CODE OF CONDUCTBridgestone Essence Framework“The larger a company grows, the greater its
responsibilities to society. A company mustseek at all times to fulfill this mission…
My hope is that Bridgestone will continue togrow and contribute to society while preserving
this traditional Bridgestone spirit.”
Shojiro Ishibashi
Bridgestone FounderBridgestone’s
Corporate Mission“Serving Society with Superior Quality.”
Written by the founder in 1968.

Corporate Commitment

Bridgestone E8 Commitment
EnergyEcology

Efficiency

Extension

EconomyEmotionEase

Empowerment

Code at a Glance

06

14

26

40

58

68

BRIDGESTONEINTEGRITY
IN ACTION

BRIDGESTONEINTEGRITY
IN THE
WORKPLACE

BRIDGESTONEINTEGRITY
IN THE
MARKETPLACE

BRIDGESTONEINTEGRITYIN OUR DAILYWORK LIVESBRIDGESTONEINTEGRITYIN OURCOMMUNITIESINDEXRespecting Each Other

Playing by the Rules

Protecting Company Assets

Bridgestone E8 Commitment 08

Promoting Respect and Dignity 16

Product Safety and Quality 28

Gifts and Entertainment 42

Serving the Community
and Society

The Purpose of the Code 09

Diversity 16

Competitive Information 28

Conflicts of Interest 44

When the Code Applies 10

Health and Safety 18

Free and Fair Competition 30

Confidential and Proprietary Information 46

Our Responsibilities as Employees
and Managers 10

Workplace Violence 18

Bribery and Corruption 32

Use of Company Resources 48

Drugs and Alcohol 19

Our Dealings with Suppliers 34

Our Expectations for Suppliers
and Contractors 11

Privacy and Personal Data 20

Our Dealings with Customers 34

Patents, Trademarks and Copyrights—
Ours and Others’ 48

Retaliation is Prohibited 11

Communication and Information
Sharing 21

The Government as a Customer 35

Introduction: A Cultureof Integrity

Where to Go for Help 12
The Bridgestone Integrity Test 13

Trade Restrictions 35

Electronic Communications andComputer Systems 49
Integrity of Records, Disclosures
and Financial Reports 50
Insider Trading 52
Money Laundering 52
Internal Controls, Audits andInvestigations, and Fraud 53

Our Commitment to the Environment 60
Personal Charity and Community Service 61
Corporate and Personal Political Activities 62
Government, Media and Other Inquiries 64

BRIDGESTONEINTEGRITY
IN ACTION
Introduction: A Cultureof Integrity
Bridgestone E8 Commitment
The Purpose of the Code
When the Code Applies
Our Responsibilities as Employees and Managers
Our Expectations for Suppliers and Contractors
Retaliation is Prohibited
Where to Go for Help
The Bridgestone Integrity Test

6

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7

Bridgestone E8 Commitment

The Purpose of the CodeSince its founding in 1931, guided by its unchanging mission of“Serving Society with Superior Quality,” the Bridgestone Group has
expanded and evolved its business to meet the changing needsof society by continuing to support the mobility and lifestyles ofindividuals. This mission is at the core of the Bridgestone Essence
as well as the company’s Safety, Quality and Environmental Mission
Statements, which together make up the Bridgestone Essence
Framework.

This Code of Conduct was developed with Bridgestone’s Mission
and the company’s other foundational documents in mind andis intended to provide practical guidance for handling many ofthe ethical issues you may face as a Bridgestone employee. Bylearning and following the principles in the Code, we will continue
to earn the trust of our customers and communities and take pridein our company and coworkers across the globe.

Bridgestone positioned 2020 as the first year of the “thirdfoundation” or Bridgestone 3.0 and announced its Mid-Long TermBusiness Strategy, placing sustainability at the core of management
and business. The Group identified its vision: “Toward 2050,
Bridgestone continues to provide social value and customer value
as a sustainable solutions company.” In addition, to acceleratetransformation to realize this vision, in 2022 Bridgestone announced
its corporate commitment “Bridgestone E8 Commitment” as the axis
to drive management while earning the trust of future generations.
We will commit to supporting the realization of a sustainable society
by co-creating value with employees, society, our partners and ourcustomers.
The Bridgestone E8 Commitment reaffirms our foundational
principles in the Bridgestone Essence Framework, and also embraces
fundamentals such as governance, compliance and behavioral
principles that will ensure Bridgestone operates with the level ofintegrity expected of a global company.
Our evolution into a sustainable solutions company depends on the
day-to-day actions of our employees. This is fundamental to the way
Bridgestone does business as a global company.

8

BRIDGESTONE INTEGRITY IN ACTION

The Code cannot, of course, cover every situation. It’s not a
substitute for good judgment and common sense. Instead,think of the Code as a GPS for the company’s commitment to
responsible business practices. You’re responsible fordetermining where to go and how to get there. The principles in
the Code are there to help you stay on course.

EnergyEconomyCommitted to the realization ofa carbon neutral mobility society

Committed to maximizing the economic
value of mobility and business operations

Ecology

EmotionCommitted to advancing sustainable tire
technologies and solutions that preserve
the environment for future generations

Committed to inspiring excitement andspreading joy to the world of mobility

Efficiency

Ease

Committed to maximizing productivity
through the advancement of mobility

Committed to bringing comfort andpeace of mind to mobility life

Extension

Empowerment

Committed to nonstop mobility and innovationthat keeps people and the world moving ahead

Committed to contributing to a society that
ensures accessibility and dignity for all

Read the Code carefully, considering the issues it raises and how
they affect you in your daily work life. Review the Questions andAnswers at the end of each section for additional clarification.
The topics covered in this Code are important. Violations of theCode can cause great harm to the company and its reputation.
Employees who violate the Code may be subject to appropriate
disciplinary action, up to and including termination of theiremployment. The Code of Conduct is a living document, andBridgestone may change it from time to time, as appropriate.

BRIDGESTONE INTEGRITY IN ACTION

9Our Responsibilities as
Employees and Managers

Our Expectations for
Suppliers and Contractors

The Code is intended to create a common guide for employeesof all Bridgestone companies around the globe. As used in thisCode, the term “employees” includes directors and officers ofthese companies.

As Bridgestone employees, we all:

The rules and expectations set forth in this Code not only apply
to all Bridgestone employees worldwide, they also serve as aset of expectations for the suppliers and contractors who workwith us in all our locations. Share these expectations with our
suppliers and contractors. Explain their importance.

In some cases Bridgestone companies may have local policies
with content that overlaps with this Code. If a local policy is lessrestrictive than the Code, the Code will apply.

• Contact the BridgeLine or speak to any person listed in “Where to
Go For Help” (page 12) regarding possible Code or policy violations
or other ethical concerns.

Additionally, in very rare cases, a country’s local laws may prohibit
compliance with certain provisions of this Code. If you believe
this may be the case, please consult with a member of the Law
Department.

In addition to their responsibilities as
employees, Bridgestone managers must:

When the Code Applies• Must demonstrate integrity in all we do.
• Familiarize ourselves with and follow the Code of Conduct andother company policies that may apply in our locations.

From the Field• Ensure that employees understand the importance of thisCode and follow it.

You work in a small department. You want toreport misconduct, but are afraid that if you contact
the BridgeLine everyone will know and find subtle
ways to get back at you. Does the company reallyprohibit this sort of retaliation?

• C hampion the company’s ethics and compliance programand participate actively in their location’s ethics andcompliance initiatives.

10

BRIDGESTONE INTEGRITY IN ACTION

Retaliation is a deliberate adverse action against an employee
for making a report in good faith. Examples of retaliation include
firing or demoting an employee, removing an employee from a
project, and verbally or physically threatening an employee who
has reported, threatened to report, or otherwise taken action toaddress conduct that is illegal or inconsistent with this Code or
any policy in your location.
Bridgestone prohibits retaliation when business conduct
or ethical issues are reported in good faith.

• Create an environment where Bridgestone employees feel
comfortable raising and speaking openly about ethicalquestions or concerns.

• Act as a role model at all times.

Retaliation is Prohibited

Absolutely. We understand that retaliation can take many forms. The
company does not tolerate any forms of retaliation. If you believe you arebeing retaliated against for raising a good-faith concern, reach out to anyof the contacts listed in “Where to Go for Help” (page 12).

BRIDGESTONE INTEGRITY IN ACTION

11

Where to Go for Help

The Bridgestone Integrity Test

You have many resources available to help you with questions or concerns relating to ethics, legal compliance and company policy, including:

When confronted with an ethical question that does not appear
to have an obvious answer, ask yourself the following questions:Your Supervisor

Law Department

Your supervisor is often a good person to start with for an
ethics or company policy question. If you are not comfortableasking your supervisor, any other resource listed on this page
can assist you.

If you have any doubt about the legality or ethics of a courseof conduct, or just want to understand the legal risks involved,
contact any member of the Law Department.

• Does it seem like the right thing to do?

Internal Audit• Would I be proud if my actions were shared in thenews media?

Human Resources
Members of your Human Resources Department can often help you
determine the best course of action for a broad range of ethical andcompliance concerns.

Chief Compliance Officer
You can always contact your region’s Chief Compliance Officer or acompliance professional with any questions about Bridgestone’s ethics
and compliance program or any other concern relating to this Code.

Your region’s Internal Audit department is able to discreetly
discuss and follow up on questions regarding internal controls andcompliance with established policies.

• Would I stake my reputation on it?
• Does it build trust and pride in Bridgestone?

Many of the topics addressed in this Code are also covered in global,
regional or local Bridgestone policies. Please consult these policies
for additional guidance and information.

NO

Bridgestone has established web-based reporting systems and phone hotlines operated by third party specialists to allow employees
and others to confidentially report suspected criminal conduct; violations of this Code, other company policies, or the law; or other ethicalconcerns and questions. In this document, we refer to these hotlines and electronic reporting systems as the “BridgeLine.”
Where permitted by local laws, BridgeLine reports can be made anonymously. The BridgeLine operator or web portal will indicate whether
an anonymous report is possible.
To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

BRIDGESTONE INTEGRITY IN ACTION• Would I feel comfortable talking to my family about
my course of action?

Company Policies| The BridgeLine

12• Do I know that it is legal and consistent with both
Bridgestone’s values and this Code?

If the answer to any of these questions is NO, theaction may have serious consequences.
Do not do it. Seek guidance.

YES
If the answer to all of these questions is YES, proceedwith confidence.

IF YOU ARE NOT SURE, OR OTHERWISE
HAVE ANY QUESTIONS, SEEK GUIDANCE.

BRIDGESTONE INTEGRITY IN ACTION

13

BRIDGESTONEINTEGRITY
IN THE WORKPLACE
Respecting
Each Other
Promoting Respect and Dignity
Diversity
Health and Safety
Workplace Violence
Drugs and Alcohol
Privacy and Personal Data
Communication and Information Sharing

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15

Promoting Respect and Dignity

Diversity

Bridgestone’s employees are its most valuable resource. To
be successful, we must treat each other with respect anddignity at all times.

Diversity is a source of strength for Bridgestone. The diverse
experiences, viewpoints and styles of the company’s employees
not only give us an important competitive advantage in themarketplace, but also contribute to a rich work environment
where we can all learn from one another.

No Harassment
Bridgestone will not tolerate bullying or harassment, including(without limitation) sexual harassment. Harassment can takemany forms, but can generally be defined as any unwelcome
conduct that creates an intimidating, hostile or offensive work
environment, or that has the purpose or effect of unreasonablyinterfering with an individual’s work performance. Harassment
does not require intent to offend. Inappropriate conduct meant
as a joke, a prank or a compliment can contribute to harassment.

YOU SHOULD• Speak out. If you see someone harassing a coworker,
tell them to stop. If they don’t stop, contact any of theresources listed in “Where to Go for Help” (page 12).
• Be mindful of how your words and actions affect others.
• Make decisions regarding the hiring, development andpromotion of employees solely on the merits.
• Participate in employment and labor relations training
and familiarize yourself with employment laws in yourlocation. Follow them.

We are committed to maintaining an inclusive culture where
diversity is embraced and celebrated, enabling all Bridgestone
employees to thrive.

No Discrimination
Bridgestone makes employment and career development
decisions on the merits. We affirm the fundamental
principle that everyone is entitled to fair treatment andequal opportunity without discrimination on the basis of
any characteristic such as race, ethnicity, color, nationality,
gender, gender identity, sexual orientation, age, language,
religion, creed, social status, disability, or any other legally
protected class.
We do not tolerate behavior that is discriminatory, harassing,disrespectful, or otherwise degrading to individual dignity. We arecommitted to protecting the rights of individuals in traditionally
under-privileged groups and expanding their employment
opportunities.

Group Global Human Rights Policy
As part of our dedication to be a true global leader inall that we do, the Bridgestone Group has confirmed its
commitment to respecting human rights and advancing
responsible labor practices throughout our worldwide
operations by adopting, regularly assessing, and updatingwhen needed, a Global Human Rights Policy. The policy,
which applies to all employees and locations of theBridgestone Group, affirms the company’s:• Respect for Diversity, Equity and Inclusion• Prohibition of Discrimination and Harassment• Focus on Workplace Safety and Health• Commitment to Responsible Labor Practices• Protection of Freedom of Association andCollective Bargaining
Familiarize yourself with the policy. We expect all of ouremployees to uphold this policy, and we also expect ourbusiness partners, including our suppliers, contractors,
vendors and customers, to uphold the principles set
out in this policy, as reflected in our Global Sustainable
Procurement Policy.

• Embrace the views of a coworker whose life experience
differs from your own.

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17

Health and Safety

Workplace Violence

Drugs and Alcohol

Bridgestone prides itself on providing a safe, healthy working
environment. Safety is our top priority, and we expect ouremployees and contractors to embrace our philosophy ofputting “Safety First, Always.”

Bridgestone prohibits violence, threats of violence, intimidationand disruptive conduct on company premises and even off
company premises if the employee is on company business or
the behavior is an extension of the workplace, such as online
bullying directed at a coworker.

Bridgestone employees have a right to a workplace freefrom the effects of alcohol and drugs. Employees under the
influence of drugs or alcohol are a danger to themselves, totheir coworkers and to the business.

YOU SHOULD

The possession, sale or use of illegal drugs on company time orproperty is prohibited. Impairment from alcohol or improperuse of legal drugs while conducting company business is also
forbidden. Review your location’s drug and alcohol policy forthe specific rules that apply to you.

• Understand and follow your location’s drug and alcohol
policy.

Bridgestone is committed to complying with all laws andregulations governing workplace safety. We will provide you,our employees, with all the training and education you needto perform your jobs safely. No job is so important, no task sourgent that it cannot be done safely. Safety always comes first.

YOU SHOULD• Understand your facility’s health and safety rules andfollow them. Make sure your coworkers do the same.
• Always follow the working standard. Don’t takeshortcuts.
• Make sure you know what to do in an emergency.
• Immediately tell your supervisor or your location’s safety
manager about any accidents, unsafe conditions, unsafe
behaviors or other safety concerns.

YOU MUST NOTThis prohibition applies to all Bridgestone employees, whether
full-time, part time or temporary—as well as to customers,
suppliers, contractors and visitors.
For the safety of all employees, customers and visitors,
Bridgestone prohibits the possession of firearms or otherweapons on company property, in company vehicles, in rental
vehicles, while on company business or at company-sponsored
events (even if held off company premises). Very limited
exceptions, such as those necessary to comply with local laws,
may apply, but only with proper approval in accordance withyour local policy. Ask a Law Department member if you needmore information.

• If you suspect someone is using drugs or alcohol in
violation of company policy, immediately tell the person’s
supervisor or another member of management.

• Contact any of the resources listed in “Where to Go forHelp” (page 12) if you suspect illegal drug activity in theworkplace.

When allowed by law, Bridgestone may conduct pre-hire andpost-hire drug and alcohol testing to ensure that our workplace
is safe and productive.

You should immediately notify management, Security or Human
Resources of any prohibited behavior. Security procedures mayvary region by region, so please consult local policies. Also see
the resources listed in “Where to Go For Help” (page 12).

• Make verbal or physical threats.
• Engage in hitting, fighting, pushing or any intimidating
physical contact.
• Send harassing or threatening emails or
correspondence, or make harassing or threatening
phone calls.
• Make threats or otherwise encourage or support
violence.

18

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19

Communication andInformation Sharing

Privacy and Personal Data
Bridgestone respects the confidentiality of our customers’ andemployees’ personal, financial and health information. Personal
data should be handled, used, or shared only when there is alegitimate reason to do so, and then only in accordance withapplicable law and company policy.

YOU SHOULD

Penalties for violating data protection laws can be severe. If you
deal with personal data in your work, you are responsible forunderstanding and complying with legal requirements and thecompany data security and privacy policies for your location.

• Understand that privacy laws vary greatly from country
to country. Acceptable handling procedures in one
country may not be acceptable in another.

• Use caution when handling personal, health or financial
information to ensure that confidentiality is maintained.
When in doubt, ask Human Resources or a member ofthe Law Department for guidance.

Follow these simple rules when interacting with your coworkers
to build trust and the sound, lasting relationships that makeBridgestone a stronger company:• Tell the truth.
• Be respectful.
• Be open and transparent.
• Share good news and bad news without hesitation.
•B e mindful and respectful of local customs and practices, andtake special care to communicate clearly and respectfully,
when communicating with others outside of your region.
• If you believe the other person may have misunderstood you,take the time to correct any misunderstanding.
• If you do not understand the other person, have the courage
to speak up and let them know you do not understand.
• When requesting information, always explain the purpose of
the request clearly and accurately.
Remember, proper communication and information sharing is
critical to Bridgestone’s success as a global company.

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Q&A

Promoting Respect and Dignity

Diversity

Health and Safety

Workplace Violence

Q: I just learned a coworker has accused me of harassment.
What’s going to happen to me?

Q: I’ve been passed over for a promotion for which I believe I
am qualified. I think it is discrimination because I have received
positive reviews while others who have not performed as well
get promoted. What should I do?

Q: Two employees suffered minor accidents on the production
floor last week. Neither was seriously hurt. My supervisor told
me not to include the events on an accident report since they
were minor, and the department wants to get the safety award
this year. Should I allow the accidents to go unreported?

Q: I was in the office last weekend and used my company ID
to enter the building. A well dressed man entered right behindme without using his ID. Did I make a mistake by letting him in?

A: The company will conduct a complete and impartial
investigation into the allegations. You and others will beinterviewed and given an opportunity to describe what
happened. The outcome will depend on a number of factors,
including the specific facts, seriousness of the conduct andhistory.
Q: A coworker in my department is constantly joking aboutother members of the department. He thinks he’s funny but he’s
making everyone feel really uncomfortable. What can I do?
A: Each of your coworkers deserves respect. Someone needs
to talk with the disrespectful coworker. If you are comfortable
doing this yourself, you should. If not, you should talk to yoursupervisor or Human Resources about the situation. If the
conduct continues, contact Human Resources immediately.

A: The first thing to do is to talk with Human Resources or thehiring manager about the qualifications and performancenecessary for the position, and why you were not selected. If
you still believe you may have been discriminated against,
contact Human Resources. You may also contact the BridgeLine
with your concerns.
Q: I may be old fashioned, but I believe certain jobs in mydepartment require too much travel time for single parents.
Can I screen out single parents from my list of job candidates?
A: Absolutely not. At Bridgestone, equal opportunity means justthat—a fair chance for everyone.

Q: My new supervisor has been paying me a lot of attention
recently. Last week, he stopped by my desk to ask a questionand started rubbing my shoulders. I did not invite him to touchme, and it made me very uncomfortable. What should I do?

A: No. Even small incidents and minor injuries can have serious
consequences. Bridgestone requires employees to report all
accidents and injuries. Reports can be used to spot safety issues
and trends that may help prevent more serious injuries in the future.
Q: A couple of things that we do in my area bother me
because they don’t seem safe. The problem is, I don’t want
to bring them up because I’m new here and don’t want toseem like a troublemaker.
A: Immediately discuss your concerns with your supervisor oryour location’s safety manager. Sometimes new eyes see things
that other eyes have missed. Raising a concern for safety is not
making trouble. It shows you care.

A: Yes. An unescorted and unidentified person on company
property is a serious security risk and could even increase therisk of violence at your workplace. Even though it may havefelt awkward, you should have asked to see the person’s work
identification or separately confirmed his right to enter before
letting him in the building. If the person refused, you shouldhave contacted a manager or Security immediately.
Q: A coworker in my department is having marital problems.
Last week, she told me her husband has threatened tocome to the office to “settle some things.” How should thissituation be handled?
A: First of all, take this situation very seriously. Never dismiss evena potential threat. Immediately notify Security or your manager
so that they can determine appropriate methods to deal withthe situation. If you believe you are in imminent danger, remain
calm, determine the best course of action for your safety, signal
coworkers if you can and as soon as possible, call the police.

A: If you are comfortable doing so, you should let yoursupervisor know that his behavior is unwelcome and makes
you uncomfortable. If not, you should talk to Human Resources
about the situation or contact the BridgeLine. If the conduct
continues, contact Human Resources immediately.

| The BridgeLine
22

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

BRIDGESTONE INTEGRITY IN THE WORKPLACE

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23

Q&A

Drugs and Alcohol

Privacy and Personal Data

Q: My manager has been coming to work with alcohol on
his breath. He doesn’t seem drunk, and I don’t want to getanyone in trouble. What should I do?

Q: I was working late last night at the office. When I went
to use the copier, I found a stack of personnel records in thesorter. There is a lot of personal information on these forms.
I don’t think it is right that this kind of information is left for
all to see. What should I do?

A: If someone has alcohol on their breath, a problem may exist.
Speak right away with another supervisor, Human Resources orcontact the BridgeLine so the situation can be addressed.

A: You should return the papers to Human Resources immediately
by confidential means. Protecting confidentiality and privacy is
the personal responsibility of each Bridgestone employee. You
are doing the right thing by being alert to the issue and acting
accordingly. Human Resources should identify the person who
left the papers in the copier and counsel him or her on the duty
to protect the confidentiality of coworkers’ personal information.
Q: Is my company laptop private?
A: Bridgestone provides its employees services and equipment
such as computers, email and mobile devices for work-related
purposes. To protect its employees and the company as a whole,
Bridgestone, subject to applicable law, may inspect its facilities
and property, including computer hard drives, telephonerecords, voice mail, email, Internet usage, documents, offices,filing cabinets, lockers and other work spaces.

| The BridgeLine
24

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

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BRIDGESTONEINTEGRITY
IN THE MARKETPLACE
Playing by
The Rules
Product Safety and Quality
Competitive Information
Free and Fair Competition
Bribery and Corruption
Our Dealings with Suppliers
Our Dealings with Customers
The Government as a Customer
Trade Restrictions

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Product Safety and Quality

Competitive Information

If you have spent any time working at or with Bridgestone, youknow our Mission—Serving Society with Superior Quality. Simply
put, the services we provide and the products we make and sellmust be safe for our customers and of high quality.

In today’s marketplace, it is important to keep an eye on thecompetition. As Bridgestone employees, however, we havean obligation to ourselves and the company to ensure that ourcollection of competitive information is both legal and ethical.
We should never gather competitive information throughmisrepresentation or theft, accept confidential informationfrom someone who is not authorized to disclose it, or misuseconfidential information that was provided under a confidentiality
agreement for a limited purpose. When in doubt, seek guidancefrom the Law Department.

When thinking about safety, remember that the concept ofsafety includes not just the product itself, but also instructions
for use, product certifications, safety warnings, maintenance,
the selection of the right application, installation and service.
Bridgestone aims to create customer value and trust bypromoting Total Quality Management (TQM) improvement
activities in all its departments globally.
Remember, quality improvement and customer satisfaction are
the responsibilities of all Bridgestone employees. You should
always follow our quality processes and continuously seek out
ways we can improve on safety and quality. Immediately notify
your supervisor or your facility’s quality manager of any suspected
quality issue or failure to follow the company’s quality control
processes.

YOU SHOULD
Use acceptable sources for competitive information.
For example:

From the FieldYour department has just hired a new employee
who previously worked for a Bridgestonecompetitor.
Can this person share information about her
former employer?

Although the new employee may of course use the professional skills
she has acquired throughout her career, she is not permitted to use or
share trade secrets or sensitive competitive information she learned
while working for her former employer. And she should never seek toobtain competitive information about her former employer from former
coworkers or other business contacts.
You may not ask for or allow the new employee to volunteer any suchinformation about her former employer. Speak to your supervisor or the
Law Department if you have any questions.

• Articles in a newspaper or magazine or on public
Internet sites.
• Industry surveys by reputable consultants.
• Trade shows.
• Public filings.

YOU MUST NOT• Other publicly available information.

• Sacrifice safety for cost or deadlines.
• Hide substandard work.
• Falsify test results.

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29

Free and Fair Competition
Bridgestone is a strong competitor in the marketplace. We
may play hard, but we always play fair and by the rules. We
win on the merits.
Be careful. Antitrust and competition laws are tricky. Simple
things like a careless conversation with an old friend over lunchor over a break at a trade association meeting can violate thelaw. The penalties can include prison time for employees andsteep fines for companies.

Always consult with the Law Department before acting as
Bridgestone’s representative at a trade association to ensure
proper review of the association’s policies and practices.
Always review available guidance or seek advice from the Law
Department prior to other dealings with competitors. And
immediately report any potentially prohibited communications
by a competitor to a member of the Law Department.
Remember: Bridgestone has antitrust and competition training
available for all its employees. If you have not received training
recently, don’t wait. Contact the Law Department for assistance.

30• Discuss with competitors or otherwise tamper with acompetitive bidding process (i.e., engage in “bid rigging”).

• Divide customers, markets or territories with a competitor.

• Share confidential company information with a competitor,
including information received from customers.

BRIDGESTONE INTEGRITY IN THE MARKETPLACE

Never discuss anything related to pricing or other terms of salewith a competitor. If a competitor attempts to have a prohibited
communication with you:
• Inform the person that you will NOT discuss the prohibited subject.
• End the conversation immediately.
• WALK AWAY if the other person insists on continuing the conversation.

What should you do?

• Agree on or discuss prices or related terms of sale witha competitor.

• Agree with competitors to not deal with suppliers
or customers.

You are attending a trade association meeting.
During a coffee break, an executive from a competitor approaches you. This executive was yoursupervisor many years ago, and you have a lot of
respect for her. She complains about another competitor’s price discounting policies. She suggeststhat you talk to the competitor about the need todevelop a more “realistic” pricing strategy.

• Report the matter IMMEDIATELY to a member of the Law Department.

YOU MUST NOT• Agree with competitors to limit production.

From the Field• Agree with another employer not to recruit certain job
candidates or not to compete on terms of compensation.

BRIDGESTONE INTEGRITY IN THE MARKETPLACE
Bridgestone Integrityin the Marketplace

31
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Bribery and Corruption
Bridgestone employees in all countries are absolutely prohibitedfrom engaging in bribery. Under no circumstances may a
Bridgestone employee or a third party acting on Bridgestone’s
behalf offer anything of value to a government official or any otherthird party, or their representatives, to obtain or retain business orfor any other commercial advantage.
Bribery is illegal in countries throughout the world. Additionally,some countries have bribery laws that can extend to certain actions
taken by Bridgestone companies outside that country’s borders.
These laws carry stiff penalties such as fines and imprisonment.
Violation of these laws can ruin Bridgestone’s good name andbusiness prospects from a global perspective.

Bridgestone Global Anti-Bribery Policy
Bridgestone has confirmed its commitment to prohibiting any
forms of bribery by any Bridgestone employee or a third party
acting on Bridgestone’s behalf by adopting a Global AntiBribery Policy. The Bridgestone Global Anti-Bribery Policy
provides practical guidance and describes Bridgestone’s
requirements regarding the prevention of bribery and how toaddress bribery risks.

YOU MUST NOT

Bribery of Government Officials

Look for Warning Signs

Many countries have very strict laws regarding bribery of
government officials. For purposes of these laws, a government
official can be a government employee, a political party candidate
or employee, an employee of a state-owned enterprise, an
employee of a public international organization, or anyone acting
in an official capacity. If you have any dealings with government
officials or manage those who do, contact your Law Department
for special guidance and training.

Companies can be held responsible not only for bribes offeredby employees, but also by third parties acting on their behalf.
We must therefore use great care when hiring and working
with third parties who will represent Bridgestone—always
looking out for warning signs suggesting that a representative
might be engaged in bribery.

SEEK ASSISTANCE
If you notice that an agent or representative of Bridgestone exhibits any of these “red flags” for corruption, contact the Law Department.
The agent or representative:• Was recommended to the company by a government
official or third party whose favor we are seeking.
• Has close family or other affiliation with a government
official or third party whose favor we are seeking.
• Requested payment to a third party or to accounts inforeign countries.

• Requested reimbursement for poorly documented expenses.
• Requested payment that is unusually high for services
performed.
• Has inconsistencies on expense reports.
• Used undisclosed subagents to assist in performing services.

From the Field

Bribery is strictly prohibited.
Remember, a bribe can be anything of value or benefit
and this can include many things. Cash, gifts, donations to
selected organizations, a job offer for a family member,personal favor, even paying for a business trip, a meal orother business courtesies could be considered a bribe if
offered to obtain an improper business advantage.

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BRIDGESTONE INTEGRITY IN THE MARKETPLACE

Are bribes only items of value that have afinancial or quantifiable value?

No. While bribes often have a financial or quantifiable value, there can beinstances when an item of value can still constitute a bribe even if there is nofinancial amount that can be attributed to the item of value or it is difficult
to financially quantify the item of value. Examples can include job offers tofamily members, introductions to political figures or other people, or personalfavors. Always contact a member of the Law Department if you are ever indoubt about the appropriateness of an item of value or if you have questions.

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Our Dealings with Suppliers

Our Dealings with Customers

The Government as a Customer

Trade Restrictions

Bridgestone and its customers have long benefited from thecompany’s strong, lasting relationships with its suppliers.
Simply put, we cannot succeed without them.

How we do business is just as important as what we do. As a
Bridgestone employee, it’s your job to ensure that every single
dealing with our customers is honest, fair and professional.

In many respects, our relations with a government agency ora government-owned business as a customer are just like ourdealings with private sector customers. Each must be treatedwith the highest standard of fairness and honesty.

When selecting and managing suppliers, including consultants,
brokers, agents, or contractors, verify that they are qualified
to do business with us. Many countries have laws prohibitingtransactions with certain restricted parties or may require
certain credentials or certifications. Bridgestone also has
specific procurement policies, including the Global Sustainable
Procurement Policy, which establish requirements for supplier
operations.

When entering into sales agreements, verify the transaction is
not prohibited by trade or sanctions laws. Many countries havelaws requiring product certifications or prohibiting transactions
with certain restricted parties.

Bridgestone does business in many countries around theworld. Each of these countries has laws that control the importand export of goods, services and information. Some of theselaws prohibit the sale of any goods or services to certain
countries. Others require companies to obtain special permits
for certain types of products. Some laws prohibit the sharing oftechnology with citizens of certain countries. Serious penalties,
including fines and imprisonment, can apply when these laws
are violated.

Choose the qualified supplier that will provide the best overallvalue, taking into account quality, price, service, delivery,
and reputation. Always choose suppliers based on the
merits, avoiding conflicts of interest, inappropriate gifts andentertainment, or any other favoritism that might improperly
influence or appear to influence the selection process (see theGifts and Entertainment section of this Code for additional
guidance). Never, ever accept payments or other items ofvalue intended to influence our decisions about suppliers.
Competitive bidding must be handled fairly, with each supplier
having an equal chance to compete for our business. And
when we engage a supplier, contract terms should specificallydescribe the services to be provided and otherwise comply
with Procurement policies.

We must tell the truth when advertising our products, andnever make false claims about our own or our competitors’
offerings. And we must never charge a customer for services
or products that we have not provided, nor cause customers toincur costs due to carelessness or faulty workmanship. If you
believe a customer may have been treated unfairly, it’s yourduty to fix it.

However, there are many special rules and safeguards that
apply to government sales. These rules can apply to bidding
processes, the use of subcontractors, gifts and entertainment,
conflicts of interest, the company’s hiring practices, and otherareas. Government contracting regulations vary from country
to country and even within some countries from one location
to another. If you deal with sales to the government or agovernment-owned business, you are responsible for knowing
and complying with all applicable laws and regulations. Please
consult a member of the Law Department for guidance.

If you are involved in the sale or transfer of products, services
or information across international borders, make sure thatyou are familiar with the applicable laws and regulations. Be
sure to follow all applicable import and export control policies
and procedures. Keep in mind that trade prohibitions vary bycountry and are subject to frequent change. If you are uncertainor have any questions, contact the Law Department.

Remember, our suppliers’ reputation and behavior can directly
affect Bridgestone. Only do business with companies thatcomply with the law and understand and operate consistently
with our commitment to compliance and ethics.

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Q&A

Product Safety and Quality

Free and Fair Competition

Bribery and Corruption

Our Dealings with Suppliers

Q: A shift supervisor has told us to skip a quality control
procedure. I think this violates company policy, but he is thesupervisor. What should I do?

Q: I got a call from a former coworker who works for acompetitor, asking if Bridgestone was planning to bid on aparticular program. He suggested that if we skipped this one,his company would skip the next one. Frankly, we’re too busy
to finish this bid in time anyway. Should I accept his offer?

Q: I know it’s against the law to make payments to government
officials, but everybody tells me that it’s the only way to getthings done in this country. Can’t I get around this by hiring
an agent who will pay the officials a commission?

Q: One of our oldest and most reliable suppliers has been
struggling financially and has asked for a temporary priceincrease. One of the supplier’s competitors offers the same
products cheaper but does not have the same track record for
quality. Do we have to give the business to the supplier withthe lowest prices?

A: Don’t skip the quality control procedure. If you think thesupervisor is breaking the rules, contact your supervisor’s
manager, your company’s Quality Assurance Department, or
contact the BridgeLine.

Competitive Information

A: No. This offer is bid rigging, or collusion, and it’s illegal to accept
his proposal. Our company’s decision not to compete for thisbusiness must be made for valid reasons, not as part of a “deal”
with a competitor. Be very clear with your former coworker that
our company would never consider this kind of offer. Contact the
Law Department immediately.

Q: Sometimes a customer will complain that our prices arehigher than the competition. Can I ask the customer for copies
of our competitor’s proposals to confirm that the competitor’s
price is lower than the price we are quoting?

Q: One of our largest dealers emails me all the timecomplaining about another dealer’s pricing. He says he wants
us to talk to them about their “pricing philosophy.” I don’t
want to offend him. What can I do?

A: Possibly, but this is a tricky area. Contact a member of the
Law Department for advice on how to proceed.

A: Politely but firmly explain that we cannot involve ourselves in
the pricing decisions of our customers. Each dealer is free to set
its own prices in the marketplace. Contact the Law Department
for additional guidance.

A: No. It’s against the law. The consequences of getting caught
for you and the company could be severe. You can’t get aroundyour legal responsibilities by hiring agents to do what you are
not permitted to do.
Q: I took a course on the Foreign Corrupt Practices Act, theU.S. anti-bribery law, recently. I remember learning thatsometimes “facilitating payments” (small payments togovernment officials to expedite routine transactions) werepermitted under the law. What is our company’s position on
facilitating payments?

A: Not necessarily. Bridgestone looks for the best overall value.
Price is an important factor but not the only one. We also musttake into account quality, delivery, service and reputation,
among other considerations.

A: Facilitating payments are not permitted under company policy
and are prohibited by law in most countries.
Q: I have heard rumors that my manager recently offereda bribe to a prospective customer in order to secure theirpurchase of our products. I don’t know if they are true. Whatshould I do?
A: Contact the Law Department or the BridgeLine right away.

| The BridgeLine
36

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

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Q&A

Our Dealings with Customers

The Government as a Customer

Trade Restrictions

Q: My coworkers and I compete with people from othercompanies who take business from us by lying about theirpricing policy and services. Sometimes I feel like the only
way to compete is to resort to the same cheap tactics. Whatshould I do?

Q: The company is bidding on a state contract. We had several
meetings with state officials that extended through the lunch
hour. Is it okay to treat them to lunch?

Q: We have received an order for an unusual volume of tires
from a new customer. The customer is in a country where weare allowed to ship, but we have heard that the customer
may have close ties to a regime in a country where we may
not ship. Payment will be made in the currency of yet anothercountry. It’s a big sale and our local representative says not
to worry. Can we just assume that the tires will be used in the
country where we are shipping, or is this a problem?

A: Don’t give in. Bridgestone’s success depends on long-term
customers—customers who are satisfied that we have fulfilled
our commitments to them. You will build a better company
through referrals and continued business from satisfied
customers than from quick sales that disappoint. If you learn ofcompetitor misconduct, notify the Law Department.

A: It might not be. In many locations, it is a crime to give evensmall, token gifts to government officials. We should not doanything that may improperly influence, or appear to improperly
influence, the bidding process. Ask a Law Department member
for help.

A: The information you have indicates that the tires might beshipped to a prohibited country. You should seek advice from the
Law Department before acting.
Q: I believe European law applies restrictions to sales to Syria
and certain other countries, but I am not a European citizen
and I don’t work in the European Union. Do these laws apply
to me too?

Q: I work in Bridgestone’s U.S. Commercial Tire Sales divisionand recently met a prospective customer at a trade show.
When he gave me his business card, I realized that his
business is located in a country that is subject to U.S. trade
restrictions. Can I pass his information along to a coworker inanother country that does not have trade restrictions?
A: No. U.S. law not only prohibits you from selling products topeople or businesses located in the restricted country, but also
prohibits facilitation of sales to people or businesses located inthat country—even if the company that ultimately makes thesale is not located in the U.S. Just forwarding a business card toa coworker could constitute facilitation, if it results in a sale. If
you aren’t sure what to do, ask the Law Department.

A: Many EU trade laws apply not only to EU companies but also
indirectly to their subsidiaries around the world. Please consult
with the Law Department for assistance in this complex area.

| The BridgeLine
38

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

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BRIDGESTONEINTEGRITY IN OURDAILY WORK LIVES
Protecting
Company Assets
Gifts and Entertainment
Conflicts of Interest
Confidential and Proprietary Information
Use of Company Resources
Patents, Trademarks and Copyrights—
Ours and Others’
Electronic Communications andComputer Systems
Integrity of Records, Disclosures andFinancial Reports
Insider Trading
Money Laundering
Internal Controls, Audits and Investigations,and Fraud40

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Gifts and Entertainment
The exchange of small gifts and modest business courtesies between
business partners is a common and often a positive part of doing
business. This practice, however, can sometimes create conflictsof interest or the appearance of wrongdoing. At Bridgestone, wecannot allow the exchange of gifts and entertainment to influence
or appear to influence our independent business judgment or the
independent business judgment of the companies with which we
do business.

NEVER ACCEPTABLE
Bridgestone employees are prohibited from giving
or accepting gifts or entertainment that are:• Illegal.
• Offered in exchange for something in return.
• Sexually oriented or otherwise inappropriate.

Some gifts and forms of entertainment might be acceptable, but
require special review and approval. Seek guidance and written
approval from your supervisor:• If you are exchanging gifts or entertainment with the same
person or company on multiple occasions.
• When your location’s policy requires supervisor approval for
certain gifts.
In addition to these basic principles, be sure to review the gift
and entertainment policy for your location closely to understandthe specific rules that apply to you. For example, although cash
and cash equivalents are generally not acceptable, there may berare circumstances in which local policy expressly allows for very
limited exceptions to this. Be proactive. Regularly inform suppliers,
customers and other companies with whom we do business about
our policy on gifts and entertainment. An especially good time todo this is several weeks before the holidays or periods in which
it is customary to give gifts. You can, seek guidance from yoursupervisor, a member of the Law Department, Human Resourcesor Internal Audit.

From the Field
My department or location has a “no gifts”
policy. Is that allowed?

Our Code provides general guidance as to what types of items of value
can be offered, given and received, but a specific department, function,business unit or location may impose more restrictive limits. Check withyour manager or supervisor or the Law Department to understand if
there are any more restrictive policies in effect that apply to you.

• Offered to a government official without the priorwritten approval of the Law Department.
• In violation of any more restrictive policy in effectin your department or at your location.

USUALLY ACCEPTABLE
The following are examples of gifts that areusually acceptable:• A box of chocolates or fruit basket during the holidays.
• A reasonable business meal at a local restaurant.
• Promotional items of small value such as coffee
mugs, pens or golf shirts with company logos.
• Occasional attendance at a regular season sporting
event or similar entertainment event where the priceper ticket is not excessive, as determined by thepolicy for your location.

And remember, other companies have gifts and entertainment
policies, too. Be mindful of these policies and ask before offering
gifts and entertainment.

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Conflicts of Interest
Bridgestone employees have a duty of loyalty to the company.
We must avoid financial, business and other relationships thatconflict, or even appear to conflict, with our duty to act in thebest interest of the company at all times.

Common Conflicts of Interest
A potential conflict of interest can arise in many ways. A
common situation arises when you or a close family member
or a member of your household is employed by or otherwise
affiliated with a competitor or supplier or any other company
seeking to do business with us.

Other examples include:• Direct or indirect supervision of a family member, amember of your household, or someone with whom you
have a romantic relationship.
• An ownership interest in a customer, supplier orcompetitor of Bridgestone (excluding small investments
in large publicly traded companies).
• Participating in a business transaction to your personaladvantage based on information or relationships
developed as a company employee.
• Holding a second job that interferes with your ability to
do your regular job.

How to Resolve Conflicts of Interest
The first step in resolving any potential conflict of interest is
simply to notify your supervisor. The disclosure should bemade in writing. Your supervisor will then work with Human
Resources and, as appropriate, others to determine what, if
anything, needs to be done.
In many cases, disclosure alone (with proper documentationof the disclosure and resolution of the conflict) will be enough.
Occasionally, it may be necessary to reassign some of your job
responsibilities. Certain conflicts can only be resolved by ending theconflicting relationship. For example, it would not be permissible
for a Bridgestone employee to work for a competitor while also
working for Bridgestone.

YOU SHOULD• Notify your supervisor of any potential conflict ofinterest in which you are involved.
• Ensure the assessment or resolution of the conflict isproperly documented.
• If you observe a conflict of interest relating to others,
notify your supervisor or Human Resources or contact
the BridgeLine.

Your location may have a policy that helps clarify othersituations that create a conflict.

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Confidential and
Proprietary Information
As a Bridgestone employee, you may have knowledge ofconfidential and proprietary information about our products,
services or the business affairs of the company, its customers,
suppliers and other third parties. This information is vital to
our success and must be protected. It should never be used for
personal gain.
Understand and follow local policies for classifying and protecting
confidential information. You can protect the company’s
proprietary and confidential information by maintaining it inauthorized, secured locations (e.g., locked filing cabinets or
password protected computer files). Never disclose proprietary or
confidential information to third parties without authorization. If
you plan on electronically sharing confidential information withany third party, be sure to comply with data security requirements
in your location. Be careful when using speakerphones and cell
phones, and never discuss sensitive company information in
public. Some employees may have access to our customers’
and others’ financial or personal information. This informationmust be safeguarded at all times and only used for legitimate
purposes. Remember, your duty to safeguard proprietary andconfidential information continues even after you leave thecompany.
If you are not sure about whether certain information is
confidential and must be protected, talk to your supervisor
or ask a member of the Law Department.

Confidential / Non-Confidential Items
Confidential Items
The following are examples of proprietary and confidential
information and/or trade secrets that should not be sharedwithout proper authorization:• Compounds and formulas for our products.
• Written or oral agreements between the company andits business partners.
• Financial information about the company.
• Engineering drawings and other technical information.
• Pricing, sales and marketing information.
• Manufacturing processes, know-how andproduction schedules.
• Strategic and business planning information.
Non-Confidential Items• News reports.
• Court records that are not sealed.
• Advertising or sales literature.
• Public speeches.
• Published financials.

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Use of Company Resources
We each have a duty to use Bridgestone’s assets and resources,
including cash, inventory, facilities, equipment, computer
software, vehicles, supplies and tools, carefully, efficiently and forthe company’s benefit. Occasional, limited use of the company’s
office equipment for personal use is permissible in some
Bridgestone locations. As always, exercise good judgment andwhen, in doubt, ask your supervisor for guidance.

SEEK ASSISTANCE
Ask the Law Department or Intellectual Property
Department if you have any questions about how to handle
the intellectual property of Bridgestone or any third party.

Patents, Trademarks and
Copyrights—Ours and Others’

Electronic Communications
and Computer Systems

Many of Bridgestone’s ideas, inventions, trademarks, logos
and other writings are protected by patents, trademarks andcopyright law. This intellectual property is very valuable andmust be used in strict accordance with company guidelines.

Bridgestone has adopted comprehensive policies governing the use of the company’s electronic communications and computer
systems in each of its locations. Each of us must know and follow the policies applicable in our location.

If you are unsure how to handle the company’s intellectual
property, consult a member of the Law Department or Intellectual
Property Department for guidance.
Third parties have intellectual property rights, too, and we must
always be careful to respect them. You may not download, copy,
distribute, display or modify copyrighted materials without theconsent of their owner. Please be aware that a work may beprotected by a copyright even if there is no copyright notice on
the work.

Key Features of These Policies
Business Use

No Unauthorized Downloading of Software

Bridgestone’s electronic communications and computer systems
are provided for business use. Limited personal use that does
not consume significant company resources is, however,
permissible in some Bridgestone locations.

Do not download software to the company’s electronic communications and computer systems without prior authorization from IT or a person designated by IT.

Company Rights
Subject to applicable law, the company has the right to access,review and disclose any information stored on or communicatedthrough its computers or electronic communication systems.

Limitations on Access
Access to information in our electronic communications
and computer systems is allowed only to authorized
employees and third parties. You may only access, use or
download company information for which you have specificauthorization.

No Harassment
All electronic communication, like other forms of communication, must be professional and appropriate. Your electronic communication must not include messages or links to websites thatare discriminatory, harassing, sexually explicit, racist or otherwise offensive in the company’s reasonable opinion.

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BRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVES

Computer Security
Bridgestone invests heavily in the latest information technology
security controls for its electronic communications and computer
systems. Bridgestone employees are responsible for ensuringthat they are using the latest security controls that the company
offers and must never disable the security controls that thecompany has in place.

Social Media
When using social media, do not disclose confidential company
information or communicate in a way that could reflect
poorly on the company or its employees. Always distinguishcarefully between your own personal views and the views of
the company. Do not speak on the company’s behalf without
proper authorization from the Communications Department.

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Integrity of Records, Disclosures
and Financial Reports
Bridgestone’s success and credibility in the global marketplace
depend on the accuracy and completeness of its financial
and business records. Moreover, Bridgestone Corporation, asa publicly-traded company, must disclose certain importantbusiness information periodically. Accurate business records
provide a foundation for wise business decisions. Incomplete
or inaccurate records will lead to poor decision-making and canplace Bridgestone at financial and legal risk.

False or misleading entries in financial statements, disclosurestatements or other business records are prohibited. Strict
compliance with generally accepted accounting principles isrequired. No undisclosed or unrecorded funds or assets, orother off-book accounts, are to be established for any purpose.
If you are unsure how to record a financial transaction, don’t
guess. Ask for help from a manager in the Finance, Accounting
or Internal Audit departments.

Whether you are completing time cards, expense reports, financial
statements, disclosure statements, testing reports, quality control
records or other business records, take extra care to ensure thateach and every document you prepare or review is complete andaccurate.

Never authorize payment of company funds without proper
documentation, or with the knowledge that all or part of thepayment will be used for any purpose other than the purpose
described in the supporting documents.

YOU SHOULD
SPEAK UP—for your own benefit and the benefitof the company.
If you suspect that a company document is not accurate,
tell your supervisor, Internal Audit, the Law Department or
contact the BridgeLine.

Never conceal, alter or otherwise tamper with company records.
Retain and destroy documents only in accordance with applicablelaw and your location’s records management policy.

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Insider Trading

Money Laundering

In the course of their work, Bridgestone employees may learnmaterial, nonpublic information about Bridgestone Corporationor another publicly traded business—for example, a vendor,
customer or acquisition target. Legal and ethical requirements
prohibit us from:

Money laundering is the process of hiding funds obtained throughillegal activity, or otherwise making such funds look as though they
were legitimately obtained. Participation in any money laundering
activity is strictly prohibited.

• Making investment decisions based on this insider knowledge(“insider trading”), andIf you suspect that a coworker, vendor or customer is involved
in money laundering activities, immediately notify the Law
Department or Internal Audit, or contact the BridgeLine.

• Sharing information with others that enables those individuals tobenefit from this insider information (“tipping”).

SEEK ASSISTANCE
If you notice that a coworker, vendor, prospective business partner or customer exhibits any of these “red flags” for money
laundering, contact the Law Department or Internal Audit:• Requesting unusual funds transfers—for example, askingthat payments be made to another entity with no apparent
connection to the arrangement.

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BRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVESInternal Controls
Reliable internal controls can limit fraud and waste, and help
ensure the accuracy of our books and records. Become familiar
with the internal controls in place in your department. Using theprinciples of “kaizen” (continuous improvement), each of us should
periodically evaluate the adequacy of these controls, working
to improve them whenever we believe they do not adequately
detect or prevent inaccuracies, waste or fraud.

Audits and Internal Investigations

The consequences of insider trading and tipping are serious
and can include criminal and civil liability, reputational damage,and revenue loss. Contact the Law Department if you haveany questions.

• Seeking to establish “structured transactions” or “structured
payments” (repeated transactions or payments in amounts
intended to avoid triggering the reporting obligations offinancial institutions).

Internal Controls, Audits andInvestigations, and Fraud• Requesting a wire transfer to a country where the personor entity is not located and to which it cannot prove a
legitimate connection.
• Refusing or failing to provide complete and accurate
information about a company making or receiving
payment or its owners.

Bridgestone’s internal and external auditors work hard to eliminate
waste and fraud and to ensure that each of us complies with thecompany’s policies and procedures. They can do their jobs only if
we provide them prompt, courteous and complete cooperation.
When you are asked to respond to requests for documents byauditors, or in connection with an internal investigation, yourresponses must be complete and truthful. Don’t play games. Your
responses should include all relevant information.

Fraud
Any effort to cheat someone out of money, property or honest
services is fraud. Submitting false expense reports, misusing
company property, and altering company records are all examplesof fraud. Fraud, as well as the theft of assets that belong to thecompany, is a violation of company policy and the law and will
not be tolerated. If you suspect that a Bridgestone employee,
contractor or business partner is engaged in fraud or theft, notify
any of the resources listed in “Where to Go for Help” (page 12).

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53

Q&A

Gifts and Entertainment

Conflicts of Interest

Confidential and
Proprietary Information

Q: I received an expensive basket of fruit from a supplier as aholiday present. I did not ask for the gift. What should I do?

Q: I am dating a coworker who is being considered for aleadership position for the group I am in. Do we have to bringthis to the attention of our supervisor?

Q: I have been asked to speak at an industry conference on
the subject of our company’s technology and its benefits toour customers. What should I do?

A: Yes. This situation could create a conflict of interest in yourgroup. Even if you and your coworker are currently equals in thesame group, you should advise your supervisor of the relationshipso that your supervisor can prevent an inappropriate reporting
relationship.

A: Discuss the content of the presentation with your supervisor
before accepting the invitation. Industry conferences can be agood opportunity to promote the company. However, we must use
extra caution to protect confidential information. Your presentationmaterial may also need to be reviewed by the Communications
Department and the Law Department.

A: Tell your supervisor that the gift was received. Generally, wemust return gifts exceeding an acceptable value to the sender.
In case of a gift of food, it might be appropriate to share it withothers in the work area or give it to a charitable organization.
Q: I want to give one of our best customers a special gift tosay thanks. Bridgestone has access to tickets to a Firestonesponsored music tour, and giving them to this customer
would be in line with our policies. I know she would like thetickets, but I think it is against her company’s policy for her
to accept them. If she doesn’t care about the policy, can I give
her the tickets?
A: If you aren’t sure whether the customer’s policy allows the gift,ask her whether she is permitted to receive it. If she says no, or
you otherwise know giving a gift will violate her company’s policy,
you may not give the gift. Just as we want others to respect ourstandards, we must respect theirs.

Q: My coworker’s son has just been hired for a job in our
department. Does this represent a conflict of interest?
A: A conflict of interest would clearly exist if his parent is directlysupervising him. However, we do have cases where relatives
work in the same department. When this occurs, raises and job
performance evaluations must be handled by an independent
person. These decisions should be monitored on an ongoing basis
to ensure objectivity and fairness for all.
Q: I do contract work for a company that has business dealings
with Bridgestone. In my job at Bridgestone, I also have contact
with that company from time to time. Is this a problem?

Q: My work involves confidential information. I use a laptop
computer when traveling on business. What precautions
should I take?

Use of Company Resources
Q: I am moving into a new home. Is it OK if I borrow a company
truck over the weekend to move a few of the larger items?
A: No. The company provides vehicles solely for use on company
business and not for personal activities.
Q: My daughter has asked me to photocopy a homeworkassignment for her. Can I use the company’s copier?
A: Please check your local policy. Occasional and limited personaluse of company copy machines is acceptable in many locations.

A: Keep your laptop computer secure at all times, following
security requirements applicable in your location. If you travel withconfidential information, be careful where you work on sensitive
documents. If you are traveling to high-risk locations, check withIT or Security to see if any special steps are required by your local
policies. Avoid public places where your information might be seen,such as planes, airports, hotel lobbies or restaurants. If you travel
frequently and must use a laptop in public spaces, use a screen
guard.

A: Quite possibly. These circumstances must be brought to theattention of your supervisor. It is important that all actual or
potential conflicts be disclosed so that any issues can be anticipatedand avoided.

| The BridgeLine
54

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

BRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVESBRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVES

55

Q&A
Patents, Trademarks and
Copyrights—Ours and Others’

Electronic Communications
and Computer Systems

Integrity of Records andFinancial Reports

Internal Controls, Audits andInvestigations, and Fraud

Q: I work as a sales manager in India. Over the past several
months, I have seen instances of companies selling tires withnames similar to ours—“Blackstone,” “Richstone,” names
like that. What should I do?

Q: When I eat lunch at my desk, I will often surf the Internet
to take care of small personal matters or check the news. Am
I violating company policy?

Q: It is the last week in the quarterly reporting period. My
boss wants to make sure we meet our numbers for thequarter, so he asked me to record an unconfirmed sale now
that won’t be finalized until next week. I guess this won’t
hurt anyone—should I do what he says?

Q: I thought I saw a coworker change environmental monitoring
reports. What should I do?

A: Notify a member of the Law Department or the Intellectual
Property Department. These companies are trading on our
good name and possibly doing harm to our reputation in theprocess. Our Intellectual Property team can take the steps
needed to protect the company.

A: Maybe. Check with your manager regarding local policies. In
many locations, limited personal use of the Internet that does notinterfere with your job performance is permitted.
Q: My friends and I use various social media platforms all thetime. Sometimes the topic of work comes up. Are there any
special rules that apply to my use of social media?
A: When using social media, do not disclose confidential
company information or communicate in a way that could reflect
poorly on the company or its employees. Always distinguishcarefully between your own personal views and the views of thecompany. Do not speak on the company’s behalf without proper
authorization from the Communications Department. This is a
dynamic area. Seek guidance and follow company policies foryour location as they are developed.

| The BridgeLine
56

A: Immediately notify your supervisor, the site environment
manager, Internal Audit, the Law Department or the BridgeLine
and provide the details.

A: No. Costs and revenues must be recorded in the correct time
period. The sale is not yet complete. It would be a misrepresentationand could amount to fraud to include the transaction in an earlier
period. Check with Finance if you have any questions about
revenue recognition rules; they can be complex.
Q: I ordered some software and my supervisor asked me torecord the charge against another expense category because
our software budget has been exceeded. What should I do?
A: Remind your supervisor that no one should knowingly makean incorrect entry in the books and records of the company. If
your supervisor persists, contact your supervisor’s boss, the Law
Department, Internal Audit or the BridgeLine.

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

BRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVESBRIDGESTONE INTEGRITY IN OUR DAILY WORK LIVES

57

BRIDGESTONEINTEGRITY IN OUR
COMMUNITIESServing The Community
and Society
Our Commitment to the Environment
Personal Charity and Community Service
Corporate and Personal Political Activities
Government, Media and Other Inquiries

58

BRIDGESTONE INTEGRITY IN OUR COMMUNITIESBRIDGESTONE INTEGRITY IN OUR COMMUNITIES59

Our Commitment
to the Environment
Bridgestone’s Environmental Mission Statement, “to help ensurea healthy environment for current and future generations,”
serves as the company’s enduring environmental philosophy. To
support that mission, Bridgestone has declared its commitment
to working together with its many stakeholders to realize asustainable society.
We honor our mission and this commitment by providing
quality products and services in a manner that embraces careful
and responsible management of our natural resources andthe environment. We are committed to building a sustainable
society because it is good for business and the world around us.

Personal Charity andCommunity Service
Consistent with these principles, all employees are required tocomply with all applicable environmental laws and regulations,as well as the company’s environmental policies. This is our
minimum standard. Our expectation is that all employees will
act as environmental stewards, actively looking for ways toreduce the company’s environmental footprint. If you knowof any potential violation of environmental laws or company
environmental policy, you must report the matter immediately
to any of the resources listed in “Where to Go for Help” (page 12).
If you have questions or are uncertain of how to proceed withregard to an environmental matter, contact your location’senvironmental manager or the Law Department.

At Bridgestone, conservation goes beyond simply decreasing
the amount of natural resources we use to create our
products. Conservation extends to our operations and ouractivities in the community.

YOU SHOULD• Familiarize yourself with the company’s
Environmental Mission Statement and policies andprocedures that apply to your area of the business.

60

BRIDGESTONE INTEGRITY IN OUR COMMUNITIES• Think about how you can help the company meet its
environmental objectives.

The commitment of Bridgestone employees to their communities
and local charities is inspiring. We are proud of what you do andwant you to keep up the great work.
Please make sure that your outside activities do not interferewith your work for the company or create a conflict of interest.
Community service and charitable contributions are voluntaryand personal choices. A Bridgestone employee should never feelpressured to do either by coworkers, supervisors or managers.
Finally, do not claim to represent the company in connection withyour community service unless specifically authorized to do so.

Corporate and Personal
Political Activities
The laws of many countries set strict limits on, and in somecases prohibit, contributions by corporations to politicalparties and candidates.

Political Contributions
To avoid any confusion, Bridgestone has adopted a simple
rule with regard to political contributions: No company funds,
resources or facilities may be used for the purpose of supporting
directly or indirectly any political party or candidate anywherein the world, unless the contribution has been determined tobe legal by the Law Department, has been approved by theGovernment Relations Department for your region (if any), andis made in strict accordance with your regional and local policies.

62

BRIDGESTONE INTEGRITY IN OUR COMMUNITIESPersonal Political Activities

Lobbying

Bridgestone honors its employees who are personally activein the political process. When you do engage in the politicalprocess, be sure to do so on your own time and with your own
resources. Take care to ensure that any views you express areunderstood to be yours personally and not the company’s.

Company officials and representatives sometimes meet withmembers of government to share views and concerns on
specific policies and legislation of interest to the company.
These lobbying activities are subject to special rules and must be
coordinated to be effective.

If you plan to seek or accept a public office, notify your manager
in advance. You will need to discuss with your manager andHuman Resources whether your official duties might affect yourwork for the company.

Before engaging in any non-routine contact with government
officials or employees, you must first consult with the Law
Department.

YOU SHOULD NOT
Use company funds, resources or facilities for the purposeof supporting, directly or indirectly, any political partyor candidate in the world without prior approval inaccordance with this Code and local policies or rules foryour region.
Examples of indirect support include:• Buying tickets for a political fundraising event.
• Providing meals, goods, services or transportation toa candidate, a government official or political party.
• The “loan” of Bridgestone employees to political parties
or campaigns.

BRIDGESTONE INTEGRITY IN OUR COMMUNITIES

63

Government, Mediaand Other Inquiries
Governmental Requests and Investigations

Media Requests

Other Inquiries

Bridgestone occasionally receives requests for information anddocuments from regulators, government agencies and officials.
Our responses to those requests must always be accurate.

Bridgestone values its relationship with the media. We wantto ensure that information about the company is portrayedaccurately in the public eye. The Communications Department is
responsible for ensuring that all responses to media inquiries areprompt and accurate and made by authorized personnel.

Bridgestone prefers to resolve business disputes on friendly
terms without resorting to costly litigation. However, this is
not always possible. All inquiries or documents received fromany attorney or legal representative for any third party must
be immediately forwarded to the Law Department for review
and response.

If you receive a request for information from a regulator,
government agency or official that is non-routine or relates toan investigation, promptly notify the Law Department. The Law
Department will help to ensure that the responses are accurate,
timely and complete, fully satisfy our legal obligations, and thatthe company’s own rights under the law have been preserved.

64

BRIDGESTONE INTEGRITY IN OUR COMMUNITIES

If you are contacted by a reporter or other member of the media,
you must politely refer the inquiry to the Communications
Department or other person in your organization designated tohandle media inquiries. Be sure to follow any media relations
policies and procedures developed specifically for your location,
including policies related to social media. If you do not know who
handles these inquiries for your location, simply take a message
and ask your supervisor to assist you in directing the message tothe right person. It is important to remember that comments toreporters may be misconstrued no matter how careful you are.

BRIDGESTONE INTEGRITY IN OUR COMMUNITIES

65

Q&A
Our Commitment
to the Environment

Personal Charity andCommunity Service

Corporate and Personal
Political Activities

Government, Mediaand Other Inquiries

Q: I have heard about Bridgestone’s efforts to keep our local
streams and rivers clean. How can I participate in these kindsof activities?

Q: A coworker and I would like to use company stationery
to solicit donations for a charity fundraising event we arecoordinating in our community. The company isn’t involvedin the event, but I think using the Bridgestone name may
encourage companies to donate. Do we need permission
before sending the letters?

Q: I am working on a campaign to re-elect our city’s mayor
and need to attend a fundraiser that is happening during
work hours. This is a personal interest and does not involve
the Company. Can I go if I get my supervisor’s permission?

Q: A lawyer telephoned me at the office recently and asked
me questions about Bridgestone. He said his law firm wasworking for us on a big case and needed the information fast.
Should I have answered his questions?

A: Yes. However, the time off cannot be charged to the company.
You’ll have to use personal time to attend this event.

A: No. Before disclosing any confidential information about
Bridgestone, you should ensure that: (1) you know precisely towhom the information is being disclosed and why the person
requires the information; and (2) you have permission from the
Law Department to disclose the information.

A: We are glad you want to help. Contact Human Resources, theCommunications Department, or your location’s environmentalgroup for additional information about upcoming projects.
Q: What happens to all the tires we make after they are usedby our customers?

A: Yes. Even though the coordinators of the event happen to be
Bridgestone employees, the event is not company-sponsored.
You will need to obtain approval before using company stationeryor the company’s name in connection with this charitable activity.

A: Increasingly, they are recovered and recycled to be used in theconstruction of asphalt roads, athletic fields, construction projects
and numerous consumer products. Bridgestone continues towork to advance the environmentally and economically soundmanagement of used tires.

Q: A business partner has asked us to support a charitableorganization of which he is a board member. I have neverheard of the organization. Is it acceptable for the company tomake a donation?
A: Bridgestone must be particularly careful when making
charitable donations. These transactions, by their nature, involve
Bridgestone making a payment without receiving anything ofvalue in return. Before making a donation, sufficient backgroundinformation on the establishment and the purpose of theorganization must be collected in order to verify the donationis consistent with legal requirements. Check your local policy on
donations and the authority schedule for required information
and approvals necessary for donations.

| The BridgeLine
66

Q: I am running for public office. I want to use the officecopier to make copies of my campaign flyer. Is that okay?
A: No. Company property and equipment may not be used
for a political purpose without authorization from the Law
Department. Running for any public office is a political purpose.

Q: I work on the second shift at a Bridgestone plant. A
reporter called me at home asking for my comments about achange in our production schedule. I know the answer to hisquestion. Can I tell him what he wanted to know?
A: No. You should not answer any questions about Bridgestone’s
business from reporters. Refer calls from the media to
the Communications Department or other person in yourorganization designated to handle media inquiries. They will
determine how to respond and if your involvement is required.

To find BridgeLine information for your location, visit https://www.bridgestone.com/responsibilities/bridgeline/.

BRIDGESTONE INTEGRITY IN OUR COMMUNITIESBRIDGESTONE INTEGRITY IN OUR COMMUNITIES

67

A

D

I

R

Accidents - 18, 23
Accurate Business Records - 50, 53, 57
Alcohol - 19, 24
Allocation of Markets or Customers - 30, 31, 36
Antitrust - 30, 31, 36
Audits and Auditors - 12, 53

Data Privacy - 20, 24
Dating a Coworker - 44, 54
Disciplinary Action - 8
Disclosure of Conflicts of Interest - 44, 54
Discrimination - 16-17, 22
Diversity - 16-17, 22
Drugs and Alcohol - 19, 24

Improper Payments - 32, 33, 37
Import Controls - 35
Insider Trading - 52
Intellectual Property - 48, 56
Internal Controls - 12, 53, 57
Internal Investigations - 53
Internet Usage - 24, 56
Investments - 44, 49, 52

Records - 24, 47, 50, 53, 57
Retaliation - 11
Recycling - 66

B
Bribery and Corruption - 32, 33, 37
BridgeLine - 11, 12
Bridgestone Integrity Test - 13
Business Records - 50, 53, 57

C
Charity - 61, 66
Chief Compliance Officer - 12
Code at a Glance - 4, 5Communication and Information Sharing - 21
Community Activities - 60, 61, 66
Community Service - 61, 66
Company Assets - 48, 49, 55
Competition - 30, 31, 36
Competitive Information - 28, 29, 36
Computer Use - 24, 47-49, 55, 56
Confidential and Proprietary Information - 28-30, 47, 49, 55-56, 67
Conflicts of Interest - 34, 44, 45, 54, 61
Conservation - 60
Contractors - 11, 18, 34
Copyrights - 46, 54
Corporate Audit - 12, 50, 53, 57
Corporate Security - 18, 23
Corruption - 32-33, 37
Customers - 18, 20, 28, 30, 34-36, 38, 43-47, 52, 54-55, 66

EElectronic Communication - 45, 49, 56
Entertainment - 34-35, 42-43, 54
Employee Responsibilities - 10, 28
Environment - 55, 60, 66
Expectations for Suppliers and Contractors - 11, 18, 34, 37
Export Controls - 35

F
Facilitation Payments - 37
Family Members of Employees - 32, 44, 54
Financial Investments - 44, 52
Firearms and Weapons - 18
Foreign Corrupt Practices Act (FCPA) - 32, 33, 37
Fraud - 53, 57
Free and Fair Competition - 30, 31, 37

GGeneral Counsel, Corporate Compliance - 12
Gifts - 32, 34-35, 38, 42-43, 54
Government as a Customer - 35, 38
Government Inquiries - 64, 67
Government Officials - 32-33, 35, 37-38, 43, 63-64

H
Harassment - 16-17, 22, 49
Health and Safety - 17-18, 23
Human Rights - 17

68

INDEX

K
Kickbacks - 32, 33, 37

L
Lawsuits and Claims - 65, 67
Lobbying - 63

M
Manager Responsibilities - 11
Media Inquires - 64, 67
Mission, Vision, Values Statement - 3, 8, 9
Money Laundering - 52

P
Patents - 48, 56
Political Activities - 62, 63, 67
Political Contributions - 62, 63
Price Fixing - 30, 31, 36
Privacy and Personal Data - 20, 24
Product Safety and Quality - 25, 28
Promoting Respect and Dignity - 16, 22
Proprietary Information - 28, 29, 47, 55
Protecting Corporate Assets - 41-57

Q

S
Safety - 17, 18, 23, 25, 28
Second Jobs - 44
Sexual Harassment - 16, 22
Suppliers - 11, 17-18, 30, 34, 37, 43-47, 54
Social Media - 49, 56, 64
Structured Payments - 52
Structured Transactions - 52

T
Third Parties or Agents - 32-34, 37, 47-49, 65
Tipping - 52
Trade Associations - 30-31
Trade Restrictions - 35, 39
Trade Secrets - 29, 45
Trademarks - 48, 56

U
Use of Company Resources - 48, 55

VViolence - 18, 23
Volunteer Work - 60-61

W
Weapons - 18
Where To Go For Help - 12
Workplace Safety - 17-18, 23

Quality Control - 25, 28

INDEX

69