Code of Conduct

The Company and all its subsidiaries refer to the principles contained in the Fiat S.p.A. code of conduct (the “Code of Conduct”) and related Guidelines until approval of the new Code of Conduct by the Board of Directors.

The latest version of the Code of Conduct, a revision of the 2003 version, took effect in February 2010. The Code of Conduct represents a set of values recognized, adhered to and promoted by the Group which understands that conduct based on the principles of diligence, integrity and fairness is an important driver of social and economic development.

The Code of Conduct is a pillar of the governance system which regulates the decision-making processes and operating approach of the Group and its employees in the interests of stakeholders. The Code of Conduct amplifies aspects of conduct related to the economic, social and environmental dimensions, underscoring the importance of dialog with stakeholders. Explicit reference is made to the UN’s Universal Declaration on Human Rights, the principal Conventions of the International Labor Organization (ILO), the OECD Guidelines for Multinational Enterprises and the U.S. Foreign Corrupt Practices Act (FCPA). The Code of Conduct was amended to include specific guidelines relating to: the Environment, Health and Safety, Business Ethics and Anti-corruption, Suppliers, Human Resource Management, Respect of Human Rights, Conflicts of Interest, Community Investment, Data Privacy and Use of IT and Communications Equipment.

In May 2014, the Code of Conduct was updated to reinforce the principles regarding “Antitrust” and “Export controls” regulations and two new related Guidelines also entered into force. The Code of Conduct applies to all Directors, employees of Group companies and other individuals or companies that act in the name and on behalf of one or more Group companies.

The Company promotes adoption of the Code of Conduct as a best practice standard of business conduct by partners, suppliers, consultants, agents, dealers and others with whom it has a long-term relationship. In fact, Group contracts worldwide include specific clauses relating to recognition and adherence to the principles underlying the Code of Conduct and related guidelines, as well as compliance with local regulations, particularly those related to corruption, money-laundering, terrorism and other crimes constituting liability for legal persons.

The Code of Conduct is available on the Investors section (Fiat S.p.A. Archive) of the Group’s website.