Dear Madam or Sir,

Volkswagen has announced that it will have the Volkswagen SAIC plant in Urumchi, China, audited. According to media reports, chief executive officer Oliver Blume announced during a conference call with investors on June 21, 2023 that Volkswagen plans “a transparent, independent external audit to provide full transparency to the public”.

In general, we welcome that Volkswagen takes the risk of potential human rights violations at the Volkswagen SAIC plant seriously. However, there is serious evidence of forced labor in relation to Volkswagen’s supply chains...

With regard to Volkswagen’s planned audit of the Volkswagen SAIC plant, we have reasonable doubts as to whether an external audit can now be an effective and sufficient measure in this specific case, which is why we would like to ask the following essential questions about your audit plans:

1. Who or which company is to carry out the audit?
2. What is the scope of the audit and which specific topics and risks are to be examined?
3. How do you ensure the independence and significance of the results?
4. How will it be ensured that employees can speak freely and without risk of government repression?
5. Do the auditors speak Uyghur and Chinese, or do they rely on external translators? If so, where do the translators come from and how is their independence guaranteed?
6. Are the auditors informed about the political context in which the audit will take place?
7. Is the audit company aware of legal restrictions imposed by China’s recently passed counterintelligence law, which experts warn could criminalize corporate due diligence?
8. Are the auditors aware that there is only one legal trade union in China, which is part of the Chinese Communist Party and must comply with the party?
9. Does the audit include suppliers, both suppliers of the Volkswagen SAIC plant in Urumchi and suppliers from the affected region who supply other Vokswagen sites?
10. What requirements do you place on the transparency of the audit?
11. Will you publish the results of the audit in full?
12. Will the questions and topics of the audit also be made public?
13. Will activities within the scope of the audit be announced in advance?
14. Will the audit be discussed with the joint venture partner SAIC in advance?
15. What other measures is Volkswagen taking to preventively identify, minimize and eliminate the risks of forced labor at suppliers in China?

Our doubts about the effectiveness of an audit stem from the fact that the drastic repressive policies in the Uyghur region make it impossible to collect valid information on the ground...