VOLKSWAGEN
GROUP OF AMERICA

MEDIA INFORMATION
FOR IMMEDIATE RELEASE
Jeannine Ginivan
Corporate Communications
703-364-7816
Jeannine.Ginivan@vw.com

Volkswagen Reaches Settlement Agreements with U.S. Federal Regulators, Private
Plaintiffs and 44 U.S. States on TDI Diesel Engine Vehicles
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Proposed settlement program includes vehicle buybacks and lease terminations, emissions
modifications (if approved) and cash payments to affected customers for approximately 475,000
eligible 2.0L TOI vehicles
Volkswagen agrees to $2.7 billion environmental remediation fund and to invest $2.0 billion in
initiatives to promote the use of zero emissions vehicles in the U.S.
Separate resolution with U.S. states settles consumer protection claims

Herndon, Va. /Wolfsburg, Germany (June 28, 2016) - Volkswagen AG announced today that it has
reached settlement agreements with the United States Department of Justice (DOJ) and the State of
California; the U.S. Federal Trade Commission (FTC); and private plaintiffs represented by the
Plaintiffs' Steering Committee (PSC) to resolve civil claims regarding eligible Volkswagen and Audi 2.0L
TOI diesel engine vehicles in the United States. Of approximately 499,000 2.0L TDL vehicles that were
produced for sale in the United States, approximately 460,000 Volkswagen and 15,000 Audi vehicles
are currently in use and eligible for buybacks and lease terminations or emissions modifications, if
approved by regulators. Volkswagen will establish a maximum funding pool for the 2.0L TOI settlement
program of $10.033 billion. That amount assumes 100% participation and that 100% of eligible
customers choose a buyback or lease termination.
The agreements covering the proposed 2.0L TOI settlement program are subject to the approval of
Judge Charles R. Breyer of the United States District Court for the Northern District of California, who
presides over the federal Multi-District Litigation (MDL) proceedings related to the diesel matter.
Volkswagen also announced that it has agreed with the attorneys general of 44 U.S. states, the District
of Columbia and Puerto Rico to resolve existing and potential state consumer protection claims related
to the diesel matter for a total settlement amount of approximately $603 million.
"We take our commitment to make things right very seriously and believe these agreements are a
significant step forward," said Matthias Muller, Chief Executive Officer of Volkswagen AG. "We
appreciate the constructive engagement of all the parties, and are very grateful to our customers for
their continued patience as the settlement approval process moves ahead. We know that we still have
a great deal of work to do to earn back the trust of the American people. We are focused on resolving
the outstanding issues and building a better company that can shape the future of integrated,
sustainable mobility for our customers."
Three agreements have been submitted to the Court for its approval with respect to the proposed 2.0L
TOI settlement program: (1) a Consent Decree filed with the Court by the DOJ on behalf of the
Environmental Protection Agency (EPA) and by the State of California by and through the California Air

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Resources Board (CARB) and the California Attorney General; (2) a Consent Order submitted by the
FTC; and (3) a proposed class settlement agreement with the PSC on behalf of a nationwide settlement
class of current and certain former owners and lessees of eligible 2.0L TOI Volkswagen and Audi
vehicles. The parties believe that the class settlement as presented to the Court will provide a fair and
reasonable resolution for affected Volkswagen and Audi customers. Volkswagen continues to work
expeditiously to reach an agreed resolution for affected vehicles with 3.0L TOI V-6 diesel engines.
On April 22, 2016, Volkswagen recognized total exceptional charges of €16.2 billion in its financial
statements for 2015 for worldwide provisions related to technical modifications and repurchases, legal
risks and other items as a result of the diesel matter. As noted at that time, due to the complexities and
legal uncertainties associated with resolving the diesel matter, a future assessment of the risks may be
different.
"Today's announcement is within the scope of our provisions and other financial liabilities that we have
already disclosed, and we are in a position to manage the consequences. It provides further clarity for
our U.S. customers and dealers as well as for our shareholders. Settlements of this magnitude are
clearly a very significant burden for our business. We will now focus on implementing our TOGETHERStrategy 2025 and improving operational excellence across the Volkswagen Group," said Frank Witter,
Chief Financial Officer of Volkswagen AG.
The agreements announced today are not an admission of liability by Volkswagen. By their terms, they
are not intended to apply to or affect Volkswagen's obligations under the laws or regulations of any
jurisdiction outside the United States. Regulations governing nitrogen oxide (NOx) emissions limits for
vehicles in the United States are much stricter than those in other parts of the world and the engine
variants also differ significantly. This makes the development of technical solutions in the United States
more challenging than in Europe and other parts of the world, where implementation of an approved
program to modify TOI vehicles to comply fully with UN/ECE and European emissions standards has
already begun by agreement with the relevant authorities.
Proposed 2.0L TOI Settlements
Subject to Court approval of the proposed 2.0L TOI settlement program, Volkswagen has agreed,
among other terms, to:
• Buy back or terminate the leases of eligible vehicles, or provide free emissions modifications (if
approved by the EPA and CARB), and also make cash payments to affected current and certain
former owners and lessees.
o Volkswagen will establish a single funding pool to cover the 2.0L TOI settlement
program. The maximum funding amount will not exceed $10.033 billion and is
dependent on how many customers participate in the program and which option they
choose if proposed modifications are approved.
o Customers can choose to sell back their vehicle to Volkswagen or terminate their lease
without penalty, or, if a modification is approved, choose to have their vehicle modified
free of charge and keep it. Customers who select any of these options will also receive a
cash payment from Volkswagen.
o An eligible vehicle's value for a buyback will be determined based on the Clean Trade-In
Value as published in the September 2015 edition of the NADA Used Car Guide, with
adjustments for factory options and mileage.
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Support the following environmental programs in the United States by agreement with the EPA
and CARB:

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Pay $2. 7 billion over three years into an environmental trust, managed by a trustee
appointed by the Court, to remediate excess nitrogen oxide (NOx) emissions from 2.0L
TOI vehicles.
Invest $2.0 billion over 10 years in zero emissions vehicle (ZEV) infrastructure, access
and awareness initiatives.

Volkswagen will begin the settlement program as soon as the Court grants final approval to the
settlement agreements. At the earliest, approval will occur in the fall of 2016. Potential claimants under
the class settlement do not need to contact Volkswagen or Audi, or their dealers, at this time. Individual
class members will receive extensive notification of their rights and options (including the option to "opt
out" of the settlement agreement) if the Court grants preliminary approval of the proposed class
settlement at a hearing scheduled to take place on July 26, 2016.
More information about the proposed 2.0L TOI settlement program, including the settlement
agreements in full, can be found at www.VWCourtSettlement.com or www.AudiCourtSettlement.com .

NOTES TO EDITORS
Volkswagen in the United States
Volkswagen Group of America (VWGoA), a wholly owned subsidiary of Volkswagen AG, employs more
than 6,000 people in the United States and supports more than 1,000 dealer locations in all 50 states.
Volkswagen has more than 60 years of history in the United States, where VWGoA maintains more
than 30 U.S. locations including a LEED Platinum-certified manufacturing facility in Chattanooga,
Tennessee.
The Chattanooga facility employs more than 2,500 people and supports suppliers who provide some
9,200 jobs. The facility produces the Volkswagen Passat and will launch production of a new, sevenpassenger midsize SUV in late 2016. Volkswagen is investing $900 million to expand its U.S.
manufacturing footprint through production of the new SUV as part of Volkswagen AG's plan to invest
more than $7 billion in North America from 2015 through 2019.

The Multi-District Litigation (MDL)
The case is known as In Re: Volkswagen "Clean Diesel" Marketing, Sales Practices and Products
Liability Litigation, MDL 15-2672, in United States District Court for the Northern District of California in
San Francisco before Judge Charles R. Breyer.
The following 2.0-liter TOI engine vehicles are included in the proposed 2.0L TOI settlement program:
VW Beetle
2013- 2015

VW Golf
2010-2015

VW Jetta
2009-2015

VW Passat
2012-2015

AudiA3
2010-2013; 2015

The proposed 2.0L TOI class settlement was executed by Volkswagen AG, Volkswagen Group of
America, Inc., Volkswagen Group of America Chattanooga Operations, LLC and Audi AG, which have
agreed to cover claims administration costs as well as plaintiffs' reasonable attorneys' fees and
expenses. Volkswagen has agreed to the appointment by the Court of a Claims Supervisor who will
review customer claims to confirm that the claims administration process is conducted in accordance
with the FTC Consent Order.
After final approval of the class settlement, claims of class members who have not opted out of the
class settlement will be dismissed.

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Resolution with U.S. States
The separate agreements with U.S. states, the District of Columbia and Puerto Rico resolve existing
and potential consumer protection claims under state statutes governing unfair and deceptive acts and
practices (UDAP) in relation to more than 534,000 2.0L and 3.0L TOI vehicles originally sold or leased
in the participating states and districts before September 18, 2015. They were executed by Volkswagen
AG, Volkswagen Group of America, Inc., Audi of America, LLC, Volkswagen Group of America
Chattanooga Operations, LLC and Audi AG, as well as Dr. Ing. h.c. F. Porsche AG and Porsche Cars
North America, Inc.
Volkswagen will pay approximately $583 million to the signatories and $20 million to the National
Association of Attorneys General (NAAG) for use by state attorneys general for consumer protection
oversight, training and enforcement, and for the reimbursement of costs and expenses related to this
matter. Participating states include California, Florida, Illinois, New York, Pennsylvania and Texas. At
this point, the signatories do not include Arizona, New Jersey, New Mexico, Oklahoma, Vermont and
West Virginia, which have 30 days to join in the settlement.
Other Legal Matters
Volkswagen continues to work to resolve outstanding legal matters in the United States. These include
civil claims by the DOJ, FTC and private plaintiffs represented by the PSC related to 3.0L TOI vehicles
and various other putative class action claims, civil penalties sought by the EPA and potential state
environmental claims, and any criminal investigations by the DOJ.
About Volkswagen Group of America, Inc.
Volkswagen Group of America, Inc. (VWGoA) is a wholly owned subsidiary of Volkswagen AG, one of
the world's leading automobile manufacturers and the largest carmaker in Europe. VWGoA operates a
manufacturing plant in Chattanooga, Tennessee and is the U.S. headquarters for distinguished and
exciting brands, including Audi, Bentley, Bugatti, Lamborghini and Volkswagen, as well as VW Credit,
Inc. Founded in 1955, the company's headquarters are in Herndon, Va. The company has
approximately 6,000 employees in the United States and sells its vehicles through a network of
approximately 1,000 dealers.
Notes:
This press release and images are available at media.vw.com. Follow us @VWNews.

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