CODE OF CONDUCT AND ETHICS POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES

Transcription

1 CODE OF CONDUCT AND ETHICS POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES Magna Internatinal Inc. Plicy n Gifts & Entertainment 1

2 POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES Magna is cmmitted t ensuring that it cmplies with the laws f all jurisdictins in which it des business, including sanctins laws and regulatins. This Plicy applies t all emplyees f Magna Internatinal Inc., and its perating Grups, Divisins, jint ventures and ther peratins glbally (cllectively, Magna ). This plicy als applies t all persns wh act n Magna's behalf, including emplyees, fficers, directrs, cnsultants and agents. Yu, must cmply with all applicable laws and regulatins ( Sanctin Laws ) regarding restrictins n engaging in business with: cuntries r plitical subdivisins f cuntries that are subject t sanctins (cllectively, Sanctined Cuntries ); and persns, cmpanies r entities, including representatives and agents theref, that are dmiciled in Sanctined Cuntries r are listed n natinal r internatinal sanctin lists (cllectively, Sanctined Persns ). What is a Sanctin r Trade Embarg? Sanctins and trade embarges are measures implemented by a gvernment r an internatinal rganizatin such as the United Natins. They are intended t pressure the gvernment f the Sanctined Cuntry, r the Sanctined Persns, t change plicies r practices alleged t be harmful t internatinal peace and security. What D Sanctin Laws Prhibit? Sanctin Laws restrict r prhibit different things, depending n the Sanctined Cuntry and Sanctined Persn invlved. Sanctin Laws typically place restrictins and cntrls n the mvement f gds, services r funds. Sanctin Laws may, but d nt necessarily, restrict r prhibit the: Sale r purchase f any gds, services r technical infrmatin t r frm anyne in a Sanctined Cuntry; Sale r purchase f any gds, services r technical infrmatin t r frm a Sanctined Persn wherever that persn may be lcated; Transfer f funds t r thrugh any Sanctined Cuntry r Sanctined Persn, as well as receipt f funds frm a Sanctined Persn (e.g., a bank); and Sale f any gds, services r technical infrmatin t a permitted persn in a permitted cuntry, if the seller knws that the gds, services r technical infrmatin is intended fr a Sanctined Cuntry r t a Sanctined Persn. Hw des a Cuntry r Persn becme a Sanctined Cuntry r Sanctined Persn? Typically, a cuntry, individual r cmpany faces sanctins r embarges because it is alleged t engage in certain types f illegal activity, such as terrrism, human rights vilatins, unlawful Magna Internatinal Inc. Plicy n Cmpliance with Sanctins & Trade Embarges 2

3 exprts, nuclear prliferatin, and ther criminal actins. Sme f the key perating jurisdictins f Magna (i.e. Canada, the United States and the Eurpean Unin) prepare and publish lists f Sanctined Cuntries and Sanctined Persns. Plicy Magna will nt enter int business transactins with r invlving any Sanctined Cuntry r Sanctined Persn. If yu becme aware f an existing r pssible business transactin with r invlving any Sanctined Cuntry r Sanctined Persn, prmptly cntact yur supervisr, a Grup, Reginal r Magna Crprate lawyer, a Reginal Cmpliance Officer r the Gd Business Line. Please nte that as Magna s shares are traded n the New Yrk and Trnt stck exchanges, Magna s plicy is t cmply glbally with the Sanctins Laws f the United States and Canada in all f its glbal peratins. In additin, the Eurpean Unin and mst f the cuntries in which Magna perates als have restrictins n trading with Sanctined Cuntries and Sanctined Persns. Sanctined Cuntries Sanctin Laws can change frequently. T ensure that yu have the latest infrmatin, please cnsult the fllwing websites and, if necessary, check with a Grup, Reginal r Magna Crprate lawyer fr further advice. Canada: Vilatins Magna has n tlerance fr cmpliance vilatins. Any vilatin will be treated as a serius matter and will be sanctined with disciplinary actin up t and including terminatin f emplyment fr cause. If yu are aware f r suspect that anyne is in vilatin f Magna s Cde f Cnduct and Ethics r this plicy, yu shuld reprt yur cncern by infrming (i) yur manager, (ii) a Grup, Reginal r Crprate lawyer, (iii) a Magna Cmpliance Officer r (v) Magna s Gd Business Line. Pursuant t the Plicy n Anti-Retaliatin, Magna will prtect emplyees frm being penalized, discharged, demted, suspended r discriminated against fr reprting in gd faith any vilatin f Magna s Cde f Cnduct and Ethics r this plicy. FOR FURTHER INFORMATION: Fr further infrmatin r advice, please cntact yur Grup r Reginal Legal Cunsel, a Magna Cmpliance Officer r Magna s Vice-President, Ethics and Chief Cmpliance Officer. Effective: April 1, 2017 Owner: Ethics and Legal Cmpliance Review Date: April 1, 2019 United States: Eurpean Unin: United Natins: Set frth n Schedule A is a list f cuntries which are Sanctined Cuntries r sme f whse entities r citizens are Sanctined Persns. If yu are cntemplating business transactins in the cuntries listed n Schedule A, yu must cnsult a Grup, Reginal r Magna Crprate Lawyer, r a Reginal Cmpliance Officer. Magna Internatinal Inc. Plicy n Cmpliance with Sanctins & Trade Embarges 3

4 SCHEDULE A Belarus Burma Burundi Central African Republic Cuba Ivry Cast Demcratic Republic f the Cng Eritrea Iran Iraq Lebann Libya Nrth Krea Russia Smalia Suth Sudan Syria Tunisia Ukraine Venezuela Yemen Zimbabwe Last updated: April 1, 2017 Magna Internatinal Inc. Plicy n Cmpliance with Sanctins & Trade Embarges 4

5