This statement has been prepared pursuant to section 54 of the United Kingdom Modern Slavery Act 2015. In particular, it details the measures implemented at WirelessCar Sweden AB and its entities to prevent any form of modern slavery and human trafficking.
In view of the advancing globalization we recognize our global responsibility which includes the protection of human rights. Our statement covers WirelessCar Sweden AB as well as our entities; WirelessCar (Beijing) Co., Ltd, WirelessCar North America, Inc., WirelessCar GmbH and WirelessCar Japan K.K. hereon collectively referred to as WirelessCar. We have, through our owner the Volkswagen Group, affirmed our understanding and our commitment to the internationally recognized agreements and conventions in the “Declaration by the Volkswagen Group on Social Rights, Industrial Relations and Business and Human Rights” (Social Charter – link to document).
WirelessCar Sweden AB is owned by CARIAD Group, which itself is part of the Volkswagen Group (hereon referred to as VW). Our role in the connected car ecosystem is to connect the car, the telematics unit in the car, and the MNO (mobile network operator), as well as all the possible touch points around the car where access to car data is needed; call centers, customer portals, service providers, content providers, and your own back-end systems. We collect, analyze and optimize the data sent to and from the car, package it and send it to isolated services, making them easy for relevant parties to access through portals, apps and API's.
While spread on three continents, Europe remains our most concentrated region for both customer, suppliers and personnel. We work with a range of suppliers who support our business – such as MNOs, portal providers, vehicle device providers, but also employee benefit providers, facility management companies etc. However, due the nature of our business, we still have a limited number of suppliers and do not work in a high-risk sector in terms of modern slavery.
However, although modern slavery is most prevalent in Africa, followed by the Asia and the Pacific region, analyses confirms that modern slavery is a crime that affects all countries globally, including highly developed countries.* While risk might be lower in white collar work and organization where our business resides, we recognize our responsibility in keeping a transparent and fair business practice.
We will not tolerate or condone slavery or human trafficking in any part of our organization. Our expectations for responsible, ethical and legal conduct are applicable to all parties who work with or for us worldwide, including employees, partners, suppliers and their suppliers. WirelessCar will continue to be committed to ensuring that modern slavery is not taking place within our organization or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Our commitment and integrated approach are included in e.g. our Code of Conduct, the Social Charta, our Whistleblower system and our risk management.
WirelessCar Code of Conduct is a local adaption of Volkswagen Group Code of Conduct and it is readily available to all employees, suppliers and customers on our website. The Code of Conduct supports ethical and responsible conduct. It is supplemented by internal guidelines and provisions in employment contracts. It also goes without saying that we comply with national and international statutory provisions. We have a duty to observe the law under which we operate in all business decisions we make.
As a result, compliance with the Code of Conduct is mandatory for all personnel: it is a condition for working with us. The Code of Conduct is based on shared values, with a focus on honesty, integrity, compliance and ethical behavior. The rejection of all forms of modern slavery and human trafficking is also an integral part of the Code of Conduct.
This important document includes a section dedicated to human rights. Stating “Respect for human rights is of paramount importance. We are convinced that sustainable economic activity is only possible by acting ethically and with integrity. Within the framework of our entrepreneurial activities, we are fully committed to our responsibility regarding human rights”
Furthermore, “Our entrepreneurial activities follow the UN Guiding Principles on Business and Human Rights (UN Global Compact), which determine the most important cornerstones for our actions”.
The violation of Human Rights is an example of a violation that can be reported through a Whistleblower System. It enables not only employees but also business partners and customers around the world to report misconduct by employees. At WirelessCar, violations can be reported through different methods, either through country specific channels or directly to relevant authorities depending on local legislation. Violations can also be reported to the Suitable body at WirelessCar, consisting of WirelessCar Compliance Manager, Legal Counsel and Vice President People & Culture. The Whistleblower System guarantees the highest possible protection for whistleblowers and affected persons. Discrimination against whistleblowers is a serious regulatory violation and will not be tolerated.
All WirelessCar entities have their own Whistleblower Systems, adapted to correspond to their respective local legislations which can be found here.
When managing risk - integrity, corporate values and compliance are especially important. The statutory regulations, voluntary commitments and internal company guidelines must be observed. The Code of Conduct is a binding guideline for everyday professional life, it offers guidance, advice and support, and summarizes key basic principles, for risk management too.
Risks are to be dealt with actively and openly. Major risks that cannot be sufficiently mitigated within the existing responsibilities are to be communicated openly and promptly to a higher level position in WirelessCar. Risk management is practiced in all parts of our business e.g. business partner due diligence.
We have human resources governance documents to protect our personnel and potential personnel from modern slavery and human trafficking. These include among other the Human Resources Directives on Diversity and Harassment. It is in the fundamental interests of WirelessCar to protect the health and safety of every employee.
Employees at all hierarchical levels play a key role in our Code of Conduct training. Everyone working for WirelessCar has an obligation to take the training which includes both human rights aspects as well as business partner due diligence. The training is repeated every 2nd year and includes an awareness test in the end. Failure to complete the Code of Conduct training has work-related sanctions.
Furthermore, all procurement personnel is trained in our Business Partner Due Diligence process. If any doubts in the supplier credibility, they should inform their manager and Head of Partnership. Our Business Partnership Due Diligence process will then start where our company examines business relations with this business partner more closely and, if necessary, break them off.
We respect, protect and promote all regulations in force to protect human rights, both within our own company and towards our partners. We expect the same of our business partners. Before entering into a relationship with a customer, business partner or other third-party supplier we check the reputability of said party. It is our aim to conduct business solely with reputable partners who operate in line with legal provisions and who use resources from legitimate sources. Our major suppliers are generally large multinational companies who have their own ethical standards of behavior in place and a stronger ability to enforce sustainability in the supply chains, and we have not identified any instances of modern slavery occurring in our supply chains.
We are continuously expanding our activities in the sustainability and governance of our supply chains. We want to be able to identify risks to minimize them by means of various instruments such as auditing and certification. We are constantly taking steps to enhance our process relating to due diligence and perform audits with prioritized suppliers and partners. Our work is reflected in our policies on Supplier Relations Sustainability and Business Partner Due Diligence.
The policy structures sustainability requirements for suppliers.
WirelessCar is committed to sustainable environmental protection and compliance with social standards, in particular human rights and compliance with anti-corruption regulations, within its business activities throughout the value chain. WirelessCar also assumes this responsibility in its supplier relationships with the aim of actively and continuously improving the sustainability performance of its suppliers and fulfilling its overall due diligence obligations along the supply chain.
To ensure that the business practices of business partners are based on integrity, WirelessCar performs due diligences for business partners (BPDD process). The BPDD process is a tool used for risk-based review of whether existing and potential new direct business partners act with integrity and comply with all applicable laws, regulations and directives in order to prevent potential reputational damage.
The establishment or continuation of a business relationship with a business partner and the conclusion of a corresponding contract governing that relationship is based on the result of the completed BPDD process.
Should you require more information, don’t hesitate to contact us.
Signed by Niklas Florén, CEO WirelessCar
Date: 2024-08-28
*https://www.globalslaveryindex.org/2018/findings/global-findings/
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