Security and Compliance & Integrity
Compliance - Rechte, Vorschriften und Grundsätze
VfL Wolfsburg-Fußball GmbH Security Policy
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, players, 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.
9. The consistent implementation of all legal requirements of the “German Infection Protection Act” in compliance with any further protection regulation of the state of Lower Saxony and the City of Wolfsburg as well as the “DFL and DFB Covid 19 Hygiene Concept” in its current version.
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.
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 of VfL Wolfsburg
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.
Slavery and Human Trafficking Statement
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.
Scouting - Data privacy guidelines
VfL Wolfsburg-Fußball GmbH (VfL Wolfsburg) watches games throughout Germany and across the globe in order to assess potential transfer targets for all its teams, from VfL youth sides to its professional teams. In order to track the sporting development of potential new signings, system-supported information is gathered on the player in question.
VfL Wolfsburg only handles personal data obtained permissibly from publicly available sources, as well as scouting databases and similar sources. Subjective player assessments are made on the basis of observations during games.
Personal data handled by VfL includes the following:
- Surname, first name
- Date of birth, age
- Place of birth
- Preferred foot
- Preferred position
- Club history
- Beginning/end of contract (based on information available to the public)
- Sporting statistics (league appearances, goals, etc.)
- International career
- Subjective assessment of physical (e.g. stature, physical attributes), personal and sporting attributes and abilities (e.g. technical/tactical attributes). These may be related to the player’s country of origin
- Estimations on a player’s health or injury proneness are only made if these are either public knowledge or clearly obvious on the day of the observation
Article 6, Paragraph 1 of the EU General Data Protection Regulation (GDPR):
Legitimate interest: Maintaining VfL Wolfsburg’s ability to compete and obtaining players of the required standard
Generally, the type of data listed above will only be retained until a move to VfL Wolfsburg no longer seems likely. This is normally the case towards the end of a player’s career.
A player may assert the following rights against VfL Wolfsburg at any given time and free of charge:
Right of access according to Article 15 of the GDPR, in conjunction with Paragraphs 29 and 34 of the Federal Data Protection Act (BDSG): A player has the right to obtain confirmation from VfL Wolfsburg as to whether or not personal data concerning him or her has been processed.
Right to rectification according to Article 16 of the GDPR: A player has the right to demand the rectification of inaccurate personal data concerning him or her.
Right to erasure according to Article 17 of the GDPR: In accordance with the requirements listed under Article 17, a player has the right to obtain from VfL Wolfsburg the erasure of personal data concerning him or her. For example, the player can demand the erasure of personal data when said data are no longer necessary in relation to the purposes for which they were collected. The player can also demand the erasure when he or she withdraws consent on which VfL Wolfsburg’s processing of the data was based.
Right to restriction of processing according to Article 18 of the GDPR in conjunction with Paragraph 35 of the BDSG: The player has the right to obtain from VfL Wolfsburg restriction of processing in accordance with the requirements listed under Article 18. For example, restriction can be obtained when the accuracy of the personal data is contested by the player, for a period enabling VfL Wolfsburg to verify the accuracy of the personal data.
Right to object: The player has the right to object to processing of his or her personal data unless there are legal grounds for the processing which override the interests of the player, and when personal data are processed for direct marketing purposes. The player has the right to object when the processing of personal data is carried out in the public interest or in the exercise of official authority, or when the processing is carried out in the legitimate interest of VfL Wolfsburg or third parties. In the event of objection, we ask the player to inform VfL Wolfsburg of his or her reasons for objection. The player also has the right to object to the processing of personal data for direct marketing purposes. This includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: Where processing is based on consent, the player has the right to withdraw his or her consent at any given time, free of charge, and with immediate and indefinite effect by contacting firstname.lastname@example.org or via other means of contact listed in the imprint.
It must be noted that in the event of withdrawal, the processing of personal data on a legal basis cannot be ruled out.
Right to lodge a complaint according to Article 77 of the GDPR: A player also has the right to lodge a complaint regarding the processing of his or her personal data by VfL Wolfsburg with a supervisory authority (such as the State Commissioner for Data Protection of Lower Saxony).
Integrity - the foundation of our daily actions
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.