MOIA America

Ethics & Compliance

The goal of MOIA America is to establish a more transparent culture to do the right thing for our employees, our riders, our business partners, and the communities we serve.  Our success depends on us working together, and as a company, we must act with integrity, complying with local laws and relevant regulations - standing by our values and ethical principles.

Integrity

MOIA America 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 MOIA America 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, MOIA America recognizes our responsibility to protect human rights. Our commitment to Business & Human Rights encompasses our own corporate values, local law, and relevant regulations.

 

Our Whistleblower System 

Complying with statutory regulations, internal rules, and the principles laid down in our Code of Conduct and the Code of Conduct for Business Partners, has top priority at MOIA America LLC (“MOIA America”). The success of our company is based on Integrity and Compliance. To meet these standards, it is important to learn about 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 will an investigation by a dedicated Investigating Unit 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 otherwise requiring 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.

More information on the respective procedural principles can be foundhere. 

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

 

What kind of report do you want to submit?

A report of potential misconduct to our Whistleblower System 

The Whistleblower System offers various channels for reporting potential misconduct by MOIA America, violations of the Code of Conduct for Business Partners, or serious risks and violations of human rights and environment in our Supply Chain.

E-mail 

The Central Investigation Office of Volkswagen Group can be reached via E-mail (in any language):  

For customer complaints, please contact the channels listed under "A complaint about products or services to our customer service".

Postal Address / In Person: 

Postal Address: 

Volkswagen AG, Central Investigation Office 
Mailbox 1717 
Berliner Ring 2 
38436 Wolfsburg, Germany 

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

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 Central 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/

Online Platform 

You have the option of using a web-based communication platform to contact the Investigation Office in more than 65 languages. This system is confidential and technically secured and allows you to submit reports anonymously. 

You can access the online reporting channel through the following link: https://goto.speakup.report/volkswagen 

You can find detailed instructions on how to make reports online, by app, or by phone here.

Voice intake by phone 

You can leave us a voice message by phone 24 hours a day, 7 days a week. 

After entering the phone number (specific to the country you are in), you will be prompted to enter the organization code. Then, you can submit your report as a voice recording. Only a written transcript will be received by the Investigation Office. Dial back in to listen to the reply or further questions by our team. 

Select a phone number from this list for your country or region and have the corresponding organizational code 122203 ready.

 

Do you have any questions?  

Questions or suggestions for improvement concerning the Whistleblower System can also be addressed to the Central Investigation Office. 

Furthermore, Compliance can also be addressed in all matters of the Whistleblower System: 

  • Ethics Hotline: 888-228-7317 

 

Prevention of Money-laundering

The company does not tolerate money laundering or terrorist financing. All employees, especially those who work in finance, purchasing or sales should be aware of the red flags. The purpose of anti-money laundering is to prevent funds of a criminal origin or assets, that have been illegally acquired, from being brought into the economic cycle via the Volkswagen Group companies. 

In case of questions, contact MOIA America.

Email: vwgoacorporatecompliance@vw.com