Basis of Charge

1. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents continue to be engaged in talks with the United Auto Workers to facilitate the formation and recognition of a labor organization at its Chattanooga, Tennessee facility. 2. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents are encouraging the distribution of UAW cards to employees to seek unionization and are encouraging employees to sign the cards. 3. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents are communicating to Chattanooga employees the need for a labor organization at the Chattanooga facility before any additional production would be authorized. 4. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents are threatening and coercing Chattanooga-based employees by conditioning any further expansion of the facility, and any future work opportunities, on the employees’ approval of the United Auto Workers union as their exclusive bargaining agent in order to establish a German-style works council. VW management and agents have made such threats explicitly and repeatedly to the employees in Chattanooga, including within the last six (6) months. The most recent was on October 6, 2013, when Bernd Osterloh, vice-chairman of VW and head of VW's global works council, who makes production decisions for VW, said publicly that employees in Chattanooga must form a works council and bring in the UAW as their agent if their plant is going to be given the opportunity to produce additional products for VW. 5. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents are thus interfering with Chattanooga facility employees’ rights to choose whether or not to engage in self-organization to form, join, or assist labor organizations. 6. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers’, directors’ and/or agents’ ongoing discrimination regarding terms and conditions of employment that encourages membership in the United Auto Workers and/or a labor organization are violating Section 8(a)(3) of the National Labor Relations Act. 7. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers’, directors’ and/or agents’ domination and/or interference with the formation of a labor organization at the Chattanooga, Tennessee production facility, including but not limited to contributing financial or other support to the union, are violating Section 8(a)(2) of the National Labor Relations Act. 8. Volkswagen Group of America, Inc. and its parent company, Volkswagen AG through their officers, directors and/or agents are interfering with, restraining, and/or coercing Chattanoogabased employees in the exercise of their rights guaranteed in Section 7 of the National Labor Relations Act, in violation of Section 8(a)(1).

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