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 Volkswagen Group and 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.

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.

VfL Wolfsburg-Fußball GmbH stands for an open-minded and tolerant football culture and condemns xenophobic, racist, homophobic, violent, antisemitic and extremist behaviour, ideology and political views.

Together with responsible partners, the Security Policy aims to ensure the protection of employees, players, teams and visitors from distress or physical harm. Preventive measures are in place to reduce the likelihood of unforeseen events and, if such events do occur, they must be dealt with using predetermined and appropriate measures to avoid material, economic and image damage of VfL Wolfsburg-Fußball GmbH. These include measures to prevent unauthorised access in the form of theft, criminal damage, sabotage, damage by fire etc.

The Security Policy dictates that VfL is responsible for ensuring that all appropriate and necessary measures and procedures are in place to ensure safety during the execution of VfL events and VfL’s day-to-day business. VfL is also responsible for the safety of all employees working at an event on its behalf.

These responsibilities include:

• Creating, implementing and updating security measures for VfL’s business premises and VfL events
• Implementing and guaranteeing necessary infrastructural and organisational measures, as well as providing necessary resources
• Regular communication with business partners (VfL Wolfsburg, Wolfsburg/Helmstedt Police Department, Wolfsburg Council, the ‘Fanproject Wolfsburg’, the Office of Public Order, the Wolfsburg Fire Department, stadium owners and others) for the purpose of risk and danger analysis, as well as determining and implementing security measures in cooperation with its partners
• Permanent, open and transparent communication with all fan groups with the aim of ensuring long-standing cooperation with supporters
• Adhering to the cooperation agreement in place between Wolfsburg Council, Wolfsburg Police Department and VfL regarding mutual dealings with fan groups in the city of Wolfsburg
• Employing reliable DFB-trained stewards as part of its security force
• The continued documentation of all security measures

VfL must ensure that all measures that do not fall within their area of responsibility are executed by the appropriate departments (e.g. Wolfsburg Council, Police Department, Fire Department etc.). If the measures deemed necessary by VfL are not carried out by these departments, it must document such instances and, if necessary, report these to a superior body.

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.

Data source

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
• Nationality
• Height
• 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

Legal basis

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

Data retention

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.

Players’ rights

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 datenschutz@vfl-wolfsburg.de 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).