Volkswagen AG

At Group level, the company's political representation of interests toward governments, parliaments, authorities, associations, institutions and society is coordinated worldwide in order to ensure concerted action and uniform communication between the brands and companies. Responsibility lies with the Public Affairs steering committee, which reports regularly to the Group Executive Board. Principles such as integrity, openness and traceability as well as guidelines for contact with politicians are set out in a Group-wide guideline, as are rules on transparency. This is the basis for, e.g., the entries made by Volkswagen AG in the lobby transparency registers of the Federal Republic of Germany and the European Union, as well as the disclosure of our positions vis-à-vis politicians in the reporting year, for example on decarbonization, digitalization or human rights. [...] The guideline obliges the company's political decision-makers in associations to continue to bring the Volkswagen Group's positions into discussions within the scope of what is permissible under competition and antitrust law.

**Transparency of Public Affairs**

The Volkswagen Group supports regulations on the transparency of public affairs. Where political guidelines are already in force, they are followed. Service providers are committed to the Group's principles and guidelines for public affairs, too. The Group is registered in the Trans[parency Register of the European Union (entry of Volkswagen AG) and in the German lobby](https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=6504541970-40&locale=en#en)
[register (entry of Volkswagen AG) and complies with the associated requirements.](https://www.lobbyregister.bundestag.de/suche?q=R001681&filter%5Bactivelobbyist%5D%5Btrue%5D=true)

###### Climate protection and a successful transformation to climate neutrality can only succeed if politics and the business sector work hand\n\n\nin hand. The Group's Public Affairs departments act as the liaison between Volkswagen and the industry and political arenas. This is com###### plemented by the Volkswagen Group's strong engagement in alliances, associations and networks, which we consider a key element for\n\njointly working on the best future mobility solutions. In addition, association memberships allow us to better engage with our stakeholders\n\nand create forums for discussion.\n\n###### To ensure the effective promotion of our ambitious climate protection targets and to identify potential for improvement, we decided to\n\nreview our association memberships with a view to their alignment with our climate policy positions.\n\n###### We are therefore pleased to present the first Volkswagen Group Association Climate Review (also the "Review Report"). It is the result of\n\nan over­arching project of the Investor Relations, Sustainability and Public Affairs departments and will be published regularly. The aim of\n\n###### this Review Report is to provide a methodologically sound basis for leveraging the full potential of our climate policy lobbying and to\n\nenrich dialog with all stakeholders. We would like to thank the team involved in preparation of the Review Report, which was coordinated\n\n\nat Volkswagen Group level and carried out in direct collaboration with the Group's Political Representatives.\n\n[...]\n\n###### Volkswagen's Political One-Voice Policy (also the "Group Policy")\n\n\n\naims at ensuring that a single, coordinated and binding position is\n\n\ndefined for political issues that are relevant to the Group. Such a\n\n###### position is globally communicated to the respective target group through identical messages from the Group, related brands and companies. This way, Volkswagen's interests are represented using\n\n\nthe same internally agreed content, aims and statements. As a result,\n\n\nthe Political One-Voice Policy enables professional political lobbying\n\n\nwith consistent content when several Group entities are involved.\n\n\nonly permit lobbying to be carried out through designated chan\n\n\nnels with defined Principles and Guidelines for Public Affairs. The policy\n\n\nalso defines criteria for determining whether a topic is politically\n\n###### relevant to the Group and describes the tasks and obligations for\n\n\nthose involved.\n\n\nWithin the framework of the Group Policy, responsibility for the Polit\n\n\nical One-Voice Policy lies either with the Group Public Affairs office\n\n\nor the Group Steering Committee Public Affairs. For the Group Steering\n\n###### Committee Public Affairs, the brands appoint members and depu\n\n\nties who are allowed to make policy-related determinations for the\n\n\nbrand and/or its holding company.\n\n\n[...]\n\n###### The methodological concept, the selection criteria and the analysis of\n\n\nthe associations were developed in an overarching project group\n\n\nconsisting of experts from the Investor Relations, Sustainability and\n\n\nPublic Affairs departments. The whole project and process is super###### vised at senior level by the Heads of Group Treasury and Investor\n\n\nRelations, Sustainability and Group Public Affairs.\n\n\n[...]\n\n###### During Panel meetings, every association identified as "partly aligned" or "misaligned" is reviewed and addressed. In a first step, the results of the association analysis are discussed, and their consequences are explored. Where necessary, a strategy to ensure\n\n\nfuture alignment is developed. In a second step, an evaluation of\n\n\ncorresponding measures is undertaken. To this end, each department\n\n\nprepares a statement and recommendation for each specific case\n\n###### of deviation. The opinion and recommendation of the Volkswagen Group division or entity holding the membership must also be\n\n\nsought. After a thorough exploration of all possible paths, a decision\n\n\nis made within the Panel on how to proceed.\n\n\nThe Review Report will be expanded gradually to include other asso\n\n\nciations and countries according to the selection criteria developed\n\n\n\nfor this purpose. Going forward, the Review Report will be published\n\n\nat regular intervals.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]All areas and roles in the group that carry out tasks of representing political interests inform the Public Affairs Division of their activities. They undertake to unalteredly advocate the Group's positions in discussions with policy makers and associations within the limits permitted by competition and antitrust law. Positions that differ from those of the Group are considered dissenting. This guiding principle also fully applies to any policy engagement on the topic of climate change and related matters. In the case of a violation of our principles and guidelines, escalation to the Group Steering Committee for Public Affairs will take place to individually assess such incidents. The committee is directly connected to the Board of Management of the Volkswagen Group.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes