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About Volkswagen Group of America, Inc. (VWGoA)

Volkswagen Group of America, Inc. (VWGoA) is a wholly owned subsidiary of Volkswagen AG, one of the world’s leading automobile manufacturers and the largest carmaker in Europe. VWGoA houses the U.S. operations of a worldwide family of distinguished operations of a worldwide family of distinguished and exciting brands including Audi, Bentley, Lamborghini, and Volkswagen and is the sole importer and distributer of Bugatti and Rimac vehicles in the U.S. Volkswagen Group of America Chattanooga Operations, LLC, a wholly owned subsidiary of VWGoA, operates a state-of-the-art assembly facility in Chattanooga, Tennessee, while VW Credit, Inc. (doing business as “Volkswagen Financial Services”), another wholly owned subsidiary of VWGoA, provides financial services and innovative mobility solutions.. VWGoA’s headquarters are in Reston, VA. The company has approximately 10,000 employees in the United States and sells its vehicles through a network of approximately 1,000 independent dealers. Integrity VWGoA values integrity. We understand that our culture is the sum of actions taken by each employee. It is our responsibility to model ethical behavior for our employees, customers and third party business partners. Code of Conduct The Code of Conduct serves to guide all VWGoA employees and Contractors. Each employee is responsible for adhering to the Code of Conduct providing all of us with a practical guide, summarizing the key basic principles for employee conduct. Code of Conduct for Business Partners Human Rights With advancing globalization and the increased complexity of our value creation and supply chain, VWGoA recognizes our responsibility to protect human rights. Our commitment to Business & Human Rights encompasses our own corporate values, local law, and relevant regulations. 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 Volkswagen Group of America, Inc. (“VWGoA”). 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 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 against whistleblowers and all persons who contribute to investigations at VWGoA 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.

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