Policies and Guidelines

Code of Conduct

At CNH Industrial, we are keenly aware of the significant role we play and the impact we have on the environment and the communities in which we operate.

CNH Industrial believes that operating in a socially responsible and ethical manner and in compliance with the laws of those countries in which we operate is fundamental to our long-term success. This means, among other things, that we adopt fair employment practices, protect safety in the workplace, support and foster environmental consciousness and fully comply with applicable laws.

Our Code of Conduct is the cornerstone of our compliance and ethics system. Our Code of Conduct summarizes our policies on various compliance and ethics issues (such as conflicts of interest, corruption, competition, and health and safety). While we comply with applicable local laws, in the event the laws of a particular jurisdiction are more lenient than those in our Code of Conduct, the higher standards of our Code of Conduct will prevail.

We endorse the Universal Declaration of Human Rights as set out by the United Nations, as well as the relevant conventions set out by the International Labor Organization and the Organization for Economic Co-Operation and Development’s guidelines for multinational enterprises.

Supplier Code of Conduct

CNH Industrial considers collaboration with its supply chain to be an integral part of its success and, therefore, strives to operate as an integrated team with its suppliers.

The selection of the Company’s suppliers is based not only on the quality and competitiveness of their products and services, but also on their adherence to acceptable social, ethical and environmental principles, which is a pre-requisite to becoming a supplier and developing a lasting business relationship with the Company.

In our Supplier Code of Conduct, we describe what we expect from our suppliers. Consequently, it is critical for our supplier to read and understand our Supplier Code of Conduct and act accordingly.

California Transparency in Supply Chains Act

A California law, the Transparency in Supply Chains Act of 2010, requires certain disclosures regarding human trafficking and slavery, in particular. We do not currently verify our product supply chain or audit suppliers specifically to evaluate risks of human trafficking and slavery or require our direct suppliers to certify that materials incorporated into products comply with laws regarding slavery and human trafficking in the countries in which they are doing business. We also do not currently maintain internal accountability standards for employees and contractors regarding slavery and human trafficking specifically or provide training to employees and management on these specific matters. CNH Industrial employees and management do receive regular training on Our Code of Conduct and are expected to respect the human rights and dignity of all people. Additionally, our Supplier Code of Conduct clearly establishes guidelines for the standard of ethical behavior expected from our suppliers. It states that suppliers may not use child or forced labor. Our Code of Conduct and the Supplier Code of Conduct are publicly available.

Integrity Helpline

CNH believes that operating in a socially responsible and ethical manner and in compliance with the laws of those countries in which we operate is fundamental to our long-term success. This means, among other things, that we adopt fair employment practices, protect safety in the workplace, support and foster environmental consciousness and fully comply with applicable laws.

The Board of Directors has established a procedure to ensure that the Company's employees and third parties have the possibility to report alleged irregularities of a general, operational and financial nature with the Company.

The Company's Integrity Helpline is managed by an independent third party and is available 24 hours per day/seven days per week/365 days per year. Reports may be submitted through a dedicated web portal (www.cnhintegrityhelpline.com), by phone (to a call center managed by a third party), or to a Company representative. Where legally permissible, reports may be submitted on an anonymous basis. In addition, where legally required, the nature of the reports may be limited to certain subject matters. The Company investigates reports submitted and, in appropriate cases, implements corrective actions.

If you become aware of a circumstance or action that violates, or appears to violate, CNH Code of Conduct, company policies or applicable law, you can seek guidance, or report a violation, by using the CNH Integrity Helpline, available at www.cnhintegrityhelpline.com.