At Porsche, the Code of Conduct sets out the most important principles and expectations of compliance in three different aspects: as a member of society, as a business partner, and in the workplace. Another code, the Code of Conduct for Business Partners, states that Porsche expects its business partners to adhere to the relevant laws, recognize basic ethical values, and act in a sustainable manner. Both of these codes explicitly bring the whistleblower system at Porsche to people’s attention. Furthermore, the Executive Board has adopted the Compliance Management guidelines: these represent an undertaking by Porsche to ensure compliance with laws and guidelines.

Compliance organization and compliance measures

The compliance management system (CMS) at Porsche is a preventative framework for the totality of all principles, measures, and objective processes that serve to safeguard and implement compliance in six areas of compliance. It is intended to ensure that violations of the law and/or directives in these areas of compliance are prevented, or at least rendered significantly more difficult.

Employees can report potential breaches of the rules using an internal whistleblowing mechanism that has been set up and communicated. Outside the company, employees and external individuals can report breaches to two ombudsmen who are subject to professional duties of secrecy under German law. These internal and external points of contact for the whistleblower system can be contacted in a variety of ways at any time, even anonymously, free of charge. Porsche acts on incoming reports, taking into account data protection, labor law, and co-determination regulations. Whistleblowers need not fear any disciplinary measures or other repercussions from Porsche. The company reacts to identified violations in compliance with the data protection, labor law, and co-determination regulations. Regardless of the outcome of the investigation, suitable countermeasures are introduced on a case-by-case basis, and individual misconduct is punished on a case-by-case basis depending on the outcome of the investigation.

Overall, Porsche’s whistleblower system was responsible for following up on 63 of 168 submitted reports. The plausibility check rated 34 of these 63 reports as plausible. Of the 34 plausible reports, 13 were categorized as potentially severe breaches of the rules, and investigated through Porsche’s whistleblower system. The focal points of the potential misconduct were violations of the German Trade Secrets Act (GeschGehG) and offenses against property (such as fraud and embezzlement).

Eight cases concluded in the identification of a serious breach of the rules and resulted in sanctions. Four investigations ended without identifying a breach of the rules. One case was still open at the end of 2022.

The central Compliance department has been conducting compliance monitoring since 2021. Besides interviews with managers, it involves risk-oriented activities such as random inspections of transactions that are of relevance in terms of compliance. The results are compiled in a report that also describes appropriate action if there is an evident need for improvement.

Compliance communication at Porsche focused on intranet posts in 2022, addressing topics such as the updated Code of Conduct leaflet and International Anti-Corruption Day. The compliance officers also released various internal communications in the form of info sessions, posts in departmental groups, and messages to managers.

Compliance training

In cooperation with the HR department, the compliance officers provide compliance training at Porsche and selected subsidiaries. The basis is a subject-specific plan which uses risk analyses to identify the relevant target groups and key areas of content. There are mandatory training formats for managers, junior managers, and new employees. The compliance officers also provide organized training for specific departments and target groups, such as on legally mandatory or current topics, or on request.

In 2022, 5,817 employees at Porsche and its relevant German subsidiaries received compliance training at in-person and virtual events, and 57,337 participants received compliance training through digital training modules. The digital Code of Conduct training module was completed by 17,296 employees from Porsche and 7,458 employees from its relevant German subsidiaries. This training module covers the directive of the same name and provides information about the whistleblower system and the contact details of the compliance help desk. The training also covers the content of the “Avoidance of conflicts of interest and corruption” and “Human rights” guidelines. By the end of 2022, the rate of training in face-to-face and virtual events within the target group at Porsche and its relevant German subsidiaries was 93 % on average for the defined areas of compliance. In 2022, Porsche piloted a digital training module on fraud prevention within Procurement.

Employees can find further information about compliance related training and communications at Porsche on the intranet. Aside from the relevant Group and company guidelines, the intranet provides information on the compliance culture and organization, as well as details about points of contact and reporting channels. This is complemented by videos, flyers, note cards, and brochures.

Anchoring integrity organizationally

At Porsche, the topic of integrity is based within a central management function. It is anchored within the Employee Development and Corporate Culture division of the Human Resources department. The purpose of integrity management is to anchor sustainability in the corporate culture on a long-term basis. It aims to enable managers and employees to act with responsibility, conviction, and steadfastness in keeping with ethical principles.

Aside from the principle of honesty, integrity, and ethical conduct, the Code of Conduct emphasizes the special example that managers and Executive Board members are expected to set. Furthermore, integrity is an integral part of the management mission statement, the Porsche Code, which makes it a high priority at work.

Integrity is even enshrined in internal processes and decisions, especially in onboarding, recruitment, development, remuneration, and disciplinary processes within Human Resources. The Group’s HR Compliance guidelines set out the minimum standards. For instance, aspects of integrity are even discussed in the selection phase of the recruitment process. The development path to become a manager covered by a collective agreement, as well as the paths into and within management, all pay particular attention to the topic. Whenever proposals for decisions are submitted to the top boards of Porsche, the process involves an integrity assessment.

Integrity structure strengthening program

Porsche has rolled out the topic of “Culture and Integrity” internationally as part of its Together4Integrity (T4I) program. Under the program, long-term measures have been drawn up to strengthen the integrity culture. The management teams of the 97 subsidiaries that are currently part of the T4I program, including Porsche, are responsible for local implementation in line with the schedule and milestone plan. The packages of measures and implementation times can vary depending on the local circumstances. However, the subsidiaries of Porsche can base their local implementation on the centrally developed policies.

Within Porsche, a central reporting system details the implementation of T4I measures by degrees of implementation. Besides the measures relating to “Culture and integrity”, the system contains the minimum integrity standards from Porsche’s Group HR Compliance guidelines. The T4I committees also report on its progress on a regular basis.

The importance of the topic is reflected in the half-yearly progress reports to the Compliance Council, the special-purpose reports to the Executive Board, and the Supervisory Board’s annual integrity report. Reporting to the management and other relevant committees is an object of the T4I measures in connection with “Culture and integrity”.

Raising awareness of integrity

Acting with integrity on a daily basis at work requires the ability to make decisions with integrity. Therefore, the training for newly recruited or promoted managers at Porsche and relevant national subsidiaries has been enhanced in the context of the new development path into management: it is based on a skill model that identifies and strengthens the skills needed for decisions to be made with integrity. In doing so, the training offers guidance and practical assistance with moral dilemmas.

The training has been part of integrity training courses for managers covered by collective agreements since the third quarter of 2022. Here, it makes an important contribution to the practical application of integrity in real-world scenarios.

New dialogue formats have also been developed especially for managers, in order to help them build a common understanding of integrity with their teams and promote integrity within the team. At Porsche , integrity is generally incorporated into training formats for new and existing employees on the basis of specific target groups.

Networks and tools

The interdisciplinary multiplier network covering the brand, culture, and integrity provides Porsche employees with a platform to share their experience, ideas, and presentations. It helps the ambassadors embed the topic of integrity within the departments. The intranet provides employees with packages of information about integrity. Intranet users can also access a series of internal podcasts about corporate culture, which also feature content relating to integrity.

Managers at Porsche have access to a tool kit in their own special integrity section. It features self-reflection tools, dialogue formats, and other information and ideas relating to integrity. This way, as role models, managers can hold their own workshops to hone their understanding of integrity and, working with their employees, define and implement measures designed to improve integrity. A workshop format, in which the team actively deals with everyday situations and decisions that require people to act with integrity, was added to the range of measures in 2022. As part of the transfer phase of the annual Leadership Lab for all disciplinary managers at Porsche, they were given the opportunity to take part in integrity deep dives, such as on the topic of psychological security as a prerequisite of a “speak-up culture”.

Integrity in employee surveys

Porsche endeavors to enshrine integrity in day-to-day work and bring it to life everywhere and on all levels. Surveys help the company understand where it currently is. For example, a poll on acting with integrity and lawful behavior within the corporate organization is part of the annual employee survey known as the mood barometer. The poll illustrates how the culture of integrity is developing and what additional measures can be derived. In the year under review, around 31,000 employees were surveyed at Porsche.

The results of the mood barometer are then discussed within the organizational units. These compulsory discussions integrate into the team dialogue on the culture and values of Porsche – an open discussion at eye level about cooperation within the organizational unit. The purpose of the format is for managers and employees to work together to draw up measures that will improve the way they work together as a team. The team dialogue is an object of the T4I measures.

If the mood barometer fails to meet a given integrity score, a special process within Porsche is activated to investigate the reasons for the score and introduce appropriate measures if necessary, with the involvement of HR and the relevant line manager.

The results of the annual employee survey on integrity within the company show that the culture of integrity is highly advanced. The question about every individual’s opportunity to behave with integrity scored in the highest category on the underlying five-point scale. The integrity question has consistently been in third place out of 24 questions in the mood barometer since 2019. Thus, confirming the previous year’s level.