Multimatic Code of Conduct

    Adherence to Applicable Laws

    Multimatic is committed to complying with all laws in the jurisdictions in which the Company operates and requires its employees, consultants, contractors, agents and other representatives, as well as suppliers, to comply with applicable laws and this Code of Conduct. Multimatic also believes in conducting business with integrity, honesty and fairness and requires its employees to respect and be sensitive to the cultures, customs and environment of the countries where the Company conducts business. Multimatic expects its employees to perform their duties honestly, credibly, without conflict or compromise, and in a manner which seeks to ensure the Company’s best interests ahead of their own interests. The Company provides a safe and healthy working environment that meets or exceeds applicable standards for safety and occupational health, and expects that others in Multimatic’s supply chains will do the same. Multimatic will comply with all applicable environmental laws, regulations and standards, including respecting valid land and water rights, avoiding forced evictions and reducing deforestation.

    Zero-tolerance of bribery and corruption

    Multimatic maintains a zero-tolerance for bribery and corruption, and will uphold all laws relating to fraud, bribery, embezzlement, unfair competition (including antitrust), money laundering or other forms of corruption in all jurisdictions in which the Company operates (including, without limitation, the U.S. Foreign Corrupt Practices Act of 1977, the Canadian Corruption of Foreign Public Officials Act and the U.K. Bribery Act 2010). Multimatic’s employees shall not engage in unfair or illegal trade practices, or other corrupt or anti-competitive behaviour. More specifically, they shall not, directly or indirectly, offer bribes, kickbacks or other similar payments, or promise other improper benefits, for the purpose of illegally influencing any customer, supplier, public official or any other person. Similarly, Multimatic’s employees are prohibited from, directly or indirectly, accepting bribes, kickbacks or other improper benefits which could influence, or appear to influence, the proper performance of their duties.

    Activities which are permissible under applicable law are not prohibited under this Code of Conduct. For example, reasonable business entertainment and hospitality, or gifts of nominal value or those which are appropriate in the circumstances, will not be considered a breach of our commitment to fair dealing, so long as such entertainment or gifts are consistent with business practice, not intended as an inducement, not contrary to applicable law or customer policies, and will not embarrass Multimatic or its employees if disclosed publicly. The foregoing applies equally to Multimatic’s contractors, agents and other representatives, with the same types of consequences in the case of breach.

    Anti-harassment and discrimination

    Multimatic will not permit or tolerate harassment or discrimination against its employees in any form. Additionally, the Company prohibits the use of forced, compulsory or child labor at any of its facilities (or at the facilities of its suppliers or other business partners), and will comply with applicable human rights legislation in the places where the Company carries on business (including, without limitation, the Canadian Modern Slavery Act, the U.K. Modern Slavery Act 2015 and the German Supply Chain Due Diligence Act (LkSG)). Multimatic is also committed to protecting personal information relating to its employees and other stakeholders in accordance with applicable statutes and regulations in jurisdictions in which the Company operates, and to conducting its business in an environmentally responsible manner, including minimizing the impact of its operations on the environment.

    Ethics reporting and escalation process

    Multimatic believes that good communications among its employees at all levels of the Company promotes better business practices. To that end, the Company has an ethics reporting and escalation process (whistleblower policy) and encourages all employees to raise genuine concerns in good faith without fear of reprisal. If an employee has a concern relating to one of the areas listed below, that concern can and should be reported to the Company. The purpose of this procedure is to enable the Company to investigate and deal properly and sensitively with actual or potential compliance concerns. This procedure is not intended to replace, for those employees covered by it, the disciplinary and grievance policy and procedure which continues to be the appropriate way to address personal job or employment issues.

    If an employee genuinely believes that the Company, any employee of the Company or any other person with whom the Company transacts business (for example, a customer or supplier) has taken, is intending to take or has failed to take action that reasonably may lead to:

    • a criminal or civil offence due to fraud, bribery, embezzlement, unfair competition or other forms of corruption;
    • a failure to comply with any legal obligations, including the unauthorized use or disclosure of confidential/proprietary information;
    • an act or result that is clearly mistaken, unfair or improper;
    • a misappropriation or abuse of Company property/assets;
    • a danger to the health and safety of any individual (including violations of human rights);
    • damage or risk to the environment;
    • other illegal, unethical or improper activities; or
    • the deliberate concealment of information tending to show any of above,

    the employee can disclose this concern (orally or in writing) to a Human Resources representative, a member of the Company’s management (for example, an Assistant General Manager or General Manager), a Group Human Resources Director, a Group Executive Vice President, the Corporate Vice President of Human Resources or any Corporate Legal Counsel, including the Vice President & General Counsel. Typically, the concern should be disclosed to the employee’s immediate supervisor or Human Resources representative. However, there may be occasions where the use of such channels of communication may not be appropriate. In these situations, the concern should be escalated or raised with an individual holding any of positions listed above, without the need to follow any particular order or priority.

    If a concern is disclosed, the employee should provide full details and, where possible, supporting facts and evidence. It is important that these types of issues are dealt with sensitively and quickly. Anonymous disclosures will be accepted but an investigation may be hindered if the supporting facts and evidence are not provided. If information is disclosed in accordance with this procedure, the employee’s identity will be kept confidential (unless required by law or if the employee provides consent to the contrary).

    All genuine complaints will be promptly investigated and the Company will take whatever action it considers appropriate. The assistance of the employee lodging the complaint may be required during the investigation. Where appropriate, the outcome of the investigation will be communicated to the individuals involved in the investigation as soon as practicable.

    If an employee reasonably believes that a concern relating to any of the areas listed above exists, and discloses that information to the appropriate person under this procedure in good faith, no action will be taken against the employee for making the disclosure, even if the investigation finds that the employee was mistaken. The Company will take appropriate action against any person who victimizes another person for using this procedure, deters any person from reporting genuine concerns using this procedure or makes any disclosure or allegation under this procedure maliciously.

    Application of Code of Conduct

    This Code of Conduct applies to Multimatic Inc. and its subsidiaries and automotive affiliates; it is endorsed by the Company’s senior management and will be reviewed at least once per year. In the event of a conflict between this Code of Conduct and an employee handbook, this Code shall govern.

    Failure by our employees to comply with this Code will lead to disciplinary action which is proportionate to the breach, up to and including immediate dismissal in appropriate circumstances. Our consultants, contractors, agents and other representatives, as well as our suppliers, are required to meet the same standards as our employees and will be subject to consequences in the event of a breach. They may also access the Company’s whistleblower process for ethics reporting.

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