Code of Conduct
North American Region Compliance & Ethics Policy1

Honda is Committed to Being a Company that Society Wants to Exist

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Code of Conduct

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Message
Since its foundation, Honda has strived to become a company society wants to exist by
sharing joys with people around the world based on the concepts of “Respect for the
Individual” and “The Three Joys,” which are the Fundamental Beliefs of Honda. Honda is
now capable of offering value to many customers all around the world through a variety
of products in our motorcycle, automobile and Life Creation business areas. I believethat this growth as a company was possible because we have always interacted with ourcustomers and society with sincerity and integrity.
In 2016, we formulated the “Honda Code of Conduct” which outlines the sincere conductthat all of us who work at Global Honda must practice. I believe that all Honda associates
understand and practice the “Honda Code of Conduct” in your daily work and conduct.

Toshihiro Mibe

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President, CEO &Representative Director

Today, the environment surrounding Honda business is undergoing a period of majortransformation, and further efforts to address environmental and safety challenges are
becoming urgent needs. Honda must continue fulfilling the expectations of society in atimely manner. Moreover, looking toward the future, we will continue offering new value
to our customers by fully leveraging the strength of Honda, our originality, and taking onchallenges in new areas such as the skies, ocean, outer space and the area of robotics.
In the pursuit of these goals, it is essential for us to always be sincere and ethical toward
our customers and society. No matter how capable we are to offer excellent products andservices, we cannot gain the trust and empathy of our customers and society or hope forfurther growth unless we conduct ourselves with such sincerity and strong ethics.
Regardless of business conditions, we will always maintain sincerity and integrity toward
our customers and society, and that is the origin and the immutable belief that is serving
as a backbone of Honda.
Please continue to have clear awareness that the behaviors and actions of each one ofus represent Honda and conduct yourself with sincerity and integrity in accordance withthe “Honda Code of Conduct.”4

Introduction
Under the guidance of the Honda Philosophy and as acompany empowered by its aspiration to realize people’s
dreams, Honda has thus far been able to establish trust with
its customers and society by engaging in global business
operations and sharing joy with people around the world.
As a result of our global deployment, Honda now has associates
in numerous countries and regions around the world. Considered
conduct grounded on the Honda Philosophy on the part of eachindividual associate is essential for Honda in reinforcing thetrust established with our customers and society. By sincere,
we mean free from deceit and hypocrisy and being earnest.
Recently, we have established the Honda Code of Conduct
as sincere actions that we would like all persons working at
Honda around the world to follow.

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To reinforce the trust of customers and society and make
Honda “a company society wants to exist,” all associates
including officers and directors of Honda and its subsidiaries(hereinafter referred to as “associates”) (where HM and its
subsidiaries are collectively called as the “Honda Group”)
should fully understand and comply with the Honda Codeof Conduct, and practice sincere and ethical conduct that
conforms to the Code.
Acts in violation of the Code may be subject to discipline
under company policies and applicable laws and regulations.

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Responsibilities of the Management
As a member of the management, you should
serve as a role model and carry out work underhigh ethical standards to foster a sincere andethical corporate culture.
You should also strive to foster an organizational
culture in which your associates put the Honda
Code of Conduct into practice and are able toreport or consult any concerns without fear of
retaliation.
In cases where violations or possible violationsof the Code are found, you must not neglect thesituation. Instead, you should respond appropriately
by taking actions such as reporting to the legal
department or compliance & ethics contact line.
Scope of Application
The Honda Code of Conduct applies toassociates of the Honda Group.
Honda also advocates adherence to theCode on the part of its affiliates.

Relationships with Customers
Quality of Products and Services

Appropriate Advertising and Publicity

Honda’s policy

Honda’s policy

Honda strives to provide products and services thatexceed the expectations of customers and society. In
this sense, it is essential to place the highest priority on
quality and safety, voluntarily establish high standards,
and respond in an appropriate manner.
Required conduct
I will place the highest priority on the quality andsafety of products as well as services, and comply
with established standards and procedures. I will also
request business partners and distributors/dealers toadhere to Honda’s standards and procedures.

Honda engages in advertising, publicity, and sales
promotion activities in good faith so as to constantly meet
the trust and expectations of customers and society.
Required conduct
I will properly engage in product advertising, publicity,and sales promotion activities to avoid misleading
customers.

Compliance with Competition Laws
Honda’s policy

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Honda will engage in free and open competition
with competitors to maintain its stance as a company
trusted by customers and society.
Required conduct
I will comply with competition laws (antitrust laws).

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Relationships with Business Partners
Sound Business Practices
Honda’s policy
Honda will engage in sound business practices under
an environment of free and open competition which isbuilt upon mutual trust with suppliers, distributors/dealers,
subcontractors and all other business partners, whileaiming to build long-term, constructive relationships
with them.
Required conduct
I will comply with the following in order to maintainsound relationships with business partners:• I will carry out appropriate procedures in accordancewith company policies in selecting business partners,
and will comply with laws, regulations, and company
policies related to business transactions.
77• I will not receive from or provide to business partners
benefits in the form of goods (both monetary andnon-monetary) or entertainment beyond what is
generally considered appropriate by society. I will
also not use my position or authority to receive
improper benefits from interested parties.

Relationships with Colleagues /Work Environment
Communication in the Workplace

Respect of Human Rights

Honda’s policy

Honda’s policy

Honda strives to create workplaces in which co-workers
can trust one another at all times.

Honda strives to maintain its stance as a company
committed to practicing fairness and sincerity andrespects human rights.

Required conduct
I will strive for smooth communication in the workplace
to create a harmonious work environment.

Required conduct
I will respect fellow associates, interact with them ina sincere and appropriate manner, and never engage
in any form of harassment or unjust, discriminatory
behavior in the workplace.

Safety and HealthHonda’s policy8

Honda will provide a safe and healthy workplace tomaintain a pleasant and safe work environment.
Required conduct
I will comply with laws, regulations and company
policies related to safety and health, strive to maintaina safe and healthy workplace, as well as prevent andminimize accidents.

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Relationships with Honda (Company Assets)
Company Assets
Honda’s policy
Honda will appropriately maintain and manage allcompany assets, both tangible and intangible, as
enterprise resources to achieve its business objectives.
Required conduct
I will appropriately handle company assets and not engage in acts that damage the value of company assets.
I will appropriately handle facilities, equipment, tools,
products, parts, accessories, items supplied by thecompany, money, intellectual property, and all othercompany assets in compliance with company policies
and not use them for anything other than for achieving
Honda’s business objectives.
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Company Assets
Honda’s policy
Honda will appropriately maintain and manage allcompany assets, both tangible and intangible, as
enterprise resources to achieve its business objectives.
Required conduct
I will appropriately handle company assets and not
engage in acts that damage the value of company assets.
I will appropriately handle facilities, equipment, tools,

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products, parts, accessories, items supplied by thecompany, money, intellectual property, and all othercompany assets in compliance with company policies
and not use them for anything other than for achieving
Honda’s business objectives.

Management of Information
Honda’s policy
Honda will appropriately protect and manage confidential
information and personal information that it holds forthe purpose of conducting proper business operations.
Required conduct
I will appropriately handle confidential information suchas internal information, business partner information andpersonal information of customers and other associates
in compliance with laws, regulations, and company
policies. I must also refrain from illegitimate use of suchinformation for insider trading or other improper deeds.

Conflicts of Interest
Honda’s policy
As a measure to ensure appropriate business
operations, Honda prohibits any conduct by associatesthat conflict with the interests of Honda.
Required conduct
I will not engage in acts that conflict with the interestsof Honda for my own benefit or the benefit of business
partners or third parties.

Relationships with Society
Traffic Safety

Contribution to Society

Honda’s policy

Honda’s policy

Honda will develop advanced safety technologies andengage in activities to promote safe driving with the aimof realizing a safer motorized society.
Individual conduct
I will observe traffic rules, good driving etiquette andendeavor to drive safely.

Environmental Protection
Honda’s policy
Honda actively endeavors to protect the global environment throughout all business activities as a responsible
member of society.
1010Required conduct
I will comply with laws and regulations, company
policies, and internal standards related to environmental
protection and strive to reduce the burden on theenvironment by engaging in resource conservation,energy conservation, and recycling.

Honda strives to contribute to society through its
business activities, such as the provision of products
and services that exceed the expectations of customers
and society. Honda also engages in socially beneficial
activities to fulfill its social responsibility as a corporate
citizen.
Required conduct
I will fully acknowledge Honda’s basic stanceto contribute to society and strive to fulfill our
expected roles in the community.

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Relationships with Political and
Administrative Entities

Relationships with Shareholders, Investors,
and Other Stakeholders

Relationships with Political and
Administrative Entities

Timely and Appropriate Disclosureof Information

Honda’s policy

Honda’s policy

As an independent corporate entity, Honda maintains
appropriate relationships with political entities (politicalorganizations and politicians) and administrative entities(governmental agencies and government officials).

In order to remain a highly transparent company,
Honda strives for appropriate communication withcustomers, business partners, shareholders andinvestors, local communities, and other stakeholders.

Required conduct

Required conduct

I will interact with political and administrative entities
in an appropriate manner in compliance with laws,
regulations, and company policies and will not offer
politicians or government officials entertainment nor
gifts (both monetary and non-monetary) that areprohibited by laws, regulations, and company policies.

I will appropriately disclose information in compliancewith laws, regulations, and company policies whenengaging in disclosure of information to outside parties
and interact with stakeholders in a courteous manner.

Compliance and Reporting Non-compliance
Incidents
Compliance and Ethics
Honda’s policy
Honda continuously carries out initiatives to strengthen
compliance in order to reinforce the trust establishedwith society. Persons who work at Honda are also
required to comply with relevant laws, regulations,and policies while acting ethically.
Required conduct
I will comply with laws, regulations and company
policies.
I will act ethically in accordance with social norms
and common sense.

Reporting Non-compliance Incidents
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Required conduct
If I become aware of any violation or possible violationof laws, regulations or company policies, report thematter, I will submit suggestions, and consult asnecessary with my manager, the legal department,or the compliance & ethics contact line*.
*This includes the internal whistleblower hotlines established by
the group companies.

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north american region

compliance & ethics policy
Powering the Future with Integrity

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Table of Contents
MESSAGE FROM THE PRESIDENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
MESSAGE FROM THE NORTH AMERICAN REGIONCOMPLIANCE OFFICER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

17 INTRODUCTION
THE HONDA PHILOSOPHY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
TO WHOM THIS POLICY APPLIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
USING THIS POLICY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
OUR RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
ADDITIONAL RESPONSIBILITIES OF HONDA’S LEADERSHIP. . . . . . . 20
ACCOUNTABILITY AND DISCIPLINE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

22 YOU AND YOUR FELLOW ASSOCIATESRESPECT FOR THE INDIVIDUAL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  22
Diversity and Non-Discrimination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  23
Harassment-Free Workplace. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  24
SAFE, SECURE, AND HEALTHY WORK ENVIRONMENT . . . . . . . . . . . .  26
Alcohol and Drug Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  27
Preventing Workplace Violence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  27
TIMEKEEPING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  27

28 YOU, HONDA, AND OUR CUSTOMERS14PROTECTING HONDA RESOURCES AND ASSETS . . . . . . . . . . . . . . . . . 28
ELECTRONIC INFORMATION DEVICES. . . . . . . . . . . . . . . . . . . . . . . . . . . .  29
DOING BUSINESS WITH THE GOVERNMENT. . . . . . . . . . . . . . . . . . . . . . 30
PRODUCT SAFETY AND QUALITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

32 YOU AND OUTSIDE BUSINESSES
MAINTAINING STRONG BUSINESS RELATIONSHIPS. . . . . . . . . . . . . . .  32
BUSINESS PARTNER INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
CONFLICTS OF INTEREST. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Selecting Business Partners. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Self-Dealing and Corporate Opportunities. . . . . . . . . . . . . . . . . . . . . . 34
Services and Discounts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Outside Employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Former Associates Seeking to do Business with Honda. . . . . . . . . 34
Financial Dealings and Investments . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
External Boards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Personal Relationships. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Reciprocity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
GIFTS AND ENTERTAINMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  37
Providing Gifts and Entertainment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
Guidance for Acceptance of Gifts/
Favors/Discounts/Entertainment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

40 YOU, OUR COMMUNITIES, AND THE ENVIRONMENTSUPPORTING COMMUNITIES WHERE WE WORK AND LIVE . . . . . . . 40
COMMITMENT TO THE ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
POLITICAL ACTIVITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  42

44 YOU AND BUSINESS INFORMATIONCONFIDENTIAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
COMPETITIVE INTELLIGENCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  47
CYBERSECURITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  47
INSIDER TRADING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
BUSINESS AND ACCOUNTING PRACTICES. . . . . . . . . . . . . . . . . . . . . . . . 48
GOVERNMENT REQUESTS AND INVESTIGATIONS . . . . . . . . . . . . . . . . 50
LITIGATION AND CLAIMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
COMMUNICATING WITH THE MEDIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Social Media. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

52 YOU AND THE LAWCOMPLIANCE WITH ALL LAWS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  52
ANTITRUST AND COMPETITION LAWS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
ANTI-CORRUPTION AND ANTI-MONEY LAUNDERING LAWS. . . . . . 54
Payments to Attain Business or Favorable Action. . . . . . . . . . . . . . . 54
CUSTOMS AND INTERNATIONAL TRADE. . . . . . . . . . . . . . . . . . . . . . . . . . 55

57 YOUR RESOURCES – HOW TO GET HELPOUR COMPLIANCE & ETHICS PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . .  57
QUESTIONS OR CONCERNS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
Difficult Decision Guide. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
REPORTING CONCERNS – WITHOUT RETALIATION. . . . . . . . . . . . . . . . . 61
WHAT TO EXPECT WHEN CONTACTING COMPLIANCE & ETHICS. .  62
NORTH AMERICAN COMPLIANCE & ETHICSCONTACT INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
OTHER RESOURCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
HONDA’S EXPECTATIONS OF YOU . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

Message From the President
More than 60 years ago, American Honda Motor Co., Inc. established operations in North America.
Since then, the North American region has grown to encompass companies and facilities across the
U.S., Canada and Mexico, including sales, manufacturing, research and development and finance.
The Honda Philosophy forms the basis for all company activities and sets the standard for thedecision-making process and conduct of all associates throughout Honda.
As associates, we have the privilege of being part of a diverse company that has a proud tradition
and a long-standing commitment to associates, customers, business partners, colleagues and thecommunities where we live and work. With this privilege comes the responsibility for all of us tomeet the highest level of ethical standards. Accordingly, I am proud to share the North American
Compliance & Ethics Policy, which provides consistent guidance to help you make the best decisions
and take the right actions. We need to do business the right way, achieving our high goals in a mannerconsistent with our Philosophy and our company’s policies.

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Shinji Aoyama

If you find yourself in a situation where you are unsure of the correct course of action, or you observe

Chief Officer of North American
Regional Operations

what you believe to be a violation of a company policy, it is your responsibility to come forward andPresident & Chief Executive Officerof American Honda

management team, Human Resources/Associate Relations, Compliance & Ethics, and the AHM

ask the question or report the concern. There are many channels available to you, including yourLaw Division. Only if we know of issues or concerns can we address them.
I believe the quality and diversity of our associates and our commitment to ethics and the Honda
Philosophy will not only enable us to succeed today but will help us to thrive and excel in the future.
Working together and maintaining high ethical standards, we will achieve our 2030 Vision of serving
people worldwide with the joy of expanding their life’s potential.
Sincerely,
Shinji AoyamaMessage From the North American
Region Compliance Officer
Dear associate:
At Honda, we hold ourselves to very high standards. Our reputation and long-term success depends uponeach associate maintaining the highest degree of integrity. As we rise to meet any and all challenges before
us, we must never compromise our ethical standards. It is important to preserve the trust of our customers,
suppliers, fellow associates and everyone else on whom our business depends. Each of us is responsible
for conducting Honda’s business with the highest standards of ethical conduct and in compliance withapplicable laws and Honda policies. For Honda, high standards are nothing new. It is who we are.
Honda periodically issues the Global Honda Code of Conduct and the North American Region Compliance& Ethics Policy to make sure that you are aware of Honda’s expectations that you comply with Honda’s
policies and legal requirements. These policies take into account the evolving business climate, reflect
Honda’s values and expectations, provide guidance on a variety of topics and highlight your responsibilities.
Please read and understand these policies and refer to them as often as needed to help ensure your dayto-day actions and decisions proudly reflect Honda’s values.

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Cathy McEvilly
Senior Vice President andNorth American Region
Compliance Officer

In this policy update, most sections have at least some minor enhancements and, one section, Customs
and International Trade, has more significant enhancements.
In the coming weeks, an all-new North American Region Compliance & Ethics Training will be launchedto support the release of this revised policy. If you have any questions or concerns after you read the policy,
you may ask your supervisor, Human Resources/Associate Relations or Compliance & Ethics (C&E).
We believe Honda is among the finest companies in the world and, ultimately, Honda’s long-term successdepends upon each associate’s judgment and the decisions made by each of us.
Sincerely,
Cathy McEvilly

Introduction

The Honda Philosophy  Guided by the Honda Philosophy,
Honda has expanded its businessglobally based on the pursuit of new
dreams and the determination to makethem come true. Through these efforts,
we have shared the “joys” and established trust with customers and society
around the world.  To further advanceour business, every Honda associatemust share the core values of the Honda
Philosophy: Dreams, Joy, Challenging
Spirit, Passion, and Respect. With eachof us sharing these values, we will beable to further gain the trust of ourcustomers and society, helping Honda
strengthen its position as “a company
that society wants to exist.”  

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From the beginning, the Honda Philosophy
has emphasized the obligations we haveto our customers, business partners,
society, and to each other. We will
always conduct business lawfully andhonestly. Safety, quality, integrity andrespect aren’t just words at Honda—
they are the way we work together andthe foundation of our legacy of integrity.

For us, our Philosophy has always been more than justlofty thoughts and words. It has always been the foundation
for actions and decisions. For that reason, the Honda
Philosophy goes hand-in-hand with our North American
Compliance & Ethics Policy. The two are closely interrelated. Our Philosophy provides the foundational ideas
and principles that distinguish us as a company. Our
Philosophy also expresses our vision, ideals, and what
we aspire to be. Our North American Compliance &Ethics Policy is an extension of that Philosophy and acommitment that we will conduct business the right way.  

To Whom This Policy Applies
This Policy applies to all Honda associates, including
officers and directors, at all Honda locations within
North America. This Policy also applies when you aretraveling or on assignment outside of North America.   

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Business partners (such as contractors, suppliers, vendors,
service providers, dealers) and contingent workers
should understand that Honda associates must conductbusiness in accordance with this Policy and conduct byany business partner that violates Honda’s standards ofcompliance and ethics might result in the need to severour business relationship with that person or entity.  

Using This Policy  This North American Compliance & Ethics Policy is a
guide to the ethical and legal responsibilities of Honda
associates. This Policy is not a comprehensive rulebook,and many of the responsibilities and expectations included
here may also be discussed in other Honda materials (forexample, the Associate Handbook, Global Confidentiality
Policy, Anti-Corruption and Anti-Money Laundering
Policy, Antitrust and Competition Law Compliance Policy,
procurement policies, and applicable business unit or
department policies and procedures). This Policy is notintended to be a substitute for any of those more specificpolicies. Additionally, this Policy must be read in conjunction with the global Honda Code of Conduct.
This Policy references many laws and regulations aswell as many Honda standards that go beyond legal
minimums. This is obviously not an exhaustive list.
Contact AHM Law or your local company’s legal groupif you find yourself in a situation where you are unsure ofyour responsibilities under the law.

Our Responsibilities  
The words in this Policy are empty promises if they are
not practiced by each of us and enforced consistently
throughout the Company. Since prevention is the best
way to minimize problems associated with unethical or
illegal conduct, Honda provides periodic training on
ethical and legal responsibilities. Honda also may
evaluate an associate’s adherence to this Policy
during the annual performance appraisal process.
We recognize that sometimes people make mistakes.
If you make a mistake, promptly disclose the error toyour leadership. Covering up a mistake only makes thesituation worse and is a serious violation of Honda policy.
Each of us, regardless of where we may be assigned
to work, has the responsibility to always act and makedecisions consistent with this Policy, the Honda Philosophy, and Honda’s core values.   
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In addition, you, and all associates, must:
Understand the information in this Policy and other
Honda policies, paying particular attention to the
topics that pertain to your job responsibilities.  

Complete all required associate training in a timely
manner and keep up-to-date on current standards,
practices, and expectations.
Report any conduct that may violate the law or thisPolicy to your manager, senior management, Human
Resources/Associate Relations, Compliance & Ethics,
or AHM Law and/or your local company’s legal
group. If you have already reported your concern
through internal channels, and/or you believe theconcern should be reported to the regional level,
you may contact the Corporate Compliance &Ethics Office at AHM or AHM Law and/or yourlocal company’s legal group. Contact numbers
can be found at the back of this Policy under North
American Compliance & Ethics Contact Information.
You may remain anonymous when reporting a
concern.
Cooperate and tell the whole truth when responding
to an investigation or audit and never alter, delete,or destroy records in response to an investigationor when an investigation is anticipated, or when
they are on litigation hold.

Remember, no reason, including the desire, or pressure
to meet business goals, should ever be an excuse forviolating laws, regulations or Honda policies.

Additional Responsibilities of
Honda’s Leadership  Every Honda leader is expected to follow our management
policies, which are rooted in the Honda Philosophy:
Proceed always with ambition and youthfulness.
Respect sound theory, develop fresh ideas andmake the most effective use of time.
Enjoy work and encourage open communications.
Strive constantly for a harmonious flow of work.
Be ever mindful of the value of research andendeavor.
Leaders must also:

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Lead by example. Leaders are expected to exemplify
the highest standards of ethical business conduct.
Be proactive. Look for opportunities to discussand address ethics and challenging situations
with others.
Make sure any business partner with whom theywork understand their compliance and ethics
obligations under Honda’s policies.  

Q: I’m a manager. If I observe misconduct in an area notunder my supervision, am I still required to report theissue?
A: Although you are primarily responsible for associates
and business partners with whom you work, all Honda
associates are required to report any misconduct they
become aware of and, as a leader, you are especiallyobligated to take action. The best approach is to talkfirst with the associate who oversees the area where
the problem is occurring; if this doesn’t work, or isn’t
practical, you should contact the other resources
listed in this Policy.

Accountability and Discipline  
Violating relevant laws, regulations or Honda policies, or
encouraging others to do so, may expose the Company
to liability and puts Honda’s reputation at risk. If an ethics
or compliance problem does occur, you are required toreport it so it can be addressed appropriately. Meetingthese requirements is vital to Honda’s success. Therefore,
violations of our policies, or the law, may result in
discipline, up to and including separation/termination of
employment. You should also understand that violations oflaws or regulations may result in legal proceedings andpenalties against you including, in some circumstances,criminal prosecution.

Disciplinary action may be taken when:
An associate authorizes or participates in conductthat violates this Policy;
An associate has deliberately failed to reportviolations of this Policy, concealed violation(s) of
this Policy, or deliberately withheld or encouraged
others to withhold relevant information concerninga violation of this Policy;
A person violates this Policy, and the manager
could have prevented, discovered, or stopped theviolation, and/or mitigated its impact with more
effective supervision;  
Any manager, or associate, retaliates, directly or
indirectly, or encourages others to do so, against
anyone who reports a suspected violation of thisPolicy; and21

Anyone makes a report they know to be false or
fails to cooperate in a formal investigation.

You and Your
Fellow Associates

Respect for the Individual  We owe each other honesty, respect
and fair treatment and we need toalways treat others as we would want
to be treated. This is the basis of ourcommitment to one another and is thefoundation of our success. To maintainour commitment and to attract andkeep talented individuals, it is vital that
we continue to have a supportive, professional, diverse and respectful workLawenvironment.

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Maintaining this environment not only
helps Honda succeed, it also createsthe setting for each of us to thrive andto reach our full potential. At Honda wedemonstrate Respect for the Individualin many ways. What follows are some of
the key areas where we must be guided
by our commitment to our values and toeach other.

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Trust

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Relationships among our associates
should be based on mutual trust. Trustis created by repeatedly recognizing
each other as individuals, helping out,
and accepting help when appropriate,sharing our knowledge, and making a sincere effort tofulfill our responsibilities.
Initiative
Initiative means not being bound by preconceived ideas,
but thinking creatively and acting on your own initiativeand judgment, while understanding that you must takeresponsibility for the results of those decisions and actions.

Our colleagues, job applicants, and business partners
are entitled to respect regardless of race, color, national
origin, ancestry, sex, sexual orientation, gender identity
or expression, religion, age, pregnancy, disability, military
status, genetic information, marital status, any factor thelaw protects from employment discrimination, or any
other factor that influences an individual’s working or
thinking style.

Equality
Equality means recognizing and respecting individual
differences in one another and treating each other fairly.
We are committed to fostering an accepting and inclusive
work environment and to creating equal opportunities
for each individual to enjoy a work environment free fromall forms of discrimination.
Diversity and Non-Discrimination
23

Inclusion and diversity are fundamental strengths of
Honda’s corporate culture of Respect for the Individual.
An inclusive work environment brings together a wide
variety of working and thinking styles, backgrounds,
skills, and cultural experiences that enable us to meetthe needs and expectations of an increasingly diverse
global customer base. Inclusion also makes every
workplace welcoming and safe for Honda’s associates,
contingent associates, contractors, suppliers anddealers.

Make sure you:
Treat others respectfully and professionally.
Promote diversity in hiring and other job-related decisions.
Do not discriminate against others on any basis protected by law
or Honda policy.
Watch out for:Comments, jokes or materials, including emails, which others
might consider offensive. Materials of such kind should never beshared or sent.
Inappropriate bias when judging others. If you supervise others,
judge them on performance. Avoid introducing unrelated considerations into your decisions. Use objective, quantifiable standards.

Harassment–Free Workplace  
Q: How does Honda benefit from diversity?
A: Diversity is important at Honda because each associate has a unique experience and perspective thatcan strengthen our organization and create a moreproductive workplace. Inclusion is important because
each associate wants to feel valued and important.
When associates feel included, it fosters commitment
to our company’s goals and motivates us to contribute to our success.
Q: One of my co-workers sends emails containing jokes
and insulting comments about certain nationalities.
They make me uncomfortable, but no one else has
spoken up about them. What should I do?

24

A: You should notify your manager, Human Resources/
Associate Relations or Compliance & Ethics. Sending
such jokes violates our values as well as our policies
and may expose Honda to other risks. By doing
nothing, you are condoning inappropriate behavior
and tolerating beliefs that can seriously erode theteam environment that we have all worked to create.

Harassment, intimidation, and abuse are prohibited at
Honda. It doesn’t matter if you are an associate, contingent,or business partner, harassment violates Honda’s belief
in Respect for the Individual. We must protect the right ofeveryone to work in a harassment-free environment.
Harassment can take many forms, all of them unacceptable.
Some examples are:Jokes, insults, threats and other unwelcome
actions and/or comments concerning a person’srace, color, sex, gender identity and expression,sexual orientation, age, religion, national origin,disability, military status, educational background,or economic status;
Unwelcome sexual advances, requests for sexual
favors, and other unwelcome verbal or physicalconduct of a sexual nature;
Conduct that disrupts another’s work performance,or creates an intimidating or hostile work
environment; andNonverbal conduct, such as staring, leering, or
giving inappropriate gifts.

Honda’s expectations:
Help each other by speaking out when a co-worker’s
conduct makes you/others uncomfortable;
Do not engage in sexual harassment, including
requests for sexual favors or other unwelcome
verbal or physical conduct of a sexual nature.
This is strictly prohibited;  
Demonstrate professionalism, including reliability,
honesty, and integrity;
Do not visit inappropriate internet sites or display
sexually explicit or offensive pictures; andReport all incidents of harassment, intimidation,
and abuse.  

25

If you observe, or are the subject of harassment,
intimidation, or abuse, ask the offending person to stopand tell her or him that the conduct is unwelcome.
Regardless of whether or not you discuss the problem
with the offending person, you must also promptly
report the incident to your manager, Human Resources/
Associate Relations or contact Compliance & Ethics.
Retaliation against anyone who objects to, or reports
unwelcome conduct, is strictly prohibited.
Honda utilizes the support of consultants, service
providers, and suppliers for various business activities.

We also utilize contingent workers to support the variable
volume of work required by our business. All of theseworkers are to be treated with respect and they deservea harassment-free environment. They must also follow
Honda’s established safety procedures and follow
Honda’s non-harassment policy.   Honda will not tolerateillegal actions conducted by anyone while doing businesswith Honda or on Honda’s behalf.

Q: While on a business trip, a colleague of mine repeatedly asked me out for drinks and made comments
about my appearance that made me uncomfortable.
I asked him to stop, but he wouldn’t. We weren’t
on site and it was ‘after hours’ so I wasn’t sure what I
should do. Is it harassment?
A: This type of conduct is strictly prohibited, not only
during working hours, but in all work-related situations
including business trips. Honda’s policy against
harassment does not just apply on Honda premises
or during work hours. It applies in all work settings at
all times - even when you are off-site, on a businesstrip, or at a company-sponsored event. In the example
above, even if you’ve asked your colleague to stop,
you need to report the problem.  

Q: My new manager is very intimidating and sometimes
she humiliates me in front of my co-workers. This may
just be her style, but it’s affecting my morale. Is there
anything I can do?
A: If you feel you are not being treated in a professional manner, speak to your manager about how her
behavior is affecting you. If you are not comfortable
doing that you can speak to another manager, or you
can go to Human Resources/Associate Relations orcontact Compliance & Ethics.
Q: A coworker often jokes about my ability to use the tools
provided for my job, but doesn’t make the same jokes
to my male counterparts. I do not want to be treateddifferently if I report it. Should I just ignore him?

26

A: If you feel you are being treated differently by yourco-worker, talk to them about how their behavior
is affecting you. If you are not comfortable talking
directly to your co-worker then you can speak to yourmanager, or you can go to Human Resources/Associate
Relations or contact Compliance & Ethics.

Safe, Secure, and Healthy
Work Environment
Honda is committed to providing a safe, secure andhealthy work environment. We have an obligation toourselves and each associate to ensure safe, secureand healthy working conditions. You must participate
in safety training when required and always comply
with all relevant safety codes, regulations, standards andpolicies.  Promptly report any safety concerns including
accidents, injuries, or unsafe conditions. Make safety apriority in everything you do.

Q: Are subcontractors expected to follow the same
safety policies and procedures as associates?
A: Absolutely. Managers are responsible for ensuringthat all business partners working on Honda projects
both inside and outside the premises understand andcomply with all applicable laws and regulations
governing the particular facility, as well as withadditional requirements the Company may impose.  

Alcohol and Drug Use  

Timekeeping

Possessing or using alcohol or illegal drugs at work, or
working while under the influence, is strictly prohibited.
It is dangerous to you and an obvious threat to a safe
workplace. For additional information, consult yourindividual company’s policy in this area.

Honda is committed to paying associates fairly and incompliance with all relevant laws. You are accountableto accurately record the time you work and to follow
company timekeeping policies (such as meals andbreaks, overtime, etc.). Managers are responsible for
ensuring that associates follow timekeeping policies
and requirements. Accurate time reporting is necessary
to appropriately calculate your pay and benefits. If you
have reason to believe your pay is inaccurate or incorrect,
then it is your responsibility to inform your manager or
Human Resources/Associate Relations as soon as possible.     Preventing Workplace Violence  
Violence, intimidation, and direct or implied threats ofviolence are strictly prohibited at Honda. We all have aduty to promptly report any workplace threat, activity or
incident that you reasonably believe violates this Policy.
In addition, weapons, including firearms, or relatedparaphernalia are not allowed in the workplace. Laws
may vary by state or province. For additional information,
consult your individual company’s policy in this area.

27

For the full Safe, Secure, Healthy Work Environment
policy visit HondaWeb

Any falsification or attempt to misrepresent hours worked
is a violation of Honda policy and may result in discipline,
up to and including termination from employment.

You, Honda
and Our Customers

Protecting Honda
Resources and Assets
We all have a responsibility to use
Honda’s resources and assets wisely
and with care and to ensure that Honda’s
property is not misused, damaged, lost,
stolen, or wasted. Properly care forthese and all other Honda assets.
Use Honda assets for company
business or for purposes authorizedby management. Protect them fromtheft, carelessness, waste, and misuse,and document all asset inventories
accurately and honestly.

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Electronic Information Devices
Business tools that are supplied by Honda and/or any
device or system connected to the Honda network is forthe purpose of increasing productivity and the qualityof your work. Examples of these business tools are
email, internet access, phones, computers, tablets,
voicemail, and removable media. Use these businesstools in a productive, professional manner, and remember:
Passwords are provided and assigned to individual
associates for their specific job function; they are
not to be shared.
Devices should not be connected to any network
not permitted by Honda.
The use of these tools must not violate our harassment-free policies.

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Copyrighted material, trade secrets, otherconfidential information, or business records
may not be transmitted or received without proper
approval, and may only be shared in compliancewith applicable confidentiality requirements.
These tools should not be used to perform work for
non-Honda business.

Limited personal use of the Company’s electronicbusiness tools may be acceptable if it does not
violate Honda policies or interfere with your work
performance or the work of others.
Communication sent or received on company
systems, including internet activity, is not private.
The Company has the right to record, viewelectronic communication, and monitor internet
activity on company systems and to blockassociates from visiting specific internet sites,or limit the amount of time an associate may
spend on a specific website.
Email must be treated as any other businessdocument. Therefore, be clear, professional, andpolite in your communication. Proofread thecontent and recipient list before hitting “send.”  
Business records must be retained according to
the Global Record Retention Policy and per any
litigation holds.
If any of your Honda-issued assets are lost, stolen, or
damaged, you should contact your manager and yourlocal Information Security group immediately so thatyour device can be disabled and any additional
measures can be taken.  

Doing Business with the Government
Honda strives to be a company that society wants toexist. A critical step in meeting this goal is to consistently
abide by the federal, state and local laws and regulations
that govern our business everywhere we operate. There
are a multitude of laws and regulations that govern acompany’s ability to successfully obtain and maintaina contract with a government entity. Our policy is tocomply fully with all applicable laws and regulations that
apply to government contracting and transactions.

30

Those who oversee work with governments andgovernment-owned entities (such as public colleges
and universities) must remain up-to-date on relevant
regulations and should contact AHM Law with anyquestions. Special care should be taken to ensurethat any agent, while acting on behalf of Honda,
who provides goods or services on government
projects, is aware of and abides by our high standards
as well as their contractual and legal obligations.
There are also a number of rules and procedures forcomplying with the required disclosure of solicitationof government business which may, in some cases,
constitute lobbying activities. AHM Government andIndustry Relations can provide guidance on any potential
lobby law requirements or disclosures necessary
to solicit business with a government entity.

If you work with government officials and contracts, you
are responsible for understanding and complying withall applicable laws. For example, many government
officials are prohibited from receiving gifts (including
food and drink), entertainment and travel. In somecountries, government regulations may also apply to thehiring of current, or recently retired, government officials
and their families. Avoid any conduct that may be viewed
as improperly influencing the objective decision-makingof government officials.
If you aren’t sure, consult with AHM Government andIndustry Relations or AHM Law.

Product Safety and Quality
We are dedicated to supplying products of the highest
quality at a reasonable price for worldwide customer
satisfaction. Remember, the Joy of Buying – one of theThree Joys – is achieved through providing products andservices that exceed the needs and expectations of eachcustomer.

31

Our reputation is riding on the safety and quality of every
product we make. Put quality into everything you do.
Follow all operation and safety standards and procedures
and take the initiative to let your manager, Senior Manager,or other appropriate Honda Safety Personnel know ofany product or process that does not meet relevant motor
vehicle safety laws and regulations or Honda’s quality
or safety standards. You may also use the Compliance& Ethics line to report any safety or quality concern.
Never attempt to conceal substandard work or products
or components. As you think about product safety andquality, remember that people you care about use our
products.

Q: During an external audit, the auditor requested that
we provide a test report for an item listed in our
Operation Standard. We are in the process of training
several new associates and missed performing thenecessary test. My senior manager asked me toretrieve the test reports and when I spoke with mymanager, he asked me to create a report and post-dateit. How can I raise the issue without upsetting mymanager?
A: Under no circumstances should you ever create false
records whether or not there is an audit. If you are
comfortable, let the manager know that it’s against
Honda policy and it’s better to inform the auditor thatthe records do not exist. If the manager persists, notify
your senior manager of the request and that you
refused to comply. The senior manager should thentake the appropriate action to address the issue. You
also may report the issue through the Compliance &Ethics line.

You andOutside Businesses

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Maintaining Strong
Business Relationships
Our business partners (such as
contractors, suppliers, vendors, service
providers, dealers) and contingent
workers make significant contributions
to our success and the high qualityof our products. We engage them inan honest and ethical fashion. We
do not take advantage of anyone,
whether directly through manipulation,
concealment, abuse of privileged
information, misrepresentation ofmaterial facts, or indirectly throughany other unfair practice.
We purchase goods and services, aswell as develop and maintain business
relationships based on sound businessreasons, such as suitability, diversity,
quality, delivery and cost. All purchasingarrangements must be done pursuant
to the Indirect Procurement Governance
Policy (“IPGP”) where applicable andyour company’s individual procurement
policies. Any goods/services purchased
must be in compliance with theapplicable IPGP and all contractual
arrangements must be properly
executed to govern the legalrelationship and all Orders/purchases must clearly
document and clearly identify all the services or products
to be provided, price, and payment terms. No payment
on behalf of Honda shall be approved without adequate
supporting legal documentation in place.
Honda believes in doing business with business partners
who embrace and demonstrate high standards of ethicalbusiness behavior and who share Honda’s commitment
to diversity and environmentally sound business practices.

Q: I have reason to believe that one of our key suppliers
is not enforcing safety rules. Should I be concerned?
A: Honda’s reputation for doing business right can bedamaged by the acts of our business partners. Reportyour concerns to your manager or Compliance & Ethics so they can determine the right course of action.
33

Business Partner Information
It is very important to respect the confidential informationof business partners. Never use or disclose a business
partner’s confidential information, such as drawings,
engineering or technical documents, methods or
instructions, or pricing, even to a Honda affiliate, unless
it is legally authorized and with the written permissionof the business partner. If you are not sure, consult
with Compliance & Ethics, AHM Law or your local legal
group. (Also see Competitive Intelligence.)

Conflicts of Interest
A conflict of interest exists whenever you have acompeting interest or loyalty that may interfere withyour ability to make an objective decision for Honda.
Each of us is expected to use good judgment andavoid situations that can lead to a clash between our
professional obligations and our personal interests orthat of our family members. That includes even theappearance of a conflict which can undermine the trust
others place in us and damage our reputation.   
Conflicts of interest may be actual, potential or evena matter of perception. Since these situations are notalways clear-cut, you need to fully disclose them to amember of leadership or Compliance & Ethics so that wecan properly evaluate and manage them. If unsure, it isbest to report the issue.

34

Selecting Business Partners

Outside Employment

You must select and deal with suppliers, service providers,dealers, competitors, customers, or any business entitythat does business, or seeks to do business, with Honda
in an impartial manner, without favor or preference
based strictly on the best interests of Honda. For more
information, see your Company’s procurement policies.  

Outside employment can create a real or perceived
conflict of interest. You may not seek compensation of
any kind, including loans, payments, subsidies, or services
from our business partners, competitors, customers,
or any person or business entity that does business, orseeks to do business, with Honda.  

Self-Dealing and Corporate Opportunities  To ensure that there are no conflicts and that potential
issues are addressed, even if it is only a perception thata conflict of interest may exist, you must disclose anddiscuss outside employment with your manager and/or
your company’s Compliance Officer, which can befacilitated through Compliance & Ethics.

If you learn about a business opportunity through yourwork, Honda’s interests take precedence. This means thatyou, or your family members, must not take that opportunity unless you have fully disclosed your interest in that
opportunity in writing to the Compliance Officer, and you
have been notified that a determination has been madethat such interest will not affect the impartial discharge ofyour duties or obligations to Honda. Any such opportunity
should be reviewed in advance through Compliance &Ethics. The topic of insider trading is addressed under thesection You and Business Information.
Services and Discounts
You, or your family, may not accept any special services,
discounts, or rebates from our business partners,
competitors, customers, or any business entity that
does business, or seeks to do business, with Honda
unless they are made publicly available to all associates
at your company.

Former Associates Seeking to do Business with Honda
It is generally Honda’s policy not to conduct business withformer associates, whether on their own behalf or on
behalf of their new employer, within two (2) years after
separation from Honda or a Honda affiliate. Honda may
continue to do business with the supplier, but requirethat the former associate not be a liaison to Honda.  
An exception to this policy can be made with written
permission from your Compliance Officer, which can befacilitated through the Compliance & Ethics function.  

Among the factors to be considered are:Financial Dealings and Investments

1. Does the former associate’s employment at Honda ora Honda affiliate provide him or her (or employer) acompetitive advantage by:

You must not have a significant financial interest in anyof our business partners, competitors, customers, or any
other business entity that does business, or seeks to dobusiness, with Honda except where such interest has
been fully disclosed in writing to the North American
Region Compliance Officer and a determination has been
made that such interest will not affect the impartial discharge of your duties or obligations to Honda. As a guidefor the purpose of determining the necessity for disclosureof such interest to Honda, ownership in such a business
entity shall be deemed significant if the aggregate interestof the associate, her or his spouse, or close relatives of theassociate represents 1% of the outstanding securities or
total equity of such firm or corporation. The North American
Region Corporate Compliance & Ethics Office will facilitate
the process. See the list of contact numbers at the end of
this Policy.

• Providing him or her access to pertinent Honda orcompetitor’s information?
• Previously influencing Honda’s decisions in areas
for which the former associate (or employer) now
seeks to do business?
2. Will it create an appearance of “unfairness” to others
competing for Honda’s business? The appearance of
unfairness is more likely if:• The former associate was/is in a position to influencecontracting or retention decisions for Honda.

35• Other competing businesses could reasonably
conclude that item 1 is true based upon information
available to them.
After the two-year period, a business division may decide
whether to conduct business with the former associateand should continue to consider the same factors above.

Publicly traded mutual funds or similar pooling of securities, where the individual investor has no say in which investments are included, generally do not create a conflictof interest and do not require approval. If you are unsure
whether there is a conflict, contact Compliance & Ethics.
External Boards
We encourage and are proud of associates’ involvement inand attempts to improve their communities through their
participation on boards of organizations that benefit education, the arts, athletics, scouts, and similar endeavors.

However, affiliations with outside organizations, such as
membership on a board of directors or advisory board,
may also lead to actual, potential, or perceived conflicts ofinterest. Being transparent about board memberships isbeneficial for both Honda and associates.
You may not accept a seat on a board of directors or advisoryboard of any of our business partners, competitors,
customers or any business entity that does business, orseeks to do business, with Honda or our dealers without
advance written approval by the president of your company.
For more information, see the Honda – North American
Region External Board Approval and Disclosure Policy on
HondaWeb. The policy has guidelines for approval anddisclosure of both for-profit and non-profit organizations.

Q: I want to sit on the board of my religious organization.
Do I need approval?
36

A: No. Disclosure or approval is not required with respect
to positions with the following types of organizations:condominium associations, religious institutions, orvolunteer work with entities such as parent-teacher
associations, youth sports organizations, scout groups,
community volunteer organizations, or similar
endeavors. If you are in doubt whether your organizationof interest would fall within the exception category,contact Compliance & Ethics or your compliance officer.

Personal Relationships
You must disclose to your management when family or
personal relationships might influence, or be perceived
to influence, your ability to make objective decisions.
Management is responsible for putting appropriate
controls in place and determining whether you cancontinue to be involved in those decisions.
Reciprocity
Providers of goods and services must not be asked tobuy goods and services from Honda in order to becomeor continue as a supplier or service provider, whether or
not the goods or services are directly tied to the goods
and services that Honda is receiving in the arrangement.

Q: I have become very friendly with an associate whoworks for me. What is Honda’s position on managers
dating subordinates?
A: A romantic relationship with a direct or indirect
subordinate can hurt morale and disrupt productivity.
It may also create a conflict of interest or the appearance of a conflict of interest. If you are in such a
relationship or know someone who is, you shouldreport the relationship to your manager, Human
Resources/Associate Relations or Compliance & Ethics.  

Gifts and Entertainment
Q: I have run into a problem with a supplier. I need toreplace the supplier immediately so that the project
won’t fall behind schedule. My neighbor’s company
provides similar services at an even lower rate. Can I
ask their company to take over?
A: If you’d like to recommend your neighbor’s company,
you can do so, but you must disclose your relationshipto your manager and remove yourself from the supplierselection process. We should avoid giving the impression that we play favorites, and we should never takeshortcuts in the bidding process. Remember, allassociates must follow Honda’s sourcing andprocurement policies and procedures.

At Honda, we pride ourselves on building strong relationships with business partners and customers. On rareoccasions, entertainment or gifts may be offered to you.
The preference is for you to explain that neither gifts norentertainment are expected or encouraged from those
doing business with Honda. Acceptance of gifts orentertainment may create an appearance of a conflictof interest. Even the appearance of a conflict can bedamaging to you, Honda, and our business partners.  
To ensure that we don’t create a perception of impropriety,adhere to the following:  
Any gift or entertainment must be legal, consistent
with both companies’ policies and our values andNever be accepted during the bidding process
for new business;

37

Never be in cash or a cash equivalent (such as a
Visa gift card);
Never be received or offered for something in
return;  
Never be encouraged or solicited by you or afamily member; andBe infrequent.

Gifts must be nominal in value (policy limit of$50 dollars (Canada/US) or $1000 pesos (Mexico)).
Entertainment or other favors must be of a character that does not go beyond common courtesies
consistent with ethical and accepted businesspractices. When appropriate, consult with Compliance & Ethics in advance to discuss your specificsituation.
The Honda associate, as well as the business partner,competitor, or business entity must be present;
otherwise, the meal or entertainment must betreated as a gift.
Providing Gifts and Entertainment

38

At times, it may be appropriate to provide a modest gift
or entertainment to a business partner. Lavish spending
on business gifts is unacceptable because it can create
the perception that we are trying to obtain or give favorable business decisions by providing individuals withpersonal benefits.  
Honda is prohibited, either directly or indirectly, fromoffering any financial remuneration to any governmental
authority/official.
Gifts and entertainment provided to other entities mustbe accurately reported by the associate and recorded in
Honda’s financial records.  

Any situation that may appear to be a conflict of interest
must be reviewed by Human Resources/Associate
Relations or Compliance & Ethics. If you’re ever in doubt,
you should disclose the issue.  

Q: I overheard my manager talking about a World Series
baseball game that a business partner treated her
and a guest to over the weekend. It sounded excessive
to me; however, I don’t want to get her in any trouble(she is a good manager) and I sure don’t want any
unnecessary attention. Should I say anything?
A: All associates have a right and responsibility to bringforward concerns, even if they are not sure a violation
has occurred. We understand it may be difficult to doso. Honda has provided many channels for associates
to communicate concerns, including the option toremain anonymous. In addition, Honda has clear
policies prohibiting retaliatory actions and behaviors.
Since you had a concern, you should raise the issue.
This is particularly true since it involved a high-profile
sporting event. Ideally, the manager has already disclosed this situation to her manager and an informed,
appropriate decision was made.  Raise the issue toprotect the integrity of Honda, our process, and ourassociates.

Guidance for Acceptance of Gifts/Favors/Discounts/Entertainment
Guidance for Gifts,
Favors, Discounts
Generally Acceptable –  
Exercise Good Judgment

Unacceptable

Gifts of little or insignificant value,e.g., promotional items (hats, pens,
coffee mugs, etc.)

Gifts of more than $50 dollars (Canada/US)
or $1000 pesos (Mexico) in value (except for
consumable items such as food baskets
that may be shared with the team)  

Any other gift valued below and
up to $50 dollars (Canada/US) or$1000 pesos (Mexico)

Gifts of even a nominal value received
during a bidding/negotiating process for
new business, or with conditions attached

Retail offers to the general public

Money and items that can beeasily redeemed for cash

Careful Consideration – Consult
Discounts or special offers (must be
publicly available to all associates inyour company)
39

Guidance for Entertainment(including Meals)

Competitions or drawings at events
attended for work with prizes thatcan be regarded as gifts

Compensation of any kind, includingloans, payments, or subsidies
Promises of employment or otherfavors for relatives, friends, etc.
Overnight accommodations(business or personal)“Thanks for your help” gifts
from suppliers/dealers  Personal use of a business partner or
potential business partner’s private
property, such as a condo or boat

Business travel expenses

Frequent acceptance of even nominal gifts
Receiving gifts at any non-Honda location (e.g.
personal residence or other non-work locations)
Receiving gifts to any non-Honda email
address (e.g. personal email address)

Generally Acceptable –Exercise Good Judgment
A working lunch or dinner or social dinnerreflective of the business partners
relationship with Honda
Standard tickets to a normal sporting (such as,
pre- or regular season) or cultural event
Careful Consideration –Consult with Compliance & Ethics
Above-standard tickets, such as, luxury box/
suite or play-off/championship events, higher
than face value, to a sporting or cultural event
Tickets to a high-profile
sporting or cultural event
Unacceptable
Any entertainment, events, trips, or accommodations intended to influence a decision,negotiation, business arrangement, or purchase
Entertainment received during a bidding/negotiating process for new business, orwith conditions attached  
Frequent acceptance of entertainment/meals

You, Our Communities
and the Environment

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For more than 60 years in the U.S.,
Honda has been committed to making
positive contributions to the communities where its associates live and work.
Honda’s mission is to create products
and services that improve the lives ofpeople while actively supporting community organizations.
While every associate is encouraged
to become involved in their local
community by volunteering andsupporting organizations and events,
it is important to remember thatassociates should not pressure others,
inside or outside of Honda, to contributeor participate in our community or
charitable organizations. Associates
should disclose any active relationshipwith an external organization prior
to participating in Honda’s decisions
related to the organization.

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Supporting Communities
Where We Work and Live

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Associates should:
Take community needs and interests into accountwhen making decisions;
Ensure that an associate’s personal support of acharitable organization is not viewed as Honda’s
endorsement of the organization;  
Follow company policies and/or procedures formaking and soliciting charitable contributions;Obtain approval from management before using
any Honda resources to advance a charitable goal;andNot ask Honda’s business partners, or thoseseeking to do business with Honda, to support
charitable organizations without prior approval.
Watch out for:41

Requests from business partners to give to charitable causes. These requests must be approved by
Honda, like all other charitable contributions. If abusiness partner asks an associate to contribute
their personal funds, associates are under noobligation to do so. If an associate receives sucha request and would like to make a contribution,
the associate should consult with Corporate Social
Responsibility to ensure that the contribution isappropriate and legal.

To Learn MoreIf you have questions or concerns about a charitable
contribution or your work in the community, contact
AHM Corporate Social Responsibility.

Commitment to the Environment
Honda’s vision for a carbon-free society is leading tocomprehensive efforts to address society’s environmental
and energy concerns across the company’s products andbusiness operations. Honda has consistently been ranked
as a leader in fleet average fuel economy and low CO2
emissions among major full-line automakers in America,
according to the U.S. Environmental Protection Agency(EPA). Honda also is working to reduce the environmental
impact of its business operations and promotes
environmentally responsible business practices with its
suppliers and retail dealer partners across North America.
This is part of our commitment to the future and our
dedication to applying the Honda Philosophy to ouractions and decisions. Honda’s policy is to comply withall environmental laws, go beyond legal requirements
where appropriate, and seek ways to minimize
environmental impact.

We all have a role in protecting the environment and are
expected to perform our jobs in accordance with thefederal, state and local environmental laws and regulations.
For example, you are expected to understand and comply
with all Honda procedures relating to the handling,
packaging, and transporting of hazardous materials.
Honda associates are also encouraged to use theircreativity and initiative to improve the efficiency of our
products and operations so that they use less energy
and produce fewer emissions. We can demonstratesound environmental practices in every part of ourdaily operations, through our efforts to reduce waste
and conserve energy and water and by reusing or
recycling all appropriate materials. If you notice any
potential environmental hazards, or opportunities
to improve Honda’s environmental practices, notify
management immediately.

42

Political Activities
Honda encourages associates to exercise their rightto vote and participate in the political process. Like all
responsible citizens, Honda actively participates in thelegislative process and, from time to time, in the politicalprocess as well. However, corporate participation in thelegislative and political processes is highly regulated. No
Honda funds or assets can be used for federal, regional,
or local political campaign contributions, even wherepermitted by law without prior written approval of theVice President of AHM Government and Industry
Relations and the executive level associate in therespective Honda Company making the contribution.
Those prohibitions not only cover direct contributions
but indirect assistance or support of individual
candidates, ballot initiatives or political parties by suchmeans as purchasing tickets for special dinners or otherfundraising events, or the furnishing of any other goods,
associates, services, facilities or equipment to politicalparties or committees.  
In addition, no Honda funds or assets will be used forpolitical contributions outside of North America, evenif permitted by applicable law, without the prior written
approval of the Vice President of AHM Government andIndustry Relations.
The above prohibitions apply only to the use of Honda
corporate funds or assets for political purposes and are
not intended to discourage associates from making

personal contributions to candidates, parties orcommittees of their choice, including lending yourservices on your own time and at your own expense.
If you are involved in politics, you must express yourviews as an individual, not as a representative of Honda.
Therefore, implying endorsement, authorization, or using
your status as a Honda associate to promote a political
position is prohibited.
If in your official capacity as a Honda associate you havereason to interact with political candidates or elected
officials running for (re)election, please make sure you
consult with AHM Government and Industry Relations,
AHM Law or your company’s legal group for guidance inthis area

43

Q: I would like to run for political office. Is that OK?  
A: Yes, as long as you are not using Honda’s name orassets, or attributing your views to the business.   
Q: Can I host a facility tour for an elected official who isrunning for re-election or higher office?
A: Many factors go into that decision and you should
first consult with AHM Government and Industry
Relations for guidance and approval.

You and BusinessInformation

Honda’s continued success depends on
developing knowledge and using it toimprove the business. Any knowledge
that is known only to Honda, gives Honda
a competitive advantage, or that has
been entrusted to Honda by a business
partner, customer, or associate isconfidential information that must be
protected. Examples include informationthat is critical to Honda’s or a supplier’s
core business such as research anddevelopment plans or ideas; source codes;
design drawings or specifications;manufacturing methods; businessand strategic plans; financial data andreports; pricing and marketing strategy;
personal information of associates,
business partners, or customers;
computer programs; and any othersensitive information.

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Confidential Information

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You have an obligation to safeguard confidential
information by:
Keeping it secure, locking cabinets and desks, andprotecting sensitive documents with passwords;

Consulting with AHM Intellectual Property, AHM
Law and/or your company’s legal group if you knowof any ideas, inventions, or developments that may
be eligible for protection by patent, copyright ortrademark; and/or

Keeping passwords confidential in accordancewith Honda policy;

Complying with Honda’s policies and procedures
regarding confidential information.

Properly securing laptops and other mobile
storage devices;
Using the appropriate data classification markingsof “S,” “A,” or “B,” or their equivalent if your company
uses a modified classification system;
Discussing it only with other Honda associates
who have a need to know in order to do their job;45

Not discussing it in public or inadvertently sharing
it with others (such as in an airplane or similar
environment);
Not posting any confidential information to social
media sites;
Disclosing it outside Honda only if you have therequired permission to do so and the party receiving
the information has signed a Honda confidentiality
agreement pertaining to the subject matter of thedisclosure;If you are a manager, confirm that access rights toconfidential information have been revoked whenassociates change positions and no longer need it, or
when outside contractors or entities have completed
the project for which they had been given access.  
For additional information, see the Global Confidentiality
and Global Privacy policies located on HondaWeb.
When your Honda employment ends, your obligation toprotect Honda’s confidential information continues andall of Honda’s property and documents held by you must
be returned to Honda.

Q: Occasionally, on rush projects, we need to provide
our business partners with confidential Honda
information right away. Is it acceptable to provide
the information first and then quickly follow up witha non-disclosure (confidentiality) agreement?  
A: No. Disclosing the company’s confidential information
without first having the recipient sign a non-disclosureagreement (NDA) would be a serious breach of yourobligation to protect Honda’s assets. Not obtaining an
NDA could forfeit certain protections by revealing ourconfidential information. These types of agreements(sometimes referred to as confidentiality agreements)
for the most part are,  simple relatively short documents.
Please contact Purchasing if you need a supplier tosign an NDA.

46

Q: I found a picture on the internet that I think would
look great in a presentation. Since it’s available online,
I don’t need permission to use it, right?
A: Many people incorrectly believe that images, suchas photos, that they find on the internet or receive
through a social network are available for anyone
to use. Using the image without permission could
infringe on the rights of the owner of the image. You
should always get permission before using the intellectual property of another person. If you have any
questions or need assistance in obtaining approval,
you should contact AHM Intellectual Property.

Intellectual Property and Trade Secrets
Honda’s intellectual property (IP) and trade secrets areimportant assets that we must consciously work to protect.
Some examples of our IP are:Strategic, business, and marketing plans
Company initiatives (existing, planned, proposed or developing)
Customer lists
Compilations and formulas
Methods, know-how, processes, and techniques
Scientific and engineering discoveries, innovations, designs,
and drawings for themNames, symbols, logos and slogans
Original works of art or publications, including literary,musical and audiovisual
Systems, software, and source codes and related technology

Competitive Intelligence
Information about competitors is a valuable asset in
today’s competitive business environment. Whencollecting business intelligence, you, and others who
are working on our behalf, must always live up to thehighest ethical standards. Never engage in fraud,
misrepresentation or deception to obtain information.
Discuss any questions or concerns about collecting
business intelligence with Compliance & Ethics or
AHM Law.  

Cybersecurity

47

Honda companies store information and data on
computers and in networks, including confidential
business records, and associate, supplier, and customer
information. Additionally, many of our vehicles and otherproducts are, or will become, connected to the intranet.
In this policy, ”cybersecurity” refers to measures taken toprotect a computer, computer systems, or our products
from unauthorized access and attacks by third parties.
A security breach that involves competitively sensitive
information, such as trade secrets, customer lists, ormarketing plans, may threaten the ability of Honda tocompete and erode the confidence of our associates andcustomers. In addition, a breach could potentially lead tobusiness interruptions, reputational harm, and millionsof dollars in lost business, damages from lawsuits, andgovernmental fines. Likewise, a breach that affects
connected products could result in safety risks for ourcustomers or the disclosure of their confidential information
stored on the products.
Honda has taken steps to protect its computer systems
and products from breaches, intrusions, or negligencethat will result in theft or loss of data. However, almost
all are the result of human error. The most critical factor
in Honda’s cybersecurity protection systems hinges onwhat you and every associate does on a daily basis, bothinternally and externally. For that reason, engage in good
cybersecurity practices.
For clear guidance and direction, see the North America
Information Technology Security Policy (NAITSP) covering
global, regional, and cybersecurity policies.

Insider Trading

Business and Accounting Practices

The law prohibits buying or selling a company’s stock
when you know material and non-public information
about that company. Material information is information
which could affect the value of the stock or influence areasonable investor to buy or sell stock.

All records, reports and documents must be complete
and accurate. Never make false or misleading entries,
statements or alterations in any record whether it relates
to financial data, business data such as safety, quality
and personnel files; or any other kind of information.
When compiling information to be reported to other
Honda associates or outside Honda, refrain from making
assumptions and generalizations or making decisions
based merely on past practices without verification,
confirmation, or approval.  Always follow appropriate
accounting principles and practices, as well as ourinternal controls and the Global Record Retention Policy.  

Associates aware of material, non-public information
relating to Honda, companies with whom Honda does
business, or with whom Honda is seeking to do business,
may not directly or through friends or family:
Buy or sell stock until that information is madepublic by the company;
Pass information on to others, including other
Honda associates; and/or
Make substantial changes to their contributions in
the Associate Stock Purchase Plan (if applicable).
48

Contact AHM Law and/or your local company’s legal
group with any questions on this Policy.

All payments on behalf of Honda must have adequate
supporting documentation and be properly approved
and made with the intention and understanding that any
part of such payment is only to be used for, and related
to, the described purpose.  
The supplier payment process generally begins with anapproved Purchase Order, which identifies the goods
and/or services being provided. This prevents fraud andensure segregation of duties. Some companies may haveunique circumstances where a Purchase Order is notpractical. Non-Purchase Order transactions must havethe same controls in place that Purchase Orders provide.
Honda submissions to government entities must becomplete, clear, and accurate and never misleading.

Do not hide expenditures or establish any undisclosed or
unrecorded funds, assets or liabilities.

49

Legal Holds

It is imperative that in your written and oral business
communications you always tell the truth and avoid
exaggeration, inappropriate language, and derogatory
remarks or characterizations. Not only is it the rightthing to do, but business records and communications
may also become known to the public through litigation,
government investigations and the media. This applies
to communications of all kinds including oral, email,voicemail, texts, daily planner notes, and other “informal”
notes or memos.

Never alter, conceal or destroy documents or records if they
have been requested by a government agency, if they are likely
to be requested in connection with an investigation or if they
have been placed on a litigation hold by AHM Law, AHM Intellectual Property or your company’s legal group. And, of course,
never lie or mislead any government representative or lie in connection with any legal or administrative proceeding, and nevertry to influence others to lie or mislead.

Remember, only share information with those who havea business need to know and are part of the businessprocesses. Records of all kinds, including electronic
records, should always be retained and maintained
according to the Global Record Retention Policy. Some
records must be retained beyond the time specified in
the Policy if they relate to a pending or potential lawsuit,claim, or government investigation. If you aren’t sure,contact Compliance & Ethics, AHM Law, and/or yourcompany’s legal group for guidance. Never store Honda
documents or files at home.

Q: One of my co-workers asked me to approve an invoice
for services that have not yet been performed. They
told me it’s not a big deal; the company is going toperform the service next week. What do I do?

Consistent with applicable laws, Honda does not extend
personal loans to corporate directors and the executive
officer.  

A: If you approve, this invoice knowing we have notreceived the services (and the contract does not
expressly call for advance or pre-payments), you havemade a false report. Honda has protocols that mustbe followed. Talk to your co-worker or manager about
your concern. If you’re not comfortable doing that,
contact a member of Accounting & Finance, Compliance& Ethics or AHM Law and/or your local company’s
legal group about how to proceed.

Government Requests andInvestigations
Governmental agencies sometimes request informationfrom Honda, and it is always possible that such agencies
will make detailed inquiries into Honda affairs. Always betruthful and appropriately responsive to governmental
requests for information, including requests made during
investigations.
If you receive a non-routine request for Honda informationfrom a government agency or attorney, immediately notify
AHM Law and/or your local company’s legal group before
responding. This helps to ensure that Honda’s response
is appropriate both for the Company and under the law.
If you are in doubt whether the request is routine, always
refer it to AHM Law and/or your local company’s legal
group. (Also see Business and Accounting Practices.)

Litigation and Claims
50

Like all large businesses, Honda is sometimes involved
in disputes that may result in claims or litigation, or
Honda may have documents or information that parties
in a litigation not involving Honda may believe are
relevant to that litigation. If you receive a legal document
related to Honda, you must immediately contact AHM Law
and/or your local company’s legal group to ensure an
appropriate and timely legal response. Examples include
summons, statement of claim, complaint, or any othertype of written communication demanding compensation;a subpoena, or similar request for documents, records, orinformation related to Honda or its associates, customers
or vendors. Do not respond to any request, answer
questions, or produce documents without first discussing
the situation with AHM Law and/or your local company’s
legal group.
Under no circumstances should you ever threaten or
initiate legal action on behalf of Honda, or respond to
any legal document or threat of legal action against
Honda, without the prior advice of AHM Law and/or
your local company’s legal group and approval of senior
management.

Communicating with the Media
Honda values its relationship with the media. Communicating clearly and accurately serves to protect andenhance Honda’s brand and reputation. We follow a
careful review process when determining what andwhen to share with the media. Due to the potential
sensitivity of sharing information with the media, Honda
allows only North American Corporate Communications(“NACC”) and Public Relations to communicate with themedia on the company’s behalf. Associates should not
respond directly to media inquiries. An associate who
receives a media inquiry should immediately forward
it to one of these groups.

Social MediaThe use of social media and online forums have grownsignificantly in recent times. If used appropriately, social
networking tools and online forums may be new channels
for sharing information regarding our products andservices. However, if not done properly, any such use
may expose you and the Company to significant legal
and reputational risks.  
All associates, contingent associates, dealers, suppliersand vendors are responsible for what they post online.
Under the social media policy, racist and discriminatory
remarks and content, harassment, threats of violenceor similar inappropriate or unlawful conduct will not betolerated and may be subject to disciplinary action up to
and including termination.

51

Make sure that comments related to any aspect ofcompany business posted via social media and online
forums are properly distinguished between the official
position of Honda and those made from unofficial or
unrelated sources. Never give the impression that you
are speaking on behalf of Honda in any personalcommunication, including customer forums, blogs, chatrooms, and bulletin boards such as Twitter, Instagram,
LinkedIn, Snapchat, and Facebook. In your postings,
never make negative or misleading comments about
Honda or its customers, disclose Honda’s trade secrets,
confidential, and/or proprietary information (including
pictures or customer information), or violate Honda’s

intellectual property rights. If you see anything posted
on a social media or online forums that you believe may
violate this provision, or have a question about making a
specific post, please contact Human Resources/Associate
Relations, Compliance & Ethics or North American
Corporate Communications.  
Fundamental principles:
1. Be responsible and professional
2. Be transparent, but only speak on behalf of yourself
3. Protect the company’s confidential informationand intellectual property (as defined below)
4. Follow the law and all Honda policies
For the full Social Media Policy please visit HondaWeb

You and the Law

Compliance with All Laws
Honda follows all applicable laws andregulations and expects all associates
to comply with all applicable laws andregulations in carrying out their responsibilities on behalf of the Company. No
excuse or pressure can justify violating
the law nor may a person acting on
behalf of Honda (an agent) be used
to do something prohibited by law or
Honda policy.

La
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w

Having embraced the goal of being a
global company that society wants toexist, we need to be especially aware ofdifferent laws and customs that apply
in the many societies and countries
where we operate. Maintaining ourglobal viewpoint means that we respect
the norms of our business partners,
customers, and co-workers throughout
the world. However, the standards andprinciples in this Policy, unless inconsistent with local law, take priority overthose norms and customs and must be
followed by every associate. If they areinconsistent, seek guidance from AHM
Law and/or your local company’s legal
group.

Antitrust and Competition Laws
Honda supports free and open competition as well ascompliance with the antitrust laws intended to promotecompetition. Antitrust and competition laws prohibit,
among other things, agreeing with competitors to limit
production, fix prices or divide markets, customers or
territories. They also may govern exclusive purchasingor sales agreements with suppliers and customers. This
area of the law is extremely complex and can vary fromstate to state, province to province and country to country
but certain rules generally apply:
Never discuss or share with a competitor any
competitively sensitive information, regardlessof whether it’s ours or theirs, such as pricing;  
Never share competitively sensitive information ofbusiness partners or other third parties with theircompetitors, such as pricing; and  53

Never take advantage of anyone throughmanipulation, abuse of privileged information,
misrepresentation of facts, or any otherintentionally unethical or illegal action.
For more information, see the Honda North American
Region Antitrust and Competition Law Compliance
Policy and Manual on HondaWeb. If you are ever indoubt about whether a transaction may violate antitrust
laws consult AHM Law.

Q: I am a longtime friend of someone who is now asales representative for a competitor. When we seeeach other socially, we talk about the industry andhe sometimes tells me about his company’s pricing
strategies. I don’t feel comfortable about the situation.
What should I do?   
A: Tell your friend it’s inappropriate to discuss pricing
information and delete any pricing information thatfriend gave you.Then report the matter to Complianceand Ethics, AHM Law and/or your company’s local
legal group. To avoid even the appearance ofimpropriety, Honda associates should never engage
in conversations with our competitors about pricing,marketing or any other competitive activity without
first contacting AHM Law.  

Anti-Corruption andAnti-Money Laundering Laws
Honda strives to be a company that society wants to exist.
A critical step in meeting this goal is to consistently comply
with the letter and spirit of anti-corruption and anti-money
laundering laws in every jurisdiction in which we dobusiness. Honda strictly prohibits offering or receiving
bribes, or money laundering, in any business transaction
whether with a private entity or a public official. In addition,
you may not make payments to people acting on behalfof Honda (agents) or any other representative of Honda
if you have reason to believe that these payments may
result in bribes to government officials or others. Just
because a certain practice may be followed in a particular country or region of a country does not makethe practice lawful. If you have any questions regarding
practices in other countries contact the AHM Law and/or your local company’s legal group. No associate will
ever be disciplined for refusing to pay a bribe.
54

Payments to Attain Business or Favorable Action  
1. You are not permitted to pay money or give anythingof value in order to get favorable actions or decisions
from any type of government agency, to obtain/retain
business from/with a private entity, or otherwise
secure any improper business advantage. Thisapplies to any payment or gift, whether it is madedirectly to a government candidate, official, or associate, indirectly through any political party or private

enterprise or made, directly or indirectly, to a businessor associate thereof.
2. The foregoing prohibitions apply equally to the use of
Honda corporate and personal funds or assets. They
also apply to indirect payments made in any form, suchas through consultants, advisors, suppliers, people
acting on behalf of Honda (agents), sales representatives, dealers or other third parties.
3. These prohibitions extend to nominal payments of an
administrative nature made in foreign countries (suchas obtaining customs clearances, visas and work
permits), otherwise known as “facilitation payments,”
unless failure to make the payment would create an
imminent risk to an associate’s (or his/her travellingcompanion(s)) personal health, safety, or physical ormental well-being. To the extent possible, any such
facilitation payment must be pre-approved by thecompany compliance officer; otherwise, please notify
AHM Law and/or your company’s local legal groupor your compliance officer about such payment assoon as possible.
For more information, see the Honda-North American
Region Anti-Corruption and Anti-Money Laundering
Policy on HondaWeb or check with AHM Law and/or
your company’s local legal group.

Customs and International Trade

Valuation declaration and perfection

When importing or exporting products, information or
technology, Honda will comply with applicable nationallaws, regulations and restrictions. This includes compliance with all applicable tax, tariff, and trade laws andregulations. All information you, or people acting on
behalf of Honda (agents), provide to government officials
or agencies must be accurate and truthful.

All declarations to Customs authorities must accuratelyreflect the value of the goods.

Honda has developed a multitude of policies in our tradewith other countries, including, but not limited to:Supply Chain security programs

55

Honda actively participates in CTPAT, PIP, AEO andother supply chain security programs, and strongly
encourages our business partners to join these
programs or to meet the minimum security criteria
which they obligate. These programs combat boththreats of terrorism and contraband, protecting bothnational security and intellectual property rights.
Preparation of shipping papers
All documents must denote a sufficiently specificdescription so to insure correct Harmonized Tariff
Schedule classification, quantities, weight, and anyother information which may be required for legal
import or export.

Country of origin marking  All products must follow the various marking andlabeling requirements as determined by local Customs
authorities.
Hand-carry across international borders
All Honda products, equipment and tools must be
declared to Customs authorities when crossing every
international border.
Technology transfers
Exports of products and technology, even thosecommon in the country of export, may be licensed or
restricted from export to other countries or shared with
non-residents; even other Honda associates who are
non-residents and Honda companies in other countries.
Anti-boycott efforts
Participation in any foreign boycotts of other countries
is illegal. Immediately report any suspicion of improper
request to AHM Law and/or your company’s local
legal group. Even if you don’t participate in the request,
failure to report a boycott request may result in denialof export privileges or penalties.

Certificates of Origin and Free Trade Agreements
The use of preferential duty programs such as, but
not limited to the USMCA/CUSMA/TMEC provide
significant duty saving to Honda but require detailed
calculations and records. Failure to follow thecomplicated rules of these agreements when making
FTA claims to Customs authorities can result incatastrophic penalties to Honda and our customers
around the world.  

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Q: My work at Honda requires regular interaction or
declarations to Customs officials. I am routinely asked
to provide the customs officials with information about
Honda imports and exports. Do I really need tocontact AHM Trade Compliance/local trade compliancegroup or AHM Law/local legal group prior to each andevery submission of information to the government?  
A: The right approach would be to discuss the types ofrequests your department routinely receives from
Customs with AHM Trade Compliance and/or yourcompany’s local trade compliance group, AHM
Law and/or your company’s local legal group to
work out in advance a standard protocol that would
be efficient, but also safe with respect to the laws thatneed to be followed.  
Any other non-routine inquiries from Customs
officials should be immediately forwarded to AHM
Trade Compliance and/or your company’s local tradecompliance group.

Your Resources –How to Get Help57

Our Compliance & Ethics
Program
The Compliance & Ethics program wasestablished, in part, to provide associates,
suppliers, and dealers with an alternate
route to voice questions or concernswith regard to ethical or legal issues inour business. The goal of this programis to assure an environment in which
everyone feels comfortable seeking
advice on business ethics, or to help
address potential legal or ethicalviolations, anonymously or otherwise,
and to assist in consistently applying
the Honda Philosophy to their actions
and decisions.

To achieve this goal, the program consists of several
parts:The North American Compliance & Ethics Policy:
This Policy sets forth acceptable and expectedbusiness practices and conduct.
Training and communication: Associates are
required to take Compliance & Ethics training
periodically.
Compliance Officers: High-level associates are
assigned by the governing authority (Board of
Directors or managing members) to oversee theprogram. The Compliance Officer may designate aCompliance & Ethics Secretariat to support dayto-day activities.

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The toll-free Compliance & Ethics Line: This number
may be used at any time, 24 hours a day, 7 days aweek to report any possible violations of this Policy,
anonymously if preferred. Compliance & Ethics
associates do not use “caller ID” or make efforts
to identify the number from which you are calling.
Messages to the Compliance & Ethics Line will betranscribed and investigated as appropriate.
(See North American Compliance & Ethics Contact
Information.)

The Compliance & Ethics Line is available to
Honda associates. It is also available to business
partners and other people acting on Honda’s
behalf (agents) with a concern about ourbusiness practices.
Compliance & Ethics (C&E) associates: C&E
associates are available if you have a question
or want to ask a proactive question or reportany ethical concern or potential or actual legal
violation. You may remain anonymous.
Confidentiality for those who report concerns or who
have an ethics question will be maintained to the fullest
extent possible. All reports will be taken seriously.

Q: Why are we expected to cooperate with Compliance& Ethics investigations? I would rather not get involved.  
A: Your assistance is critical. When the Company conducts
an investigation, it is reviewing the possibility of aviolation of this Policy, other Honda policies or relevant
legal requirements. The investigation is necessary toprotect individuals, the Company, and, in some cases,
the public. If associates do not cooperate, it may be
impossible to get all the facts and take the right action.  

Questions or Concerns
Honda believes that every individual can make adifference. According to the Honda Philosophy, you are
expected to go to the spot, address problems personally,
face reality, and report information directly to theappropriate Honda channel. This philosophy applies toethical and legal issues just like all other issues. If you’reever concerned with the ethical or legal consequencesof an action, address it professionally by using your own
good judgment, this Policy, other Honda policies and theadvice of appropriate Honda leadership.
If the right course of action is unclear, or if you haveobserved an unethical or illegal act, you are obligatedto talk to your manager, other appropriate management,or Compliance & Ethics.

59

Q: I just learned that a good friend of mine has beenaccused of harassment and that an investigation is
being launched. I can’t believe it’s true and I think it’s
only fair that I give my friend advanced warning or a‘heads up’ so he can defend himself. Don’t I have a
responsibility as a friend to tell him?
A: In some circumstances, you may be instructed not
to give your friend a ‘heads up.’ Your friend will begiven the opportunity to respond to these allegations
and every effort will be made to conduct a fair andimpartial investigation. An allegation of harassment

is a very serious matter with implications not only forthe individuals involved but also for the Company.
Alerting your friend could affect the fact-gathering
process, jeopardize the investigation, and expose theCompany to additional risk.  
Q: My business unit sets various goals that we are asked
to achieve. Sometimes I feel pressured to violate thepolicies to achieve these goals. Is this acceptable?
A: No. While successful businesses set high goals andassociates strive to achieve them, you should neverviolate Honda’s policies to achieve any goal. If you
ever feel pressured, you can explain to your manager
how you feel. If you are not satisfied with the outcome,or are still uncomfortable with the situation, you canreport it to Human Resources/Associate Relations,
Compliance & Ethics or use the Compliance & Ethics
Line (see North American Compliance & Ethics
Contact Information).

Difficult Decision?
This decision-making tool can be useful when you are faced with a difficult decision. If after asking
yourself the following questions you are still unsure, talk to your manager, Human Resources/Associate
Relations (HR/AR), Compliance & Ethics (C&E) or the AHM Law/your legal department.
Check thepolicy or contact
your manager,
HR/AR or C&E
for advice.

Contact
your manager,
HR/AR or C&E
for advice.

Unsure?

Unsure?

Unsure?

Contact
your manager,
HR/AR or C&E
for advice.

Unsure?

Contact theAmerican Honda
Law Division/
your legal groupfor advice.

Is it legal?

Does itcomply with Honda’s
policies?

Is it consistent
with Honda’s values
and culture?

Would I 
be comfortable
if my action or inaction
were a news
headline?

Yes

Yes

No

No

No

STOP

STOP

STOP

There may
be a serious
consequence.

There may
be a serious
consequence.

There may
be a serious
consequence.

Yes

STOP
No

There may
be a serious
consequence.

Yes

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Other questions to consider
before making a final decision:
What impact would my actions or inactions have?
What would my friends and family think?
Is this the way I would want to be treated?

Reporting Concerns –Without Retaliation
If you have a concern, or see a possible violation, theHonda Philosophy calls on you to take the initiative anduse your good judgment. This may mean, as a first step,
talking to your manager. If you are uncomfortable
reporting your concern to your manager, report it tosenior leadership, Human Resources/Associate Relations,
Compliance & Ethics or use the Compliance & Ethics
Line (see North American Compliance & Ethics Contact
Information). Calls to this line may be made anonymously.
In order to completely investigate your concern,
Compliance & Ethics must have as much informationas possible.
When reporting misconduct, information should be
provided that is specific and detailed enough to allow
the allegations to be completely investigated. It is
helpful to provide any pertinent documents and disclose
sources of information.
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If you have already reported your concern throughinternal resources such as Human Resources/Associate
Relations and/or Compliance & Ethics, or you believe
the concern should be reported at the regional level,
you may contact the North American Region Corporate
Compliance & Ethics Office (NAR CCEO).

Retaliation or adverse action against an associate forcooperating in a formal audit, investigation, or reportinga suspected violation of Honda policy, is a violation of theNorth American Region C&E Policy and other policies
and will not be tolerated. Keep in mind that making areport that you know is false is also a violation of thisPolicy.
In addition to internal avenues available for reporting,associates also have the right to freely report any
concerns externally to the appropriate authorities.
Nothing in this policy, nor any other Honda policy
prohibits, or is intended to prohibit, associates from
reporting possible violations of law or regulation to
any governmental agency or entity, or making otherdisclosures that are protected under such laws or
regulations. One does not need the permission ofanyone at Honda, including anyone in AHM Law or
your local company’s legal group, to make any suchreports or disclosures. Although associates are expectedto participate actively in the Compliance & Ethics
program and report possible legal violations internally as
described by this policy, there is no obligation to notify
anyone at Honda that the associate has reported any
such possible violations to a governmental agency orentity. Associates who choose to report externally arealso protected from retaliation and/or adverse action on
this basis as described and set forth by this Policy.  

Q: How can the company protect me from retaliation?
A: Honda will take all steps necessary to protect
our associates who bring forward concerns from
retaliation. Additionally, we will thoroughly investigate
all allegations of retaliation and, if substantiated,corrective action, up to and including termination of
employment, may result for those who have retaliatedagainst an associate.

What to Expect When Contacting
Compliance & Ethics
When contacting Compliance & Ethics with a question
or concern this is what you can expect:Your report, concern or question will be taken
seriously and will be handled promptly, discreetly
and professionally.  
All reports will be given the same consideration
whether they are submitted anonymously or not.  
Any report or concern raised will be investigatedor, if appropriate, referred to Human Resources/
Associate Relations or other internal resourcechannels for response or follow-up.  

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We will maintain the confidentiality of your reportto the fullest extent possible. However, information
will be disclosed as necessary to investigate andaddress the situation appropriately.
Substantiated concerns will be resolved throughprompt and appropriate action.  

North American Compliance & Ethics
Contact Information
United States
All US Honda Companies. . . . . . . . . . . . . . . . 855-462-2236

Member of Management
Human Resources/Associate Relations

Honda Aircraft Company, LLC (HACI). . . . . . 888-217-6122

AHM Law

CanadaYour Local Company’s Legal Group

Honda Canada Finance Inc. (HCFI). . . . . . . 866-508-3288
Honda Canada Inc. (CH). . . . . . . . . . . . . . . . . 866-508-3288
Honda Canada Trading Inc. (HTC). . . . . . . . 866-508-3288
Honda of Canada Mfg., Inc. (HCM). . . . . . . . 877-434-5195
MéxicoHonda de México, S.A. de C.V. (HDM). . .  01800-4364685
Honda Trading de México,
S.A. de C.V. (HTMX). . . . . . . . . . . . . . . . . . . .  01800-4364685
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Other Resources

Global Compliance & Ethics
Contact Information
North American Region Compliance & Ethics Line:
US/Canada . . . . . . . . . . . . . . . . . . . . . . . . . . .  1-855-462-2236
México . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 01855-4622236
Honda Motor, LTD. (HM) Compliance & Ethics Email:proposal@hm.honda.co.jp

Associate Handbook
Company and Department Policies/Procedures

Honda’s Expectations of You
If the right course of action is unclear, or if you have observed an
unethical or illegal act, you are obligated to talk to your supervisor,
other appropriate management or Compliance & Ethics.
If in doubt – ask before acting. Your concern will be handled
promptly, discreetly and professionally.

Policy &Education
Honda
Philosophy

Integrity
You and
Honda

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Transparency

Communication

Accountability

Compliance& Ethics
This publication replaces the previously
released Honda North American Region
Compliance & Ethics Policy© 2021 American Honda Motor Co.

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