Code of
Ethics andBusiness
Conduct

TABLE OF

CONTENTS
Our Mission and Vision 2
Our Guiding Principles 3
A Message from Executive
Leadership 4
Our Code 5
Purpose and Overview 5
Who Must Follow This Code 5
Complying With Laws
and Regulations 6
The Compliance Office –Your Resource 6
Employee Responsibilities 6
Additional Responsibilities
of Supervisors 7
Making the Right Choice –Our Guidelines for Ethical
Decision-Making 8
Asking Questions andReporting Concerns 8
Our Non-Retaliation Policy 10
Accountability and Discipline 10
Waivers and Changes to the Code 10

Working With Our Customers
and Business Partners 16
Honest and Fair Dealing 16
Supplier Relations 17
Protecting the Confidential Informationof Others 17
Maintaining the Integrity of Our Data  17
Conflicts of Interest  19
Gifts and Entertainment 20

Protecting Information and Assets  22
Protecting Our Company Assets 22
Confidential Information and Intellectual Property  23Acquiring Competitive Intelligence  24
Creating and Managing Our
Business Records 25
Communicating With the Public 26
Using Social Media 26

Following the Letter and theSpirit of Law 27
Antitrust and Fair Competition 27
Cooperation With Audits  29
Data Protection  29

Promoting a Safe andRespectful Workplace 11

Political Activities 30

Diversity, Equal Opportunity and
Non-Discrimination 11

Anticorruption and Bribery 31

Harassment-free Workplace 12
Safe and Healthy Work Environment 14

Insider Trading  31

Anti-money Laundering 33
Imports, Exports and Global Trade  33– Alcohol and Drugs  15Serving the Greater Good 35– Workplace Violence 15

Respecting Human Rights 35
Responsible Sourcing and Conflict Minerals  35
Protecting the Environment 36

Closing Thoughts from
Our Compliance Officer  37

Code of Ethics and Business Conduct

1

Our Mission and Vision

Our vision is to be a global leader in mobility safety. We strive to provide safetysystem solutions of the highest quality and reliability that allow our customers
the design freedom and confidence to drive the next generation in mobility. We
accomplish this by building:

One team creating an inspired culture
A strong and stable partner to our OEM customers globally
Product excellence through innovations in integrated safety
A commitment to quality and compliance
A lean and competitive cost structure2Our Guiding Principles

Our Guiding Principles are our roadmap. They describe how we achieve our vision andreinforce our commitment to conducting our business with integrity.

A Commitment to Ethics and Integrity in Everything We Do
Acting with ethics and integrity is central to how we conduct our business. We set highstandards for ethical behavior and expect our employees to meet our standards andlive our Guiding Principles, even under challenging circumstances. We expect all of ouremployees to be honest and transparent in conducting our business and to have thecourage to do what is right.

A Commitment to Quality
We take pride in providing high quality safety products and services to our customers.
We are committed to upholding quality standards set forth by our customers, industry
groups and governmental agencies. On a daily basis, we strive to improve our quality
performance and maintain a continuous improvement mentality in everything we do.

Accountability
We believe in accountability. Being accountable means that we take responsibility
for our actions and the actions of our teams. When we have not acted in accordancewith our standards and values, we will take action to promptly correct mistakes orinappropriate situations. Accountability is not about blame or fault; it means living up
to our values, our Code of Ethics and Business Conduct and our policies.

Speaking Up
We value a “Speak Up” environment. “Speaking Up” means asking questions so we
can ensure that we are living up to the high standards that we set for ourselves andour business partners. We encourage our employees to “speak up” when they feelthat the law, the Code of Ethics and Business Conduct or company policies may havebeen violated. By “speaking up” you are helping us protect our brand and reputation.
We promote a culture where our employees feel comfortable raising issues or asking
questions without fear of retaliation.

Product Safety
Product safety is our most important goal. The products that we make save lives. Each ofus has an obligation to strive individually, and as a team, to work tirelessly to minimize
the risk of injury and death due to traffic accidents. The safety of drivers and passengers
guides us in all we do.

Workplace Safety
We strive to provide a safe and healthy work environment for our employees,
contractors, suppliers and customers. We are committed to conducting our businessin compliance with all applicable health and safety laws and regulations. Each of us is
responsible for acting in a way that protects ourselves and others.
Code of Ethics and Business Conduct

3

A Message from Executive Leadership
Our success as a global leader in automotive safety systems is the resultof game-changing technologies, the contributions of a passionate team,and an unwavering commitment to honesty and integrity in everything we
do. As an employee, you continue to play a critical role in who we are as acompany today and who we will be tomorrow.
Our Code of Ethics and Business Conduct (“Code”) is an important resourcein this respect. As we continue to grow, and the business landscapecontinues to shift, our Code helps us to keep meeting our day-to-day ethics
and compliance responsibilities and delivering on the promises we’ve madeto each other, our customers, our business partners and the communities
where we live and work.
Of course, our Code cannot answer every question or address every situation
you may face on the job. That’s why we have resources available to help you
when challenges arise. If, at any time, you are unsure of the proper course ofaction or have a concern that the law, our Code, our policies or proceduresare being broken, you have a responsibility to speak up.
Thank you for your support and dedication to conducting business theright way. Working together, with a shared commitment to our Guiding
Principles, we will maintain the reputation we’ve earned as a company that
advances ideas and technology to save lives, around the world.

4

Our CodePurpose and Overview
Integrity matters.
When you conduct business ethically, you send a message toothers that they can put their trust in us and in our products.
By doing the right thing, you not only protect our reputation,
but also help our company to thrive in today’s complex andcompetitive business environment.
To meet our commitments, we have created this Code. It isorganized into six sections and provides standards for:• Ensuring compliance with applicable laws, regulations andJoyson Safety Systems policies.
• Promoting integrity and the highest standard of ethical conduct.
• Helping us to avoid even the appearance of anything improperin connection with our company’s business activities.

Who Must Follow This CodeAll employees, including contract and temporary employees,
corporate officers, and members of the Board of Directors of
Joyson Auto Holdings SA and its direct and indirect subsidiaries
and affiliates (“Joyson Safety Systems”), are required toread, understand and meet the standards and obligationsin this Code. Certain business partners, such as vendors andconsultants, serve as an extension of Joyson Safety Systems.
They are expected to follow the spirit of our Code, as well as any
applicable contractual provisions, when working on behalf ofJoyson Safety Systems.
If you supervise our business partners or temporary employees,
you are responsible for communicating our standards andensuring that they are understood. If an external business
partner fails to meet our ethics and compliance expectationsor their related contractual obligations, it may result in thetermination of their contract.
Code of Ethics and Business Conduct

5

Complying With Laws and Regulations
Joyson Safety Systems is committed to compliance with all laws, rules
and regulations that apply to our business in every location in which we
do business. It’s impossible to anticipate every question you may have or
situation you might face, so in addition to the Code, Joyson Safety Systems
also has other resources that can be of help. These additional resources arelisted throughout the Code. As always, we rely on you to use good judgment
and to seek help when you need it.
We operate in many countries, so it’s important to be aware of different laws
and customs that may apply. While we respect the norms of our customers,
business partners and co-workers throughout the world, all employees mustat a minimum comply with the standards and principles in this Code. If any
provision of our Code conflicts with a local law or requirement, you shouldseek guidance from the Compliance Officer.

The Compliance Office – Your Resource
Joyson Safety Systems’ Compliance Office oversees both our Code and our
ethics and compliance program. This team helps ensure that our company ismeeting its legal and regulatory obligations and that each of us is complying
with company-wide policies and procedures.
Training on our Code and annual attestations are managed by the Compliance
Office and help to ensure that everyone, in every location, has read,understands and complies with our Code.
The Compliance Office is also your resource for help with any Code question
or concern. We believe that the way we do business is as important as thebusiness we do – the Compliance Office takes action to promote an ethical
Joyson Safety Systems and to preserve and protect our Guiding Principles.

Employee Responsibilities
Each of us must take responsibility for acting with integrity, even when thismeans making difficult choices. Meeting our responsibilities is what enables
us to succeed and grow.
• Always act in a professional, honest, and ethical manner when acting on
behalf of the company.
• Know the information in the Code and written company policies andpay particular attention to the topics that apply to your specific job
responsibilities.
• Complete all required employee training in a timely manner and keep
up-to-date on current standards and expectations.
• Report concerns about possible violations of the law, our Code or policies toyour supervisor, an executive or any of the resources listed in this Code.
• Cooperate and tell the truth when responding to an investigation or audit
and never alter or destroy records in response to an investigation or when
an investigation is anticipated.
6Remember: no reason, including the desire to meet business goals, should
ever be an excuse for violating the law, our Code or our policies.

What I’m a supervisor and not clear what my obligations are if

if?

someone comes to me with an accusation – and what if it
involves
a senior leader?
No matter who the allegation involves, you must report it. Joyson Safety
Systems provides several avenues for reporting concerns. If, for any reason,
you are uncomfortable making a report to a particular person, you may
talk to any of the other resources listed in the Code or another memberof management.

Additional Responsibilities of Supervisors
Joyson Safety Systems’ leaders are expected to meet the following additional
responsibilities:• Lead by example. As a supervisor, you are expected to exemplify highstandards of ethical business conduct.
• Help create a work environment that values mutual respect and open
communication.
• Be a resource for others. Be available to communicate with employees,
contractors, suppliers and other business partners about how the Code andother policies apply to their daily work.
• Be proactive. Look for opportunities to discuss and address ethics andchallenging situations with others.
• Respond quickly and effectively. When a concern is brought to yourattention, ensure that it is treated seriously and with due respect foreveryone involved.
• Be aware of the limits of your authority. Do not take any action thatexceeds your authority. If you are ever unsure of what is appropriate (andwhat isn’t), discuss the matter with your supervisor or Compliance Officer.
• Delegate responsibly. Never delegate authority to any individual whom you
believe may engage in unlawful conduct or unethical activities.

What I observed misconduct in an area not under my supervision. Am I stillif?

required to report the issue?
You are chiefly responsible for employees, contractors and other third parties
under your supervision, but all Joyson Safety Systems’ employees are required
to report misconduct. As a leader, you are especially obliged to be proactive.
The best approach is to talk first with the supervisor who oversees the area
where the problem is occurring, but if this isn’t feasible or effective, you
should use the other resources described in our Code.

Code of Ethics and Business Conduct

7

Making the Right Choice – Our Guidelines for
Ethical Decision-Making
Making the right decision is not always
easy. There may be times when you’ll
be under pressure or unsure of what
to do. Always remember that when
you have a tough choice to make,you’re not alone. There are resources
available to help you.

Before proceeding, ask
yourself:
Is it legal?
Is it consistent with our Code andour Guiding Principles?

Facing a Difficult Decision?
Ask yourself whether you are willingto have any contemplated actions
appear the following day on the front
page of the newspaper to be read byyour family, friends, and colleagues.
One More Thing …

Would I feel comfortable if senior
management and others within
the company knew about it?
Would I feel comfortable if my decisionor my actions were made public?

We value your feedback. If you have
If the answer to all of these questions
suggestions for ways to enhance ouris“yes,” the decision to move forward
Code, our policies or our resources tois probably OK, but if the answer to any
better address a particular issue youquestion is “no” or “I’m not sure,”
have encountered, bring them forward.
Promoting an ethical Joyson Safety
stop and seek guidance.
Systems is a responsibility we all share. Remember, in any situation, under any
circumstances, it is always appropriate toerr on the side of caution and ask for help.
Asking Questions andReporting Concerns

If you see or suspect any violation of
the law, our Code or our policies, or if you have a question about what to do,talk to your supervisor.
If you’re uncomfortable speaking with your supervisor, there are otherresources available to help you:
• Contact another member of management.
• Contact the Compliance Officer or Human Resources.
• Contact the Joyson Safety Systems Compliance Hotline toll-free or online.
Joyson Safety Systems will make every reasonable attempt to ensure thatyour concerns are addressed appropriately.
LEARN MORE
• Compliance Reporting• Non-Retaliation• Reporting Channels

8What to expect when you use the Joyson Safety Systems
Compliance Hotline
The Compliance Hotline and the web portal are available 24 hours,
seven days a week. Trained specialists from an independent thirdparty provider of corporate compliance services, will answer yourcall, document your concerns and forward a written report to
Joyson Safety Systems for further investigation.
When you contact the Compliance Hotline you may choose toremain anonymous where allowed by local law. All reports will betreated equally whether they are submitted anonymously or not.
After you make a report, you will receive an identification number
so you can follow up on your concern. Following up is especially
important if you have submitted a report anonymously, as we
may need additional information in order to conduct an effective
investigation. This identification number will also enable you to track
the resolution of the case; however please note that, out of respect
for privacy, Joyson Safety Systems will not be able to inform you
about individual disciplinary actions.
Any report you make will be kept confidential by all individuals
involved with reviewing and, if necessary, investigating it.
Remember, an issue cannot be addressed unless it is brought tosomeone’s attention.

What Our supervisor typically does nothing when concerns about

if?

potential misconduct are brought to her attention and I believeshe
has made things difficult for co-workers who have raised
issues. I have a problem – a co-worker is doing something that I believe
to be ethically wrong. What should I do?
Take action and speak up. You are required to report misconduct.
While starting with your supervisor is often the best way to efficiently
address concerns, if you do not believe that it is appropriate or do
not feel comfortable doing so, you should talk to another member ofmanagement, or any of the resources listed in the Code.

What Someone misused the Compliance Hotline, made an anonymous

if?

call and falsely accused someone of wrongdoing.


Experience has shown that the Compliance Hotline is rarely used formalicious purposes, but it is important to know that we will follow up on
calls and anyone who uses the Hotline in bad faith to spread falsehoods
or threaten others, or with the intent to unjustly damage anotherperson’s reputation, will be subject to disciplinary action, up to andincluding termination.

Code of Ethics and Business Conduct

9

Our Non-Retaliation Policy
We will not tolerate any retaliation against an employee who in good faithasks questions, makes a report of actions that may be inconsistent withthe law, our Code or our policies or who assists in an investigation ofsuspected wrongdoing.
Reporting “in good faith” means making a genuine attempt to provide
honest, complete and accurate information, even if it later proves to be
unsubstantiated or mistaken.

What I suspect there may be some unethical behavior going on in myif?

business unit involving my supervisor. I know I should report mysuspicions,and I’m thinking about using the Compliance Hotline,
but I’m concerned about retaliation.
You are required to report misconduct and, in your situation, using the Hotline
is a good option. We will investigate your suspicions and may need to talk to
you to gather additional information. After you make the report, if you believe
you are experiencing any retaliation, you should report it. We take claims ofretaliation seriously. Reports of retaliation will be thoroughly investigatedand, if they are true, retaliators will be subject to discipline, up to andincluding termination.

Accountability and Discipline
Violating laws, our Code or our policies, or encouraging others to do so,
exposes our company to liability and puts our reputation at risk. If an ethics
or compliance problem does occur, you are required to report it so thatan effective solution can be developed. You should also understand that
violations of laws or regulations may result in legal proceedings and penalties
including, in some circumstances, criminal prosecution.

Waivers and Changes to the CodeOn rare occasions, limited waivers of the Code may be necessary. Anyrequest for a waiver of this Code must be submitted in writing to the Chief
Compliance Officer.

LEARN MORE
• Compliance Reporting• Non-Retaliation• Reporting Channels

10Promoting a Safe andRespectful
Workplace
Diversity, Equal Opportunity and
Non-Discrimination
Joyson Safety Systems helps bring together
employees with a wide variety of backgrounds,
skills and cultures. Combining such a wealth oftalent and resources creates the diverse anddynamic teams that consistently drive our results.
Our colleagues, job applicants and business
partners are entitled to respect and should
be judged on the basis of their qualifications,demonstrated skills and achievements.
We support laws prohibiting discrimination basedon protected characteristics such as a person’srace, color, gender, national origin, age, religion,
disability, marital status or sexual orientation.
We respect freedom of association and obey alllaws on working hours and compensation.

Live Our Guiding Principles• Treat others respectfully and professionally.
• Promote diversity in hiring and other
employment decisions.
• Do not discriminate against others on thebasis of any other characteristic protected bylaw or company policy.

Code of Ethics and Business Conduct

11

Watch • Comments, jokes or materials, including emails, which others

Out might consider offensive.

For • Inappropriate bias when judging others. If you supervise others,

judge them on performance. Avoid introducing unrelated considerations into
your decisions. Use objective, quantifiable standards.

What One of my co-workers sends emails containing jokes and derogatory

if?

comments about certain nationalities. They make me uncomfortable,but
no one else has spoken up about them. What should I do?


You should notify your immediate supervisor or Human Resources. Sending
such jokes violates our values as well as our policies that relate to the useof email and our standards on diversity, harassment and discrimination. By
doing nothing you are condoning discrimination and tolerating beliefs thatcan seriously erode the team environment that we have all worked to create.

Harassment-free Workplace
We all have the right to work in an environment that is free from intimidation,harassment and abuse.
Verbal or physical conduct by any employee that harasses another, disrupts
another’s work performance, or creates an intimidating, offensive, abusive or
hostile work environment will not be tolerated.
At Joyson Safety Systems we do not tolerate:• Threatening remarks, obscene phone calls, stalking or any otherform of harassment.
• Causing physical injury to another.
• Intentionally damaging someone else’s property or acting
aggressively in a manner that causes someone else to fear injury.
• Threatening, intimidating or coercing others on or off thepremises – at any time, for any purpose.
• Weapons or unpermitted hazardous materials in the workplace– this includes not only our facilities, but also parking lots andalternate work locations maintained by the company.

Live Our Guiding Principles• Help each other by speaking out when a co-worker’s conduct makesothers uncomfortable.
• Never tolerate sexual harassment including requests for sexual favors, orother unwelcome verbal or physical conduct of a sexual nature.
• Demonstrate professionalism. Do not visit inappropriate internet sites ordisplay sexually explicit or offensive pictures.
12• Promote a positive attitude toward policies designed to build a safe,
ethical and professional workplace.
• Report all incidents of harassment and intimidation that may
compromise our ability to work together and be productive.

Watch • Unwelcome remarks, gestures or physical contact.

Out • The display of sexually explicit or offensive pictures or otherFor materials.

• Sexual or offensive jokes or comments (explicit or by innuendo) and leering.
• Verbal abuse, threats or taunting.

Sexual Harassment
A common form of harassment is sexual harassment, which ingeneral occurs when:• Actions that are unwelcome are made a condition of
employment or used as the basis for employment decisions suchas a request for a date, a sexual favor or other similar conduct ofa sexual nature.
• An intimidating, offensive or hostile work environment iscreated by unwelcome sexual advances, insulting jokes or otheroffensive verbal or physical behavior of a sexual nature.

What While on a business trip, a colleague of mine repeatedly asked me

if?

out for drinks and made comments about my appearance that mademe
uncomfortable. I asked him to stop, but he wouldn’t. Weweren’t in the office and it was after regular working hours, so I wasn’t surewhat I should do. Is it harassment?
Yes it is. This type of conduct is not tolerated, not only during working hours
but in all work-related situations including business trips. Tell your colleague
such actions are inappropriate and must be stopped, and if they continue,
report the problem.

What I just learned that a good friend of mine has been accused of sexualif?

harassment and that an investigation is being launched. I can’t
believeit’s true and I think it’s only fair that I give my friend anadvance warning or a “heads up” so he can defend himself. Don’t I have a
responsibility as a friend to tell him?

Under no circumstances should you give him a “heads up.” Your friend will
be given the opportunity to respond to these allegations and every effort
will be made to conduct a fair and impartial investigation. An allegation ofsexual harassment is a very serious matter with implications not only forthe individuals involved but also for our company. Alerting your friend could
jeopardize the investigation and expose our company to additional risk andpossible costs.
Code of Ethics and Business Conduct

13

Safe and Healthy Work Environment
Ensuring safety is an integral part of everything we do in our manufacturing
and operations and in our research and development activities. Each of us
is responsible for acting in a way that protects ourselves and others.
We can only achieve our goal of a safe and healthy workplace through theactive participation and support of everyone. Situations that may pose ahealth, safety or environmental hazard should be reported immediately. All
reports can be made without fear of reprisal.
Safety is a condition of employment, and we expect the commitment ofeach director, officer and employee to making Joyson Safety Systems anaccident-free workplace.

Live Our Guiding Principles• Observe the safety, security and health rules and practices that apply
to your job.
• Notify your supervisor immediately about any unsafe equipment, or
any situation that could pose a threat to health or safety or damage
the environment. As an employee, you have the right and the
responsibility to stop any work if you feel your safety is at risk.
• Maintain a neat, safe working environment by keeping work stations,aisles and other work spaces free from obstacles, wires and otherpotential hazards.

Watch • Unsafe practices or work conditions.

Out • Carelessness in enforcing security standards, such as facility		For entry procedures and password protocols.

14

Alcohol and Drugs– While at work or on company business, you should never be
impaired, and always ready to carry out your work duties.

– While conducting company business, do not use, possess or
be under the influence of illegal drugs or any substance that
could interfere with a safe and effective work environment or
harm our company’s reputation.
Workplace Violence
Violence of any kind has no place at Joyson Safety Systems.
We won’t tolerate:– Intimidating, threatening or hostile behavior.
– Causing physical injury to another.
– Acts of vandalism, arson, sabotage or other criminal
activities.
– The carrying of weapons and hazardous materials on tocompany property unless you are authorized to do so.
– Possession of a firearm, explosive or other dangerous
weapon on Joyson Safety Systems’ premises or use of an
object as a weapon.
– Inflicting or threatening injury or damage to another person’slife, health, well-being, family or property.

What I’ve noticed some practices in my area that don’t seem safe. Who

if?

can I speak to? I’m new here, and don’t want to be considered atroublemaker.
Discuss your concerns with your supervisor or Human Resources. There may
be very good reasons for the practices, but it’s important to remember thatraising a concern about safety does not make you a troublemaker, but a
responsible employee concerned about the safety of others.

What A subcontractor commits a violation of our standards. Are

if?

subcontractors expected to follow the same health, safety andsecurity
policies and procedures as employees?


Absolutely. Supervisors are responsible for ensuring that subcontractors andvendors at work on Joyson Safety Systems’ premises understand and comply
with all applicable laws, and regulations governing the particular facility, as
well as with additional requirements our company may impose.

Code of Ethics and Business Conduct

15

Working With
Our Customers andBusiness
Partners
Honest and Fair Dealing
We treat our customers and business partners fairly. We
work to understand and meet their needs, while always
remaining true to our own ethical standards. We tell thetruth about our services and capabilities and never makepromises we can’t keep.
In short, we treat our customers and business partners as wewould like to be treated.

Live Our Guiding Principles• Treat each customer fairly and honestly.
• Speak up and talk to your supervisor immediately if you
have concerns about any error, omission, undue delay
or defect in quality or our customer service.
• Promptly raise with a supervisor any potential conflict ofinterest between you, our customers or our company.
• Never follow a customer’s request to do somethingthat you regard as unethical or unlawful including thealtering of data or test reports.
• Be responsive to customer requests and questions.
Only promise what you can deliver and deliver on what
you promise.

Watch • Pressure from colleagues or supervisors to cut

Out corners on quality or delivery standards.

For• Temptations to tell customers what you thinkthey want to hear rather than the truth; if a situation is
unclear, begin by presenting a fair and accurate picture as abasis for decision.

16

Supplier Relations
Joyson Safety Systems evaluates and engages with qualified suppliers(including vendors) on an objective basis grounded in fairness. Whenselecting suppliers, we assess each supplier’s ability to satisfy our businessand technical needs and requirements. We also make purchasing decisions
based on the long-term cost and benefit to Joyson Safety Systems. All
agreements are negotiated in good faith and must be fair and reasonable
for both parties.

Protecting the Confidential Information of Others
Our customers, business partners and others place their trust in us. We
must protect their confidential information.

Live Our Guiding Principles• Understand the expectations of customers and business partners
regarding the protection, use and disclosure of the confidential
information that they provide to us.
• Limit any access to third-party confidential information to those
persons who have a need to know in order to do their job, and only
for authorized purposes.
• Do not ask for or receive competitors’ trade secrets or confidential
information unless the disclosure is covered by a non-disclosure
or confidentiality agreement approved by the Legal or ComplianceDepartment.

LEARN MORE
• Fair Competition
Policy• Immediately report any loss or theft of confidential information to
your supervisor.

Watch • Requests by business partners for confidential information about

Out our customers or about other business partners if there is no

For associated business requirement or authorization.

• Unintentional exposure of confidential information about our customers orbusiness partners in public settings or through unsecure networks.

Maintaining the Integrity of Our Data
Our customers and the driving public put not only their trust, but theirlives, in our hands. We have a responsibility to ensure that our products
are designed, manufactured, tested and suitable for use based on data thatis accurate, reliable and complete. Product quality is our highest priority,and data integrity is a fundamental aspect of our company’s Quality
Management System.

Code of Ethics and Business Conduct

17

Joyson Safety Systems – rather than any employee or department – is the owner of all
data; but each of us is responsible for ensuring that data is generated and acquired,recorded, reported, retained and disposed of in accordance with company policies,
procedures and applicable law.
All employees are expected to familiarize themselves with the company policies,
procedures and applicable law.
Each of us must adhere to sound data integrity principles to ensure that our data is
attributable, legible, contemporaneous, original, and accurate. We must refrain fromany conduct that calls into question the integrity of our data including data falsification,
making unauthorized changes or substitutions to data, destroying, deleting, oroverwriting data. And, we must report any issue that impacts the integrity of our data(for example, errors, omissions, or intentional data manipulation).
If you are responsible for entering data or verifying data accuracy, comply withestablished policies, procedures and work instructions. If you are a supervisor or
manager responsible for the quality and integrity of data within your department,
make sure that any access to data is authorized, that procedures are followed and thatdata records are kept up to date and maintained in an auditable manner.

Live Our Guiding Principles• E nsure that data is attributable, legible, contemporaneous, original, andaccurate• Never engage in any conduct that calls into question the integrity of data
including falsification of data, making unauthorized changes or substitutions todata, destroying, deleting or over-writing data.
• Report any issue that impacts the integrity of our data (for example, errors,omissions or intentional data manipulations).

What I believe that a new design we have introduced may create a safety risk. I

if?

reported my concerns to my supervisor. She shares my concern, but is taking
no action because we have already
manufactured
the product and she feels the risk of injury is small. What should I do?
Do not hide anything that you believe may pose a reasonable risk to our quality,
services, reputation or interests. Bring this issue to the attention of another memberof management or the Compliance Officer.

What I have reason to believe that a co-worker may have made some unauthorizedif?

changes to some test reports. What should I do?
You should immediately report your suspicions utilizing any of the reporting
mechanisms identified in our Code. Remember the obligation we have to maintain thetrust of our customers and the integrity of our data – speak up if you see or suspectfalsified data, unauthorized changes to data, destroyed data or any other conduct that
may call into question the accuracy of our data.
LEARN MORE
18

• Data Integrity Policy

Conflicts of Interest
A conflict of interest can occur whenever you have a competing interest
that may interfere with your ability to make an objective decision on behalfof Joyson Safety Systems. Each of us is expected to use good judgment andavoid situations that can lead to even the appearance of a conflict, which canundermine the trust others place in us and damage our reputation.
Conflicts of interest may be actual, potential or even just a matter ofperception. Since these situations are not always clear-cut, you need to fully
disclose them to your supervisor so that we can properly evaluate, monitor
and manage them.
LEARN MORE

Live Our Guiding Principles• Conflicts of Interest Policy• Avoid conflict of interest situations whenever possible.
• Always make business decisions in the best interest of Joyson Safety
Systems.
• Discuss with your supervisor full details of any situation that could beperceived as a potential conflict of interest.
• Think ahead and proactively address situations that may put yourinterests or those of a family member in potential conflict with Joyson
Safety Systems.
Be alert to situations, including the following, which are common examples ofpotential conflicts of interest:
Corporate opportunities
If you learn about a business opportunity because of your job, it belongs
to Joyson Safety Systems first. This means that you should not take that
opportunity for yourself unless you get approval from the Compliance Officer.
Friends and relatives
On occasion, it is possible that you may find yourself in a situation where you
are working with a close friend or relative who works for a customer, supplieror competitor. Since it is impossible to anticipate all situations that may create
a potential conflict, you should disclose your situation to your supervisor inorder to determine if any precautions need to be taken.
Outside employment
To ensure that there are no conflicts and that potential issues are addressed,
you always need to disclose and discuss outside employment with yoursupervisor. If approved, you must ensure that the outside activity does notinterfere with your work at Joyson Safety Systems. Working for a competitor,
supplier or customer may raise conflicts that will need to be resolved. Also,
any approved side or personal business should not compete with Joyson
Safety Systems.
Code of Ethics and Business Conduct

19Personal investments
A conflict can occur if you have a significant ownership or other financial
interest in a competitor, vendor, supplier or customer. Make sure you know
what’s permitted – and what’s not – by our policies and seek help withany question.
Civic activities
Unless company management specifically asks you to do so, you shouldn’t
accept a seat on the board of directors or advisory board of any of ourcompetitors, suppliers, customers or partners, especially if your current job
gives you the ability to influence our relationship with them.

Gifts and Entertainment
A modest gift may be a thoughtful“thank you,” or a meal may be an
appropriate setting for a businessdiscussion. If not handled carefully,
however, the exchange of gifts andentertainment may appear to create aconflict of interest or other misconduct.
This is especially true if it happens
frequently, or if the value is large
enough that someone may think it
can improperly influence a businessdecision. Proper records of such
expenses must also be createdand maintained.
LEARN MORE
• Anti-Bribery Policy• Gifts & Entertainment Policy

We do not accept or provide gifts,
favors, or entertainment – even if
it complies with our policies – if theintent is to improperly influence
any decision. Please refer to the
Anticorruption and Bribery sectionof the Code for more information
about what is appropriate and what
is not.
Be aware, also, that the rules forwhat we may give to – or accept
from – government officials, theirrelatives or associated entities
are much more strict. Do notoffer anything of value to these
individuals without obtaining
approval, in advance, from theCompliance Officer.

Live Our Guiding Principles• Do not provide gifts or entertainment or anything of value togovernment officials without prior approval of the Compliance Officer.
• Only provide and accept gifts and entertainment that are reasonable
complements to business relationships.
• Never accept gifts of any kind from a business partner with whom you
are involved in contract negotiations.
• Exchange gifts and entertainment that foster goodwill in business
relationships, but never provide or accept gifts or entertainment thatobligate or appear to obligate the recipient.
• Do not request or solicit personal gifts, favors, entertainment or services.
20• Never accept cash or cash equivalents.
• Understand and comply with the policies of the recipient’s organization
before offering or providing gifts, favors or entertainment.
• Raise a concern whenever you suspect that a colleague, third partyor other agent of the company may be engaged in any attempt toimproperly influence a decision of a customer or government official.

Watch • Situations that could embarrass you or our company, including

Out entertainment at sexually oriented establishments.

For		• Gifts, favors or entertainment that may be reasonable for a
privately owned customer but not for a government official or agency.

What When traveling, I received a gift from a business partner that I

if?

believe was excessive. What should I do?


You need to let your supervisor and Compliance Officer know as soon as
possible. We may need to return the gift with a letter explaining our policy.
If a gift is perishable or impractical to return, another option may be to
distribute it to employees or donate it to charity, with a letter of explanation
to the donor.

What During contract negotiations with a potential new supplier, the new

if?

supplier mentioned that they had a complimentary registration to a
local business seminar. They are unable to attend and asked if Iwould liketo go in their place. I had been thinking of attending the seminar
anyway, since the subject of the seminar applies to my work. There’s no
personal gain to me, it would be good for Joyson Safety Systems, and it would
be a shame to waste the registration, I planned on saying “yes,” but now I
wonder if that would be the right decision.
You should decline the offer. If you are involved in contract negotiations,
you must never accept any gifts while the negotiation process is ongoing.
Accepting gifts during negotiations can give the appearance of a something
improper and is always inappropriate.
LEARN MORE
• Anti-Bribery Policy• Gifts & Entertainment Policy

Code of Ethics and Business Conduct

21

Protecting

Information
and Assets
Protecting Our Company Assets
We are entrusted with company assets and are personallyresponsible for protecting them and using them withcare. Company assets include funds, facilities, equipment,
information systems, intellectual property and confidential
information.
Personal use of company assets is discouraged, but wherepermitted, should be kept to a minimum and have noadverse effect on productivity and the work environment.

Live Our Guiding Principles• Do not use Joyson Safety Systems’ equipment or
information systems to create, store or send content
that others might find offensive.
• Do not share passwords or allow other people,
including friends and family to use Joyson Safety
Systems’ resources.
• Only use software that has been properly licensed. The
copying or use of unlicensed or “pirated” software oncompany computers or other equipment to conductcompany business is strictly prohibited. If you haveany questions about whether or not a particular use ofsoftware is licensed, contact the IT Department.

Watch • Requests to borrow or use Joyson Safety

Out Systems’ equipment without approval.

For		• Unknown individuals without proper credentials
entering our facilities.
• Excessive use of Joyson Safety Systems’ resources for
personal purposes.

22Confidential Information and Intellectual Property
Joyson Safety Systems commits substantial resources to technology
development and innovation. The creation and protection of our intellectual
property rights are critical to our business. Intellectual property includes items
such as proprietary information, trade secrets and patents.
Each of us must be vigilant and protect Joyson Safety Systems’ confidential
information and intellectual property. This means keeping it secure, limiting
access to those who have a need to know in order to do their job, and only
using it for authorized purposes.
Be aware that the obligation to restrict your use of Joyson Safety Systems’
confidential information and intellectual property continues even after
employment ends.

Live Our Guiding Principles• Use and disclose confidential information only for legitimate business purposes.
• Properly label confidential information to indicate how it should be
handled, distributed and destroyed.
• Protect our intellectual property and confidential information by sharing it
only with authorized parties.
• Only store or communicate company information using Joyson Safety
Systems’ information systems.

Watch • Discussions of Joyson Safety Systems’ confidential information in

Out places where others might be able to overhear – for example on

For planes, elevators and when using mobile phones.

• Sending confidential information to unattended fax machines or printers.
Intellectual property
Intellectual property (IP) is an important asset that must be protected.
Examples of our IP include:• Business and marketing plans• Company initiatives (existing, planned, proposed or developing)• Customer lists• Trade secrets and discoveries• Methods, know-how and techniques• Innovations and designs• Systems, software and technology• Patents, trademarks and copyrights

Code of Ethics and Business Conduct

23

Contact the Legal Department if you receive any statements or questions
from third parties regarding (1) the scope of Joyson Safety Systems’
intellectual property rights, (2) the applicability of Joyson Safety Systems’rights to another company’s products or (3) the applicability of a third
party’s intellectual property rights to Joyson Safety Systems’ intellectual
property rights or products.
Promptly disclose to company management any inventions or other IPthat you create while you are employed by Joyson Safety Systems.

Acquiring Competitive Intelligence
Information about competitors is a valuable asset in today’s competitive
business environment. When collecting business intelligence, Joyson Safety
Systems’ employees, and others who are working on our behalf, must always
live up to the highest ethical standards.
Sharing information with a competitor or employees of a competitor isalways prohibited. We must never engage in fraud, misrepresentation or
deception to obtain information. Nor should we use invasive technology to“spy” on others. We also need to be careful when accepting informationfrom third parties. You should know and trust their sources and be sure thatthe knowledge they provide is not protected by trade secret laws or nondisclosure or confidentiality agreements.
While Joyson Safety Systems employs former employees of competitors,
we recognize and respect the obligations of those employees not to use or
disclose the confidential information of their former employers.

Live Our Guiding Principles• Obtain competitive information only through legal and ethical means,never through misrepresentation.
• Respect the obligations of others to keep competitive information
confidential.

Watch • Retaining papers or computer records from prior employers in

Out violation of laws or contracts.

sing anyone else’s confidential information without appropriate
For • Uapprovals.

		• Using job interviews as a way of collecting confidential information about
competitors or others.

• Receiving suggestions from third parties for new products, product featuresor services when the source of the original idea is not fully known.

24

Creating and Managing Our Business Records
The accuracy and completeness of our disclosures and business records
is essential to making informed decisions and to supporting investors,
regulators and others. Our books and records must accurately and fairly
reflect our transactions in sufficient detail and in accordance with our
accounting practices and policies.
Some employees have special responsibilities in this area, but all of us
contribute to the process of recording business results or maintaining
records. Ensure that the information we record is accurate, timely andcomplete, and maintained in a manner that is consistent with our internal
controls, disclosure controls and our legal obligations.

Live Our Guiding Principles• Create business records that accurately reflect the truth of theunderlying event or transaction. Be guided by the principles oftransparency and truthfulness.
• Write carefully in all of your business communications. Write as though
someday the records you create may become public documents(including email communications).

Watch • Records that are not clear and complete or that obscure the true

Out nature of any action.

For • Undisclosed or unrecorded funds, assets or liabilities.

		• Improper destruction of documents (including documents subject tolitigation holds).

What At the end of the last quarter reporting period, my supervisor asked

if?

me to record additional expenses even though I had not yet received
the invoices from the supplier and the work has not yet
started. I agreed to do it, since we were all sure that the work would becompleted in the next quarter. Now I wonder if I did the right thing.
No, you did not. Costs must be recorded in the period in which they are
incurred. The work was not started and the costs were not incurred by thedate you recorded the transaction. It was therefore a misrepresentation and,depending on the circumstances, could amount to fraud.
Retaining Corporate Records
Documents should only be disposed of in compliance with Joyson Safety
Systems’ policies and should never be destroyed or hidden. You must neverconceal wrongdoing or permit others to do so. Never destroy documents in
response to or in anticipation of an investigation or audit.
If you have any questions or concerns about retaining or destroying corporate
records, please contact the Legal Department.

Code of Ethics and Business Conduct

25

Communicating With the Public
We are committed to maintaining honest, professional and lawful internaland public communications. We communicate accurately with the public,
officials and the media.
We need a consistent voice when making disclosures or providing
information to the public. For this reason, it is important that only authorized
persons speak on behalf of Joyson Safety Systems. Communications
with media, investors, stock analysts and other members of the financial
community should be referred to executive management. Employees mustobtain approval from the Legal Department prior to disclosing businessinformation publicly.

Watch • Giving public speeches, writing articles for professional journals

Out or other public communications that relate to Joyson Safety

For Systems without appropriate management approval.

• The temptation to use your title or affiliation outside of your work
for Joyson Safety Systems without it being clear that the use is for
identification only.
• I nvitations to speak “off the record” to journalists or analysts who ask
you for information about Joyson Safety Systems or its customers orbusiness partners.

Using Social MediaBe careful when writing communications that might be published online. If
you participate in internet discussion groups, chat rooms, bulletin boards,
blogs, social media sites or other electronic communications, even under analias, never give the impression that you are speaking on behalf of Joyson
Safety Systems.
If you believe a false statement about our company has been posted, do notpost or share nonpublic information, even if your intent is to “set the record
straight.” Your posting might be misinterpreted, start false rumors or may beinaccurate or misleading. Instead, contact the Legal Department.

26

Following the Letter and theSpirit of
Law
Antitrust and Fair Competition
We believe in free and open competition and never engage
in improper practices that may limit competition. We neverlook to gain competitive advantages through unethical or
illegal business practices.
Antitrust laws are complex and compliance requirements
can vary depending on the circumstances, but in general, thefollowing activities are red flags and should be avoided and,
if detected, reported to the Legal Department:• Sharing our company’s competitively sensitive information
with a competitor.
• Sharing competitively sensitive information of business
partners or other third parties with their competitors.
• Attempting to obtain nonpublic information about
competitors from new hires or candidates for employment.

Live Our Guiding Principles• Do not enter into agreements with competitors orothers to engage in any anti-competitive behavior,including setting prices or dividing up customers,
suppliers or markets.
• Do not engage in conversations with competitors about
competitively sensitive information.

Watch • Collusion – when companies secretly communicate

Out or agree on how they will compete. This could

agreements or exchanges of information on
For include
pricing, terms, wages or allocations of markets.
• Bid-rigging – when competitors or service providers
manipulate bidding so that fair competition is limited.
This may include comparing bids, agreeing to refrain frombidding or knowingly submitting noncompetitive bids.
Code of Ethics and Business Conduct27• Tying – when a company with market power forces customers to agree toservices or products that they do not want or need.
• Predatory pricing – when a company with market power sells a service
below cost to eliminate or harm a competitor, with the intent to recover
the loss of revenue later by raising prices after the competitor has been
eliminated or harmed.

What In a conversation at an OEM workshop with a former coworker –if?

who now works for a competitor – he mentions that winningbusiness with OEM-X is a priority for him. He asks me if Joyson
Safety Systems plans to bid aggressively on the upcoming RFQ for OEM-X.
What should I do?
Do not make any comments about Joyson Safety Systems’ plans. State clearly
that you do not want to receive any confidential information about thecompetitor’s commercial strategy and immediately notify the Compliance
Officer about the incident.

What I receive a call from a competitor who wishes to discuss recent

if?

material cost increases. He complains that OEM-X refuses to accept
any price increases despite the significant surge in costs, andthat is killing his margins. He suggests adopting a joint position in negotiations
with OEM-X to ensure that material cost increases are passed on to thecustomer. What should I do?
You should state clearly that you do not want to discuss passing on ofmaterial cost increases to customers or any other aspects of customer terms
or pricing. Then, finish the call and immediately notify the Compliance Officer
about the incident.

What I received sensitive pricing information from one of our competitors.

if?

What should I do?
You should contact the Compliance Officer without delay and before any
further action is taken. It is important, from the moment we receive suchinformation, that we demonstrate respect for antitrust laws, and we make it
clear that we expect others to do the same. This requires appropriate actionthat can only be decided on a case-to-case basis and may include sending a
letter to the competitor.

LEARN MORE
• Fair Competition Policy28

Cooperation With Audits
All employees are expected to fully cooperate with internal and external
audits that are conducted by our company. In addition, in the course ofbusiness, you may receive inquiries or requests from government officials.
You are expected to fully cooperate and ensure that any information you
provide is true, accurate and complete. If you learn of a potential government
investigation or inquiry, immediately notify your manager and the Legal
Department before taking or promising any action.

Watch • Falsified information. Never destroy, alter or conceal any

Out document in anticipation of or in response to a request for

For these documents.

• Unlawful influence. Never provide or attempt to influence others toprovide incomplete, false or misleading statements to a company or
government investigator.

Data Protection
We respect the personal information of others. Follow our policies and allapplicable laws in collecting, processing, accessing, using, storing, sharing
and disposing of sensitive information. Only use it – and share it with others
outside of Joyson Safety Systems – for legitimate business purposes. The
Legal Department should be consulted concerning data protection issues.
Make sure you know the kind of information that is considered personal
information. It includes anything that could be used to identify someone,
either directly or indirectly, such as a name, email address, phone number
or credit card number.

Watch • Sending sensitive information to unattended fax machines

Out or printers.

For • Failing to shred or securely dispose of sensitive information.

		• Using “free” or individually purchased internet hosting, collaboration or
cloud services.

LEARN MORE
• Data Protection Policy

Code of Ethics and Business Conduct

29

Political Activities
You have the right to voluntarily participate in the political process, including
making personal political contributions. However, you must always make it
clear that your personal views and actions are not those of Joyson Safety
Systems, and never use company funds for any political purpose without
proper authorization.

Live Our Guiding Principles• Ensure that your personal political views and activities are not viewed as
those of the company.
• Do not use our resources or facilities to support your personal politicalactivities.

Watch • Lobbying. Interactions with government officials or regulators

Out that could be seen as lobbying must be discussed in advance andFor coordinated with the Compliance Officer.

• Pressure. Never apply direct or indirect pressure on another employee tocontribute to, support or oppose any political candidate or party.
• Improper influence. Avoid even the appearance of making political orcharitable contributions in order to gain favor or in an attempt to exert
improper influence.
• Conflicts of interest. Holding or campaigning for political office must notcreate, or appear to create, a conflict of interest with your duties at Joyson
Safety Systems.

What I will be attending a fundraiser for a candidate running for local office. Is

if?

it OK to mention my position at Joyson Safety Systems as long as I don’t
use any company funds or resources?


No. It would be improper to associate our name in any way with your personal
political activities.

What I would like to invite an elected official to speak at an upcoming

if?

company event. Would that be a problem?
You must get approval from the Compliance Officer before inviting an elected
official or other governmental officer to attend a company event. If the invitee
is in the midst of a reelection campaign, the company event could be viewed
as support for the campaign. Depending on local laws, any food, drink, ortransportation provided to the invitee could be considered a gift. In most cases,
there would be limits and reporting obligations.

30

Insider Trading
In the course of business, you may learn confidential information about
Joyson Safety Systems or about other publicly traded companies that is notavailable to the public at large. Trading securities while aware of such material
nonpublic information, or disclosing such information to others who thentrade (“tipping”), is prohibited by various laws.
Material Information
Material information is the kind of information a reasonable investor
would take into consideration when deciding whether to buy or sell asecurity. Some examples of information about a company that may bematerial are:
• A proposed acquisition or sale of a business.
• A significant expansion or cutback of operations.
• A significant product development or important information abouta product.
• Extraordinary management or business developments.
• Changes in strategic direction such as entering new markets.

LEARN MORE
• Insider Trading Policy

Live Our Guiding Principles• Do not buy or sell securities of any company when you havematerial nonpublic information about that company.
• Protect material nonpublic information from the general public
including information in both electronic form and in paper copy.
• Discuss any questions or concerns about insider trading with theLegal Department.

Watch • Requests from friends or family for information about companies

Out that we do business with or have confidential information about.
casual conversations could be viewed as illegal “tipping” of
For Eveninside information.

• Sharing material nonpublic information with anyone, either on purpose or
by accident, unless it is essential for Joyson Safety Systems-related business.
Giving this information to anyone else who might make an investment
decision based on your inside information is considered “tipping” and isagainst the law regardless of whether you benefit from the outcome of
their trading.

Anticorruption and Bribery
We believe that all forms of bribery and other corrupt practices are an
inappropriate way to conduct business regardless of local customs. Joyson Safety
Systems is committed to complying with all applicable anticorruption laws.

Code of Ethics and Business Conduct31

We do not pay or accept bribes, kickbacks or facilitation payments, at any time
for any reason. This applies equally to any person or firm who represents Joyson
Safety Systems. The only possible exception is if a potentially improper payment
is necessary to protect an individual’s health or safety. In such a situation, you
should immediately report the payment to the Compliance Officer.
Key definitions - bribery, corruption and facilitation payments
Bribery means giving or receiving anything of value (or offering to do so) inorder to obtain or maintain a business, financial or commercial advantage.
Corruption is the abuse of an entrusted power for private gain.
Facilitation payments – in some countries, it is common for companies
to pay low-level government employees to expedite or facilitate theperformance of routine, non-discretionary government actions, suchas obtaining an ordinary business license or permit, or processing
government papers such as visas. These payments are generally referred
to as “facilitating payments” and although they may be customary incertain parts of the world, they may violate applicable laws, so we prohibit
them except in situations involving the personal health or safety of ouremployees.
It is especially important that we exercise due diligence and carefully monitor
third parties acting on our behalf. We carefully screen all third parties, including
suppliers, consultants and vendors who work on our company’s behalf,
particularly when dealing in countries with high corruption rates and in any
situations where “red flags” would indicate further screening is needed before
retaining the third party. Third parties must understand that they are required
to operate in strict compliance with our standards and to maintain accurate
records of all transactions.

Live Our Guiding Principles• Never give anything of value inconsistent with local laws and regulations
to any governmental official. If you are not sure of the local laws, thesafest course of action is to not give anything of value.
• Understand the standards set forth under anti-bribery laws which apply toyour role at Joyson Safety Systems.
• Accurately and completely record all payments to third parties.

Watch • Apparent violations of anti-bribery laws by our business partners.

Out • Agents who do not wish to have all terms of their engagement with		

For Joyson Safety Systems clearly documented in writing.
LEARN MORE
• Anti-Bribery Policy• Gifts & Entertainment Policy

32

What I work with a foreign agent in connection with our operations in

if?

another country. I suspect that some of the money we pay him
goes toward making payments or bribes to government officials.
What should I do?

This matter should be reported to the Compliance Officer forinvestigation. If there is bribery and we fail to act, both you and ourcompany could be liable. While investigating these kinds of matters canbe culturally difficult in some countries, any agent doing business with us
should understand the necessity of these measures. It is important andappropriate to remind our agents of this policy.

Anti-money Laundering
Money laundering is a global problem with far-reaching and serious
consequences. It is defined as the process of converting illegal proceeds
so that funds are made to appear legitimate, and it is not limited to cashtransactions. Involvement in such activities undermines our integrity,
damages our reputation and can expose our company and the individuals
involved to severe sanctions. Report any suspicious financial transactions
and activities to the Compliance Officer and, if required, to appropriate
government agencies.

Imports, Exports and Global Trade
Joyson Safety Systems has global operations that support a growing,
worldwide customer base. To maintain and grow our global standing,all employees, officers and directors must strictly comply with not only
United States laws that govern the import, export and re-export of our
products, but also with the laws of other countries where our products are
manufactured, repaired or used. Any violation of these laws, even throughignorance, could have damaging and long-lasting effects on our business.
If your responsibilities include exporting products, or receiving imported
products, you are responsible for screening customers, suppliers andtransactions to ensure that we comply with all applicable export andimport requirements.
Anti-Boycott Regulations
We follow the trade laws of all of the countries in which we dobusiness including laws related to participating in international
boycotts and those that prohibit transactions with specific countries,
entities or people.

Code of Ethics and Business Conduct

33

Live Our Guiding Principles• Obtain all necessary licenses before the export or re-export of products,
services or technology.
• Report complete, accurate and detailed information regarding every
imported product, including its place(s) of manufacture and its
full cost.
• Direct any questions you have regarding imports or exports of our
products, parts or technology to the Legal Department.

Watch • Transferring technical data and technology to someone in anotherOut country, such as through email, conversations, meetings oraccess. This restriction applies to sharing information
For databasewith co-workers, as well as non-employees.

• Transporting company assets that contain certain technology (such as acomputer an associate takes on a business trip) to another country.

What My work requires regular interaction with customs officials. As partif?

of my job, I am routinely asked to provide the Customs Service withinformation about our imports and exports. Do I really need tocontact theLegal Department prior to each and every submission of
information to the government?
The right approach here would be to discuss with the Legal Department thetypes of requests your department routinely receives from Customs. Theseroutine requests, once understood, might be handled without any legal
review. Extraordinary requests would still require Legal Department review
to ensure that you are responding accurately, fully and in accordance withthe law.

34

Serving theGreater
Good
Respecting Human Rights
We conduct our business in a manner that respects thehuman rights and dignity of all, and we support international
efforts to promote and protect human rights, including an
absolute opposition to slavery and human trafficking.
Each of us can help support efforts to eliminate abuses suchas child labor, slavery, human trafficking and forced labor.

Live Our Guiding Principles• Report any suspicion or evidence of human rights
abuses in our operations or in the operations of
our suppliers.
• Remember that respect for human dignity begins with
our daily interactions with one another and with our
suppliers and customers. It includes promoting diversity,
accommodating disabilities and doing our part toprotect the rights and dignity of everyone with whom
we do business.

Responsible Sourcing andConflict Minerals
Revenue from conflict minerals has been linked to funding
for groups engaged in extreme violence and human rights
atrocities, so we are proactive in implementing policies
and procedures throughout our supply chain to source
responsibly, monitor our suppliers’ performance and, where
needed, request corrective action.
We work closely with suppliers of raw materials, partsand components and communicate our expectation that
suppliers and vendors will comply with all applicable laws,
including laws aimed at providing conflict-free minerals.

Code of Ethics and Business Conduct

35

Protecting the Environment
We recognize our environmental and societal responsibilities. We arecommitted to sustainability and to minimizing damage to the environment
as well as any potential harm to the health and safety of employees,
customers and the public.

Live Our Guiding Principles• Do your part to ensure that protecting employee safety and theenvironment is a priority. Stop work and report any situation thatyou believe could result in an unsafe working condition or damage tothe environment.
• Read and understand all the information provided by our company
that is relevant to your job and the health, safety and environmental
effects of our operations.
• Fully cooperate with environmental, health and safety training andwith our company’s periodic compliance reviews of our products
and operations.
• Be proactive and look for ways that we can minimize waste, energy
and use of natural resources.
• Contact the Compliance Officer if you have any questions aboutcompliance with environmental, health and safety laws and policies.

36

Closing Thoughts from Our Compliance Officer
As an employee, you are our most valuable asset.
You are Joyson Safety Systems. You are the “driving” force behind the
products we make and the customers we serve. You are part of a teamthat brings both an entrepreneurial spirit and innovative technology to themarketplace. And you are on the frontlines every day, ensuring that we
maintain an unwavering commitment to saving lives.
I encourage you to read our Code and refer to it often. It’s not a book ofrules, but a guide for doing the right things the right way and preserving the
reputation we’ve earned as a company that not only makes a difference, butdoes so with integrity.
Look to my office as your resource and your partner in conducting businesshonestly, ethically and in compliance with the law. Speak up about any
conduct that could put our hard-won reputation at risk, and in every decision,
ask yourself, “Am I honoring our Guiding Principles?”When you do, you’ll be honoring the legacy of those employees who came
before you and paving the way for those who follow. You’ll also be helping toensure the safety of Joyson Safety Systems’ customers all over the world.

Code of Ethics and Business Conduct37