Summary
Details
- Global
Mandatory obligations include:
compliance with the Volkswagen Group Code of Conduct for Business Partners.
S-Rating participation for relevant direct suppliers.
flow-down of sustainability requirements to relevant sub-suppliers.
environmental and human rights due diligence cooperation.
corrective action where non-conformities are identified.
raw-material disclosure for covered battery material contracts.
Functionally mandatory obligations include:
product-level CO₂ information where requested.
energy consumption data.
Scope 1, 2 and 3 emissions data.
recycled-content validation.
renewable electricity evidence.
logistics emissions data.
raw-material traceability.
supplier and sub-supplier mapping.
The strongest obligations apply to:
battery suppliers.
steel suppliers.
aluminium suppliers.
electronics suppliers.
plastics suppliers.
logistics providers.
high-emissions component suppliers.
direct suppliers subject to S-Rating.
suppliers linked to critical raw materials.
suppliers involved in electric vehicle platforms.
Lower-risk suppliers may face lighter monitoring, but they remain covered by baseline business partner requirements.
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What’s Required
Audi’s supplier climate framework is a procurement-driven regulatory system embedded in the Volkswagen Group’s wider supply-chain governance architecture. Audi is a Volkswagen Group brand, so supplier obligations are shaped by both Audi-specific CO₂ requirements and group-level responsible sourcing systems.
The framework is built around:
Audi CO₂ Program
Audi Mission:Zero environmental programme.
Volkswagen Group's Responsible Supply Chain System, known as ReSC.
Volkswagen Group Code of Conduct for Business Partners.
Sustainability Rating, or S-Rating.
Responsible raw material due diligence.
battery raw-material supply-chain disclosure.
product-level CO₂ and recycled-content requirements.
logistics decarbonization.
supplier flow-down obligations.
Audi states that its CO₂ Program is designed to improve the CO₂ balance in the supply chain before vehicles enter the use phase. Audi also states that CO₂ emissions and recycled content are binding technical requirements specified by Audi and must be ensured and validated by suppliers. This is a critical point: supplier climate performance is not only a reporting matter, but a technical procurement requirement.
The wider Volkswagen Group Responsible Supply Chain System is based on systematic risk analysis and aims to avoid and minimise human rights, social and environmental risks across the supply chain. Violations of sustainability requirements are to be eliminated, and supplier sustainability performance is to be continuously improved.
1. Code of Conduct for Business Partners as contractual baseline
The Volkswagen Group Code of Conduct for Business Partners applies to suppliers, sales partners and other B2B business partners of Volkswagen Group companies. It covers sustainability requirements including human rights, environmental protection, ethical business conduct and responsible raw-material sourcing.
For Audi suppliers, this creates a baseline contractual compliance system. Suppliers must demonstrate that their operations and their own supply chains can meet group sustainability expectations.
Supplier obligations include:
environmental protection.
greenhouse gas emissions reduction.
responsible raw-material sourcing.
legal compliance.
business integrity.
human rights and labour standards.
risk management.
audit cooperation.
corrective action implementation.
flow-down of sustainability requirements to relevant sub-suppliers.
The Code requires business partners to contractually pass on sustainability requirements to business partners, especially suppliers, that affect the contractual relationship with the Volkswagen Group, and to ensure, as far as possible and reasonable, that these requirements are passed on along the supply chain.
This creates a multi-tier compliance chain. Audi may contract with a tier-one component supplier, but the obligations can extend to battery materials, mining, refining, electronics, logistics and material-processing suppliers.
2. Supplier CO₂ data and product-level disclosure requirements
Audi’s supplier framework includes product-level CO₂ and recycled-content obligations. Audi states that, for the brand, CO₂ emissions and recycled content are binding technical requirements specified by Audi and validated by suppliers.
The Volkswagen Group Code of Conduct also states that business partners supplying products to the Volkswagen Group provide information on request at the product level on overall energy consumption in MWh and carbon emissions in tonnes, covering Scope 1, 2 and 3, so that Volkswagen can improve product environmental indicators.
Suppliers may therefore need to provide:
facility-level energy consumption.
product-level energy data.
Scope 1 emissions.
Scope 2 emissions.
relevant Scope 3 emissions.
product carbon footprint information.
recycled-content evidence.
material composition data.
renewable electricity documentation.
manufacturing process emissions.
logistics emissions.
component-level lifecycle data.
This is a dense data architecture obligation. Automotive suppliers must connect energy, production, bill-of-materials, logistics, recycled-content and emissions systems. A generic corporate emissions estimate may not be sufficient. Audi needs product-specific data that can be assigned to vehicles, components, materials and platforms.
3. Audi CO₂ Program and embedded material decarbonization
Audi’s CO₂ Program focuses on improving the emissions profile of vehicles before their first kilometre on the road. This is especially important for electric vehicles, where upstream emissions from batteries, aluminium, steel and electronics become more material.
Suppliers in the Audi CO₂ Program may be expected to support:
lower-carbon aluminium.
lower-carbon steel.
recycled plastics.
recycled aluminium or secondary materials.
renewable electricity in component production.
battery cell and battery material decarbonization.
lower-carbon logistics.
product carbon footprint validation.
circular material loops.
process efficiency measures.
The key regulatory feature is that Audi treats CO₂ and recycled content as technical specifications. This places climate data alongside quality, performance and safety criteria. Suppliers unable to validate CO₂ reductions or recycled content may lose competitiveness in future sourcing.
4. S-Rating and procurement enforcement
Volkswagen Group’s Responsible Supply Chain System uses the Sustainability Rating, known as the S-Rating, as a procurement-relevant mechanism. The Group states that since 2019, all relevant direct business partners must undergo a mandatory sustainability rating in which environmental and social standards are assessed alongside other sourcing criteria such as costs or quality.
For Audi suppliers, the S-Rating functions as a private regulatory gate.
It may affect:
supplier onboarding.
nomination for new contracts.
sourcing decisions.
continuation of supplier relationships.
corrective action expectations.
monitoring intensity.
eligibility for strategic programmes.
The S-Rating turns sustainability from a reputational topic into a commercial requirement. A supplier can be technically capable and cost-competitive but still be commercially disadvantaged if its sustainability rating is inadequate.
5. Responsible raw material and battery supply-chain due diligence
Audi’s supplier governance is reinforced by Volkswagen Group's raw-material due diligence. The Group’s Responsible Raw Materials reporting has become especially important for electric vehicle supply chains.
Volkswagen Group stated that since 2020, it has demanded full disclosure of the supply chain right up to the mining level as part of all new contracts relating to battery raw materials.
This affects suppliers linked to:
lithium.
cobalt.
nickel.
graphite.
copper.
aluminium.
rare earths.
steel inputs.
battery cells.
cathode and anode materials.
electronics.
semiconductors.
Suppliers may need to provide:
chain-of-custody information.
mine, smelter, refiner or processor data.
origin information.
environmental risk assessments.
human rights due diligence evidence.
audit reports.
corrective action records.
traceability documentation.
sub-supplier mapping.
evidence of responsible sourcing.
This is a classic example of upstream cascade regulation. A battery cell supplier or cathode supplier may have to collect information from refiners and mines because Audi and Volkswagen Group require transparency beyond tier one.
6. Mission:Zero and logistics decarbonization
Audi’s Mission:Zero environmental programme covers decarbonization, water, resource efficiency and biodiversity. Audi states that the programme bundles initiatives to reduce the ecological footprint in production and logistics, and that partner companies are involved in developing and applying progressive techniques.
Audi also states that logistics decarbonization is part of Mission:Zero and is pursued with Volkswagen Group Logistics through a long-term roadmap to organise transport to and from plants with as little CO₂ as possible.
This affects logistics providers and suppliers responsible for inbound and outbound flows.
Relevant obligations may include:
transport emissions data.
route optimization.
modal shift.
lower-carbon fuels.
electrified transport where feasible.
packaging optimization.
load factor data.
warehouse energy information.
cooperation with plant-level logistics planning.
Logistics suppliers, therefore, become part of Scope 3 governance, not merely service providers.
7. Data systems and governance architecture
Audi’s supplier framework requires advanced data governance. Suppliers must be able to provide sustainability, emissions, materials and traceability data in formats that support procurement decisions, S-Rating assessments, product development and group-level reporting.
Supplier data systems may need to cover:
carbon accounting.
product carbon footprinting.
energy monitoring.
renewable electricity tracking.
recycled-content verification.
material traceability.
raw-material origin mapping.
sub-supplier due diligence.
audit evidence.
corrective action management.
logistics emissions tracking.
lifecycle assessment inputs.
The compliance challenge is allocation. Suppliers must often allocate emissions to specific products, components or materials. This requires reliable production-volume data, energy allocation methods, emissions factors and documentation.
8. Audit, verification and monitoring
Audi and the Volkswagen Group use a risk-based monitoring system. The Responsible Supply Chain System considers business models, S-Ratings, external materials such as media reports, whistleblower information, research, NGO reports and stakeholder discussions on human rights and environmental risks.
Monitoring may include:
supplier self-assessments.
S-Rating review.
documentation requests.
risk-based audits.
media and NGO screening.
whistleblower information.
corrective action plans.
raw-material traceability reviews.
contract-level escalation.
sourcing consequences.
The highest audit intensity applies to suppliers with high environmental impact, high human rights risk, high emissions relevance or involvement in battery raw materials.
Important Deadlines
Key timelines include:
2019: Volkswagen Group made mandatory sustainability ratings applicable to all relevant direct business partners
2020: Volkswagen Group required full disclosure to the mining level in new contracts for battery raw materials.
2025: Audi states that all Audi production sites worldwide have had net carbon-neutral operations since 2025 through its production strategy and Mission:Zero context.
2050: Audi targets to achieve net carbon neutrality at the latest.
Ongoing: S-Rating assessments for relevant direct suppliers.
Ongoing: supplier CO₂ and recycled-content validation.
Ongoing: product-level energy and emissions disclosure on request.
Ongoing: raw material due diligence and battery supply-chain transparency.
Ongoing: logistics decarbonization roadmap under Mission:Zero.
Current Status
The framework is active, mature and procurement-integrated. Audi’s supplier climate governance is especially strong because it combines brand-level CO₂ requirements with Volkswagen Group-wide enforcement mechanisms.
The framework is currently characterised by:
binding technical requirements for supplier CO₂ emissions and recycled content.
S-Rating as a procurement gate.
Responsible for Supply Chain System risk analysis.
Code of Conduct flow-down obligations.
battery raw-material supply-chain disclosure.
Mission:Zero logistics and production decarbonization.
integration into the vehicle lifecycle CO₂ reduction.
This is more advanced than a voluntary supplier ESG questionnaire. It is a sourcing eligibility system.
Penalties for Non-Compliance
Enforcement is procurement-driven.
Potential consequences include:
failed S-Rating.
blocked supplier nomination.
corrective action requirements.
increased audit intensity.
reduced sourcing volumes.
exclusion from future sourcing.
loss of approved supplier status.
contract escalation.
termination for persistent non-compliance.
exclusion from low-carbon or electric vehicle programmes.
reputational exposure through supply-chain risk escalation.
The key penalty is loss of commercial access. A supplier that cannot validate CO₂ data, recycled content, raw-material origin or sustainability compliance becomes less eligible for Audi sourcing.
Examples of Known Violations
This analysis does not identify specific public violations by named Audi suppliers. Realistic failure modes include:
incomplete product-level CO₂ data.
inconsistent Scope 1, 2 or 3 reporting.
missing energy consumption data.
unsupported recycled-content claims.
weak renewable electricity evidence.
failure to achieve an adequate S-Rating
inability to trace battery raw materials to the mining level.
incomplete sub-supplier mapping.
weak corrective action implementation.
failure to pass sustainability requirements upstream.
logistics emissions data gaps.
inconsistent lifecycle assessment assumptions.
These failures can directly affect sourcing eligibility and supplier competitiveness.
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