Complaint Submission andHandling Policy

1.0

Policy: LEG-046

Page 1 of 2

Original Issue Date:
Mar. 15, 2004

Rev. Date: August 20, 2018
Rev. Letter: D

Purpose and Scope

BorgWarner maintains a procedure for: (a) the receipt and treatment of reports concerning
violations and suspected violations of law and BorgWarner policies including suspicion of illegal
payments; (b) the receipt, retention and treatment of complaints received by the Corporation
regarding accounting, financial, internal accounting controls or auditing matters; and (c) theconfidential, anonymous submission by employees of concerns regarding questionable auditing
matters. You are expected and encouraged to report violations of Company policies and ofapplicable laws and regulations.
This policy applies to BorgWarner and its subsidiaries worldwide.
2.0

Policies and Procedures
A. The Company has processes in place for the receipt, retention and treatment of reportsof reasonable, good faith concerns on all subjects discussed in the Company’s Code ofEthical Conduct, including the making of illegal payments and the suspicion of the same,described above through its Compliance with Laws and Policies Program. Reports canbe made to the employee’s supervisor, local Compliance Coordinator, subsidiary
Compliance Officer, Human Resources Department or the Company Compliance Officeor the Law Department. Reports can be made by collect telephone call to 1-248-7540656 or by e-mail or letter to:Complianceoffice@borgwarner.com
orCompliance Office3850 Hamlin Road
Auburn Hills, MI 48326
Anonymous reports can be made from outside the United States, go to
http://www.convercent.com/report to find your country’s toll free number, or by calling001-720-514-4400 collect from outside the United States or to 1-800-461-9330 within theUnited States.
Other than complaints or reports relating to accounting or auditing (which will go directlyto the Audit Committee as described below), all reports or complaints will be reviewed by
the Compliance Office, which will determine whether an investigation into the subject
raised is warranted. In consultation with the Law Department, Human Resources andthe business or corporate function as appropriate, the Compliance Office will ultimately
determine whether any remedial action is required by such reports. The Compliance
Office will maintain a database of all reports received and the status of investigation of
those reports, if any. Files on reports and their disposition will be maintained for a periodof five years.

Complaint Submission andHandling Policy

Policy: LEG-046

Page 2 of 2

Original Issue Date:
Mar. 15, 2004

Rev. Date: August 20, 2018
Rev. Letter: D

B. Complaints or reports relating to accounting, financial, internal accounting controls orauditing matters (regardless of the amount cited in the report) may be madeanonymously in the manner described above and will be submitted directly to the Audit
Committee. The Audit Committee, at its discretion, may request assistance from theInternal Audit Department, the Law Department or outside legal or financial experts.
C. The Audit Committee Chair or the Audit Committee as a whole, may also request special
treatment for any specific complaint, including the retention of outside counsel.
D. Interested parties may also make concerns known directly to the non-management
directors on-line at compliancehotline.borgwarner.com or by toll-free call to 1-800-4619330.
3.0

Non-Retaliation

No employee shall be penalized in any respect for reporting criminal conduct or a violation of
any law or policy relating to compliance with law or the reasonable good faith belief that such aviolation has occurred, is on-going or is about to occur, where the employee is not otherwise
engaged in the activity.

APPROVALS
Policy Committee
Corporate

REVISION HISTORY
Rev.

DateDescriptionA

5-01-05

Changed Finance & Audit Committee to Audit CommitteeB12-12-06

Clarification of call-in numbers

C

08-09-13

Clarification of matters to be reported and non-retaliation

D08-20-18

Update to phone number outside U.S. in 2.0A