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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Here’s Volkswagen’s full anti-corruption policy

Volkswagen left its mark on the history of the world with the love it or hate it Beetle. Is it a similar story with its (incredibly) thorough anti-corruption policy? Let’s dive into the Antikorruptionsrichtlinie (my word).

1. It’s 36 pages long.

The purpose of this Guideline is to raise awareness among all employees* of the dangers of corruption and provide assistance on how to follow internal rules at the workplace.

For comparison, Apple’s is four pages. Novartis was the previous longest we’d benchmarked at six pages.

2. When it comes to public officials, hold the butter. 

Benefits granted to officials and holders of political office are particularly susceptible to being considered a form of corruption. In most countries, more stringent criminal law re- gulations apply to dealings with officials than with business partners or private persons, mainly to ensure the impartiality of the administration. In some countries, what is known as “buttering up” of officials or holders of political office is punishable as a crimi- nal offense. This refers to the favorable treatment of officials or holders of political office by giving them relatively small favors or benefits. It is therefore advisable to exercise particular caution when dealing with authorities and / or their representatives and to take a very restrictive approach to granting benefits.

3. Use of examples. 

Favoritism is often linked to corruption. This involves a person using their position of power to obtain an advantage for a family member or an acquaintance.


As an employee of the Volkswagen Group you are negotiating a large sales order from a business partner. One day the business partner’s employee responsible for order management asks for a meeting. During the meeting he offers to arrange for the order to be placed with the Volkswagen Group. However, in return he asks you to fix an apprenticeship for his nephew without going through the regular application process.

4. Facilitating payments? NeinNein. Nein.

Facilitation payments (also called bribes) are relatively small amounts paid to officials in order to accelerate routine official procedures to which citizens are legally entitled. Bribes are a criminal offense in any countries and are therefore prohibited.
The Volkswagen Group expressly prohibits facilitation payments.

This policy is similar to Apple, Novartis, and Microsoft. In contrast, Tesla might approve some facilitating payments.

5. Donations are important to the Volkswagen brand. 

The Volkswagen Group supports organizations and events worldwide through sponsorship and donations. These strengthen the Volkswagen Group brands. Donations are important measures which express how we perceive our social responsibility.

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View more anti-corruption policy benchmarks here.

Click here to view the Volkswagen anti-corruption policy

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