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QUESTIONS & ANSWERS

Marelli Ethics and Compliance System - Commonly Asked Questions Reporting - General Reporting Security & Confidentiality Tips & Best Practices

Marelli Ethics and Compliance System - Commonly Asked Questions

What is the Marelli Ethics and Compliance System?

The Marelli Ethics and Compliance System is a comprehensive and confidential reporting tool to assist Marelli workforce members and third parties to report concerns or seek guidance regarding Marelli Group Code of Conduct or other corporate policies or applicable laws.

Why do we need a Marelli Ethics and Compliance System?

By creating open channels of communication, Marelli can promote a positive work environment. The Ethics and Compliance System allows for an effective reporting which will aid to foster a culture of integrity and ethical decision-making.

What is NAVEX?

NAVEX is an independent third party service provider that has been retained by Marelli to administer the Marelli Ethics and Compliance System and case management application.

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Reporting – General

What type of situations should I report?

Marelli Ethics and Compliance System is designed to ask questions and report any concerns pertaining to Marelli Group Code of Conduct, other corporate policies or applicable laws.

May a report be filed either via the Internet or the telephone?

Yes, the process allows for both web-intake and telephony services.

Why is it important to report a concern?

We all have the right to work in a positive environment. With this right comes the responsibility of acting in an ethical manner and letting the appropriate people know if you believe someone is not acting appropriately. By working together, we can maintain a healthy and productive work environment. Violations of the Code of Conduct, other corporate policies or the Law can threaten the assets, goodwill and reputation of an entire company. Reporting a concern allows those responsible for conducting due diligence to ensure the matter is properly addressed.

Where do these concerns go?

Concerns are entered directly into NAVEX's secure server to prevent any possible breach in security.

Who can access the reported concern?

Reported concerns are made available by NAVEX only to specific individuals within Marelli who are entrusted with evaluating the reports, based on the type of reported concern and location of the incident. These reports will be kept confidential to the fullest extent practicable under the circumstances.

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Reporting Security & Confidentiality

It is my understanding that any concern I send from a company computer generates a server log that shows every website my PC connects with; won't this log identify me as a report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to NAVEX is available when you access the Ethics and Compliance System. In fact, NAVEX is contractually committed not to pursue a reporter's identity. Marelli guarantees that tracing activities is not in place; in most countries it is even not permitted by Law unless required by local authorities under particular circumstances. However if you still feel uncomfortable making a report on your work PC, you have the option of using a PC outside of the work environment through the NAVEX secure website.

Can I file a concern from home and still remain anonymous?

No matter where a report is generated it will remain protected, confidential and anonymous. An Internet portal never identifies a reporter by screen name and the NAVEX system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX is contractually committed not to pursue a reporter's identity.

I am concerned the information I provide NAVEX will ultimately reveal my identity. How can you assure me that will not happen?

The NAVEX system is designed to protect your anonymity. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you - as a reporting party – should not reveal any identifying details as part of your report.

Is the telephone toll-free helpline confidential and anonymous?

Yes. A reporter will be asked to provide the same information that would be provided in an Internet-based report. The representative will type your responses directly into NAVEX's secure environment. Telephone helpline-based reports have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

Does it help if I identify myself?

Investigating a report is usually faster and more efficient when the Marelli Team is able to follow up on the issue directly with the person reporting the matter. If you have identified yourself, your confidentiality will be respected. Your identity will not be disclosed unless necessary for carrying out a proper investigation, required in the course of legal proceedings, or as required by local laws. Marelli will not tolerate any form of retaliation for reporting a concern in good-faith.

How can I monitor the progress of my concern if I choose to remain anonymous?

Once you have finished reporting your concern, you will be provided with a report key and asked to create a password. With these two pieces of identification, you will be able to follow up on a report, either by visiting the Ethics and Compliance System portal or contacting the telephone helpline. You may need to wait a few days after your submission before you can monitor progress and check whether you are being asked for any additional information. To allow for protection of the matter and any parties involved, details of the case cannot be provided.

What if I lose my report key or password?

In order to maintain the highest level of confidentiality, you will be asked to file a new concern if you lose either your report key or your password. You should mention that your new report relates to one filed earlier.

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Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I report the matter?

Marelli Group chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. Disastrous effects can occur in an otherwise seemingly harmless lapse of poor decision making. If you are made aware of any incident of alleged misconduct or ethical violation, consider it your responsibility to report the incident, no matter how trivial it may initially appear.

I am not sure if what I have observed or heard is a violation of Marelli Group Code of Conduct, Principles, company policy, applicable law or involves unethical conduct, but it just does not look right to me. What should I do?

File a concern. NAVEX can help you prepare and file your concern so it can be properly understood. Marelli would rather you report a situation that turns out to be harmless than let a possible unethical or illegal behavior go unchecked because of uncertainty.

What if my boss or other managers are involved in a violation? Will they get the report?

The NAVEX system and report distribution protocols are designed so implicated parties are not notified about or granted access to reports in which they have been named, unless required by local laws.

What if I remember something important about the incident after I file the concern?

When you file a concern via the Ethics and Compliance System either using the portal or through telephony, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

NAVEX provides functionality that enables Marelli representatives to post questions for you, even if you report anonymously, accessing the system with the unique report key received, providing the opportunity for such dialogue aids in investigating matters.

Are these follow-ups on reports as secure as the first one?

All NAVEX correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity, if you so choose, to the extent permitted by local law.

Can I still file a report if I don't have access to the Internet?

You can file a report via the Ethics and Compliance system from any computer that can access the Internet. If you do not have access to, or are uncomfortable using a computer, you can report by phone, 24 hours a day, 365 days a year. International dialing options are available, by country, on the Ethics and Compliance system website.

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