Ethics Statement

Gifts, Entertainment and Gratuities

Both as a matter of sound procurement practice and basic business integrity, we at Federal-Mogul must make our purchase decisions solely on the basis of which suppliers offer the best value for the goods and services we need. We avoid doing anything that suggests that our purchase decision may be influenced by any irrelevant or improper consideration, whether illegal, such as a kickback or bribe, or technically legal, such as personal friendship, favors, gifts or free entertainment. Business with suppliers and customers should always be conducted in an atmosphere of mutual respect and in keeping with irreproachable standards of business and professional ethics. The giving and/or receipt of gifts (including the use of property) may raise questions of propriety concerning the relationship between the giver and receiver of the gift. Accordingly, and accepting only noncash gifts of insignificant value (under $25 USD), no employee or member of the employee’s family may accept a gift from any supplier of goods or services to Federal-Mogul or from any customer of Federal-Mogul, without prior disclosure to the Plant Manager or appropriate management. Notwithstanding the disclosure requirement, no employee or family members may receive a cash equivalent from any supplier or customer. Employees should in no way benefit financially due to transactions between Federal-Mogul and any third party with or without prior approval from the Plant Manager or appropriate management.

Entertainment provided or funded by Federal-Mogul suppliers or customers for Federal-Mogul employees or members of their families must be reasonably related to the business at hand and must not be so lavish as to give rise to even the impression that special influence is being sought. All offers of unreasonable lavish entertainment and all questions relating to the propriety of entertainment should be directed to the Plant Manager or appropriate management.

Inevitably, there will be gray areas that our employees will address using their common sense and good judgment. This policy is based upon the National Association of Purchasing Management (NAPM) “Principles & Standards of Purchasing Practice” guidelines.

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