Slavery and Human Trafficking Statement

Background

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 forms 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 and WirelessCar North America, Inc., hereon collectively referred to as WirelessCar.

Organization

WirelessCar Sweden AB is a direct affiliate of Volkswagen Aktiengesellschaft (hereon referred to as VW) and together with our two entities in China and NA we are owned by Volkswagen AG and Volvo AB. 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. 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.

Our Commitment

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.

Internal measures

Our commitment and integrated approach are included in e.g. our Code of Conduct, our Whistleblower system and our risk management.

 

Code of Conduct

WirelessCar Code of Conduct is a local adaption of Volkswagen Group Code of Conduct and it is readily available to all employees on the Intranet. 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 “We respect, protect and promote all regulations in force to protect human rights and children’s 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

Furthermore, “we recognize the basic right of all employees to establish trade unions and employee representations. 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.”

Whistleblower system

Serious violations can be reported by different methods, either by VW Whistleblower system or directly to relevant authorities depending on local legislation.  Other violations can be reported to the local compliance organization, consisting of WirelessCar Compliance Manager and Vice President HR. 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.

This is the set-up for WirelessCar Sweden AB in accordance with Swedish legislation and will soon have the corresponding Whistleblower system in place for our entities in North America and China.

Risk Management, Corporate Internal Policy 33

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 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.

Human Resources Compliance, Group Policy 35

We have human resources governance documents to protect our personnel and potential personnel from modern slavery and human trafficking. These include the Human Resources Policy and Harassment. It is in the fundamental interests of WirelessCar to protect the health and safety of every employee.

Training for employees

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 e.g. 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 will be trained in our soon to be implemented 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.

Measures with partners and supply chain

We respect, protect and promote all regulations in force to protect human rights, both within our own company and towards our 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.

In the coming year we aim to further expand our activities in the sustainability of our supply chains. We want to be able to identify risks to continuously minimize them by means of various instruments such as auditing and certification. Right now we are taking steps to structure our process relating to due diligence even more systematically. Our work is reflected in our policies.

Sustainability Management in Supplier Relations, Group Policy 12

The policy structures sustainability requirements for suppliers. The requirements connected to Slavery and Human Trafficking are:

  • Employee rights - the observance of internationally recognized human rights form the basis of all business relations. In particular, the regulations must be heeded alongside the labor law of the country in which the business partner operates
  • Freedom of association - the basic right of all employees to form trade unions and employee representations and to join them is recognized. In countries where this right is restricted by local laws, alternative legitimate options for employee participation are to be supported.
  • No forced labor - WirelessCar rejects the conscious use of forced or compulsory labor including bonded labor and involuntary prisoner labor.
  • No child labor - child labor is forbidden. The minimum age for permission to work (according to national regulations) is observed.
  • Compensation and benefits - the compensation and benefits paid or received for a normal working week correspond at the very least to the legally valid and guaranteed minimum. Where legal or collective bargaining agreements do not exist, compensation and benefits are based on industry-specific collective agreements customary to the respective location that ensure an appropriate standard of living for the employees and their families.
  • Working hours - working hours correspond at least to the respective national legal standards or the minimum standards of the respective national economic sectors.
  • Occupational health and safety - the partner complies at least with the respective national standards for a safe and hygienic working environment and takes appropriate measures to guarantee health and safety at the workplace so that good working conditions are ensured.

Business Partner Due Diligence, Group Policy 29

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 Martin Rosell, CEO WirelessCar

Date: 2020-06-30

*https://www.globalslaveryindex.org/2018/findings/global-findings/