Corporate Conduct Standards

8/10/2019 Corporate Conduct Standards

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Code of Conduct Handbook CORPORATE POLICIES AND DIRECTIVES


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For questions or comments regarding this Handbook,or for requests to update this Handbook,

go to the Ford Legal Access Web site:

and send a message toAsk a Lawyer.

OGC Corporate Compliance Office November 2


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Introduction

The Companys Commitmentto Doing Business with Integrity ................................4-5

Overview .................................................... 6

How to Use This Handbook ...............................................7

Responsibility ........................................................................7

Duty to Report Violations ..............................................7-8

Workplace Environment ........................... 9

The Code of Basic Working Conditions .....................10 Equal Opportunity and Diversity .................................11

Anti-Harassment ................................................................12

Health and Safety ..............................................................13

Substance Abuse ...............................................................14

Gifts, Favors, and Conictsof Interest ................................................. 15

Receiving Gifts or Favors ..........................................16-17

Entertainment and Social Events ..........................18-19

Preferential Treatment, and Workingor Consulting Outside the Company .........................20

Financial Interests .......................................................21-22

Insider Trading ....................................................................23

Giving Gifts or Favors to Outside BusinessContacts or Company Personnel .................................24

Use of Company Assetsand Data Safeguarding ........................... 25

Use of Company Assets ...................................................26

Careful Communications ..........................................27-28

Protecting Company Information .........................29-30

Personal Data Privacy ......................................................31

Annual File Review and RecordsManagement ................................................................32-33

Integrity of Financial andOther Company Records ......................... 35

Product Quality, Safety,and Environmental Matters .................... 36

Product Quality and Safety ......................................37-38

Environmental Matters ....................................................39

Intellectual Property ............................... 40

Inventions, Patents, Copyrights,and Trade Secrets ........................................................41-42

Trademarks .......................................................................43

Acquiring Information fromOutside the Company ...............................................44-45

Working with Governments;Restrictions on Political Activities .......... 46

Anti-Bribery ...................................................................47-48

Sale of Products to, and OtherContracts with, a Government .....................................49

Political Activities and Campaigningon Company Property ....................................................50

Government and Other Legal Inquiries ....................51

Competition and Antitrust Laws ............ 52

Relations with Competitors ...........................................53

Relations with Suppliers, Dealers,and Other Customers ................................................54-55

International Business Practices ............ 56

International Trade Importing ..................................57

Export Controls and

Prohibited Transactions ............................................58-59 Money Laundering ..........................................................60

Table of Contents


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4


Henry Ford once said, There is a most intimateconnection between decency and good business.He believed that the main purpose of a corporationshould be to serve customers, employees, andcommunities. By staying true to those values,he was able to build the greatest businessenterprise of the 20th century.

Today, the values of a company are even more

critical to its success. As we move into the 21stcentury, expectations are higher and processes aremore transparent. Now, more than ever, companiesmust not just proclaim the highest standards, theymust live them every day.

The Code of Conduct Handbook will help Ford MotorCompany personnel around the world understandand follow our policies and procedures. It builds

on our heritage of corporate citizenship, and itupdates our business practices, so that we cancompete ethically and fairly in all circumstances.

I urge all personnel to learn and follow these standards. By doing so, you will help us earnthe trust and respect that are essential for building a great Ford Motor Company for thenext 100 years and beyond.

Bill FordExecutive Chairman

A Message from Bill Ford


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Introduction


A Message from Alan Mulally

Today, companies must compete vigorously andethically in a dynamic and demanding globalmarketplace. This requires not only compliance withnumerous laws and regulations, but also recognitionof the expectations and aspirations of a variety ofstakeholders. Doing the right thing has becomemore complicated, but it is more important than ever.

The Code of Conduct Handbook is designed to give

personnel the information they need to guide theiractions in this challenging environment. It has beenupdated to be more global in scope and easier toread and understand. In addition, it will be availableonline in a variety of languages.

It is critical that Ford Motor Company personnelaround the world adhere to the highest ethicalstandards so that we can earn the trust of our

customers and grow our business. Being ignorantof a policy or having good intentions are notacceptable excuses.

By reading this Handbook and following its guidelines you will help us enhance ourreputation as an outstanding corporate citizen. This is not only the right thing to do it is the best thing to do to secure the future success of our Company.

Alan MulallyPresident and Chief Executive Officer


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Overview


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Overview

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Overview

How to Use This Handbook

This Handbook is a brief guide to the conduct expectedof you while you are working at Ford Motor Company

(the Company) (including its subsidiaries and affiliates)or providing services to the Company. It is a summaryof some of the basic Company Policies and legalrequirements that affect our business. It will help yourecognize when a potential ethical or legal issue exists,and it will tell you where to look for more information.

For details regarding the matters covered in thisHandbook , please review the Company Policy Letters andDirectives cited throughout these pages. If necessary,you should consult with the appropriate Companyattorney who is responsible for any matter that concernsyou. Or, you may consult the other experts referred to inthe various sections.

The guidance in this Handbook applies broadly to regular,part-time, supplemental, and temporary employees, aswell as to agency personnel and independent contractorswhile they are performing services for the Company.A few sections apply only to Company employees. In thoseinstances, the term employees is used.

This Handbook summarizes the major Corporate Policies

and Directives of the Company that apply generally toour global operations. However, governing law, laborcontracts, and the application of specic Policies canvary around the world. Refer to the separate appendicesto obtain information that is specic for your country orregion. You should be sure to read both this Handbook and the appendix that applies to you. If local law or laborcontracts conict with a Company Policy, then the local lawand labor contracts take priority over the Company Policy.Otherwise, local policies and practices must conform tothe Companys global Policies. If you are unsure of thepolicy to follow, please consult your management, yourHuman Resources representative, the Office of the GeneralCounsel (which can be done through the Ford Legal AccessWeb site on the Ford Intranet), or your local legal office.Again, please remember that this Handbook is only a quickreference tool. You should review the Policy Letters andDirectives for details and specic language.

Responsibility

Ford Motor Company is committed to conductingbusiness fairly and honestly. This commitment

to integrity requires each of us to act ethically.Each of us is expected to act, at all times and in allcircumstances, with the highest sense of integrityon behalf of the Company. We are expected toact in a manner that protects and enhances theCompanys corporate reputation.

All personnel must know and comply with thespirit and the letter of all Company Policies andlegal requirements related to their work. If yousupervise any personnel, you are expected to takereasonable steps to ensure that they, too, knowand follow Company policies and any applicablelegal requirements.

Remember, anyone who violates the law or aCompany Policy may be subject to disciplinaryaction, up to and including termination or release.Violations of the law can expose the Company,and even the individual violator, to nes, penalties,civil damages, and, in some cases, imprisonment.Additionally, violations could damage theCompanys reputation and result in lost salesand prots.

Duty to Report Violations*

All personnel must report all known or suspectedviolations of Company Policy or business-relatedlegal requirements, including:

Civil and criminal laws, and government rulesand regulations

ThisCode of Conduct Handbook

Company Policy Letters and Directives, includingthose described in this Handbook

CONTINUED ON PAGE 8


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Overview

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CONTINUED FROM PAGE 7

If you become aware of a known or suspected violation ofCompany Policy or business-related legal requirements,you should report it promptly to one of the following:

Your Human Resources or Personnel Relationsrepresentative

The General Auditors Office

The Office of the General Counsel or your locallegal office

Your Regional Investigation Coordinator or LocalIncident Coordinator (see description below).Coordinators are listed at the Corporate Security and

Fire Web site. The hotline in your country or region. Some countries,

such as France and Italy, do not have hotlines.

The toll-free Corporate hotline** based in the UnitedStates, listed at the Corporate Security and Fire Web site

The Corporate Security and Fire Web site (based in theUnited States)

Recipient organizations authorized to receive suchreports through other procedures, for example, Volvos

Incident Reporting Tool (IRT) system on the Volvo CarsSecurity Web site

If you are in an organization outside of the UnitedStates and receive a report of a suspected violation, youshould immediately forward the report to your RegionalInvestigation Coordinator or Local Incident Coordinatorlisted at the Corporate Security and Fire Web site. If you arein a U.S. organization and receive a report of a suspectedviolation, you should immediately forward the report toCorporate Security and Fire (see Finance Manual Section89-10-20 for details on receiving and forwarding reports).

When you report suspected violations, it is most helpfulif you provide your name so you can be reached forfurther details and follow-up information. All reports arehandled as condentially as possible, while still enablingthe Company to conduct a thorough investigation.However, you may make an anonymous report by calling

a hotline, or by submitting an incident report formobtained from the Corporate Security and Fire Web site.

Company Policy prohibits any form of retaliation

against individuals who, in good faith, report suspectedviolations of the law or Company Policy, or whocooperate in an investigation of a suspected violationreported by someone else.

*NOTE: In a few countries, reporting requirementsvary due to differences in law. For example, in France,individuals may report violations, but are not requiredto do so. Consult your local appendix or your local legaloffice if you have questions.

**NOTE: Callers in some countries must rst diala country-specic AT&T Direct Access Code (whichmay be found at the AT&T World Traveler Web site http://www.usa.att.com/traveler/index.jsp) beforedialing the U.S.-based hotline.

References

Corporate Security and Fire Web site (based in theUnited States)

Ford Legal Access Web site (based in the United States

Finance Manual 89-10-20, Incidents and Unusual EvenReporting

Finance Manual

General Auditors Office

Volvo Cars Security Web site

Overview


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Workplace Environment


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Workplace Environment 1


The Code of Basic Working Conditions

Policy Overview

The diverse group of men and womenwho work for the Company are its most

important resource. The Company hascreated guidelines for maintaining a workenvironment that is safe for all. Policy LetterNo. 24, Code of Basic Working Conditionsand Corporate Responsibility , speciesthe Companys labor and environmentalstandards throughout the Companys globaloperations. It also incorporates fundamentalelements of internationally recognized laborstandards. Policy Letter No. 24 affirms theCompanys commitment to certain universal

values that are the cornerstone of ourrelationship with you. These values reectwhat we stand for as a company and include:

A workplace that does not tolerateharassment or discrimination

A work environment that meets or exceedsapplicable standards for occupationalsafety and health

Providing competitive compensation and

work hours, in compliance with applicablelaws

Recognizing and respecting the right ofemployees to associate freely and bargaincollectively

Ensuring that child labor and forced laborare not used

When forming commercial relationshipswith third parties, including suppliers,the Company will seek to identify and dobusiness with entities that adopt and enforcepolicies similar to those in Policy Letter No. 24.

Core Requirements

Conduct yourself in a manner consistent with Policy Letter No. 24and its underlying Policies.

If you have a good-faith belief that a violation of these principlesmay have occurred in Company or supplier facilities, report theviolation through the Companys reporting system.

References

Policy Letter No. 2, Relationships with Employees

Policy Letter No. 24, Code of Basic Working Conditions and CorporaResponsibility


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Equal Opportunity and Diversity

Policy Overview

We are committed to equal opportunity inemployment and to fostering diversity in our

work force. Our hiring policies and practicesrequire that there be no discriminationbecause of race, color, religion, age, gender,sexual orientation, gender identity, nationalorigin, disability, or veteran status, and otherfactors that may be covered by local law. Werecognize that diversity in our work force isa valuable asset, and we strive to providean inclusive work environment in whichdifferent ideas, perspectives, and beliefs arerespected. Violations of the Companys equal

opportunity Policies may result in discipline,up to and including termination or release.

Core Requirements

Honor the spirit as well as the letter of the Companys non-discrimination Policies. These Policies also apply to those who do,

or seek to do, business with us. Remember, we all share responsibility for implementing the

Companys Policies of equal opportunity in employment, and ourcommitment to diversity.

Help the Company as it strives, through legally permissible means,to have minorities and women well represented throughout ourwork force.

Remember, the Company is committed to providing small, minority-owned, and women-owned businesses the fair opportunity tocompete for Company business and to participate in our supplychain.

Treat coworkers with trust and respect at all times. Do not harass acoworker or visitor to the workplace.

References


Policy Letter No. 5, Employee Involvement

Policy Letter No. 6, Equal Opportunity and Affirmative Action

Policy Letter No. 24, Code of Basic Working Conditions and CorporaResponsibility

Directive B-110, Anti-Harassment Zero Tolerance

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Anti-Harassment

Policy Overview

As part of our commitment to having arespectful and inclusive work environment,

the Company has long maintained an Anti-Harassment Policy. Harassment includeslanguage or conduct that may be derogatory,intimidating, or offensive to others. All of us,as well as vendors and other visitors to ourpremises, are protected under this Policy andare expected to abide by it. Violations of theCompanys Anti-Harassment Policy will resultin discipline, up to and including terminationor release.

Core Requirements

Dont make jokes, use language, or participate in activities that maybe offensive to others. Discourage others from engaging in such

behavior. As a precaution, always think about how something couldbe perceived by others.

Dont intimidate others through bullying, threats, or practical jokes.

Report, and encourage others to report, incidents of harassment orretaliation. Report any incidents to appropriate Human Resourcespersonnel, or use the Companys reporting system.

Take all harassment complaints seriously. Managers and supervisorsshould immediately address behavior or conduct that may beoffensive, and should encourage an atmosphere in which everyonefeels free to report potential violations.

Do not retaliate against anyone who makes a report. The Companyprohibits retaliation against anyone making a good-faith complaintof harassment, or who cooperates in a Company investigation of acomplaint that alleges harassment.

References


HR ONLINE


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Health and Safety

Policy Overview

The Company is committed to protectinghealth and safety. Safety is one of the

most important factors in any decision. Asstated in the Companys Health and SafetyCommitment:

Our most valuable asset is our people.Nothing is more important than theirsafety and well being. Our coworkers andfamilies rely on this commitment. Therecan be no compromise.

When it comes to health and safety concerns,compliance with legal requirementsrepresents a minimum. When necessaryand appropriate, we establish and complywith standards of our own, which may gobeyond legal requirements. In seeking waysto protect health and safety, the issue of costshould not rule out consideration of anyreasonable alternative.

Core Requirements

Take personal responsibility for the protection of health and safetywhile at work. We will only achieve our goal of zero injuries with the

commitment of all personnel to achieve this goal. If you are a member of management, consult with employees

and/or their representatives and involve them in matters affectingtheir health and safety. Management of each activity is expected toaccept this responsibility as an important priority, and to committhe necessary resources to health and safety.

Comply with the Companys health and safety requirements. Failureto do so may result in discipline, up to and including termination orrelease.

References

Policy Letter No. 17, Protecting Health and the Environment

Directive B-108, Occupational Health and Safety Management

Health and Safety Commitment


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Substance Abuse

Policy Overview

Substance abuse poses a threat to all ofus in virtually every aspect of our lives,

including the workplace. For the protectionof all, it is imperative that the workplace befree from substance abuse, including useor possession of illegal or illicit drugs, andalcohol abuse. You may not use, possess,manufacture, distribute, dispense, transport,promote, or sell illegal or illicit drugs or drugparaphernalia while on Company businessor on Company premises. You are prohibitedfrom being at work or on Company businesswhile under the inuence of, or impaired by,

alcohol or illegal or illicit drugs.

The Company encourages anyone havingsubstance abuse problems to seekappropriate assistance. Employees shouldcheck the local appendix for country-specic employee assistance services thatare available to you. Use of assistanceservices will not jeopardize your status withthe Company, provided that you maintainacceptable levels of performance andconduct.

Core Requirements

Do not work under the inuence of alcohol or other substances. This includes being under the inuence of alcohol or other

substances that impair judgment, performance, or behaviorwhile on Company premises, or while away from the workplaceon Company business.

Do not possess, use, sell, or transfer illegal drugs, medicallyunauthorized drugs, controlled substances, or unauthorized alcoholon Company premises.

Help identify suspected drug trafficking on Company premisesby reporting such activity to local or corporate Human Resourcesrepresentatives, local management, the facilitys Security staff, theCompany reporting system, or to appropriate law enforcement

agencies, such as the police. Make contractors and other suppliers who perform work on

Company premises aware of the Companys position on substanceabuse. Let them know they are expected to take appropriatemeasures to ensure that their employees and agents act in amanner consistent with the Companys requirements.

In order to protect everyones health and safety, the Company willtake steps to investigate possible violations of its substance abusePolicies. Subject to local agreements or law (for country-specicinformation, see your local appendix), everyone is expected to

cooperate in: Personal or facility searches for alcohol or illegal drugs when

requested

Medical evaluations

Alcohol and drug testing if: judgment or performance appearsimpaired, if behavior is erratic, or under special circumstancessuch as following an accident

Violation of the substance abuse policy or refusal to cooperate (forcountry-specic information, see your local appendix) may result in

discipline, up to and including termination or release.

References

Directive A-121, Substance Abuse


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Gifts, Favors andConicts of Interest


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Gifts, Favors, and Conicts of Interest 1


Policy Overview

Each of us is expected to act in a way thatpromotes the Companys best interests.

Personal relationships with suppliers,dealers, and customers must not affect yourability to act in a manner that is best for theCompany. Those relationships must not harmthe Companys reputation by creating theappearance of impropriety. One good test isto ask yourself how others might view youractions if they were disclosed to Companymanagement or reported in the media.

Accepting gifts or favors from a businesscontact, such as a supplier or dealer, cancloud your judgment when making decisionsfor the Company, or give the appearance thatthe supplier or dealer is buying favorabletreatment. Always follow the Companyslimitations and conditions on accepting giftsor favors from individuals or organizationsthat do business with the Company, or thatare actively seeking to do business with theCompany.

Core Requirements

Do not use your position at the Company to privately enrichyourself or others (such as family or friends). In fact, you should

avoid situations that could even look to outsiders as if you are doingsomething improper.

Never ask for a gift or favor from an individual or organizationthat does business with the Company, or is actively seeking to dobusiness with the Company.

Accept a gift or favor that is freely offered by suppliers, dealers,and others only if it is of nominal value, involves a normal salespromotion, advertising, or publicity, and there is a legitimatebusiness purpose. In the United States, $50 is considered tobe nominal value. See your local appendix, or ask your Human

Resources representative to nd out what is considered nominalvalue in your country.

Never accept any of the following types of gifts or favors from anindividual or organization that does business with the Company, oris actively seeking to do business with the Company:

Cash, gift certicates, or a gift of packaged alcohol (including beeor wine)

Tickets to any event, unless the supplier is in attendance and thesituation meets all other entertainment limitations

A loan, unless it is from a regular nancial institution on normalterms

Discounts on goods or services, unless the supplier makes themgenerally available to all employees in the Company

Gifts or other donations for parties or social events attendedprincipally by Company personnel (for example, retirement orholiday parties)

Return inappropriate gifts with a polite note explaining theCompanys Policy. If it is not possible or practical for you to returnthe gift, consult your local Human Resources representative todetermine what to do with the gift.

Ask if you are not sure if something is appropriate. You may ask youmanager, your local Human Resources representative, the Office ofthe General Counsel, or your local legal office.

CONTINUED ON PAGE 17

Receiving Gifts or Favors


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References

Policy Letter No. 3, Standards of Corporate Conduct

Directive A-107, Standards of Corporate Conduct

Directive A-109, Provision of Gifts, Prizes and Related Items by theCompany

HR ONLINE

Receiving Gifts or Favors CONTINUED


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Policy Overview

Socializing with suppliers, dealers, and otherbusiness contacts (referred to below simply

as suppliers) can be helpful in cultivatinga good working relationship, but there arelimitations on what types of entertainmentand social events are acceptable. You mustalways remember to act in a way thatpromotes the Companys best interests, andthat protects the Companys reputation.Social activities with business associatesmust be appropriate and limited. You shouldonly accept invitations that are business-related and freely offered. You should never

accept an invitation that would create anappearance of impropriety. Always follow theCompanys limitations on attending supplier-paid activities.

Core Requirements

Know and follow Company Policies regarding acceptingrefreshments, entertainment, and other social events associated

with your work at the Company: You may accept refreshments provided by a supplier while

attending a business meeting.

You may accept only one meal per quarter per supplier.

You may accept only one meal per week, in total, from allsuppliers.

You may accept up to two entertainment events (such as a golfouting, or a sporting, theatrical, or cultural event) per calendaryear, per supplier, provided that the supplier is in attendance and

the event does not require extensive travel or an overnight stay. Do not attend an event that involves adult entertainment when you

are on Company business.

Do not travel on a suppliers aircraft or vehicle for transportationunless it is an authorized Company business trip (such as a trip toa suppliers plant for a Quality Review, or a local social event thatcomplies with the Companys entertainment Policies). Additionally,any travel on a suppliers aircraft must meet the requirements ofDirective A-110.

Although you may accept invitations from multiple suppliers,remember that frequent acceptance of gifts or invitations (even ifwithin Policy limitations) may create an appearance of impropriety.

You may accept a gift while at a supplier-paid event, as long asthe gift is of nominal value. Remember, prizes given out at suchevents are considered gifts. Therefore, you may not accept a prizeof greater than nominal value, even if you win a contest to qualifyfor the prize. See your local appendix, or ask your Human Resourcesrepresentative to nd out what is considered nominal value in yourcountry.

Use good judgment when you are offered gifts or invitations. Ifthere is any doubt whether the conduct is appropriate, you shouldconsult your Human Resources representative or pay your own way.


Entertainment and Social Events


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References



Directive A-110, Business Related Travel

HR ONLINE

Entertainment and Social Events CONTINUED


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Policy Overview

The Company does not want to interfereunnecessarily with your personal affairs,

and it recognizes that it is desirable to havefriendly relationships with suppliers, dealers,and others with whom we do business. Yetit is important that you and the Companywork together to avoid any basis for criticismor misunderstandings. Therefore, do notgive preferential treatment to others, andnever use unethical business practices.You must also avoid conduct that might bemisinterpreted as being improper, or givingone supplier or dealer an unfair advantage.

It is important that you and the Companynot be placed in a situation where you havea conict of interest in conducting Companybusiness. For that reason, all salariedemployees must seek prior approval from theCompany any time they will be serving as adirector, officer, or consultant of an outsidebusiness, regardless of whether or not theCompany conducts business with thatoutside entity.

Core Requirements

Do not act on behalf of the Company with an organization in whichyou or a family member has a nancial interest, or which employs a

family member or close friend. Do not give preferential treatment, and avoid a situation that would

raise the suspicion of preferential treatment. Consult with yourmanagement, Human Resources representative, or the Office of theGeneral Counsel or your local legal office about any questionablesituation.

Do not use any nonpublic information gained through the Companyfor your personal advantage, or to enable others to prot from it.For example:

Do not prot from a business transaction in which the circumstancesindicate that the opportunity belongs to the Company.

Do not disclose any Company information outside the Company,including nancial, product, or bid information, prior to itsauthorized release.

If you are a salaried employee, obtain prior written approval fromthe Company for the following circumstances:

Before working or performing services for an organization withwhich the Company does business

Before becoming a director, officer, or consultant of any otherbusiness

For employees who are LL5 (or its equivalent) or above, beforebecoming a director, officer, or consultant of a nonprot or charitableorganization (such as the United Way or a disaster relief organization)at the national level, or before accepting a local position (in asimilar organization) that has high, community-wide visibility

Consult with your local Human Resources representative before youact, if you are in doubt about how this Policy affects you.

References Policy Letter No. 3, Standards of Corporate Conduct


HR ONLINE

Form 2402

Preferential Treatment, and Working or ConsultingOutside the Company


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Policy Overview

Each of us is expected to act with thehighest sense of integrity and in a manner

that protects and enhances the Companysreputation. You should not enrich yourself orothers while conducting Company business.In order to ensure that employees and theCompany are not placed in a situation wherean employee has a conict of interest inconducting Company business, all salariedemployees must report certain nancialinterests held by them or a family member.*

Core Requirements

Salaried employees may not own the following nancial interests inany entity that does business with the Company without the written

approval of the Ford Motor Company officers identied in PolicyLetter No. 3:

Any interest in such a business that is not a corporation

More than 1% of any class of stocks or bonds of such acorporation (including any options, loans, or other nancialarrangements), whether or not publicly owned

Salaried employees must report the following nancial interestsin any entity that does business with the Company, by submittingthe information on Form 2402 to their local Human Resourcesrepresentative:

Any nancial interest in such a nonpublicly owned entity

Any nancial interest in any business transaction to which theCompany is, or will become, a party

Salaried employees must report the following nancial interestsheld by any of their family members* (to the extent known) inany entity that does business with the Company, by submittingthe information on Form 2402 to their local Human Resourcesrepresentative:

Any interest in such a business that is not a corporation

Any nancial interest in such a nonpublicly owned entity

More than 1% of any class of stocks or bonds of such a publiclyowned corporation (including any options, loans, or othernancial arrangements)

Any nancial interest in any business transaction to which theCompany is, or will become, a party

*Family member means the employees spouse, parent, brother,sister, or child, or a spouse of such a child.

NOTE: Any new or modied interests should be reported within20 calendar days of any change.


Financial Interests


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References

Policy Letter No. 3, Standards of Corporate Conduct Directive A-107, Standards of Corporate Conduct

HR ONLINE

Form 2402

Financial Interests CONTINUED


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Policy Overview

While working for the Company, you mayhave access to information about the

Company, or to the business informationof other companies, that has not yet beenmade available to the general public. Thisis known as insider information or insideinformation. As a matter of Company Policy,and as a matter of law, you may not use suchinformation for your own nancial gain, ordisclose it to others for their nancial gain.

Specically, you may not buy or sell stockin a company if you learn of condentialinformation that a reasonable investor woulddeem important in deciding whether to buyor sell the stock of that company at the priceoffered. This means that if you have suchnonpublic information about the Company(or another company), you must not buy orsell shares of stock of the affected company,or disclose that information to others, untilthe information has been made knownpublicly.

Some examples of the types of informationthat are likely to be considered insiderinformation include: possible acquisitionsor mergers; earnings estimates, materialchanges in sales, liquidity issues, or othernancial information; signicant changes inproduction schedules; signicant changesin operations; government investigations;signicant lawsuits or settlements; andchanges in senior management.

Core Requirements

Protect the Companys nonpublic information.

Do not buy or sell stock or other securities based on nonpublic

information.

Do not tip others about nonpublic information so they can buy orsell stock.

Contact the Office of the General Counsel or your local legal officeif you have questions regarding your ability to buy or sell sharesof stock, given the information you know about the Companysbusiness.

References


Policy Letter No. 22, Preventing Improper Disclosure of CompanyInformation

Insider Trading


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Policy Overview

Giving gifts, just like receiving gifts, canharm the Companys reputation by creating

the appearance of impropriety. In somesituations, giving gifts or favors can alsoviolate the law; for example, when dealingwith government officials. Giving gifts toCompany personnel can raise issues ofpreferential or unfair treatment that canaffect morale and create perceptions offavoritism. For these reasons, it is importantto follow the Companys gift and favorPolicies.

When giving gifts or favors to those who do,or seek to do, business with the Company,several tests must be met. (Remember thatfavors include meals and entertainment).Any gift or favor must: (a) be part of normalCompany-approved sales promotions,advertising, or publicity; and (b) be oflimited value and not risk the appearance ofimpropriety. Giving gifts or favors to certainbusiness contacts may have additional legallimitations. Any time you are working with agovernment official or union representative,be sure that you understand any limitationsthat may apply.

Regarding gifts or favors to Companypersonnel, neither a Company organizationnor a Company employee may give gifts orfavors paid for by the Company to Companypersonnel or their family members withoutan approved exception.

Core Requirements

Do not give gifts or favors of value greater than the limitations inDirective A-109 to any business contact unless the gifts or favors are

part of a Company-approved promotion. You should avoid situationsthat even look to outsiders as if you are doing something improper.

Follow the guidance given in the section titled Working withGovernments; Restrictions on Political Activities in this Handbook gifts to government officials.

Never provide gifts, entertainment , or other favors to a unionrepresentative without consulting with the Office of the GeneralCouncil or your local legal office.

Be sure that any gifts or favors given to personnel on behalf of theCompany are part of a Company-approved program and complywith the limitations in Directive A-109. Items that are permittedunder Directive A-109 include:

Gifts of limited value (such as T-shirts or key chains) that are partof a Company-sponsored recognition program

Gifts of limited value that involve normal sales promotion,advertising, or publicity given to participants at Company-sponsored activities

Certain sales incentives, subject to the limitations in Directive A-109

NOTE: Company personnel may not accept or take promotionalitems given to dealers, unless the items meet the limitations ofDirective A-109.

Ask if you are not sure if something is appropriate. You can ask yourmanager, your local Human Resources representative, the Office ofthe General Counsel, or your local legal office. For country-specicinformation, see your local appendix.

References

Policy Letter No. 3, Standards of Corporate Conduct Directive A-107, Standards of Corporate Conduct

Directive A-109, Provision of Gifts, Prizes and Related Items by theCompany

Directive C-107, Payment of Travel Expenses of Non-Employees

HR ONLINE

Giving Gifts or Favors to Outside Business Contactsor Company Personnel


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Use of Company Assets andData Safeguarding


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Integrity of Financial and Other Company Records 2Use of Company Assets and Data Safeguarding 2


Policy Overview

As employees and other entrusted personnel,each of us is responsible for protecting the

Companys assets and ensuring that they areused for Company business purposes and inaccordance with Company policies.

Resources such as computers, telephones,personal digital assistants (PDAs), Internetaccess, electronic mail (e-mail), instantmessaging, reproduction equipment,facsimile (fax) machines, and similartechnologies are provided to enable you toperform your work in support of Companybusiness. All electronic data stored onCompany computers or similar assets arethe property of the Company. You shouldhave no expectations of privacy when usingCompany computers or other Companyresources. The Company has the right tomonitor or access documents on its systemsat any time, within the limits of existing lawsand agreements. In some countries, locallaws may give personnel limited privacyrights for personal data. (For country-specicinformation, see your local appendix).

If you drive a Company vehicle, you arerequired to be properly licensed and tooperate the vehicle safely (which includesusing safety belts) and in accordance withthe law.

Core Requirements

Use Company assets for Company business. In most countries,occasional use of Company assets, such as computer resources

and phones, for private, noncommercial use is permitted if it doesnot compromise the Companys interests or adversely impact yourperformance on the job.

Occasional, private use is not permitted in countries that restrict theCompanys right to access personal information on Company assets.

Do not use Company resources to run a personal business or similarventure.

Do not access, reproduce, display, distribute, or store any materialsthat are sexually explicit, obscene, defamatory, harassing, illegal,or otherwise inappropriate when using Company assets, or whenperforming your job.

Do not use Company resources to reproduce, display, distribute, orstore any materials that violate trademark, copyright, licensing, orother intellectual property rights of any party.

Remember, the Company will investigate theft or loss of its assetsand take appropriate action.

Always wear safety belts when driving on Company business. Andwhen in a Company vehicle, all occupants must wear safety belts.

Drive Company vehicles safely and in accordance with the law.Drivers must be unimpaired and properly licensed.

References


Policy Letter No. 23, Privacy and Protection of PersonallyIdentiable Information

Directive A-112, Safety Belt Use and Driving Requirements WhenTraveling by Vehicle on Company Business

Directive B-105, Assignment, Use and Sale/Lease of Company Vehic

Directive B-109, Appropriate Use of Company Computer Resourcesand Similar Company Assets


Information Technology Policy Manual (ITPM)

Use of Company Assets


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Policy Overview

You are responsible for ensuring that yourcommunications are clear, correct, and

appropriate. Responsible and appropriatecommunications are essential not onlyto conducting our business, but also tothe Companys reputation. Copies ofcommunications may be used as evidence ina courtroom, in submissions to governmentagencies that regulate our business, inthe development of articles by the media,and in determining corrective actions ordiscipline by Company representatives.Communications include such things as

written memoranda, handwritten notes,drawings, e-mail, computer les, voice mail,and photographs.

Certain business activities within theCompany have been designated to overseecommunications on specic topics, or withspecic types of groups or individuals. It isimportant that communications from outsidethe Company be immediately forwarded tothe proper activity for handling.

Core Requirements

State the facts clearly to ensure that the content of acommunication is not misunderstood. Do not exaggerate or

include unsupported assumptions in your communications. Direct communications to the proper individuals. When you are

identifying and helping to solve an issue, the communicationsshould be directed to those individuals responsible for solvingit. Include the entire context of the issue with enough detail forthem to act on it. When the issue is resolved, close the matterby documenting the full context and the nal resolution.

Be especially careful in public places or when using publicforums, including those on the World Wide Web. Be carefulnot to disclose nonpublic Company information, state or

imply that you are speaking on behalf of the Company, or doanything that would harm the reputation of the Company.

Immediately forward any communications from outsidethe Company to the appropriate activity to ensure thatthe Company makes a proper response. Listed below arecommon examples:

Contacts from a government, including any police or otherlaw enforcement agencies: Forward to the Office of theGeneral Counsel or your local legal office.

Legal inquiries: Forward to the Office of the GeneralCounsel or your local legal office.

The media: Forward to Public Affairs.

Financial inquiries: Forward to Investor Relations or PublicAffairs.

Vehicle or dealer complaints: Forward to Ford CustomerService Division (FCSD), or to the appropriate brandcustomer-service group.

Unsolicited ideas and product suggestions: Forward to theConsumer Innovation Office (CIO), in accordance with theinstructions set forth on the CIOs Web site.

NOTE: If you have received an outside contact and are unsureabout where to refer it, consult the Office of the GeneralCounsel or your local legal office.


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References

Policy Letter No. 4, Compliance with the Antitrust Laws Policy Letter No. 12, Public Affairs


Directive C-108, External Communications with Respect to FinancialPerformance or Condition

Directive E-101, Public References to Competitors and Their Product

Directive E-103, Responding to Product and Service CustomerComplaints

Consumer Innovation Office Web site

Guidelines for On-line Communications on the Ford Legal AccessWeb site

Careful Communications CONTINUED


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Policy Overview

The Companys information is a valuableasset and must be managed effectively and

securely. Generally, Company informationis any information that you receive, acquire,or record in performing your job duties,including information that is stored onCompany computers or other electronicstorage devices. It includes documentssuch as product plans, vehicle designs,strategy papers, retail nance contracts,communications to the Companys Board ofDirectors and management, and agreementsthe Company has with others, as well as

written memoranda, handwritten notes,drawings, photographs, computer les, voicemail, and e-mail notes. Though it may bein your possession, Company informationbelongs to the Company, not to you.

Effective management of Companyinformation helps the Company meet itsbusiness goals, maintain a competitiveadvantage, and achieve its objectives forquality. Proper information managementis also required to support the Companyscompliance with legal and regulatoryrequirements and internal policies. Companyinformation that you receive or acquire inperforming your job should be managed ascarefully as nancial, real estate, and othertypes of Company assets. You are required toknow the Companys procedures for creating,transferring, retaining, and disposing ofinformation. The Company takes disclosureof its information very seriously and will not

hesitate to act to protect its interests, whereappropriate.

Core Requirements

Assign the proper information security classication under GlobalInformation Standard 2 (GIS2) (Secret, Condential, Proprietary, or

Public). Take appropriate measures to safeguard and protect the

condentiality and security of Company information.

With Secret and Condential information, take extra care to protectinformation. See GIS2 and the Information Technology PolicyManual (ITPM) for additional protective measures you should take.

Do not use nonpublic information about the Company or othercompanies with which we do business for personal nancial gain, orfor the nancial gain of others.

Be sure you have an appropriate Company-approved purchaseagreement or a written Condentiality Agreement that has beenapproved by the Office of the General Counsel or your local legaloffice, if you need to share nonpublic Company information with asupplier or other business.

If you receive an inquiry from outside the Company, youmust forward it to the business activity responsible for suchcommunications to ensure that the Company makes a properresponse. See the Careful Communications subsection of thissection for further information.

References


Policy Letter No. 20, Management of Corporate Records andInformation


Policy Letter No. 23, Privacy and Protection of Personally IdentiablInformation

Directive B-109, Appropriate Use of Company Computer Resourcesand Similar Company Assets

Directive C-101, Outside Requests for Informational Visits to FordFacilities


Protecting Company Information


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Directive C-108, External Communications with Respect to FinancialPerformance or Condition

Directive C-110, Acquiring Information from Outside the Company Directive C-114, Image Capturing Devices on Company Premises

Directive E-107, Automotive Advertising Agency Relationships WithCompetitors

Global Information Standard 1 (GIS1): Management and Retention Company Records

Global Information Standard 2 (GIS2): Corporate Information Secu

Global Information Management (GIM) Web site


Security Classications for Records FAQs

Protecting Company Information CONTINUED


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Policy Overview

The trust and condence of our customers,personnel, dealers, suppliers, and others

are essential to the success of Ford MotorCompany. Each individual has legitimateexpectations that the Company will handletheir personally identiable information(PII) responsibly, and that the Company willtake reasonable and appropriate measuresto protect PII from misuse. PII is denedas any information that can be associatedwith a unique individual or that can beused to identify, locate, or contact a uniqueindividual.

Core Requirements

Make someone responsible and accountable for the propercollection, management, and security of PII that your group handles.

State the purposes for the collection of the PII; limit the collectionand use in a manner consistent with the stated or reasonablyimplied purposes, and with applicable law.

Provide reasonable and appropriate security safeguards to protect PII.

Immediately submit an incident report to Security if you suspectthe security or condentiality of PII has been compromised (forexample, unauthorized access, or the loss or theft of a laptop orother portable electronic device).

Follow Company policy if your organization shares PII with suppliers.

You must have a written agreement, approved by the Office ofthe General Counsel or your local legal office, which lays out theresponsibility of each party to protect the shared PII. Conduct aninitial assessment of the suppliers ability to protect the PII, followedby regular periodic assessments to verify continued protection.

References


Directive B-104, Condentiality of Employee Records and ProtectionPersonally Identiable Information

Directive C-110, Acquiring Information from Outside the Company

Directive C-113, Consumer Privacy Standards and Protection ofPersonally Identiable Information

Directive C-116, Supplier Safeguarding of Personally IdentiableInformation





Personal Data Privacy


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Policy Overview

The Companys Global Information Standards(GIS) program includes standards, processes,

services, and solutions that enable themanagement of Company records andinformation, regardless of media or location.

Two Global Information Standards form thebasis of the GIS program: Global InformationStandard 1 (GIS1) is the records managementstandard that establishes retentionrequirements for all Company records,regardless of format. Global InformationStandard 2 (GIS2) is the information

security standard for the Company. Itgoverns the protection and handling ofrecords and information, and denes foursecurity classications: Secret, Condential,Proprietary, and Public.

The Annual File Review (AFR) is thecompliance process associated with theGIS program. It occurs every year betweenJanuary 1 and March 31. During this period,personnel are required to review the recordsfor which they are responsible to determinewhich records should be destroyed that year,including a review of whether or not there isan applicable suspension order.

Core Requirements

Know whether the documents you are responsible for are classiedas Official or Transient records. If they are Official, apply GIS1 i

numbers to the records to track retention requirements. Assign GIS2 information security classications to records for which

you are responsible. For example:

Secret is dened as information of a strategic or other sensitivenature that, if disclosed in an unauthorized manner, would causesubstantial, severe, or irreparable damage to the Company orits relationships.

Condential is dened as information that provides theCompany with a competitive advantage that supports itstechnical or nancial position, and that, if disclosed withoutauthorization, could cause damage to the Company.

Proprietary is dened as that information created or obtained inthe normal course of business (and that is not classied as Secret,Condential, or Public), and that, if disclosed to the public, maycause some negative consequence to the Company. Examplesinclude: calendars, drawings, or specications of releasedprograms; and Company Policies.

Public is dened as that information made available to the public,including disclosures required by federal, state, provincial, or locallaw. Examples include: product brochures, advertisements, pressreleases, U.S. Security and Exchange Commission lings, andCompany Annual Reports.

Follow established requirements for access, reproduction, travel,transfer, storage, and disposal of records based on the assignedsecurity classication.

Ensure that all records in all storage locations, including recordsstored in electronic applications, shared drives, or at offsite storagelocations, are identied on the appropriate Depar tmental RecordsInventory Matrix.

Review records during the Annual File Review (AFR) for continuedrecord retention or destruction.

Retain all records, Transient as well as Official, even afterexpiration of their retention, if they are associated with currentsuspension orders.


Annual File Review and Records Management


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Complete all steps in the AFR process, and then submit an annualCerticate of Compliance.

Destroy records by following the proper procedure based on theirsecurity classication.

Transfer the responsibility for records to a new owner if your jobresponsibilities change, or if you are leaving the Company.

If you are a departmental or business activity manager, ensure thatpersonnel in your activity comply with the requirements of GIS1and GIS2.

References

Policy Letter No. 20, Management of Corporate Records andInformation






Finance Manual

Finance Manual, FM 04-10 Series, Company Records

Security Classications for Records FAQs

Annual File Review and Records Management CONTINUED


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Integrity of Financial andOther Company Records


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Integrity of Financial and Other Company Records

Integrity of Financial and Other Company Records 3


Policy Overview

Now, more than ever, it is important that all nancialrecords be accurate and complete. Companies face

severe consequences if they provide inaccurate nancialstatements to their shareholders or to governmentauthorities. The Companys Chief Executive Officer (CEO)and Chief Financial Officer (CFO) certify several statementsin quarterly lings with the U.S. Securities and ExchangeCommission. They include certications that the reportdoes not contain any untrue statement of a material fact,and that it does not omit the statement of any materialfact that is necessary to ensure that the statements beingmade are not misleading. The CEO and CFO also certify thatthe nancial statements and other nancial information in

the report fairly present the nancial condition, the resultsof operations, and the cash ows of the Company and itssubsidiaries. In addition, the directors of the Company andits various subsidiaries rely on the accuracy of the nancialdata when they are signing off on the accounts each year.

You should remember that many corporate businessrecords support the Companys nancial statements.For example, if you use funds approved for capitalimprovements to support ongoing business operations,such an action could result in the incorrect classicationof Company expenditures on our nancial statements.In a similar way, adjusting reserves without followingappropriate accounting Policy can also potentially lead toinaccurate nancial statements.

Accurate and complete business records enablemanagement to make proper and informed decisions.Additionally, the Company is required to provide certaininformation to various government agencies, and incorrectinformation could potentially subject the Company tolegal penalties. All records, therefore, must be complete,accurate, and up-to-date. This means not only nancialrecords, but also such data as sales records, businessmetrics, performance-related records, test records, andengineering records. Falsication, deliberate concealment,or deliberate manipulation of records will not be tolerated,and will be dealt with appropriately, up to and includingtermination or release.

Core Requirements

Record, accurately and completely, all Companynancial information for accounting, taxation, and

other nancial-reporting purposes. Notify management of any accounts that cannot be

reconciled. Management should take immediatesteps to reconcile such accounts, inform the necessarypersonnel and business activities, and take steps toensure that such errors do not occur again. Such stepscould include additional training of personnel andadditional management oversight.

Ensure that business records contain complete,accurate, and up-to-date information, so that

management can make sound business decisions. Notify the Company of any errors, so that they can

be assessed and corrected. Operations IdentiedComments (OICs) should be raised as appropriate. TheCompany recognizes that errors can and do occur, butthey must be handled properly once they are found.

Do not deliberately falsify business records, or conceaany errors. Such actions not only violate CompanyPolicy, but also may constitute a violation of law,and they will be dealt with appropriately, up to and

including termination or release.

References


Policy Letter No. 20, Management of Corporate Recorand Information

Finance Manual

Code of Ethics for Senior Finance Personnel


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Product Quality, Safety andEnvironmental Matters


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Product Quality, Safety, and Environmental Matters 3


Policy Overview

At Ford Motor Company, Quality is Job 1. Quality is dened by our customers, and goes

hand-in-hand with safety. Our customers arewhy we exist; their satisfaction is essentialto our success. Therefore, the quality of ourproducts and services must be our numberone priority today and tomorrow.

To be the best-in-class in customersatisfaction, it is critical that the Companybuild safe products. More than ever before,customers expect our vehicles to containsuperior safety features, and so does theCompany itself. Policy Letter No. 7, VehicleSafety , requires that the Company be activeand responsible in all areas of automotivesafety. This is a broad requirement that coversvehicle design and manufacture, driverbehavior, and the highway environment.Our products should be designed not onlyto meet or exceed applicable laws andregulations, but also to advance the state-of-the-art in safety whenever practicable.

Core Requirements

Utilize the Companys Quality Operating System (QOS) and its keyprocesses to achieve measurable results, eliminate waste, and

deliver value. The Quality Operating Systems standards and procedures

signicantly affect the quality of our products and services,and help ensure that our products meet or exceed applicableinternational standards.

Be actively involved in Quality Leadership and follow the nineQuality Leadership principles in the Global Quality Manual.

Utilize Six-Sigma and its data-driven decision making.

When selecting a supplier, include the suppliers demonstrated

ability to achieve continuous quality improvement in the selectioncriteria.

Do not rule out, based on the issue of cost, the considerationof possible state-of-the-art alternatives, in evaluating potentialadvances in product safety. Priorities should be based on achievingthe greatest anticipated safety benet that is practical.

Remember that a major objective of the Companys research anddevelopment efforts is the implementation of product, process,and manufacturing innovations that provide customer benet andvalue, and that help protect the environment and enhance safety.

Consider the performance throughout the life of the vehiclewhen working to meet the safety needs and expectations of theCompanys customers.

Address in-service safety concerns in a timely, customer-drivenmanner.

References

Policy Letter No. 1, Ford Quality Policy

Policy Letter No. 7, Vehicle Safety Policy Letter No. 8, Technological Innovation

Policy Letter No. 10, Decisions to Manufacture or Purchase Productioand Service Parts (Make/Buy Decisions)


Product Quality and Safety


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Policy Letter No. 11, Supplier Selection and Relationships

Directive A-116, Management of Ford Total Quality Excellence

Directive F-112, Global Engineering and Quality Standards

Directive F-113, Product Design and Manufacturing ChangeManagement Vehicles Built in U.S., Canada, and Mexico

Global Quality Manual

Product Quality and Safety CONTINUED


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Policy Overview

It is Ford Motor Companys Policy that itsoperations, products, and services should

accomplish their functions in a mannerthat responsibly protects health and theenvironment.

The Company is committed to meetingregulatory requirements that apply to itsbusiness. However, when necessary andappropriate, the Company establishes andcomplies with its own standards, whichmay exceed regulatory requirements.Consideration of potential health andenvironmental effects should be an integralpart of all Company business decisions.

It is clear that the strong, protablecompanies of the future will be the ones thatstrive for sustainable use of environmentalresources. The Company is focused on manyinitiatives that impact the environment,such as improving fuel economy, reducingvehicle and plant emissions, reducing waterconsumption, conserving energy, recyclingand reusing those materials that arenonrenewable, and eliminating the use andcreation of toxic materials.

Core Requirements

Know the environmental requirements (both legally mandated andCompany-initiated) that apply to your work.

Be sure your operation has practices and programs in placedesigned to ensure that the Companys environmental protectionprogram is implemented effectively.

Use the Companys environmental specialists to assist you inunderstanding and carrying out your responsibilities.

Use the Companys Environmental Quality Office (EQO), which deawith facility issues, and Vehicle Environmental Engineering (VEE)staff, who deal with product issues, if you need assistance.

If you receive a communication from any government agency

regarding environmental matters, refer it immediately to the Officeof the General Counsel or your local legal office, as appropriate. Donot try to handle the matter on your own.

Contact the Environmental Quality Office, Vehicle EnvironmentalEngineering, the Office of the General Counsel, or your local legaloffice whenever you have a question, or whenever delays or otherfactors affect the Companys ability to complete required actions.

References

Policy Letter No. 17, Protecting Health and the Environment Directive A-120, Environmental Strategy, Planning, and

Implementation

Directive A-124, Joint Venture ISO 14001 Certication

Directive D-101, Energy Planning and Control

Directive D-109, Waste Minimization Program

Directive F-102, Energy Policy and Conservation Act

Directive F-111, Vehicle Recycling

Environmental Matters


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Intellectual Property


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Intellectual Property 4


Policy Overview

The Companys various types of intellectualproperty are highly valuable assets. They are

key to our global strategy of using innovationto sell world-class products that are bothunique and technologically superior.

Intellectual property includes patents,copyrights, trade secrets, and trademarks.New ideas or inventions may be protectedthrough a formal patent, or as trade secrets.A trade secret is any information that issufficiently valuable and secret that it givesus an actual or potential advantage overothers. A copyright is a right that preventsothers from copying artistic, literary, andother works such as photographs, music,articles, and computer programs.

It is the Policy of the Company to secureand protect its intellectual property rights,and to take appropriate action against anyindividual or group making unauthorizeduse of our rights. Just as we expect others torespect our intellectual property rights, weare committed to respecting the intellectualproperty rights of others.

Core Requirements

Promptly submit invention disclosures on innovations in areassuch as product or process improvements, business methods,

manufacturing, designs, and software applications to Ford Global Technologies, LLC, (FGTL) using the Invention Disclosure systemavailable at FGTLs Web site.

Do not publish or disclose your invention to anyone outside theCompany without prior authorization from FGTL. You may discloseinventions to suppliers working under a signed purchase agreement.

Carefully follow the Companys policies on the protection of itsCondential and Secret information.

If you need to disclose trade secrets to outside parties in connectionwith a business transaction, contact Ford Global Technologies toassure that appropriate protections are in place.

Promptly report any unauthorized use of the Companys intellectualproperty. You can report it through the FGTL Web site, or your locallegal office, or the Companys established reporting system.

Consult FGTL regarding a new product feature or process thatappears likely to be used, to avoid infringing upon othersintellectual property rights.

If you wish to use a copyrighted work, for example, by adding musicto presentations or by widely circulating articles in magazines,

journals, or other publications, check the FGTL Web site or ask FGT(or your local legal office) to determine whether a copyright licenseis necessary.

Consult the FGTL Web site for guidance on the use of copyrightnotices on Company materials, or for assistance in obtainingcopyright registrations to protect the Companys materials.

Do not copy software onto another computer without verifyingthat copying is permitted under the applicable license agreement.Computer software not owned by the Company must be properlylicensed.

Do not load software that is not business-related onto Companycomputers.

Do not share software written by Company personnel outside theCompany without rst obtaining proper authorization.


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References

Policy Letter No. 8, Technological Innovation Policy Letter No. 16, Patents and Other Intellectual Property Rights

Policy Letter No. 21, Domain Names and Other Intellectual PropertyUsed in E-Commerce

Directive C-109, Unsolicited Correspondence


Directive E-102, Disposal of Assets to Outside Parties

Directive E-105, Trademarks, Trade Names and Product Designations

Directive E-108, Global Automotive Parts Trademarks

Information Technology Policy Manual, LR2 Intellectual PropertyPolicy

Ford Global Technologies Web site


Ford New Ideas Web site at http://www.fordnewideas.com

Inventions, Patents, Copyrights, and Trade Secrets CONTINUED


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Policy Overview

Trademarks are among the Companys mostvaluable assets. They are symbols of the

goodwill associated with the Companysproducts and services. Consumers worldwiderely on the Companys trademarks assymbols of superior quality and performance.

Improper use of our trademarks can weakentheir value and diminish their effectivenessas indicators of the Companys productsand services, and may result in the loss ofvaluable trademark rights.

See the Companys Corporate Identity Website for information on Company trademarksand guidance on their proper use.

Core Requirements

Follow the Companys Corporate Identity Program when usinga Company trademark. This includes making sure that there is a

written license agreement in place when you allow outsiders toplace a Company mark in print or on promotional items.

Be sure that suppliers properly mark our production parts accordingto Company standards.

Before adopting a proposed trademark for use on Companyproducts, submit a Trademark Clearance Request Form with the Trademark Office at Ford Global Technologies, LLC (FGTL) todetermine whether the proposed trademark infringes upon therights of others.

Contact the Trademark Office at FGTL (or your local legal office) ifyou believe that others are using Company trademarks withoutauthorization.

References

Policy Letter No. 21, Domain Names and Other Intellectual PropertyUsed in E-Commerce

Directive E-105, Trademarks, Trade Names and Product Designations

Directive E-108, Global Automotive Parts Trademarks

Information Technology Policy Manual, LR2 Intellectual PropertyPolicy


Ford Motor Companys Corporate Identity Web site

Trademark Clearance Request form

Trademarks


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Policy Overview

In the normal course of business, theCompany obtains information about or from

other companies, including its competitorsand suppliers. The Company collects thisinformation in order to be competitive.However, this information must be gatheredin an ethical and legal manner, and in a waythat would not put the Company at any legalrisk or affect its reputation.

In addition, suppliers may provide us withtheir condential business information.Company personnel must verify whetherthe supplier information is condential, andensure that any condential informationis handled appropriately and with propersecurity measures.

Sometimes outsiders (individuals or smallbusinesses that do not have an existingcontract with the Company) will submit newideas to Company personnel in a variety ofareas, such as product design, technology,and marketing. Many of these ideas can beconsidered intellectual property and mustbe handled in a way that protects both theCompany and the person submitting theidea. The Companys Policy is to not acceptthese new ideas without a signed waiver orother agreement approved by Ford Global Technologies.

Core Requirements

Be cautious when accepting condential information directly fromsuppliers, customers, and others. Follow the guidelines described in

this subsection. Follow the Production Purchasing Global Terms and Conditions

when handling condential supplier information in situationsinvolving production purchasing.

Outside of production purchasing situations, accept informationfrom suppliers only if there are no restrictions on its use, or if there isan approved waiver or agreement (as described below) in place.

If you must accept condential information from a supplier,take one of the following steps to eliminate any unreasonableexpectations, and to minimize the Companys exposure to liability:

Obtain and complete a Condential Disclosure Waiver Agreementform located at the Ford Global Technologies Web site. Thisform makes it clear that the Company will not accept legalresponsibility for maintaining the information in condence, andit requires the provider to waive all claims against the Company.

Or, obtain a Condentiality Agreement, which requires theCompany to retain the specied information in a condentialmanner and to take steps to prevent disclosure. You may not needa Condentiality Agreement if you are working with a supplierwho has a current purchase order for production parts.

Do not share with the Company any condential informationacquired from a previous employer, and do not ask for suchinformation from new personnel regarding their previous positions.

Do not voluntarily accept any unsolicited idea submitted byan outsider. Be especially careful of condential markings on aproposal, or requests to treat an idea as condential information.

Forward to the Consumer Innovation Office (CIO) any unsolicitedideas, including product ideas, that you receive from an outsider.Follow the instructions set forth on the CIOs Web site.


Acquiring Information from Outside the Company


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References



Production & Non-Production Global Terms and Conditions



Ford New Ideas Web site at http://www.fordnewideas.com

Acquiring Information from Outside the Company CONTINUED


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Working with Governments;Restrictions on Political Activities


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Working with Governments; Restrictions on Political Activities 4


Policy Overview

The Company has a long-standing Policynot to engage in any act that could possibly

be construed as giving or receiving a bribe. This is especially true when dealing withgovernment officials. Not only is it againstCompany Policy, but it is also against thelaw. Most countries have laws that prohibitbribing local or foreign officials. This istrue even in countries where it seems thatpayments to government officials are anormal part of doing business.

Although it is Company Policy to useCompany personnel to conduct businesswhenever possible, at times we hire agentsor others outside the Company to assistwith our business. In such situations, theCompany must take measures to guardagainst using agents that give bribes. TheCompany can be held liable for the actions ofthe agents it hires.

Core Requirements

Never give anything of value to a government official in orderto obtain or retain business, or to gain preferential treatment.

This includes, for example, offering or promising to give gifts,entertainment, travel, favors, or special purchase terms on vehicles,regardless of whether something is actually given. An offer or apromise in itself can be considered to be a bribe.

Contact the Office of the General Counsel or your local legal officebefore providing special treatment to a government official, even ifthere may be a legitimate business reason for doing so.

Remember, the term government official can include:

Officials and employees of any government-owned orgovernment-controlled business entities

Political parties

Party officials

Members of royal families

Political candidates

Employees of government departments or agencies

Employees of government-owned, joint-venture partnerships orgovernment-owned banks (in certain countries)

If you must use an agent when dealing with government officials, besure you investigate the integrity of the agent you hire. Look for redags such as:

Unnecessary secrecy

Being told not to ask

Inated invoices or unusual rebates

Unexplained or large bonuses, or unexplained or large items onexpense reports

Payments to people or entities not involved in the transaction Payments in countries other than where the transaction is located

Off-books accounts or slush funds

Anything that is not quite right


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Policy Overview

The Companys preferred practice is to useits dealers or its own personnel when selling

vehicles and parts directly to governmentsor government agencies. However, it issometimes necessary to use outside salesagents for these transactions. Regardless ofwho is arranging the sale, you must followthe procedures outlined in the FinanceManual 82-10 Series. The approval of seniorCompany management is a requirementincluded in the Finance Manual procedure.

In addition to the sale of vehicles andparts, the Company pursues other types ofcontracts with governments or governmentagencies. These include contracts forresearch, development, joint projects, or joint ventures. If you are planning to enterinto a contract with a government onbehalf of the Company, be aware that manycountries have specic requirements. Thesecould include requirements specifyingwhat costs can be included, the use of thefunds, and other conditions that must becertied. Before pursuing a contract with agovernment, be sure to consult with FordGlobal Technologies, LLC (FGTL) in the UnitedStates, or your local legal office.

Core Requirements

Always follow the procedures required by the Finance Manual 82-10Series for sales of vehicles and parts to governments or government

agencies. Be sure you are aware of legal requirements before you submit

project proposals or bids to governments or government agencies.

Consult with FGTL in the Office of the General Counsel, or yourlocal legal office, if you have questions or are planning to pursue acontract with a government.

References


Finance Manual, FM 82-10 Series, Sales to Government Activities


Sale of Products to, and Other Contracts with, a Government


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Policy Overview

The Company encourages you to participateas an individual citizen in political and

government affairs. The Company respectsyour right to use your own time andresources to support the political activitiesof your choice. However, the Company itselfoperates under legal limitations on its abilityto engage in political activities. Even wherethere are no legal restrictions, the Companyhas a Policy that restricts the Company frommaking contributions (both cash and otherassets) to political candidates or politicalorganizations. There is a minor exception for

making contributions to support or opposelocal ballot issues, with appropriate approval.

At times, candidates for public office mayask to campaign on Company property. The Company does not normally permitcampaigning on its property by candidatesor persons working on their behalf. Inaddition, some locations may have additionalrequirements, such as giving candidates ofother political parties an equal opportunityto campaign on the premises. Always get theapproval of Governmental Affairs and theOffice of the General Counsel or your locallegal office before permitting a candidateappearance.

Core Requirements

Do not use Company funds or assets to make contributions to apolitical candidate, or to otherwise benet a candidate or a political

party. Generally, prohibited contributions extend to such benets astravel on Company aircraft (see below).

Obtain appropriate senior management approval for Companycontributions in support of, or in opposition to, a local ballot issue.

Do not allow candidates for political office to campaign onCompany property. Any exceptions to this Policy mu

Corporate Conduct Standards

Documents

Transcript of Corporate Conduct Standards