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Page 1: Standards of Business Conduct and Ethics Code of Conduct · Social Media ... finding ways to optimize operational excellence at all times. Over the past six decades, Autoliv has grown

Code of ConductStandards of Business Conduct and Ethics

Page 2: Standards of Business Conduct and Ethics Code of Conduct · Social Media ... finding ways to optimize operational excellence at all times. Over the past six decades, Autoliv has grown

Message from Our CEO ............................................................................. 4Our Vision, Our Mission, Our Values ................................................. 5Introduction: Code of Conduct ............................................................. 6Our Duty & Responsibility ........................................................................ 8We Value Our Customers ....................................................................... 10

Our Quality Commitment ......................................................................................10 Deal Fairly & Compete Fairly .............................................................................11

We Value Our Environment ................................................................... 12 Limit our Impact on the Environment ............................................................ 12

We Value Our Community ...................................................................... 13 Community Involvement ......................................................................................... 13We Value Our Company ........................................................................... 14 Company Resources ................................................................................................. 14 Confidentiality .............................................................................................................. 15 Communicating Our Achievements ................................................................. 16 Social Media ...................................................................................................................17 Supplier Expectations ..............................................................................................18We Value Each Other ................................................................................20 Human Rights ............................................................................................................ 20 Safety in the Workplace .......................................................................................... 21 Respect in the Workplace .....................................................................................22 Privacy .............................................................................................................................23We Value Integrity ......................................................................................24 Anti-Corruption & Anti-Bribery ........................................................................24 International Trade ...................................................................................................25 Conflicts of Interest..................................................................................................26We Value Openness ..................................................................................28 Accurate Record Keeping & Records Management ..............................28 Insider Trading ............................................................................................................29We Value Continuous Improvement of Products.................. 31 Protect Our Intellectual Property ......................................................................31References and Contacts .....................................................................32 Autoliv Helpline ..........................................................................................................32 Key Contacts ................................................................................................................34 References ....................................................................................................................34 Non-Retaliation ..........................................................................................................35 Waivers ............................................................................................................................35

Table of Contents

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Message from Our President & CEO Our Vision, Our Mission, Our Values

Our Vision

Our Mission

Our Values

Saving More Lives

Dear Colleagues,

To be the leading supplier of Safety Systems for the Future Car, well integrated with Autonomous Driving.

One AutolivWe execute our work while considering the value to our customers and impact to our entire Company. We respect and rely on one another and all our stakeholders for exceptional results. We work together and value the power of teamwork.

TransparentOur actions and behavior are guided by integrity, openness and what is in the best interest of our Company, our customers, our employees, our shareholders, and society.

InnovativeOur passion for saving lives drives us to continually seek new solutions and improve existing products and processes to create unique selling points. We dare to lead with a focus beyond tomorrow and take opportunities to learn and grow.

AgileWe are flexible and clever in anticipating change, adapting quickly, and finding ways to optimize operational excellence at all times.

Over the past six decades, Autoliv has grown to become the global leader in automotive safety. Our success is based on a passion for saving lives and the continuous innovation of new technologies. We operate in 27 different countries across the world, and the products we make save more than 30,000 lives every year.

Our lifesaving automotive safety systems never get a second chance. This is why our commitment to deliver the highest quality, safety, and performance in our products and services is such an integral part of our quality culture.

Another fundamental part of our culture is working in an ethical and lawful manner. This is what our Code of Conduct sets out to teach us every day. We refer to the Code regularly and use it as a guide to help us make the best possible decisions, particularly in complex or challenging situations. We ask that each of you do the same.

Acting in accordance with the ethical values in this Code is important for the continued success of Autoliv. This is what our customers, colleagues and other stakeholders expect from us, and this is what we in the Executive Management Team expect from you.

We look forward to more years of positive life-saving work at Autoliv.

Sincerely,

Mikael BrattPresident & CEO, and the Executive Management Team

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Our Values in Practice z Defines the principles and standards that guide our day-to-day decision

making to ensure we act in line with our values

z Outlines our policies and points to the laws and regulations that impact our business around the world

z Fosters a culture where we all act with the highest ethical standards and integrity, where unethical conduct is not tolerated, and where everyone is empowered to speak up and raise concerns

Our Code Applies to Each of UsOur Code sets the standard for all who have a role in our business:

z Every employee

z Our Board of Directors and Corporate Officers

z Our suppliers and contractors

z Everyone who interacts with Autoliv

Our Code Does Not Replace Good JudgmentOur Code provides an overview of the principles we use to guide us, but it does not provide enough information to cover every circumstance or every law and regulation that affects us. So, we rely on you to use your judgment and, if you are unsure of what to do, seek guidance and ask questions. If you see anything that appears wrong or inconsistent, speak up.

We Take Violations SeriouslyAny unethical, unlawful, dishonest, or harmful actions can have a detrimental effect on our culture, our business, and our ability to save lives. So, we need to take them very seriously. We investigate all reported cases in a fair and consistent manner. In some cases, violations may lead to disciplinary action, including termination. Depending on the laws we may also have a legal obligation to report violations to law enforcement authorities. So it is important that you speak up and report any potential violations of the Code.

Raise Your Hand for IntegrityWhat should I report? Actual or potential violations of policies, laws and regulations, Autoliv Standards, or the Code that you believe have occurred or are about to occur should be reported immediately.

WHO SHOULD I CONTACT?

z Your Manager, or another Manager you trust

z Human Resources Representative

z Legal Department

z Compliance Department

z Autoliv Helpline

Autoliv Helpline You can report concerns about suspected issues to the Autoliv Helpline at the numbers listed by country in this document and on LifeNET. The Helpline is operated by an independent third party. It is a multilingual service, and there is no charge for the call. Reports can be made confidentially 24 hours a day, 7 days a week. You may also go online at helpline.Autoliv.com to report through our web-based reporting tool.

Introduction: Code of Conduct

Introduction: Code of Conduct

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We believe that how we do business is as important as the business we do. Each of us has a responsibility and duty to behave in an ethical and legal manner and to maintain and support our culture by taking the lead. We ask you to:

Be an example – It Starts with Me• Know the Code of Conduct and any other policies, standards, laws,

and regulations that apply to the work you do• Seek guidance and help when needed• Continually improve your skills and knowledge• Take violations seriously, and cooperate with investigations• Never compromise on integrity

Our Duty & Responsibility

It Starts with Me

Always help others – It Starts with Me• When you see a fellow teammate in a tough situation talk to them,

help them practice our values

Be accountable – It Starts with Me• Be accountable to yourself and others for your actions• Report any possible concern you may have, or escalate one that is

raised to you

Are You a Manager?• Talk about our values and Code of Conduct• Provide a safe environment to voice concerns, learn, share, and be

corrected – make it safe to speak up• Be aware of and prevent retaliation • Reward Integrity

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Our QualityCommitment

We work together to serve our customers with the respect and value they deserve, and as we would expect for ourselves and our Company. We must act honestly and in compliance with antitrust and fair competition laws and regulations.

Together we commit to: z Communicate truthfully and accurately about our products and services with

our customers z Ensure our marketing materials are truthful and complete without inaccurate

comparisons to our competitors’ products z Determine our prices independently based on our costs, market conditions,

and competitiveness z Only make lawful agreements concerning prices, territories or markets,

including avoiding any informal or implied agreements z Only use legitimate means of obtaining competitive information z Respect the confidential and intellectual property rights of our competitors

and other third parties z Always seek advice from Legal regarding any of the above

We seek to deliver the highest product quality, safety, and performance at all times. Our business, reputation, and success depend on our products working every time. Our aim is to have zero defects and to provide the best value to our customers.

Together we commit to: z Comply with contractual specifications z Comply with government and industry standards z Watch for and report any quality issues z Know and apply quality in all dimensions (Q5)

Example

Deal Fairly &Compete Fairly

Antitrust and Competition Standard; Antitrust and Competition Policy – Do’s and Don’ts

What is Price Fixing?

Illegal price fixing occurs whenever two or more competitors agree to take actions that have the effect of raising, lowering, or stabilizing the price of any product or service without any legitimate justification. When competitors agree to restrict competition, the result is often higher prices.

Learn More

ExampleWe are in danger of running late on a delivery to a customer. A supplier tells us that their components are not testing in our specifications range, but the customer will probably never find out. Should we accept this?

We cannot compromise quality. Escalate this issue immediately.

Learn More

We Value Our Customers

Quality Policy

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Limit our Impacton the Environment

Contributing to the wellbeing of the communities in which we live and work represents a priority for Autoliv. We do this by contributing to the local economy through our business operations, and through locally relevant community involvement.

Together we commit to: z Support our community and its needs z Share our skills and knowledge to benefit society z Engage in activities which are relevant both for our business operations and

for our communities, for example: • Traffic Safety• Education• Health and human services

Autoliv is committed to operating our business in an environmentally sustainable manner and to developing and producing products in an energy efficient way while preventing pollution and limiting environmental impact.

Together we commit to: z Engage to continually improve environmental sustainability

in our daily work z Commit to continuously improving of our environmental management

system, to fulfilling our compliance obligations, and to enhance our environmental performance

z Focus on resource efficiency by looking for ways to reduce energy, water, and material consumption

z Combat climate change by looking for ways to reduce greenhouse gas emissions

z Eliminate waste where possible and follow sound waste management practices

Community Involvement

We Value Our Environment We Value Our Community

ExampleAn organization that I support approached me regarding obtaining a donation from Autoliv. Does Autoliv make local donations and if so, who should I contact regarding this?

Autoliv does support local donations to organizations that align with our strategic goals and applicable regulations. You should discuss this with your HR Department.

Example

Environmental Management System Standard

I have ideas about how we could reduce waste from our operations and improve recycling. What can I do?

You can raise any idea using your local kaizen suggestion system. You can also contact your manager or local environmental team.

Learn More

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CompanyResources

Protecting confidential information about Autoliv activities, performance, products, or plans is critical to our Company’s competitive position and reputation. Company information may include various types of information about the Company, our employees, and our customers. You are required to keep Company information and third party information confidential both while you are employed and after you leave the Company.

Together we commit to: z Understand and follow the guidelines in regard to Public, Internal,

Confidential, and Secret information z Ensure that we don’t disclose confidential information to anyone outside the

Company except when disclosure is required for business purposes or by law or regulation and is subject to a written agreement

z Ensure that we don’t share stock price-sensitive or material non-public Autoliv Company information with anyone, including family or friends or even to fellow Autoliv employees unless they have a business reason to know

Company resources should always be used for Autoliv’s benefit, not for personal gain or for the benefit of outside organizations. Company resources include all Autoliv purchased, acquired, and owned physical property, information, data, records, and intellectual property, such as brands, inventions, designs, and copyrights.

Together we commit to: z Avoid personal activities during work hours that interfere with our job z Ensure that we don’t use Company resources for outside businesses z Ensure that we don’t use Company resources for illegal or unethical

activities like gambling, pornography, or other activities that would violate this Code or Autoliv Standards

z Only install Company approved software on Company hardware z Make sure we have permission before disposing of, or removing,

Company property z Recognize that all communications sent or received using our resources

are Company assets and Autoliv has the right to monitor them, unless prohibited by local law

Confidentiality

We Value Our Company

ExampleCan I tell my family and friends about a new product we are launching?You may only discuss public information with people outside of the Company. If the product has not been announced publicly, then do not discuss it with family or friends.

Example

Contact the Information Technology HelpdeskCommunications Policy; Insider Trading Policy; Data Classification Policy

Can I access my personal email from my work computer? Can I check Facebook/Twitter/ other social media?

Yes, but you cannot allow this to interfere with your work or deter you from completing your assignments.

Learn MoreLearn More

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Communicating our AchievementsWe value our reputation, so we protect our Company by being careful with the information we share publicly.

Together we commit to: z Refer any media requests for Company information to

Corporate Communications z Ensure that you don’t represent yourself as a spokesperson for the

Company unless specifically authorized to do so z Be professional in all our communications z Avoid commenting about non-public, sensitive, and/or confidential

Company information on social media or any other public platform

Social Media

We Value Our Company

ExampleI have a blog where I share innovations and solicit conversations in the engineering community. Is this allowed?Yes. If you are blogging about general concepts unrelated to the Company or its business. However, if are blogging about Autoliv products or processes, you may be violating Company policy. You are responsible for protecting our Intellectual Property and confidential information.

Example

Communications Policy; Legal Matters; Data Classification Policy Communications Policy

I noticed comments on Social Media about Autoliv that aren’t true. Can I post something online to correct these comments?

No. Don’t represent yourself as a spokesperson for Autoliv or make comments that could be attributed as being posted as the official position of Autoliv.

Learn MoreLearn More

In personal use of social media, Company employees enjoy the same rights of free speech as all other private contributors. However, we need to act responsibly to avoid accidently misrepresenting the Company or sharing inaccurate information.

Together we commit to: z Respect our colleagues z Be careful that our personal comments, opinions,

or information we post do not appear to be those of Autoliv

z Prevent disclosure of confidential or secret Company information

z Ensure that we don’t represent ourselves as an Autoliv spokesperson or make comments that may seem to be the official position of Autoliv without prior consent

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Business Conduct and Ethics for Suppliers

AUTOLIVSTANDARD

We Value Our Company

Example

Business Conduct and Ethics for Suppliers – Supplier Code of Conduct

I was visiting a supplier and noticed that their emergency exits were blocked and I didn’t see any fire extinguishers. What should I do?

Report this situation to Purchasing or Supplier Quality. We expect the same safety standards of our Suppliers as we do for our own facilities.

Learn More

Supplier ExpectationsIn today’s world we are often judged by our associations. To protect our Company and our customers we need to be very careful with whom we work. So, we expect our business partners, suppliers, and third-party vendors to have the same values as we do and to comply with all applicable laws, regulations, and ethical guidelines.

Together we commit to: z Communicate our expectations to our suppliers and other business

partners z Screen new suppliers and vendors before making any formal agreement z Only engage new suppliers in a manner consistent with our global

sourcing policies z Report any possible violations of laws, regulations or of our Supplier

Code of Conduct

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Human RightsWe strive for excellence in our treatment of employees, and are committed to offering fair terms and conditions of employment. Our Values, Code, talent development strategies, and employment policies support the principles contained in the United Nations Universal Declaration of Human Rights and the International Labour Organization Fundamental Principles and Labour Standards.

Together we commit to: z Provide fair and equitable wages, working hours, benefits and other

conditions of employment in accordance with applicable laws z Recognize and respect employees’ right to freedom of association and

collective bargaining z Provide humane and safe working conditions z Prohibit forced labor, child labor, and human trafficking and ensure that

any association with the Company is made by free choice z Promote a workplace free of discrimination and harassment

Safety inthe Workplace

We Value Each Other

ExampleWe have a tight production schedule and I will need to clear a machine jam to keep the production running. It would take me less time if I do it while the machine is running, but I am concerned about how safe that practice is. What should I do?You should lock and tag the machine out before trying to clear the jam. No job is worth doing in an unsafe manner. If you have any doubts about the safety of any procedure, stop the work and address the issue to your manager or the safety manager at your site.

Example

Respect in the Workplace Standard

Health and Safety Management System Standard

My line leader was unhappy that we didn’t meet performance targets and told us to stop taking so many water breaks. What should I do?

Speak up and report the situation. Denial of water is an inhumane practice that could have unhealthy effects that are not acceptable at Autoliv.

Learn MoreLearn More

Autoliv is committed to ensuring a healthy and safe environment as part of each of our facilities’ activities and operations. Safety is more than an element of our business—safety is our business, in both the marketplace and the workplace. We believe that people are our most important resource. Our goal, as a Company, is to protect the health, safety, and wellbeing of our employees, visitors, and contractors while maintaining regulatory requirements.

Together we commit to: z Adhere to established health and safety standards z Work to prevent work-related accidents, injuries, and illnesses z Identify and eliminate unsafe conditions and behaviors z Continuously improve our health and safety management system and

performance z Prohibit the misuse of alcoholic beverages or prescription drugs, or selling,

purchasing, transferring, using, or possessing illegal drugs on Company premises or while on Company business

z Have a zero tolerance for workplace violence. We prohibit any act that could cause another individual to feel threatened or unsafe. This includes verbal assaults, threats, or any expressions of hostility, intimidation, aggression, hazing, or the possession of weapons in the workplace

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Respect in the WorkplaceAs One Autoliv operating in many countries, we treat everyone—including employees, candidates, customers, suppliers, partners, contractors, shareholders, and communities – with respect.

Together we commit to: z Strive to have a positive and diverse working environment z Ensure that we don’t discriminate against anyone because of age, race,

religion, color, gender, gender identity, sexual orientation, mental or physical disability, national origin/ethnicity, familial status, marital status, pregnancy status, height, weight, military/uniformed service, veteran status, citizenship, genetic information, or any other criteria or characteristic prohibited by law or otherwise irrelevant for the position

z Respect one another and value each other’s contributions z Treat each other with courtesy, consideration, and respect z Prevent and refuse to tolerate harassment of any kind

Privacy

We Value Each Other

ExampleWhat is considered personal data?

Any information that can be used to identify a specific person, such as name, address, birth date, phone number, driver’s license number, credit card information, or email address.

Example

Respect in the Workplace StandardData Privacy Policy

What is considered harassment?• Racial, ethnic, religious, or sexual jokes• Sexual advances or requests for sexual favors• Bullying, abusive language, physical aggression, intimidating or

violent behavior, disparaging comments, or otherwise unwelcome and inappropriate conduct—whether verbal, physical, visual, or electronic, whether committed in person or in some other way

Learn MoreLearn More

We are committed to respecting all employees’ privacy rights, and we take precautions to protect everyone’s personal data from unauthorized access, use, retention, and/or disclosure.

Together we commit to: z Keep personal data private z Use personal data only for specific purposes in accordance with the law and

all legitimate Autoliv requirements z Ask permission to share or use personal data for purposes other than the

ones for which the data was collected

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Anti-Corruption & Anti-BriberyWe have zero tolerance for corruption and any form of bribery. Bribery is giving or offering to give anything of value to improperly influence a business decision or government action. Autoliv and anyone who represents us must not participate in or endorse any form of corruption.

Together we commit to: z Never offer, request, accept, or indicate willingness to make or accept a

payment, benefit, or anything else that could be considered a bribe z Never accept or provide concealed commissions or kickbacks z Only offer or accept entertainment, meals, gifts, and/or travel to/from

government officials with prior consent from Legal z Consult with Legal in advance of any request for a donation to a

government official or government-affiliated charity using Company resources

z Only give or accept gifts or provide hospitality if doing so is legal and appropriate

z Only exchange gifts or entertainment in accordance with Autoliv policy

International Trade

We Value Integrity

ExampleOne of our customers requested delivery to a location which is under trade restriction. How should I handle this request?

You should contact a Trade Compliance expert in your Division and contact Legal if you need further support.

Example

Anti-Corruption and Anti-Bribery Standard Export Control Policy

A local inspector reports that there are unexpected issues associated with obtaining a permit/license, but he offers to settle the issue quickly for a small fee payment. Is there any problem with this?Yes. This proposal could indicate an improper payment (bribe or facilitation payment) to a government official. Report this immediately to Compliance or Legal.

Learn More Learn More

It is our policy to comply with all applicable export, import, and trade compliance laws in all countries in which Autoliv conducts business.

Together we commit to: z Never conduct business in any jurisdiction or with any company or person

that is subject to an embargo, sanctions, or comprehensive trade restriction without a review by Legal

z Follow anti-boycott laws z Comply with any trade sanctions that apply to our Company z Understand the Export Control Policy

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Conflicts of InterestWhen conducting business, the best interests of Autoliv should be foremost in the minds of everyone who works for the Company. A conflict of interest arises when your personal activities and relationships interfere, may interfere, or appear to interfere with your ability to act in the best interest of Autoliv.

Together we commit to: z Never take advantage of opportunities developed on the Company’s

behalf for our own or other’s personal profit z Never participate in outside work which interferes with our duties,

including the quality of our work and overall professionalism z Never have a significant financial interest in one of Autoliv’s competitors,

customers, or suppliers z Disclose if you are in a position where you have direct or indirect

decision-making authority over a family member or other individual with whom you have a close personal relationship and that person is employed by Autoliv

z Avoid any appearance of bias or favoritism

We Value Integrity

Example

Conflicts of Interest Standard

My brother started a new company and he is interested in being a supplier for Autoliv. Can I recommend his company?

Yes. However you must disclose the conflict of interest to Compliance and cannot be involved in the procurement process in any way.

Learn More

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Accurate Record Keeping & Records ManagementWe all record information when we design new products, log our work hours, or sign contracts with suppliers. When these records are accurate, we are able to make informed decisions about how to run our business, manage risks, and plan for the future.

Our collected records also help Autoliv fulfill our external obligations, such as financial disclosures, safety reporting, government reports, documents subject to litigation, and other requirements.

The integrity of Autoliv’s record keeping, record retention policy, and reporting systems is of utmost importance in order for us to comply with financial, safety, and other critical reporting regulations.

Together we commit to: z Keep accurate and timely records z Maintain records according to applicable Company standards, policies,

laws and regulations z Not misuse, intentionally conceal, alter, falsify, or omit information for

personal gain or to benefit others z Report concerns of fraud or abuse

Insider Trading

We Value Openness

ExampleAs an Autoliv employee, am I allowed to buy stock in one of our customer’s or supplier’s companies?Yes, you can. However, if you are aware of non-public information you could be considered an insider and you would be restricted from buying or selling using your knowledge. Check first with the Insider Trading Policy and seek advice from Legal if you are not sure.

Example

Records and Information Management Standard Insider Trading Policy

Can we split a large expense into different days to avoid having to request management approval?

No. Misclassification of expenses purposely to hide certain spending or to avoid required approvals is not permitted.

Learn More Learn More

Autoliv’s Insider Trading policy provides guidance and additional safeguards against unintended violations of securities trading laws and explains the restrictions on when employees may trade in Autoliv shares.

Together we commit to: z Be aware of the Insider Trading Policy z Not buy or sell Company stock based on inside information that is not public z Not participate in insider trading by buying or selling a Company’s stock

based on inside information about our Company or any of our suppliers or customers

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Any new inventions, processes, works of authorship, technology advances, or unique solutions to business problems (“Intellectual Property”) are critical to our ongoing success and must be protected.

Together we commit to: z Communicate to management any new Intellectual Property z Keep the information confidential z Protect our Intellectual Property under applicable patent, trademark,

copyright, or proprietary information laws and regulations z Not disclose trade secret z Respect the Intellectual Property and confidentiality requirements of third

parties z Secure all our and customers’ and suppliers’ confidential business information

Protect Our Intellectual Property

We Value Continuous Improvement of Products

ExampleI created a great new process for developing one of our products on my own time. I would like to be a consultant to show other companies how to implement this process. Would that be OK?No. Any Intellectual Property regarding Autoliv products is Autoliv property. Employees should not disclose such confidential information to our competitors, vendors or other external companies without confirming with Legal first.

Patent StandardLearn More

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Autoliv Helpline

helpline.autoliv.com

Country/Region Toll Free Number

Brazil 0800-892-1870

Canada 1-888-978-6858

China

4006-000761

NorthLandline 10-800-711-1177Mobile phone (010) 10800 711 1177

SouthLandline 10-800-110-1099Mobile phone (010) 10800 110 1099

*Estonia First dial: 800-12001, then dial access code: 888 978-6858

France 0800-91-0501

Germany 0800-183-0846

Hungary 06-800-20-219

India 000-800-100-1556

Indonesia 001-803-1-002-6647

Italy 800-870279

Japan00531-11-01860066-33-830414

Republic of Korea 00308-13-2721

Malaysia 1-800-81-6363

Mexico 001-888-978-6858

Netherlands0800-022-25340800-402-0010

*Philippines 1-800-1-111-0683

Poland 0-0 800-111-1990

RomaniaFirst dial: 0808-03-4288,then dial access code: 888 978-68580800 400949

Country/Region Toll Free Number

Russia First dial: 8^10-800-110-1011,then dial access code: 888 978-6858

South Africa0800-999-753800 000461

*Spain 900-98-1288

Sweden 020-790854

Taiwan 00801-10-4402

Thailand 001-800-11-002-6647

Tunisia 80 10 16 16

*Turkey First dial: 0811-288-0001, then dial access code: 88 978-6858

United Kingdom 0808-234-0961United States 1-888-978-6858

*Doesn’t support mobile dialing

References and Contacts

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AS 030 Autoliv Standard Environment Management System

AS 103 Autoliv Standard Patent

AS 251 Autoliv Standard Communications Policy and Guideline

AS 262 Autoliv Standard Information Technology

AS 263 Autoliv Standard Data Privacy Policy

AS 265 Autoliv Standard Data Classification Policy

AS 300 Autoliv Standard Legal Matters

AS 303 Autoliv Standard Records and Information Management

AS 304 Autoliv Standard Export Controls Policy

AS 310 Autoliv Standard Standards of Business Conduct and Ethics Guidelines

AS 312 Autoliv Standard Antitrust and Competition Policy

AS 313 Autoliv Standard Anti-Corruption and Anti-Bribery

AS 314 Autoliv Standard Insider Trading Policy

AS 315 Autoliv Standard Respect in the Workplace

AS 316 Autoliv Standard Conflicts of Interest

AS 319 Autoliv Standard Business Conduct and Ethics for Suppliers

HRS-ALV-001 Autoliv Standard Health and Safety Management System

Autoliv Financial Manual see LifeNET/Finance

The Corporate Governance Guidelines of Autoliv, Inc. see www.autoliv.com

WaiversGenerally, no one is exempt from any provision of our Code, regardless of position.However, in certain limited circumstances, the CEO together with Corporate Compliance may waive the applicability of a provision of our Code for employees.Any waiver of our Code for executive officers or directors may be authorized only by our Board of Directors or, to the extent permitted by the rules of the New York Stock Exchange, a committee of the Board of Directors and will be disclosed to stockholders as required by applicable laws, rules, and regulations.

Non-RetaliationAt Autoliv, we are committed to protecting individuals who make a report or participate in an investigation in good faith. “Good faith” means that you honestly provide all the information you have when making a report or participating in an investigation. It does not matter if you realize later that you were mistaken or if the incident reported was not a violation after all.Retaliation, harassment, and reprisals of any kind are not tolerated at Autoliv. In addition, no employee will be adversely affected because they refused to carry out a directive they believe constitutes fraud or a violation of laws, regulations, or our Code or any other Autoliv Standard. If you know or suspect that retaliation has occurred or is occurring, report the situation to Legal, to a Compliance officer, or to the Autoliv Helpline.

Key Contacts

Resource Contact About

Your Supervisor or Manager Any issue, concern or question

Your local HR representative

Any HR-related issues, questions or concerns

Legal Department Any violations of law, policies, rules, regulations, or our Code of Conduct

Compliance Officers Any ethical issues, questions, or concerns; violations of law, policies, rules, regulations or our Code of Conduct

Corporate Communications Office Questions from the media

References

34 | Code of Conduct Code of Conduct | 35

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January 2019

Saving More Lives.


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