkswagen AG.

    Volkswagen AG has appointed a data protection officer. Affected parties can contact the data protection officer of Volkswagen AG directly:

      • Datenschutzbeauftragter der Volkswagen AG
      • Berliner Ring 2
      • 38440 Wolfsburg

    • datenschutz@volkswagen.de

    Confidential handling of reports

    Incoming information is handled by a small group of expressly authorised and specially trained employees of Volkswagen AG’s Group Compliance department, and is always treated confidentially. The employees of Group Compliance check the facts of the matter and may conduct a further case-related investigation.

    In certain cases, Volkswagen AG is obliged by data protection legislation to inform the suspect of the charges made against them. This is a legal requirement in cases where it can be objectively established that the disclosure of information to the suspect can no longer have an adverse effect on the whistleblowing investigation in question. As far as is legally possible, your identity as a whistleblower will not be disclosed and steps will also be taken to ensure that no conclusions can be drawn as to your identity as the whistleblower.

    Confidentiality cannot be guaranteed if you deliberately submit false information with the aim of discrediting a person (denunciation).

    During the processing of a report or the conducting of a special investigation, it may become necessary to forward reports to additional employees of Volkswagen AG or subsidiaries of the Volkswagen Group and their employees, e.g. if the reports refer to activities in subsidiaries of the Volkswagen Group. If necessary for clarification, data may be transferred to subsidiaries of the Volkswagen Group in a country outside the European Union or the European Economic Area on the basis of appropriate data protection guarantees to protect those affected. Unless a specific adequacy decision has been taken by the EU Commission for the respective country outside the EU or the EEA, the above-mentioned guarantees are the standard contractual clauses of the European Commission. Data subjects have the right to obtain from Volkswagen AG a copy of the appropriate or appropriate guarantees for the transfer of personal data to third countries.

    We always ensure that the applicable data protection regulations are complied with when sharing reports.

    Other possible categories of recipients include law enforcement authorities, antitrust authorities, other administrative authorities, courts and international law and auditing firms commissioned by the Volkswagen Group if required to do so by law or data protection law.

    All persons who receive access to the data are obligated to maintain confidentiality.

    Duration of storage of personal data

    Personal data will be kept for as long as it is required for clarification and final assessment or if the company has a legitimate interest or if it is required by law. This data is then deleted in accordance with legal requirements. The duration of storage depends in particular on the severity of the suspicion and the reported possible breach of duty.

    Rights of the data subject

    Pursuant to European data protection legislation, you and the persons named in the report have a right of information, rectification, erasure, restriction of processing and objection to processing of your personal data. If the right to object to the processing of the personal data is invoked, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that are no longer required will be deleted immediately. Further information and the possibility to assert your rights can be found under:

    • Homepage: https://datenschutz.volkswagen.de/
    • Email: info-datenschutz@volkswagen.de

    You also have the right to lodge a complaint with the supervisory authority.

      • Die Landesbeauftragte für den Datenschutz Niedersachsen
      • Prinzenstraße 5
      • 30159 Hannover

    • https://www.lfd.niedersachsen.de/

    Using the whistleblowing system

    Type of personal data collected

    The whistleblowing system is used on a voluntary basis. We collect the following personal data and information when you submit a report via the whistleblowing system:

    • Your name, should you disclose your identity
    • Whether you are employee of Volkswagen AG
    • Where applicable, the names of persons and other personal data of the persons named in your report.

    The communication between your computer and the reporting system is carried out via an encrypted connection (SSL). The IP address of your computer is not stored while using the whistleblowing portal. To maintain the connection between your computer and the BKMS® System, a cookie which contains only the session ID is stored on your computer. The cookie is only valid until the end of your session and becomes invalid when you close the browser.

    You have the option of using a self-chosen pseudonym/user name and password to set up a secured postbox in the whistleblowing system. This allows you to send secure messages to the relevant employees of Volkswagen AG, by name or anonymously. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular email communication.

    Notes on sending attachments

    When submitting a report or supplementary information, you have the option of sending attachments to the relevant Volkswagen AG employees. If you want to submit a report anonymously, please observe the following security information: Files may contain hidden personal data which might endanger your anonymity. Remove these data before submission. If you are unable to remove these data or are unsure of how to do so, copy the text of the attachment into your report text or send the printed document anonymously to the address contained in the footer, quoting the reference number that you receive at the end of the reporting process.

    Version dated: 25.05.2018