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8

MAGNA INTERNATIONAL | CODE OF CONDUCT AND ETHICS

Compliance with Anti-Bribery Laws

We do not offer or accept

bribes

or

kickbacks

, either directly or through

third parties

. In giving or accepting

things of value ,

we must think about whether doing so could influence a business decision or give others that

impression. We must also always ensure that the records of all payments we make are accurate and complete.

These obligations apply in all cases, but are especially strict in matters involving

government officials .

Our commitment to anti-bribery applies, without exception, to all of our operations, no matter what the local laws

or cultural practices may be. We also expect any third parties acting on our behalf to uphold this principle.

To find out more about our commitment to conducting business free of bribery, see our

Policy on Bribery & Improper Payments.

Q: In my country, it is common to give government workers a small payment (typically under $100) so that

work gets done more quickly. Am I allowed to make these payments under our Code and Policies?

A: No. Our Code and

Policy on Bribery & Improper Payments

prohibit the making of these payments.

The type of payment you describe is often referred to as a “facilitation payment” or “grease payment”.

Although these payments are legal and common in some countries, they are illegal in many others.

Q: A government official who oversees our safety compliance gave me her nephew’s résumé and asked that I

consider him for any positions that might be open in my department. I’ve reviewed the resume and he has

strong credentials. What should I do?

A: You should immediately let your manager or a Legal Compliance expert know about this request. As

a qualified applicant, he should be treated the same as other qualified applicants for the position.

Requests like this need to be handled with care to ensure that we respect the law and our values while

preserving our relationships.