INTEGRITYEXCELLENCETEAMWORKCOMMITMENTSUSTAINABILITYINZETEXZELLENZTEAMARBEITVERPFLICHTUNGKEBERLANJUTANRZETELNOŚĆFÖRTRÄFFLIGHETÅTAGANDE HÅLLBARHETOUR VALUESIN ACTION
CATERPILLAR’S
CODE OF CONDUCTA MESSAGE FROM OUR CHAIRMAN & CEO................... 1
LIVING BY THE CODE............................................... 3
REPORTING RIGHTS & RESPONSIBILITIES................... 4
NO RETALIATION POLICY.......................................... 4
INTEGRITY............................................................ 7
Honesty and Integrity...................................................8
Conflicts of Interest......................................................8
Competitive Conduct....................................................9Free Trade......................................................................9
Financial Reports and Accounting............................ 10
Fair Communication.................................................. 10
Inside Information..................................................... 11
Improper Payments................................................... 11

EXCELLENCE........................................................ 13
Product and Service Quality...................................... 14
Value to Customers.................................................... 14
Work Environment..................................................... 15
Employee Performance.............................................. 15
Employee Development............................................. 16
Risk Management...................................................... 16
Enterprise Point of View............................................ 17

TEAMWORK......................................................... 19
Respect and Non-Harassment................................... 20
Fairness and Non-Discrimination............................. 20
Inclusive Environment.............................................. 21
Global Standards........................................................ 21
Outside Organizations............................................... 22
Dealers and Distributors............................................ 22
Suppliers..................................................................... 23

page_2

COMMITMENT..................................................... 25
Personal Responsibility............................................. 26
Protection of Assets................................................... 26
Confidential Information.......................................... 27
Electronic Communications...................................... 27
Personal Privacy......................................................... 28
Public Matters............................................................. 28
Government Contracts............................................... 29

SUSTAINABILITY.................................................. 31
Health and Safety....................................................... 32
Innovation................................................................... 32
Environmental Responsibility................................... 33
Infrastructure and Energy......................................... 33
Communities.............................................................. 34
Best Team................................................................... 34

ENTERPRISE POLICIES........................................... 35
WAIVER.............................................................. 35

Revised 2023

A MESSAGE FROM OUR CHAIRMAN & CEO

AT CATERPILLAR, WE DESIGN AND MANUFACTURE
PRODUCTS THAT HELP BUILD, POWER AND DEVELOPCOMMUNITIES, AND IMPROVE PEOPLES’ STANDARD
OF LIVING.
THROUGH THE WORK AND DEDICATION OF OUR GLOBALTEAM WE DELIVER THE BEST PRODUCTS POSSIBLE TOOUR CUSTOMERS – AND BUILD A BETTER WORLD.
We are proud that the people on our team come from across the globe, withdiverse backgrounds, experiences and perspectives. This diverse culture andcharacter makes us stronger.
What unites us within this diversity is a common set of Values; that we are notjust accountable for the work we do, we also care deeply about how we do it.
Our Code of Conduct defines those Values in Action – what we stand for andhow we conduct ourselves with our customers, suppliers and one another.
Its purpose is not to provide a set of rules that covers every situation orchallenge we may face, but to guide us in living those values everyday. The
Code of Conduct explains what Integrity, Excellence, Teamwork, Commitment
and Sustainability mean to us and how we use these Values to make sound,ethical decisions.
I think our Code of Conduct is the most important document we produce
at Caterpillar.
Thank you for taking the time to read and understand it, and more
importantly, for staying true to the Values which have shaped our company
for almost 100 years, and will see us through the years ahead.

JIM UMPLEBY

Chairman & CEO
page 1LIVING BY THE CODEINTEGRITY. EXCELLENCE. TEAMWORK. COMMITMENT. SUSTAINABILITY.
The words in this Code of Conduct define us. Despite our differences – in
geography, culture, language and business – we are one Caterpillar, one company
united by these common principles with a shared commitment to the highest
standards of conduct.
While we conduct our business within the framework of applicable laws andregulations, for us, compliance with the law is not enough. We strive for morethan that. Through our Code of Conduct, we envision a work environment all cantake pride in, a company others respect and admire and a world made better by
our actions. Together, we are laying the foundation for the values-based culturethat will carry us forward to even higher levels of success. Together, we are
upholding the reputation of one of the world’s great companies – andstrengthening it for tomorrow.
This Code of Conduct applies to the daily activities of employees ofCaterpillar Inc., its subsidiaries and affiliates worldwide and members of its
Board of Directors. Each of us has a personal responsibility to read the Codeof Conduct, understand what it means and apply it consistently. Those in ourcompany who lead others hold a special position of responsibility to set theexample of what it means to “live by the Code.”

page 3

CODE OF CONDUCTREPORTING RIGHTS AND RESPONSIBILITIES
If you become aware of a circumstance or action that violates, or appears to violate,
the Code of Conduct, enterprise policy or applicable law, contact your supervisor or
local management as soon as possible. You have a further personal right andresponsibility to report any circumstance or action that violates, or appears toviolate, the Code of Conduct, enterprise policy or applicable law. You must use
these reporting rights responsibly and must report issues only where you
reasonably believe there has been a violation, and not where the report is intended
to be harassing, is based on personal opinion only or is otherwise trivial. You canraise a question or concern or make such a report to your supervisor, local
management, local or corporate human resources teams or Legal Services. You
always have the option to contact the Office of Business Practices using the contact
information below.
Direct Telephone: +1-309-675-8662 (English only)
Toll-free Helpline: Caterpillar maintains toll-free Helpline numbers in various
countries. Inside Canada, the United States and the U.S. Virgin Islands thenumber is 1-800-300-7898. Toll-free numbers currently in effect for othercountries are posted at https://codeofconduct.cat.com. Language translation isavailable for those numbers. You may remain anonymous when you call from acountry in which anonymous reporting is allowed.
Call Collect Helpline: +770-582-5275 (language translation available)
Regional Contacts: Available at https://codeofconduct.cat.com
Email: BusinessPractices@cat.com
Mailing Address: 100 NE Adams, Peoria, IL 61629, USA
Violations of Caterpillar policies, procedures or this Code of Conduct will be
addressed promptly and effectively. In conjunction with the company’s HR
guidance and local laws, violations may result in disciplinary action up to andincluding employment separation.
You can request a copy of the Office of Business Practices’ Data Privacy Statement
using any of the methods listed above.

NO RETALIATION POLICY
Caterpillar will not take any action against you as a result of raising an ethical issue
in good faith. Also, Caterpillar does not tolerate any reprisal by any individual
against an employee for raising a concern or making a report in good faith.
page 4OUR VALUESIN ACTION
CATERPILLAR’S CODE OF CONDUCT

Sustainability
The Power of Endurance

page 5

INTEGRITY
The Power of Honesty

INTEGRITY IS THE FOUNDATION OF ALL WE DO.

It is a constant. Those with whom we work, live andserve can rely on us. We align our actions with ourwords and deliver what we promise. We build andstrengthen our reputation through trust. We do not
improperly influence others or let them improperly
influence us. We are respectful and behave in an open
and honest manner. In short, the reputation of theenterprise reflects the ethical performance of thepeople who work here.

page 7

CODE OF CONDUCT

We put Integrity in action when…

WE ARE HONEST AND ACTWITH INTEGRITY
We hold ourselves to the highest standard of integrity and ethical behavior. We tell
the truth. We promise only what we can reasonably expect to deliver. We strive tokeep our commitments. Our company’s stockholders, customers, dealers,
distributors, suppliers, those with whom we do business and our fellow employees
must be able to trust what we say and believe that we will always keep our word.

WE AVOID AND MANAGE CONFLICTS
AND POTENTIAL CONFLICTS OF INTEREST
We must not engage in activities that create, or even appear to create, conflict
between our personal interests and the interests of the company. These situations
arise where a personal interest or family or other relationship makes it difficult for
an individual to represent the company fully and fairly. Conflicts of interest canarise in any part of Caterpillar’s operations. The most serious conflicts of interest
usually arise where an employee or former employee has authority to spend thecompany’s money, has authority to hire or engage with a person outside thecompany or has information that could be valuable to a person outside thecompany. A conflict of interest or the appearance of a conflict of interest very often
arises when an employee is offered a gift, favor or entertainment. While some ofthis activity is part of a normal business relationship, we do not accept gifts, favors
or entertainment that have a value greater than we could reasonably reciprocate orthat obligate or appear to obligate us to act in any way contrary to the law,Caterpillar business interests or Caterpillar’s ethical business practices.

page 8INTEGRITY – The Power of Honesty

WE COMPETE FAIRLY
Caterpillar believes that fair competition is fundamental to free enterprise. We
observe antitrust and competition laws where we do business. In relationships withcompetitors, dealers, distributors, suppliers and customers, we avoid arrangementsthat restrict our ability to compete with others. We are not involved in any
arrangements, understandings or agreements with competitors affecting prices,
terms upon which products are sold, or the number or type of products
manufactured or sold.

WE ADVOCATE FOR FREE TRADE AND
FOLLOW INTERNATIONAL TRADE LAWS
Caterpillar competes best in a free trade environment. Free trade requires us tocontinually improve our global competitiveness and creates an environment thatallows us to better respond to our customers’ needs. We promote policies thatenhance competition in the global marketplace and reduce – or better yet,eliminate – trade and investment barriers. We believe trade liberalization leads toeconomic gains that raise standards of living and improve quality of life. We arecommitted to following applicable international trade laws including import andexport controls regulations, and compliance with sanctions and anti-boycott laws.
Each of us has a responsibility to ensure that we comply with trade laws andregulations in any country where we do business.

For more information: www.caterpillar.com/Code-of-Conduct

page 9

CODE OF CONDUCTWE ENSURE ACCURACY ANDCOMPLETENESS OF OUR FINANCIALREPORTS AND ACCOUNTING RECORDS
Investors, creditors, regulatory authorities and others have a legitimate interest in
our company’s financial and accounting information. The integrity of Caterpillar’sfinancial reports and accounting records is based on validity, accuracy,completeness, timeliness and understandability of basic information supporting
entries to the company’s books of account. We will ensure every accounting or
financial entry accurately reflects what is described by the supporting information.
Each person at Caterpillar – not just those in finance and accounting – has a role inensuring our financial records are complete and accurate and internal controls arehonored. The same standards of integrity that apply to external financial reporting
also apply to the financial statements that are used as internal management tools.

WE ARE FAIR, HONEST AND OPEN IN
OUR COMMUNICATIONS
As employees, we communicate with each other in a respectful, fair, honest andopen manner. As a public company, we have a responsibility to communicate
information about our business to our stakeholders clearly, accurately and honestly.
The disclosures we make in our reports and filings submitted to the U.S. Securities
and Exchange Commission and to other governmental and regulatory agencies
must be full, fair, accurate, timely and understandable. When we communicate
publicly, we are consistent in our messages. Only designated spokespersons may
communicate on behalf of Caterpillar or respond to requests for information fromthe media, governments, analysts and stockholders. When we release information
about Caterpillar to the public, we do it fairly and impartially, without favoring any
individual or group.

page 10INTEGRITY – The Power of Honesty

WE HANDLE INSIDE INFORMATIONAPPROPRIATELY AND LAWFULLY
Inside information may be defined as information about a company that is notknown to the public. Such information – certain financial data, technical materials
and future plans for example – may have significant value to others and therefore
must be kept strictly confidential. Inside information may be “material” if aninvestor would consider it important in making an investment decision. Anyone
who has “material” inside information about Caterpillar must not use it for
personal gain, provide it to others or trade in Caterpillar securities. Additionally,
any Caterpillar employee who, as a result of his or her employment, receives
material inside information about a third party (including dealers, suppliers,
customers or competitors) must not trade in that company’s securities or advise
others to do so. We expect all employees, their families and others whose
relationships with Caterpillar give them access to inside information to comply
with these principles and with Caterpillar’s policies regarding insider trading.

WE REFUSE TO MAKE
IMPROPER PAYMENTS
In dealing with public officials, other corporations and private citizens, we firmly
adhere to ethical business practices. We will not seek to influence others, either
directly or indirectly, by paying bribes or kickbacks or by any other measure that isunethical or would tarnish our reputation for honesty and integrity. Even theappearance of such conduct must be avoided.

For more information: www.caterpillar.com/Code-of-Conduct

page 11

page_12

EXCELLENCE
The Power of Quality

WE SET AND ACHIEVE AMBITIOUS GOALS.

The quality of our products and services reflects thepower and heritage of Caterpillar – the pride we take inwhat we do and what we make possible. We are
passionate about people, process, product and service
excellence. We are determined to serve our customers
through innovation, continuous improvement, an
intense focus on customer needs and a dedication tomeet those needs with a sense of urgency. For us,
Excellence is not only a value; it is a discipline and ameans for making the world a better place.

For more information: www.cat.com/Code-of-Conduct

page_13
page 13

CODE OF CONDUCT

We put Excellence in action when…

WE ACCEPT NOTHING BUT THE
BEST QUALITY IN OUR PRODUCTS
AND SERVICES
We are dedicated to quality and take personal pride in all the products and services
we provide. Our intense, acute focus on the needs of our customers continuously
drives us to improve. Our continued success depends on exceeding the expectationsof our customers and standing behind everything we do.

WE FOCUS ON DELIVERING THE
HIGHEST VALUE TO OUR CUSTOMERS,ALWAYS WITH A SENSE OF URGENCY
We are driven to meet the needs of our customers. We have built a reputation for
excellence by listening to our customers, understanding their needs and challenges
and delivering products, services and solutions that help them succeed. Our
customers expect the best from Caterpillar. Each of us must ensure that our
individual decisions and actions contribute to a positive perception of the company,
enhance our customers’ satisfaction and promote their loyalty. To do so, we act with asense of urgency to deliver the highest possible value in the products and services weprovide. Our commitment to quality, the Guiding Principles of the Caterpillar
Production System and continuous improvement makes that possible.

page 14

EXCELLENCE – The Power of Quality

WE ESTABLISH A WORK ENVIRONMENTTHAT SUPPORTS EXCELLENCE
Caterpillar employees expect our work environment to promote personal
achievement, continual learning and a feeling of self-worth. We actively seek andshare diverse viewpoints to achieve excellence. Employees have the right to express
good-faith opinions about how we can improve our own performance and theperformance of the company. We actively listen, respond, encourage teamwork andmake decisions based on facts and data.

WE SELECT, PLACE AND EVALUATEEMPLOYEES BASED ON THEIRQUALIFICATIONS AND PERFORMANCE
Caterpillar selects, places, evaluates and rewards employees based on their personalqualifications, skills for the job, demonstrated performance and the contributions
they make to Caterpillar.

For more information: www.caterpillar.com/Code-of-Conduct

page 15

CODE OF CONDUCTWE PROVIDE EMPLOYEES WITHOPPORTUNITIES TO DEVELOP
We ask employees to give their best efforts, learn from their successes and setbacks
and pursue opportunities to improve their performance on their own initiative, as
well as through continual learning programs offered by the company andrecommended by their leaders. We encourage self-development and will assist
employees in mastering their current jobs and improving their job skills. We arecommitted to assuring opportunities for all employees to develop their abilities andcontribute to Caterpillar’s success.

WE SEE RISK AS SOMETHING
TO BE MANAGED, AND AS
POTENTIAL OPPORTUNITY
Because we realize that business and risk are inseparable, we proactively identify,
assess and manage risks that have the most potential to impact our business.
For us, managing risk also involves looking for opportunities for potential
competitive advantage.

page 16

EXCELLENCE – The Power of Quality

WE TAKE AN ENTERPRISE
POINT OF VIEW
Taking an “enterprise point of view” means promoting the best interests of ourcompany as a whole. We strive to ensure local decisions do not put the enterprise at acompetitive disadvantage. We must always consider the enterprise when making
decisions. Our success requires that we continually leverage entrepreneurial thinking
in our individual business units and apply what we learn across the enterprise to
make all our products and services better.

For more information: www.caterpillar.com/Code-of-Conduct

page 17

TEAMWORKThe Power of Working Together

WE HELP EACH OTHER SUCCEED.

We are a team, sharing our unique talents to help thosewith whom we work, live and serve. The diverse
thinking and decision making of our people
strengthens our team. We respect and value people
with different opinions, experiences and backgrounds.
We know that by working together, we can produce
better results than any of us can achieve alone.

page 19

CODE OF CONDUCT

We put Teamwork in action when…

WE TREAT OTHERS WITH RESPECT
AND DO NOT TOLERATE INTIMIDATIONOR HARASSMENT
The full value of each individual’s contribution can be realized only when we treat
one another with the respect, trust and dignity we ourselves expect. Caterpillar insists
on a work environment free of intimidation and harassment. As individual
employees, we have the right to expect a positive working environment, along withthe responsibility to speak out and ask for change if we observe conduct that runs
contrary to this principle.

WE TREAT PEOPLE FAIRLY AND
PROHIBIT DISCRIMINATION
We build and maintain a productive, motivated workforce by treating all employees
fairly and equitably. We respect and recognize the contributions of employees as wellas other stakeholders. We will select and place employees 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 support and obey laws that prohibit discrimination everywhere we do business.

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TEAMWORK – The Power of Working Together

WE FOSTER AN INCLUSIVEENVIRONMENT
We embrace diversity and inclusion. We respect the uniqueness of individuals andappreciate our differences. We value the diversity of unique talents, skills, abilities,
cultures and experiences that enable our people to achieve superior business andpersonal results. We know that when we seek out and are receptive to various pointsof view, we drive innovative solutions, deliver superior results and positively impact
the people and communities we serve.

WE CONDUCT BUSINESS WORLDWIDEWITH CONSISTENT GLOBAL STANDARDSAs a global company, we understand there are many differing economic and politicalphilosophies and forms of government throughout the world. We acknowledge thewide diversity that exists among the social customs and cultural traditions in the
countries in which we operate. We respect such differences, and to the extent that we
can do so in keeping with the principles of our Code of Conduct, we will maintainthe flexibility to adapt our business practices to them. We will leverage our global
experience to achieve the best results for the enterprise.

For more information: www.caterpillar.com/Code-of-Conduct

page 21

CODE OF CONDUCTWE COLLABORATE WITH KEY
ENTITIES AND ORGANIZATIONSOUTSIDE OUR COMPANY
The company’s strength and longevity are the result of our ability to sustain longlasting, mutually rewarding relationships with our customers, dealers, distributors,
suppliers, investors and others with whom we do business. We engage inmeaningful dialogue with these stakeholders as well as appropriate governmental
and nongovernmental organizations. We listen, learn and innovate and wecontinuously work to strengthen these relationships through conscientious,
trustworthy behavior.

WE BUILD OUTSTANDING
RELATIONSHIPS WITH OUR DEALERS
AND DISTRIBUTION CHANNEL MEMBERS
Our dealers and distributors around the world serve as a critical link between ourcompany and our customers. We rely on them to participate with us in building andmaintaining the long-standing customer relationships that have made Caterpillar
successful. We value their positive contributions to our reputation and their deep
commitment to the customers and communities they serve. We sustain ouroutstanding relationships with them through trust, communication and shared
rewards. We work continuously with them to provide products, services and support
solutions necessary to satisfy customer needs worldwide.

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TEAMWORK – The Power of Working Together

WE VIEW OUR SUPPLIERS AS OUR
BUSINESS ALLIES
We seek strong, mutually rewarding business relationships with suppliers whoenhance the value of our products and services through close collaboration
throughout the entire life cycle. We view suppliers as extensions of our company andan essential part of our extended value chain and commitment to quality. We look forsuppliers and business allies who demonstrate strong values and commit to the
ethical principles outlined in the Caterpillar Supplier Code of Conduct. We expect
suppliers to comply with the sound business practices we embrace, follow the law
and conduct activities in a manner that respects human rights. No supplier isrequired to buy Caterpillar products in order to compete for business or to continue
as a supplier. We do reserve the right, consistent with applicable law, to require
suppliers to use Caterpillar equipment when performing work on Caterpillar
premises and where Caterpillar offers a product appropriate for the work being
performed. We encourage fair competition among our potential suppliers,
contractors and other vendors and work equitably and reasonably with all.

For more information: www.caterpillar.com/Code-of-Conduct

page 23

page 24

COMMITMENT
The Power of Responsibility

WE EMBRACE OUR RESPONSIBILITIES.

Individually and collectively, we make meaningfulcommitments – first to each other, and then to thosewith whom we work, live and serve. We understandand focus on the needs of our customers. We areresponsible members of our communities who are
dedicated to safety, care for our environment andmanage our business ethically. We know it is bothour duty and our honor to carry the Caterpillar
heritage forward.

For more information: www.caterpillar.com/Code-of-Conduct

page 25

CODE OF CONDUCT

We put Commitment in action when…

WE TAKE PERSONAL RESPONSIBILITY
We are committed to the success of Caterpillar and we each have a responsibility toprotect and uphold Caterpillar’s reputation. All employees are personallyaccountable for meeting both individual and shared goals. We expect employees touse good judgment and avoid any communication, disclosure or interaction thatmight disparage, defame or damage our reputation. Employees are personallyresponsible for adhering to applicable business practices, following company
policies, procedures and complying with the law.

WE PROTECT OUR ASSETS, BRANDSAND INTELLECTUAL PROPERTY
We go to extraordinary lengths to preserve, protect and responsibly use all of ourassets. This includes tangible as well as intangible assets, such as our brands,
technology, business information and intellectual capital. We will not makeunauthorized disclosure of trade secrets or other sensitive information belonging
to the company, our customers, dealers or suppliers – either during employment
by our company or thereafter. When sharing company information with others, we
strive to ensure appropriate controls are in place to protect our interests. We
respect the valid intellectual property rights of others. While we may hire
individuals who have knowledge and experience in various technical areas, we do
not employ people as a means of gaining access to trade secrets and sensitive
information of others. We have a personal responsibility to use every appropriate
means to safeguard our company’s assets from loss, theft, damage or misuse.

page 26

COMMITMENT – The Power of Responsibility

WE SAFEGUARD OURCONFIDENTIAL INFORMATION
We consider information we own to be an asset and protect it accordingly. Some
information we communicate publicly, including advertising, productdocumentation, 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 – we protect
through appropriate and reasonable safeguards and where applicable, legally
enforceable agreements.

WE USE ELECTRONIC COMMUNICATIONSTECHNOLOGY RESPONSIBLY
AND PROFESSIONALLYElectronic communication technology plays a vital role in how we conduct ourbusiness every day. The company’s technology is maintained for legitimate
business activities by authorized individuals and to support a positive, professional
business climate. Access to and use of company technology including the Internet
and Caterpillar systems is expected to be managed in a responsible andprofessional manner consistent with the Code and other company policies.

For more information: www.caterpillar.com/Code-of-Conduct

page 27

CODE OF CONDUCTWE RECOGNIZE AND RESPECTPERSONAL PRIVACY
We recognize and respect the personal information privacy interest of individuals.
We collect and process only personal information needed or appropriate forbusiness purposes, and do so only by lawful and fair means. We take reasonable
and appropriate measures designed to safeguard the security and confidentiality ofcompany records containing personal information whether those records are heldby Caterpillar or by a Caterpillar business partner.

WE PARTICIPATE IN PUBLIC MATTERS
IN AN APPROPRIATE MANNER
We believe engagement in public policy issues around the world is vital toCaterpillar’s success. With oversight by the Board of Directors, the company
engages in public policy issues and may make political contributions as laws allow
and with the approval of government affairs. Our employees should feel free toparticipate in public matters and political processes according to their individual
beliefs. Where employees participate as individuals in public matters or thepolitical process, such activity must be done in an individual capacity as a private
citizen without the use of company assets.

page 28

COMMITMENT – The Power of Responsibility

WE RESPECT THE UNIQUE RULES THAT
GOVERN DOING BUSINESS WITH THE
PUBLIC SECTOR
We are mindful that special rules apply to contracts with governments and stateowned enterprises. We honor our contractual commitments to these customers
and follow all applicable laws for transacting in the public marketplace. We holdourselves accountable for meeting the obligations imposed by this type of businessand ensure we act with honesty and integrity.

For more information: www.caterpillar.com/Code-of-Conduct

page 29

SUSTAINABILITY
The Power of Endurance

WE ARE COMMITTED TO BUILDING A BETTER WORLD.

Sustainability is part of who we are and what we doevery single day. We recognize progress involves abalance of environmental stewardship, social
responsibility and economic growth. We consider thisas we work toward a vision of a world in which people’s
basic needs – such as shelter, clean water, education
and reliable energy – are fulfilled. We provide work
environments, products, services and solutions thatmake productive and efficient use of resources as we
strive to achieve our vision. We believe thiscommitment supports the enduring success of ourcustomers, stockholders, dealers and our people.

page 31CODE OF CONDUCT

We put Sustainability in action when…

WE PROTECT THE HEALTH AND SAFETYOF OURSELVES AND OTHERS
We value our people and contribute toward a global environment in which people
can live safe, healthy and productive lives. We put safety first with an aspirational
goal to prevent all injuries, occupational illnesses and safety incidents. We actively
promote the health and safety of everyone on our property with policies andpractical programs that help individuals safeguard themselves and theirco-workers. Our commitment to safe practices extends throughout our value
chain – from suppliers to end users. We are committed to providing our customers
with products and services that are safe and reliable.

WE INNOVATE TO MAKE OUR
CUSTOMERS MORE EFFICIENT
AND PRODUCTIVE
We innovate to provide customers with products, services and solutions that
improve the sustainability of their operations. We leverage technology andcustomer insight to improve product performance, promote remanufacturing toextend product life and make job sites more productive, safer and more efficient.
We encourage our dealers to do the same. We support sustainable solutions that
protect and preserve the environment while leading to profitable growth forCaterpillar and our customers. Our products and services will meet or exceed
applicable regulations wherever they are initially sold.

page 32

SUSTAINABILITY – The Power of Endurance

WE FOCUS ON ENVIRONMENTALRESPONSIBILITY AND
PREVENTING WASTE
We focus on improving the quality and efficiency of our operations while reducing
our environmental impact. We support environmental stewardship by utilizing
business processes that enable waste prevention, improve quality and promote theefficient use of resources in our locations. Our waste prevention efforts areintegrated end-to-end across the value chain from suppliers to our dealers.
We work with them to improve the processes and systems used throughout the
manufacturing and delivery of our products. We are committed to complying
with environmental laws and regulations and expect our suppliers and dealers to
do the same.

WE SUPPORT INFRASTRUCTURE
DEVELOPMENT AND ACCESS TO ENERGY
Meeting the demands of the increasing global population and improving thestandard of living throughout the world will require infrastructure development
including access to safe and reliable energy sources. We support balanced andcomprehensive policies that promote continued infrastructure development andutilization of all energy resources, including traditional sources of energy as
well as alternative and renewable energy technologies. We develop products andservices that contribute to sustainable power generation and infrastructuredevelopment solutions.

For more information: www.caterpillar.com/Code-of-Conduct

page 33

CODE OF CONDUCTWE ARE PRO-ACTIVE MEMBERS
OF OUR COMMUNITIESAs individuals and as a company, we contribute our time and resources to promote
the health, welfare and economic stability of communities around the world.
We conduct our business in a manner that respects human rights. We encourage
all employees to participate in activities that strengthen our communities. Our
success should also contribute to the quality of life, prosperity and sustainability ofcommunities where we work, live and serve.

WE ATTRACT AND DEVELOPTHE BEST TEAM
We understand the importance of our people to Caterpillar’s enduring success.
We attract and develop the best team of innovative, high performing employees
and strategically plan our global workforce needs. We build trust and engagement
through open and honest dialogue and encourage employees to pursue their career
aspirations and personal development. A sustainable workforce is one that isalways ready to deliver on our commitments now and in the future.

page 34

ENTERPRISE POLICIES AND
ADDITIONAL INFORMATIONEnterprise Policies and other moredetailed company policies, as well as
additional information and guidance on
this Code of Conduct, are available toemployees at https://codeofconduct.cat.
com, or by contacting the Office ofcom
Business Practices using any of themethods listed previously. The Code of
Conduct is also available to the public at
http://www.caterpillar.com/Code-ofConduct. The Enterprise Policies in force
Conduct
at the time this Code of Conduct was
published are:

WAIVER
Those in our company who lead others
hold a special position of responsibility to
set the example of what it means to “liveby the Code.” As a result, any waiver of theCode of Conduct for an Executive Officer
or Director may be made only by the Boardof Directors and will be promptly disclosed
as required by law or regulation. Waiversof the Code of Conduct for any other
employee may be made only by the Chief
Ethics and Compliance Officer and Officeof Business Practices.

• Antitrust• Company Attitudes on Partisan Politics
and Public Issues• Conflicts of Interest• Data Privacy• Enterprise Facilities• Free Trade• Improper Payments• Intellectual Property Rights• Protection of Assets• Providing and Receiving Travel, Gifts
and Entertainment• Public Communications

For more information: www.caterpillar.com/Code-of-Conduct

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