Security and Compliance & Integrity

VfL Wolfsburg-Fußball GmbH (VfL) stands for an open-minded, tolerant football culture and condemns xenophobic, racist, anti-semitic, violent, homophobic, left-wing and right-wing extremist behaviour, ableism as well as other radical views and ideologies.

The aim of the security policy is to work with responsible network partners in order to protect employees, teams, visitors, and guests from any adverse effects or physical injury. It is also designed to implement preventative measures against unforeseen events and to react to undesirable events with previously defined and customised actions to avoid any material, economic or reputational damage to VfL. This includes all actions required to avoid unauthorised access in the form of theft, property damage, sabotage, arson etc.

As part of its security management, VfL must put in place all requisite actions and procedures that are suited to or required for security when running events and in the club’s everyday operations.

VfL thereby assumes responsibility for all persons contracted to work for the club.

Preventative, security-oriented, and legally compliant thoughts and actions are basic prerequisites for the future success of VfL. They also form the basis of a safe and secure stadium experience.

Our long-term objective is to document the specific and organisational procedures of VfL Wolfsburg-Fußball GmbH in accordance with the rules of the German Football Association (DFB): Certification of security management in professional football and to develop them systematically in compliance with internal nd external requirements.

The basic principles of our security policy:

1. The creation, implementation and ongoing maintenance of security concepts for all operating facilities and events with systematic monitoring of safety and security regulations applicable to VfL.

2. The provision of the requisite materials for the development and maintenance of a security management system and for the implementation of the measures arising from said system.

3. The permanent, honest and trusting exchange of information with all fan groups with the objective of achieving long-term, inclusive work with supporters.

4. The creation and implementation of a training concept for targeted and systematic training and further education measures on the basis of the German Football Association’s training procedures. This applies in particular to employees working in the security service, with the objective of promoting an understanding of security and the obligation to act safely.

5. The maintenance and ongoing development of the security standard through structured planning, action and leadership as part of a continuous improvement process.

6. The consistent documentation of all security measures.

7. The development and promotion of security awareness amongst employees of VfL and external partners (e.g. media staff, catering personnel, promotion teams). This is achieved through partnerships based on the security policy, which ensure that these persons conduct themselves in a way that contributes to the stadium experience and prevents security risks.

8. Taking into account the security level of service providers and suppliers during selection, and ongoing monitoring while they are working.

VfL must strive to ensure that all measures for which it is not responsible are covered by the responsible departments (e. g. City of Wolfsburg, police, fire service etc.). If these departments do not perform the measures deemed necessary by VfL, the club must document this and notify any higher bodies as required.

In order to implement these basic principles, obligations and objectives, a security management system will be introduced and made mandatory for all employees of VfL Wolfsburg Fußball GmbH.

Download: Safety and security policy VfL Wolfsburg-Fußball GmbH (01.03.2024)

The Volkswagen Group has developed a Whistleblower System in order to protect the Volkswagen Group and VfL Wolfsburg from serious breaches of rules and legal violations.

The Whistleblower System acts as a port of call for employees, business partners and other third parties who wish to report such breaches and violations concerning VfL Wolfsburg and the Volkswagen Group.

The good reputation of VfL Wolfsburg and the Volkswagen Group is built on integrity and compliance, as well as the trust of our clients and business partners.

The Code of Conduct serves as a binding guideline in the day-to-day business of all VfL Wolfsburg employees. It offers guidance on company regulations by providing orientation and support in employees’ daily work. All employees must respect and observe company rules everywhere and at all times.

PDF-Download: Code of Conduct for Business Partners

The VfL Wolfsburg-Fussball GmbH opposes any form of modern slavery and human trafficking.

In our Slavery and Human Trafficking Statement we outline the implemented measures by VfL Wolfsburg in cooperation with Volkswagen AG to prevent slavery and human trafficking.

Attached you will find the Slavery and Human Trafficking Statement of the VfL Wolfsburg-Fußball GmbH

The publisher of this data protection declaration is VfL Wolfsburg-Fußball GmbH, In den Allerwiesen 1, 38446 Wolfsburg, personalwesen@vfl-wolfsburg.de, registered in the commercial register of Braunschweig Local Court under HRB No. 100486. Whenever reference is made below to "VfL Wolfsburg", "we" or "us", this always refers to VfL Wolfsburg-Fußball GmbH.

Principles

As part of its scouting activities, VfL Wolfsburg-Fußball GmbH (VfL Wolfsburg) screens matches throughout Germany and internationally to examine potential transfer options for all relevant VfL Wolfsburg teams. This applies to the youth teams of our VfL-Fußball.Akademie as well as our professional players. In order to track the sporting development of potential new recruits, information about the player is recorded in IT systems.

VfL Wolfsburg carries out observations of opposing teams and potential opposing teams as part of its match operations for all age groups of the youth teams in its academy (VfL-Fußball.Akademie) as well as for the men's and women's professional teams in connection with the preparation for and follow-up on sporting competitions with other teams.

The collection of match-related and performance-related information about the player - including in the form of photographs and video recordings - during scouting and during preparation and follow-up work with opponents is carried out to protect the legitimate interests of VfL Wolfsburg.

Processing of your personal data

In connection with scouting and the observation of opponents, VfL Wolfsburg processes personal data that it has obtained and is permitted to process from publicly accessible sources (e.g. press, specialist media, internet platforms) or other sources (e.g. scouting databases). Furthermore, subjective assessments of the player's performance are recorded on the basis of observations of individual matches and, if applicable, training sessions.

Processed personal data of the respective player - also in the context of the observation of opponents - are in particular

• Surname, first name
• Date of birth, age
• Place of birth
• nationality
• Height
• Strong foot
• Playing position
• Club history
• Start/end of contract (especially based on publicly available information)
• Sporting statistics (league appearances, goals etc.) & performance data
• International playing career
• Subjective assessment of physical (e.g. stature, physical requirements), character and sporting qualities and abilities (technical/tactical qualities), which may also be linked to the player's origin
• We only record assessments of health or susceptibility to injury if these are publicly known or evident based on the appearance and performance on the day of observation.

Legal basis for the collection of your personal data

This personal data is only collected, processed and transmitted for a specific purpose and only if there is an applicable legal basis for doing so. The purposes described above are based on the following legal bases:

Art. 6 para. 1 lit. f) European General Data Protection Regulation (GDPR): Legitimate interest: Maintaining the competitiveness of VfL Wolfsburg, recruitment of capable players

Retention and deletion periods for your personal data

This personal data is only processed and stored for as long as the respective purpose exists or as long as the law requires. We delete the data in accordance with our retention concept.

The above-mentioned data will be stored until a transfer to VfL Wolfsburg is no longer expected. This is usually the case at the end of the player's career.

Data subject rights

You can assert the following rights towards VfL Wolfsburg at any time free of charge at www.vfl-wolfsburg.de/betroffenenrechte or via the contact details provided in this declaration:

Right to information in accordance with Art. 15 GDPR in conjunction with §§ Sections 29, 34 of the Federal Data Protection Act (BDSG): You have the right to receive information from us about the processing of your personal data.

Right to rectification in accordance with Art. 16 GDPR: You have the right to obtain from us the rectification of inaccurate or incomplete personal data concerning you.

Right to erasure in accordance with Art. 17 GDPR in conjunction with. § Section 35 BDSG: You have the right to request the erasure of your data if the conditions specified in Art. 17 GDPR are met. For example, you can request the erasure of your data if it is no longer necessary for the purposes for which it was collected. You can also request erasure if we process your data on the basis of your consent and you withdraw this consent.

Right to restriction of processing in accordance with Art. 18 GDPR in conjunction with § Section 35 BDSG: You have the right to request the restriction of the processing of your data if the requirements of Art. 18 GDPR are met. This is the case, for example, if you dispute the accuracy of your data. You can then request the restriction of processing for the duration of the verification of the accuracy of the data.

Right to object: If the processing is based on an overriding interest, you have the right to object to the processing of your data. An objection is permissible if the processing is either in the public interest or in the exercise of official authority or on the basis of a legitimate interest of VfL Wolfsburg or a third party. In the event of an objection, we ask you to inform us of your reasons for objecting to the data processing.

Right to data portability under Art. 20 GDPR: If the data processing is based on consent or contract fulfillment and is also carried out using automated processing, you have the right to receive your data in a structured, commonly used and machine-readable format and to transmit it to another data processor.

Right of withdrawal: If data processing is based on consent, you have the right to withdraw your consent to data processing at any time with effect for the future. Please note that even in the event of revocation, processing of your data on a legal basis is not excluded.

Right to file a complaint pursuant to Art. 77 GDPR: You also have the right to complain to a supervisory authority (e.g. the State Commissioner for Data Protection of Lower Saxony) about our processing of your data.

Adaption of this data protection declaration

We reserve the right to update this privacy policy from time to time. Updates to this privacy policy will be sent by post to the last known address. Changes are valid from the date of publication.

Contact information regarding data protection

The data protection officer of VfL Wolfsburg-Fußball GmbH is the first point of contact for all data protection-related concerns and for exercising your rights. However, you also have the option of contacting our Data Protection Officer directly at Data Protection Officer of VfL Wolfsburg-Fußball GmbH, Volkswagen AG, Berliner Ring 2, P.O. Box 8091, 38440 Wolfsburg or via konzerndatenschutz@volkswagen.de. We recommend that you first address your request to our direct contact person:

VfL Wolfsburg-Fußball GmbH
Data protection
In den Allerwiesen 1
38446 Wolfsburg
datenschutz@vfl-wolfsburg.de
www.vfl-Wolfsburg.de/betroffenenrechte

Our conviction is: Only through lasting and reliable integrity and compliant behavior can the trust of our employees, customers, business partners and the public in our company be gained and strengthened. It is our declared aim to become a role model in integrity and compliance so that we can continue to be a company of integrity in the future.

Acting with integrity is firmly anchored in the Group's "TOGETHER 2025+" strategy - and is thus on a level with our key financial figures and the satisfaction of our business partners as well as fans. With the implementation of the integrity program and the Group Principles, which provide guidance for the daily value-based actions of all employees, we have set an important course for the future.

The integrity program key initiative is part of the Together4Integrity program. Its aim is to increase the understanding of integrity and its importance as the basis for entrepreneurial action among all employees and managers at VfL Wolfsburg and to create a culture in which behavior with integrity is not only possible throughout but is also taken for granted. This is associated to the requirement for a constructive approach to mistakes, an increase in the transparency of decision-making and a strengthening of the willingness to address undesirable developments and risks, also towards superiors. For us, integrity is a core element of professional conduct, and this is the only thing we aim for: It is about doing the right thing in all situations.

As the basis for entrepreneurial action, integrity must operate at all levels. For example, it is a mandatory criterion for all management decisions: Every draft resolution must include a statement by the responsible department on how the intended resolution and its consequences are consistent with the integrity and compliance of the company, or whether integrity or compliance risks are associated with it and how they can be reduced.