SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR MARELLIAUTOMOTIVE SYSTEMS EUROPE PLC AND ITS SUBSIDIARIES FOR THE
YEAR ENDED 31ST DECEMBER 2022
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”)
by Marelli Automotive Systems Europe plc on behalf of all subsidiaries to which Section 54 of
the Act applies (“Subsidiaries”).
This Statement sets out the steps that Marelli has taken to address the risks of slavery andhuman trafficking being present within its operations and supply chain, and has been
adopted by the Subsidiaries as their respective slavery and human trafficking statement for
the financial year ending 31st December 2022.

OUR ORGANISATION & SUPPLY CHAIN

Marelli is one of the world’s leading global independent suppliers to theautomotive sector.
We oppose modern slavery in all its forms, including human trafficking, forced orcompulsory labour, bonded labour, servitude and child labour.
We unequivocally support the human rights of our workforce and also the workforce of ourglobal suppliers, and believe that everyone deserves a life free from slavery.
We recognise the role that businesses can play in combatting these exploitative crimes.
We are committed to being a socially responsible corporate citizen, and to conduct
ourselves in a way that considers and promotes our social and ethical responsibilities. We
will continuously seek to implement and improve our policies and procedures to ensurethat all forms of slavery are not present within our operations or supply chain.

Our Organisational Structure
Marelli Automotive Systems Europe plc and its subsidiaries are part of a wider group ofcompanies belonging to Marelli Holdings Co., Ltd, headquartered in Japan (“Marelli”).
With around 50,000 employees worldwide, the Marelli group footprint includes 142
manufacturing sites and 27 non-productive sites across Asia, the Americas, Europe andAfrica as at the end of 2022.
Marelli Holdings Co, Ltd is the highest decision making body for the whole Marelli Group.
Throughout 2022, , Marelli has continued to introduce standardised global policies andprocedures that apply to all subsidiary companies within the group, including Marelli
Automotive Systems Europe plc and its subsidiaries.

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Our Supply Chain
Marelli is a purchaser of parts, assemblies, components, raw materials, tooling, andequipment. The supply chain within the automotive industry is highly complex and oursupply chain typically consists of many layers between the goods that we sell and the raw
materials that enter the manufacturing process.
The majority of Marelli purchases are from 3rd party suppliers, however we also conduct
inter-company purchases from within the group, and we might also be supplied with parts
from 3rd parties who have been selected directly by our customers.
Marelli is also a purchaser of services, including outsourced services which are labour
dependant.

POLICIES & PROCEDURES

Our internal policies, procedures and controls ensure that we make grounded businessdecisions that consider the broader impact of our corporate actions on our wider
community.
Our internal compliance framework covers three main areas; to comply with (i) legal andregulatory requirements, (ii) company policies, regulations and procedures and (iii) social
norms, ethical and moral standards.

Code of Conduct
Our compliance framework is supported by our Code of Conduct (the “Code”) which
represents our core values. The Code is available in 19 languages, applies to all stakeholders
and offers a clear framework around how we interact with customer, suppliers, communities,governments and employees. It aims to ensure that all members of Marelli’s workforce act
with the highest level of integrity, comply with applicable laws and build a better future forour company and the communities where we run our business.
Marelli endorses the United Nations Universal Declaration on Human Rights and theInternational Labour Organization (“ILO”), and accordingly, the Code is intended to beconsistent with such guidelines. The Code includes an obligation to comply withemployment laws, and to respect the human rights of all human beings.
The Code is shared with all stakeholders, and its acceptance from suppliers is also tracked.
In 2022, 87% of active suppliers accepted our Code of Conduct.

Human Rights Policy
At Marelli, upholding the highest standards of human rights is a fundamental value that weconsider non-negotiable. To underscore our commitment to this critical issue, we reflect

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these values in our Code of Conduct and our Human Rights Policy.. The Human Rights Policy
aims to manage and reduce potential risks of human rights violations in our operations andour supply chain.

Employee Representation
Under our Human Rights Policy, we recognize the right of our employees to freely form ortake part in trade unions or other organizations aimed at defending and promoting theirinterests, aligning with local laws. Collective agreements cover topics such as employees’
health and safety (the provision of protective clothing, compensation in case of injury, etc.),
working conditions (wages, working time, flexibility schemes, vacation days, etc.), andtraining (training opportunities, the availability of funds for training, etc.), as well as
discrimination and harassment. As of December 31, 2022, collective bargaining agreements
covered 78% of Marelli’s employees,.

Purchasing Values
Marelli aims to conduct itself as an accountable and responsible business across our fullvalue chain. Marelli is committed to developing and implementing sustainable purchasing
activities, and “Sustainability” is one of our 8 core Purchasing Values. To create long-termvalue for our stakeholders, we demand that our partners and suppliers comply with a set ofrequirements for conducting business with our Company.

Appointment of Suppliers
Our global suppliers are requested to sign the Marelli Purchase Agreement, which regulates
the business relationship’s framework and contains environmental and social clauses thatcover conflict minerals, ethics and compliance. We proactively engage our suppliers insustainability initiatives through our Supplier Sustainability Program. On-site audits are
conducted at selected suppliers to identify any non-conformance to the mandatory
corporate social responsibility (CSR) requirements.

Conflict Minerals Policy
Conflict minerals are natural resources of tin, tungsten, tantalum, and gold (3TG) extracted
in conflict zones, which may be linked to human rights abuses and armed groups.
Marelli is a signatory of the Responsible Minerals Initiative.
Our suppliers are required to respect the Organization for Economic Co-operation andDevelopment (OECD)/ RMI guidelines. Our commitment is reflected in our Code of Conduct
and in coherence with it, we implemented the following activities to identify, assess, andmitigate conflict mineral risks in our supply chain:

3 of 6• Make the use of conflict minerals key performance indicator (KPI) a criteria for thesupplier selection process.
• We monitor supplier declarations of tin, tungsten, tantalum, gold, cobalt and mica. We
also monitor rare earth materials gallium and germanium due to new restrictions in China.
• We require selected suppliers to fill out the Conflict Minerals Reporting Template (CMRT)
or formally state their non-use of any conflict minerals.
• Track and be attentive to the suppliers’ answers.
• Inform suppliers about conflict mineral issues through written communication andrequest a corrective action plan.
Annually, we require our suppliers to disclose the source(s) of any conflict minerals used intheir products and comply with applicable laws and regulations including the EuropeanRegulation on Registration, Evaluation, Authorization and Restriction of Chemicals (REACH).
Furthermore, we request the availability of related International Material Data System(IMDS) documentation for each component.
Dedicated email accounts have been created to track our communication with suppliers andcustomers.

Integrity Hotline
We have established an Integrity Hotline, which allows employees and third parties to reportpossible violations of the Code, company policies or procedures, or laws and regulations.
The channel is available 24/7 and in 19 local languages. This system fosters a culture ofintegrity and ethical decision-making, in alignment with our company values.
In FY22, all concerns raised were addressed. For the substantiated cases, disciplinary actions
were taken (including termination). We also implemented remediation plans like feedback,interviews, training and guidance. No concerns regarding forced labour, trafficking or otherhuman rights breaches were raised in any of the operations of Marelli Automotive System
Europe plc and its subsidiaries.

DUE DILIGENCE PROCESSES

Recruitment
We conduct right to work checks on all direct employees of Marelli Automotive Systems
Europe plc and its subsidiaries; this includes checking that our employees are of an
appropriate age to work and that, where applicable, the employee has a valid work visa.

3rd party due diligence

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The primary risk exposure for our business lies in our supply chain so building a responsible
and resilient supply chain is a top priority for Marelli.
Within Marelli’s supply chain structure,.
a dedicated Purchasing Department engages with local and global partners to ensure all ourproducts and services suppliers comply with the terms and conditions set out in ourstandard Marelli Purchase Agreement, which mandates compliance with the UN Principles
for International Human Rights Protection and Environmental Stewardship.
Supply chain risks are identified through our external AI platform provider, Resilinc, which
predicts potential disruptions periodically by mapping and monitoring the ESG, macroeconomic, geo-political, and natural disaster risks that all direct and indirect suppliers arefacing.
On-site audits are conducted at selected suppliers to identify any non-conformance to ourmandatory corporate social responsibility (CSR) requirements.

RISK ASSESSMENT & MANAGEMENT

As part of our Corporate Governance, Marelli revised its integrated Risk Management
System, through an Enterprise Risk Management (ERM) process, including environmental,social and governance (ESG) risks, based on the ISO 31000 standard. The goal of this updated
system is to create and improve performance, encourage innovation, and support theachievement of business and ESG objectives. The assessment methodology relies upon
improved assessment criteria consisting of a revised enterprise-wide Risk Model organizedin two main areas: (i) strategy setting and execution risks, and (ii) operational risks. It also
introduces enhanced metrics (earnings before interest and taxes (EBIT), free cash flow (FCF),
reputational, operational, ESG and likelihood, to support our business operations with amore effective methodology for risk assessment and opportunities to achieve oursustainable goals.
In 2022, Marelli assessed our supplier base by identifying critical suppliers and collecting
primary data. Marelli began the process to obtain four third party audits on human rights,
labour conditions, ethics and environmental managed at three Chinese and one Mexican
plants. These audits will be finished in mid-2023.

TRAINING

In 2022, 4.8 hours of human rights training was provided per employee. . This included (i)training on “Labour and Employment: A Global Perspective” to increase awareness of humanrights principles, which achieved a 99% completion rate, and (ii) training on sustainableprocurement that was delivered to the entire purchasing department (1,019 employees).

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EVOLVING APPROACH TO SLAVERY AND HUMAN TRAFFICKING RISKS

Marelli is a company committed to ongoing improvement and we will continue toimplement an ongoing programme to improve and strengthen our compliance activities. In
accordance with the requirements of the Act, this statement will be reviewed, updated andpublished annually.

BOARD APPROVALThis statement has been made on behalf of Marelli Automotive Systems Europe plc on
behalf of its subsidiaries. It has been approved by Marelli Automotive Systems Europe plcand all of its UK registered trading subsidiary companies pursuant to board of director
approval held on the 14th September 2023. A full list of such companies is held at Marelli
Automotive Systems Europe plc’s registered office in accordance with the Act. The board ofDirectors of each company has delegated authority to Mr. Paul Paton to sign this statementon their behalf.

Paul PatonDirector
Marelli Automotive Systems Europe plc

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