Magna Code of Conduct and Ethics

To report suspected violations of Magna’s Code of Conduct and Ethics,

Q: At Auto Shanghai, I ran into a former sales colleague

who now works for a competitor. Over lunch, he

asked if we could come up with a joint strategy to

deal with a difficult new buyer. I told him I would get

back to him. What should I have done?

A: While having a casual lunch with a former colleague

need not be a problem, any attempt to coordinate

strategy with a competitor is strictly prohibited.

In such a situation, you should immediately end

the conversation about strategy coordination and

tell your lunch companion that you do not wish to

discuss the topic. You should then promptly inform

your manager or a Legal Compliance expert.

Compliance with Antitrust and

Competition Laws

We compete vigorously, but with respect for free and fair competition. As a result, Magna employees are

committed to complying with all applicable antitrust and competition laws. We will not engage in any

activities that violate these laws such as agreeing with our competitors to fix prices, discounts or terms of

sale, limit production, divide markets, coordinate bidding activities or boycott customers or suppliers.

Our

provides a more complete explanation on how we uphold this

commitment.

Conducting Business with Integrity,

Fairness and Respect

Our operating philosophy is that all of us, employees and management alike, share in the responsibility to

ensure Magna’s success.

To live up to this responsibility, we must all act with integrity. This means that we must obey the letter and

spirit of laws that apply to us, uphold this Code, and honour our commitments.

We must also be fair in our dealings with other employees, customers, suppliers or other stakeholders.

It is also essential that we respect others who may have different thoughts and opinions, act with

sensitivity and concern toward the cultures and customs of countries in which we operate, and strive to

consider our impact on the communities and environments where we conduct business.