If there is an integrity concern that should be brought to the attention of management,
employees are urged to take it directly to a responsible person at their location. All managers are expected to respond to integrity concerns seriously, to address them promptly, and to avoid retaliation against the employee voicing the concern. Federal-Mogul believes that immediate reporting of integrity concerns to responsible management is the most efficient path to a successful resolution.

There may be times when reporting an integrity concern to local management is not appropriate. When the complaint involves local management, it may be reported to group or department management. If the complaint involves group or department management, it may be reported anonymously to management at Headquarters or through the Federal-Mogul Helpline.

This policy is designed to provide specific guidance on the handling, review and reporting of such complaints, including the description of certain complaints that will be sent to the Audit Committee of the Board of Directors.

II. Federal-Mogul Helpline Administration

“The Network” is an independent third-party service provider that operates Federal-Mogul’s Helpline. For each call or written communication received, an “Alertline Confidential Memorandum” is completed. To allow tracking, a report number is assigned and each Memorandum is forwarded by e-mail to the following people at Federal-Mogul:

• Senior Vice President — Human Resources
• Corporate Compliance Officer
• Associate General Counsel (with functional responsibility for HR matters)
• Director, Global Security
• Director, Audit Services

Coordination of reported issues is the responsibility of the legal and human resources departments, acting on behalf of the Compliance Review Board, and involves:

• Logging of all reports upon receipt;
• Assigning lead investigative responsibility, depending upon the nature of the issue;
• Requiring that a preliminary response (status report) be returned within 14 calendar days. The Network provides this updated information to the original caller if the caller places a follow-up call requesting the status of the reported issue; and
• Conducting periodic follow-up with the department assigned responsibility for investigating the issue until the case is closed.

III. Management Response and Follow-up

The Compliance Review Board (CRB) is chaired by the Corporate Compliance Officer, and is comprised of the following senior officers of the Company: Chief Executive Officer and President, Executive Vice President and Chief Financial Officer, Senior Vice President — Human Resources, Internal Audit and Corporate HR. The CRB is responsible for the review and monitoring of the Company’s Integrity Policy and ensures that management responds in a timely and appropriate manner to all issues raised through the Helpline.

IV. Ranking of Complaints and Investigation

The Corporate Compliance Officer and Director, Audit Services, will note any reported issues of an accounting, internal control or audit nature (i.e., potentially resulting in a financial loss or inaccurate financial reporting) and request that the individual who is assigned follow-up responsibility quantify the potential loss or financial statement impact within three calendar days and recommend a course of action.

Regular Priority (Under $100,000)

Internal investigation with outside resources retained as needed. In the event the likely financial impact is determined to be greater than $100,000, the investigation becomes High Priority and the procedures specified below will be followed. Regular priority items will be reported regularly to the Audit Committee by the Corporate Compliance Officer.

High Priority (Between $100,000 and $1,000,000)

Reported promptly by the Corporate Compliance Officer and Director, Internal Audit to the Chairman of the Audit Committee, senior management (not involved in the complaint) and external audit lead partner. The Internal Audit and Legal departments will conduct the investigation. The Audit Committee can participate in the investigation and dictate the use of outside resources, as appropriate. Investigative activity in progress will be reviewed with the Chairman of the Audit Committee and concurrence sought with the recommended course of action.

Maximum Priority (Greater Than $1,000,000)

Reported immediately by the Corporate Compliance Officer and Director, Internal Audit to the Chairman of the Audit Committee, senior management (not involved in the complaint) and external audit lead partner. The Audit Committee will determine the scope of the investigation, using internal and external resources as appropriate. This category also includes any integrity concerns relating to executive officers or directors of the Company, and SEC or other regulatory investigations.

V. Outside Resources

The Audit Committee may consider employing the following resources in its investigation of any integrity issues:

Legal: Thomas Cole, Esq.
Sidley Austin Brown & Wood
Bank One Plaza
10 South Dearborn Street
Chicago, IL 60603
Phone: 312-853-7473
E-mail: tcole@sidley.com

Accountants: Jonny Frank
Partner, Fraud Risks & Controls
PricewaterhouseCoopers LLP
1177 Avenue of the Americas
New York, NY 10036
Phone: 646-471-8590
Fax: 813-329-4922
E-mail: jonny.frank@us.pwc.com