12/19/2023

Dear Madam or Sir,

We, the undersigned organizations, note the publication of the ESG audit results of the SAIC Volkswagen plant undertaken by Löning- Human Rights & Responsible Business GmbH. In our letter dated July 11, 2023, we expressed our extensive concerns about the credibility of an audit in the Uyghur Region. Following the publication of the audit findings, staff from Löning posted a statement on LinkedIn, distancing themselves from the audit, claiming “no other team member from Löning participated in, supported or backed this project.” An article in the Financial Times provides more detail on this internal disagreement on conducting this audit. Consequently, this has raised more questions regarding the credibility of the findings from the audit, and we have the following questions: 

1. Löning staff have distanced themselves from the audit due to the human rights situation in China and the Uyghur Region, noting: “The human rights situation in China and Xinjiang and the challenges in collecting meaningful data for audits are well known and are also present in this project.” Were you aware that no other team member at Löning approved of this audit? If so, why did you decide to proceed?
2. Markus Löning, Managing Director at Löning, acknowledged the challenges related to collecting data. How did you account for this in conducting the audit? How did you account for this in analyzing the results of the audit?
3. According to Markus Löning, the main basis for the audit was a review of documentation relating to the 197 employees at the plant rather than interviews, adding that this could be “dangerous”. Löning told the Financial Times: “Even if they would be aware of something, they cannot say that in an interview”. Nevertheless, 40 individuals were interviewed for the audit. If the firm understood that the interviews were dangerous to the participants and were unlikely to generate the information necessary, why was the safety of those 40 individuals put at risk? Additionally, if it was understood that interviews would not garner the necessary and reliable information needed, why was the audit conducted? 
4. According to Markus Löning, his senior strategy adviser, Christian Ewert, who oversaw the project, has over 20 years experience of social audits in China. What experience does Christian Ewert have with state-imposed forced labour contexts, and what indicators are applied in this context?

In addition to the individual facility at issue, Volkswagen’s supply chains are at risk. A report by Sheffield Hallam University, revealed that Volkswagen’s supply chains are heavily exposed to the Uyghur Region and are at a particular high risk of using Uyghur forced labour. According to a dpa release, VW’s Chief Legal Officer Manfred Döss assures: “We will continue to take any indications of human rights violations very seriously in the future. If there are any suspicions or indications, we will investigate them.” At Volkswagen AG’s 2023 Annual General Meeting, we drew attention to forced labour risks in China’s steel and aluminum sector; affected suppliers could also supply Volkswagen sites in China. As far as we know, you actively use your sustainability rating (S rating) in this context, according to your own statements. 

1. What further measures are Volkswagen AG and its joint ventures taking to preventively identify, minimize, and exclude risks of state-imposed forced labour at suppliers in China?

Wide-spread,systemic state-imposed forced labour is being perpetrated throughout the Uyghur Region; it is not possible to separate an individual facility from this context, nor for any company to prevent or remediate individual instances of forced labour. Within this context and in line with the UN Guiding Principles on Business and Human Rights, we believe the only responsible action for a company is to leave the region entirely.

We welcome the fact that you want to be more transparent with the public. This letter with our questions is therefore also an open letter, which we have published here on our website. We therefore also ask you for public answers by 19.01.2024.

Yours sincerely,

Gheyyur Kuerban
Berlin Director World Uyghur Congress

Eva Stocker
Senior Project Officer World Uyghur Congress

Hanno Schedler
Advisor on Genocide Prevention and the Responsibility to Protect, Society for Threatened Peoples Germany

Christian Russau
Board Member Association of Ethical Shareholders Germany

Tilman Massa
Co-Director Association of Ethical Shareholders Germany