OUR PRINCIPLES OF CONDUCT

Compliance

During about 30 years of operation, the Hungarian subsidiaries of Porsche Holding Salzburg have gained an excellent reputation for their corporate responsibility and high ethical standards.

What is compliance?

Compliance means to comply with all laws and regulations. The main purpose of compliance is to prevent violations and irregularities.

As a member of a globally active group of companies, compliance for us means that, in addition to existing laws, our employees also adhere to moral principles that go far beyond the law. These principles are summarized in our Code of Conduct for all member companies.

It goes without saying for us that we abide by all laws and internal rules and, as a member of society, we act responsibly towards the company and our business partners. This includes adhering to the principles.

All our employees are aware of their responsibilities as members of society and must ensure that our company also contributes to sustainable development.

As part of our responsibility for society, we act in accordance with the following principles:

Human Rights

We respect, protect and promote all regulations in force to protect human rights and children’s rights (hereinafter called human rights) as a fundamental and general requirement throughout the world. We reject all use of child labor and forced or compulsory labor as well as all forms of modern slavery and human trafficking. This applies not only to cooperation within our Company but also as a matter of course to the conduct of and toward business partners.

Equal opportunity and equal treatment

We do not discriminate or tolerate discrimination on grounds of ethnic or national origin, sex, religion, views, age, disability, sexual orientation, skin color, political views, social background or any other characteristics protected by law. We embrace diversity, actively encourage inclusion and create an environment that fosters each employee’s individuality in the interests of the Company.

Product conformity and product safety

It is not only our statutory duty but also our mission to comply with the laws and regulations as well as the internal standards that apply to our products. Our products are state of the art and are developed in accordance with legal requirements. This is monitored continually and systematically through processes and structures, as well as through product surveillance under real field conditions. We make no compromises on that. We ensure that suitable measures can be taken in good time in the event of any discrepancies.

Environmental protection

As a commercial enterprise, we bear responsibility for the environmental compatibility and sustainability of our products, locations and services. We focus on environmentally friendly, advanced and efficient technologies, which we implement throughout the entire lifecycle of our products. Starting with the early phases of development and production, we make sure we manage natural resources carefully and steadily reduce the environmental impact to comply with environmental protection laws and regulations. Furthermore, we constantly reassess the environmental compatibility of products and manufacturing processes, optimizing these where necessary.

Donations, sponsorships and charity

We make monetary donations and donations in kind to support science and research, education, charitable causes, sports, culture and churches and ecclesiastical institutions. We grant donations only to recognized non-profit organizations or organizations that are authorized by special provisions to accept donations. The granting of donations and sponsorship measures is permitted only in accordance with a transparent approval process.

Communication and marketing

We ensure that our communication is clear and consistent in order to maintain the confidence of customers, investors and other stakeholders. Before committing to and executing any planned communication or marketing measures, such measures must first be coordinated with the relevant department.

Political lobbying

We conduct political lobbying centrally and in line with the principles of openness, accountability and responsibility. It goes without saying that our interaction with political parties and interest groups is based on the principle of neutrality. Dishonestly influencing policymakers and government is not permitted.

As part of our responsibility as a business partner we set particularly great store by systematically implementing its legal framework, intragroup guidelines and corporate values, and by communicating them clearly. This also includes distributing our products and services exclusively through our authorized distribution partners

We respect the personal interests and the private lives of our colleagues. However, it is important to us to avoid conflicts between private and business interests, or even the appearance of such a conflict. All our decisions are made exclusively on the basis of objective criteria and we do not allow ourselves to be swayed by personal interests or relations.

Our internal guidelines on handling gifts, hospitality and invitations set out what benefits are appropriate and what steps must be taken when accepting and granting benefits.

The quality of products and services from our Company is the key to our success. Consequently, we do not tolerate corruption. We grant benefits to business partners, customers or other external third parties only within the permissible legal framework and in line with existing rules.

Our contacts with officials and holders of political office are strictly in line with all laws and legislation as well as the relevant internal rules concerning the avoidance of conflicts of interest and corruption. We do not make any “facilitation payments”. Such payments are sums paid to officials to accelerate routine administration matters..

In the framework of the prevention of money laundering and the fight against terrorist financing we carefully check the identity of customers, business partners and other third parties with whom we wish to do business. It is our declared aim to conduct business solely with reputable partners who operate in line with legal provisions and who use resources from legitimate sources. We ensure transparent and open cash flows.

We strictly comply with the statutory provisions for proper accounting and financial reporting. Transparency and correctness are our top priorities. To that end, we regularly inform all capital market players of our financial position and business developments. We publish our periodic financial statements punctually in accordance with national and international accounting regulations..

We are aware of our social responsibility to meet our obligations with regard to taxes and customs, and we explicitly endorse compliance with national and international legislation. We design internal structures and processes in such a manner as to ensure that the taxes and customs to be paid by the respective Group companies are calculated correctly, promptly and in full, are disclosed in reporting, and are paid to the appropriate fiscal authorities.

We conduct business solely on the basis of merit and market economy principles, as well as free and unhindered competition. We like to measure ourselves against our competitors, always abiding by rules and regulations and observing ethical principles. We do not enter into any anti-competitive agreements with competitors, suppliers or customers. If our Company holds a dominant market position, we do not abuse this position. We comply with the specific antitrust provisions for distribution systems in our dealings with our authorized distribution partners.

We carefully select suppliers and service providers based on objective criteria. When purchasing products and services, we involve the appropriate purchasing departments as laid down in the applicable procurement guidelines. We ensure that we comply with all regulations regarding the export and import of goods, services and information.

We handle information pertaining to share performance in accordance with capital market requirements and do not tolerate any insider trading. We may use knowledge relating to insider- relevant projects and processes only internally in accordance with the applicable intracompany rules and may not divulge such knowledge to any outside party, including family members (e.g. a spouse).

As part of our responsibilities in the workplace, we keep the following in mind:

We preserve and promote the health, performance and job satisfaction of our employees through continuous improvements in the working environment and a raft of preventive healthcare and health promotion measures.

We protect the personal data of employees, former employees, customers, suppliers and other affected parties. We collect, gather, process, use and store personal data strictly in accordance with legal provisions.

We are aware of the value of Company know-how and take great care to protect it. We respect the intellectual property of competitors, business partners and other third parties. We respect IT and EDP security and abide by the applicable regulations We respect the Company’s tangible and intangible assets and do not use them for non-business purposes.

We are committed to working with employee representatives in candor and trust, to conducting a constructive and cooperative dialogue, and to striving for a fair balance of interests. Professional dealings with employee representatives that do not allow either privilege or discrimination are part of our corporate culture.

In order to explain and comply with the above, we continuously train our employees.

Integrity

What is integrity?

Integrity is about doing the right thing out of personal motivation and conviction, while taking responsibility for the company, business partners and members of society.

Therefore, integrity is not only a demand of our company, but also an integral part of our corporate culture.

If something is legal, it doesn’t necessarily mean it’s right. Honesty helps you make the right decision.

Initiatives on Integrity, Compliance, Corporate Culture and Risk Management are based on the same foundations as the company's top priorities.

In order to describe and comply with the above, we continuously train our employees, and we also consider integrity aspects during the selection process.

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 Porsche Finance Group Hungary. It is important to learn of potential employee or supplier misconduct and to put a stop to it. Based on Section 18 (1) of Act XXV of 2023 on complaints, public interest reports, and rules related to the reporting of abuses, our company has established a Whistleblower System. Pursuant to Section 19 (2) of the Act, we as emplyer, entrusted Volkswagen AG with the operation of the independent, impartial and confidential reporting system, and pursuant to Section 22 (4) of the Act, we, entrusted the investigation of the reports to the Porsche Holding Salzburg Investigation Office. Based on the principle of procedural fairness, the Whistleblower System guarantees the greatest possible protection for whistleblowers, persons implicated and employees contributing to the investigation of reported misconduct.

If your report concerns potential serious violations with regards to human rights and environment by suppliers, the Investigation Office will inform the responsible departments, who will process the issue accordingly.

Making a report to our Whistleblower System

The Whistleblower System offers various channels to report potential employee and supplier misconduct that allow a swift review and reaction by our company if necessary. Reports can can be made 24/7 in every language.

• In Person – book appointment via e-mail prior to visit

• Postal address
  Investigation Office, Post Box 1717
  Berliner Ring 2, 38436 Wolfsburg (Germany)

• E-Mail
  io@volkswagen.de

• Online reporting channel
  https://goto.speakup.report/phs

• Hotline (24h/7d)
  +800 909 683
  Porsche Holding Salzburg Code: 122333

• Ombudspersons
  http://www.ombudsmen-of-volkswagen.com

• External points of contact
  https://www.porsche-holding.com/en/company/compliance-integrity/whistle-blower-system

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 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.

Separate Whistleblower Systems established by individual state bodies (external reporting channels)

Based on the law, the following state bodies establish separate whistleblower systems:

a) the Directorate General for Auditing European Grants,

b) the Economic Competition Office,

c) the Integrity Authority,

d) the Public Procurement Authority,

e) the Hungarian Energy and Utilities Regulatory Office,

f) the Hungarian National Bank,

g) the National Data Protection and Freedom of Information Authority,

h) the National Media and Communications Authority,

i) the National Atomic Energy Office and

j) the Supervisory Authority of Regulated Activities.

By decree of the Government, the Government or a member of the Government may appoint a body under its control or supervision to establish a separate whistleblower system.

In the separate whistleblower system, anyone can report information about illegal or presumed illegal acts or omissions, as well as other abuses.

Further information on this procedure is available on the websites of the above state bodies.

Do you have further questions?

Please direct questions or suggestions for improvement concerning the Whistleblower System to the Investigation Office.

Furthermore, our local Compliance Officer can also be adressed in all matters of the Whistleblower System via whistleblowing@centerofcompetence.hu

Do you have any concern or feedback regarding a product or service?

If you have any questions or inquiries regarding products, your, feedback or complaints about services or our business partners please contact our Customer Care Contact via info@porschefinance.hu

We kindly ask for your understanding that the Whistleblower System unfortunately cannot process customer complaints.