BORGWARNER LIMITED
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
Financial Year End: December 31, 2023

1. INTRODUCTION
This statement is submitted per the United Kingdom’s Modern Slavery Act 2015, which
requires certain companies doing business within the UK to provide information about
their efforts to address the issue of modern slavery and human trafficking within theirbusiness and supply chain. BorgWarner fully supports these efforts, which align with OurBeliefs.
2. STRUCTURE OF THE ORGANIZATIONBorgWarner Inc. is a global automotive supplier that is publicly traded on the New YorkStock Exchange. BorgWarner Limited is a UK subsidiary of BorgWarner Inc. BorgWarnerInc. along with its subsidiaries achieved net sales of $14.2B (USD) worldwide in the year
ending on 31 December 2023. To find out more about BorgWarner's business, please
visit borgwarner.com.
3. SUPPLY CHAINS
BorgWarner works with a range of suppliers across the globe who provide raw
materials, components and parts for our manufacturing processes and products. We
have over 3,750 direct (production) and over 26,000 indirect material (non-production)
suppliers in over 48 different countries to meet its complex global business needs.
These relationships are managed globally by our Business and Enterprise Supply Chainteams.
For suppliers, the applicable terms and conditions, policies and guidance can be found
via the BorgWarner website at a dedicated section: borgwarner.com/suppliers.
4. POLICIESWe maintain policies to ensure our requirements on modern slavery/forced labor are wellcommunicated, integrated into our contractual framework, and agreed upon by all
employees and business partners. These policies are periodically reviewed,
benchmarked, and updated as the law and, in some cases, societal circumstances
require. This includes our Code of Ethical Conduct and Human Rights Policy, which wereupdated in 2023.
BorgWarner’s suppliers are required to adhere to our BorgWarner Supplier Manual, which
prohibits the use of forced labor and human trafficking and was updated in 2023.

BorgWarner's Chief Compliance Officer and the Compliance Office are responsible formonitoring compliance with our policies. Across BorgWarner there are locally situatedCompliance Coordinators responsible for compliance training and escalation of reports.
In parallel, the Business and Enterprise teams also have responsibility for the ongoing
monitoring, oversight, and management of suppliers to BorgWarner and accordingly
share in the responsibility of ensuring that all suppliers comply with their obligations,
including but not limited to human rights issues, in practice.
5. DUE DILIGENCE
To monitor and reduce the risk of slavery and human trafficking occurring within our
supply chains, we have adopted the following key due diligence procedures:•Our global supply chain team assess all new suppliers before we work with them.

•

We undertake regular reviews with our main suppliers to ensure that they operatein accordance with our requirements and policies.

•Our supplier contracts provide us with the right to audit our suppliers including,where appropriate, conducting audits using both BorgWarner employees andexternal resources.

•Direct material suppliers are audited prior to entering a business relationship withBorgWarner and audited periodically once a relationship has been established.

•BorgWarner also engages a third party to release a Sustainability Assessment
Questionnaire to our high-impact and high-risk suppliers, which includes questions
relating to human rights governance and working conditions. A third party is used
to verify supplier responses to the questionnaire.

A breach of BorgWarner's relevant policies would constitute a breach of the suppliercontract and would enable us to act up to and including termination of the arrangementwith the supplier.
Our procedures are designed to:•establish and assess areas of potential risk in our business and supply chains;•monitor potential risk areas in our business and supply chains;•reduce the risk of slavery and human trafficking occurring in our business andsupply chains; and•provide adequate protection for whistle-blowers.

6. RISK AND COMPLIANCE
BorgWarner regularly evaluates the nature and extent of its exposure to the risk of modern
slavery occurring in its operations and supply chain. Risk monitoring is an ongoing activity
handled by the Business and Enterprise teams.
In 2023, the Sustainability Assessment Questionnaire was added to a supplier scorecard
for monitoring risk. When significant risks relating to modern slavery are identified, anappropriate investigation is initiated by the Compliance Office, which may or may notinclude external support. At the conclusion of each investigation, remedial action isassessed and, where necessary, requisite modifications to our processes are made.
We also ensure all our suppliers adhere to our terms and conditions, which containexpress language prohibiting modern slavery. We enforce a strict culture of complianceand do not tolerate slavery and human trafficking within our supply chains. Our policies
make clear that in the event we find evidence of a failure to comply with our policies orwhere a potential negative human rights impact has been identified, we can and willterminate business contracts.
We have multiple reporting platforms, including a global whistleblower hotline (phone andweb-based) to allow internal and external parties to report directly or anonymously(consistent with applicable law) any activity that is contrary to BorgWarner's policies andBeliefs. The hotline calls are free and available in multiple languages consistent with ourdiverse global footprint. Additionally, we encourage reporting to be made throughmanagers, local or global human resources, legal, or compliance teams. Each report istaken seriously and is resolved using BorgWarner's investigation procedures, which
include a strict anti-retaliation policy.
7. EFFECTIVENESS
BorgWarner’s global supply chain management function continuously assesses its
policies and processes to prevent acts of modern slavery and human trafficking fromoccurring within its global business and supply chain.
TRAINING
In 2023, 99% of our salaried workforce completed ethics and compliance training. Suchtraining encourages employees to report any potential breaches of BorgWarner's ethics
and compliance policies. We encourage an open and transparent environment whereemployees and business partners feel safe and are protected from retaliation for speakingout.
FURTHER ACTIONS
BorgWarner continues to review our actions to prevent slavery and human trafficking fromoccurring in our business or supply chains. BorgWarner intends to take any necessary
further steps that are identified to tackle slavery and human trafficking.

This statement was approved by the Directors of BorgWarner Limited.
Signature:____________________________________
Dave Bate
Plant Manager
May 2024