

8
MAGNA INTERNATIONAL | CODE OF CONDUCT AND ETHICS
Compliance with Anti-Bribery Laws
We do not offer or accept
bribesor
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 Paymentsprohibit 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.