CATERPILLAR’S SUPPLIER
CODE OF CONDUCTA MESSAGE FROM PAM HEMINGER,STRATEGIC PROCUREMENT VICE PRESIDENTAt Caterpillar, our internal Code of Conduct is the foundation of the work we do. It
defines our Values in Action – what we stand for and how we conduct ourselveswith our customers, suppliers, and one another. While we conduct business within
the framework of applicable laws and regulations, we also recognize we must set
clear expectations, beyond the law, for ourselves and our business partners.
As a Caterpillar supplier, you are an extension of our extended value chain and ourcommitment to quality. We ask you to demonstrate strong values and commit to theprinciples outlined in this document. Simply put, we expect our partners to always
follow the law and the sound business practices Caterpillar embraces, and toconduct activities in a manner that respects human rights.
Thank you for your commitment to Caterpillar, and for taking the time to read andunderstand our Supplier Code of Conduct.

Pam Heminger, Vice President
Caterpillar Strategic Procurement

CONFLICTS OF INTEREST

Suppliers must not engage in activities that create, or even appear to create,
conflict between the Supplier’s interests and the interests of Caterpillar.
Caterpillar expects prompt disclosure of any potential, actual and perceived
conflicts of interest. Suppliers must use good judgment when extending
business courtesies to ensure that any exchange of gifts, favors, orentertainment is proportionate or reasonably related to the business being
conducted between the parties. Caterpillar prohibits accepting or offering
gifts, favors or entertainment that obligate or appear to obligate ourEmployees, business partners or customers to act in any way contrary to
the law, Caterpillar’s business interests and commonly accepted businesspractices. When conducting activities with Caterpillar to meet theexpectations of this Code, Suppliers are always expected to follow thelaw and adhere to their own conflict of interest and gift policies.

FAIR COMPETITION

We expect suppliers to observe antitrust and competition laws where they
do business. In relationships with suppliers, Caterpillar avoids arrangementsthat restrict our ability to compete with others.

INTERNATIONAL TRADE LAW

We expect suppliers to follow applicable international trade laws, including
import and export controls regulations, and compliance with sanctions
and anti-boycott laws. Our suppliers have a responsibility to ensure they
comply with these trade laws and regulations in any country where they
do business.

IMPROPER PAYMENTS

Suppliers must not seek to influence others, either directly or indirectly, bypaying bribes or kickbacks or by any other measure that is unethical or thatwould tarnish Caterpillar’s reputation for honesty and integrity. Even theappearance of such conduct must be avoided.

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DIVERSITY AND INCLUSION

We expect suppliers to embrace diversity and inclusion. Suppliers mustvalue the diversity of unique talents, skills, abilities, cultures andexperiences that enable people to achieve superior business results.

FAIRNESS AND NON-DISCRIMINATION

We expect suppliers to select and place employees and sub-suppliers on
the basis of their qualifications for the work to be performed, considering
accommodations as appropriate and needed - without regard to race,religion, national origin, color, gender, gender identity, sexual orientation,age and/or physical or mental disability. We expect our suppliers to support
and obey laws that prohibit discrimination everywhere they do business.

CONFIDENTIAL INFORMATION

We consider information Caterpillar owns to be an asset. Some information
we communicate publicly, including advertising, product documentation,news releases and public financial reporting. Everything else - including
trade secrets, confidential financial information, new product or service
development plans and other corporate and personal information – weprotect through appropriate and reasonable safeguards and whereapplicable, legally enforceable agreements. To the extent our suppliers
have access to such information, we expect them to do the same.

PROTECTION OF ASSETS

Suppliers must preserve, protect and responsibly use all Caterpillar assets
to which they have access. This includes tangible as well as intangible
assets, such as our brands, technology, business information and intellectualcapital. Suppliers must not make unauthorized disclosures of trade secrets
or other sensitive information belonging to the company, our customers ordealers at any time. When sharing Caterpillar’s information with others suchas sub-suppliers, the supplier must ensure appropriate controls are in place
to protect Caterpillar interests.

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HEALTH AND SAFETY

We expect suppliers to put safety first with an aspirational goal to prevent
all injuries, occupational illnesses and safety incidents. Our suppliers must
actively promote the health and safety of everyone on their property withpolicies and practical programs that help individuals safeguard themselves,
their co-workers and Caterpillar employees. Our commitment to safe
practices extends throughout our value chain – from suppliers to end users.
We expect suppliers to provide Caterpillar with products and services thatare safe and reliable.

HUMAN RIGHTS

Caterpillar is committed to respecting internationally recognized humanrights principles throughout our global operations. We clearly articulate
our commitment to upholding and respecting human rights in Our Values inAction – Caterpillar’s Code of Conduct. We expect our suppliers to comply
with Caterpillar’s sound business practices, follow the law and conduct
activities in a manner that reflects Caterpillar’s Code of Conduct.
Caterpillar has developed a human rights policy that is uniquely our own
and is available to view on our website. We are committed to respecting
recognized human rights principles aimed at promoting and protecting
human rights in the countries in which we operate. We do not condone
and we strive to eliminate all forms of forced labor, child labor, anddiscrimination in the workplace. We encourage all of our business partners
to assess their own business activity and to develop their own approachthat respects human rights in their operations.
Additional information is available at:https://www.caterpillar.com/en/company/governance/politicalengagement/human-rights.html

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CONFLICT-FREE SOURCING

Caterpillar encourages its suppliers that manufacture components, parts,or products containing “Conflict Minerals” (Under the Dodd Frank Act
known as tin, tungsten, tantalum, and gold) to procure those materials fromconflict-free sources. We expect our suppliers to adopt, implement andcommunicate to sub-suppliers their positions and policies regarding Conflict
Minerals, and where possible, require their down-stream suppliers to adoptand implement similar positions and policies. Suppliers are expected to workwith their sub-suppliers to establish traceability of Conflict Minerals to thesmelter level and encourage the use of a standard reporting process (e.g.
the Responsible Minerals Initiative Conflict Minerals Reporting Template).
Caterpillar reserves the right to request its suppliers to provide further
evidence of their Conflict Minerals supply chain, including down to the minelevel. We expect suppliers to maintain such traceability data for five yearsand provide this information to Caterpillar upon request.
Additional information is available at http://www.caterpillar.com/en/company/sustainability/conflict-minerals.html

INNOVATION

Caterpillar wishes to be the collaborator of choice with industry,government and academic institutions around the world to leverageworld-class expertise and speed up the pace of Research & Development
to help our customers build a better world. We expect suppliers to leveragetechnology and customer insight to help Caterpillar differentiate ourproducts and services, improve product performance, promoteremanufacturing to extend product life, and make customers moreproductive, safer and more efficient.

CATERPILLAR’S SUPPLIER CODE OF CONDUCT6ENVIRONMENTAL RESPONSIBILITY

We expect suppliers to support environmental stewardship by utilizing
business processes that enable waste prevention, improve quality andpromote the efficient use of resources. Caterpillar will work with suppliers
to improve the processes and systems used throughout the manufacturing
and delivery of our products. Suppliers are required to comply withenvironmental laws and regulations.

WATER CONSERVATION STEWARDSHIP

Our suppliers are expected to implement policies and procedures to reducewater consumption in water scarce regions and use water resources
efficiently throughout the world.

ENERGY

Caterpillar recognizes energy is a key requirement for sustainable progressaround the world and is foundational to economic and social development.
Our suppliers are expected to implement policies and procedures to improveenergy efficiency and/or reduce greenhouse gas emissions.

WASTE REDUCTION

Caterpillar works to minimize waste across the end to end value chain, as agood environmental steward and as an important strategy for competing intoday’s markets. Our suppliers are expected to develop systematic policies
and procedures, including LEAN principles, to relentlessly and continuouslyeliminate or reduce waste in terms of both the resources and/or materials consumed by any process in our extended supply chain. Where waste
cannot be avoided, we expect suppliers to focus first on reusing materials,
second on proper recycling methods, and last on proper disposal, thereby
improving overall efficiency.

CATERPILLAR’S SUPPLIER CODE OF CONDUCT7REPORTING RIGHTS AND RESPONSIBILITIES

If you become aware of a circumstance or action that violates or appears toviolate this Supplier Code of Conduct or Our Values in Action - Caterpillar’s
Code of Conduct, contact the Office of Business Practices:
DIRECT TELEPHONE:+1-309-675-8662(English only)
CALL COLLECT HELPLINE:+1-770-582-5275(language translation available)
TOLL-FREE HELPLINE:
Caterpillar maintains toll-free Helpline numbers in various countries.
Inside Canada, the United States and the U.S. Virgin Islands the number is
1-800-300-7898.
Toll-free numbers currently in effect for other countries are posted at https://codeofconduct.cat.com.
Language translation is available for those numbers. You may remain
anonymous when you call from a country in which anonymous reportingis allowed.
E-MAIL:
BusinessPractices@cat.com

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