Supplier Code of Conduct

Responsible business

General Expectations

Working in adherence with all applicable laws and regulations is a basic requirement for all suppliers. We also firmly believe that working relationships based on high standards of ethics and integrity enable the most productive partnerships.

All suppliers should think proactively about the training, controls, and monitoring processes to help them implement their own responsible business practices, including business continuity plans, to appropriately manage their legal and compliance risks.

Anti-Corruption & Bribery

All suppliers must comply with global Anti-Corruption & Bribery regulations such as the US Foreign Corrupt Practices Act, the UK Bribery Act, and article 164 of the Chinese Criminal Code. Therefore, all suppliers must have zero tolerance for any form of bribery, in any business dealings, in any location. This means all suppliers must inform and monitor all employees, agents, and others working on their behalf to never offer, promise, request, or receive anything of value, either directly or indirectly (i.e., via a third party), to improperly influence or perform any business decision or task or to gain any other form of unfair advantage. This covers dealings with both private individuals and government officials.

Extra caution should be applied to dealings with government officials. Accurate books and records must be maintained to enable appropriate monitoring and review.

To the extent any gifts or hospitality are proposed between a supplier and Autoliv, this must be done with transparency and never in a manner that could raise allegations of bribery or the creation of a conflict of interest.

Should a supplier become aware of any incident or suspicion of bribery or corruption (including fraud, money laundering, embezzlement, or extortion) impacting their business dealings with Autoliv or involving any Autoliv employee, they must report this immediately. For reporting options please see www.autoliv.com/speak_up on the Supplier Portal.

Conflicts of Interest

All suppliers, their employees, and their own suppliers must be encouraged and supported to make fair decisions based on objective criteria.

Adequate training should be provided to help identify and avoid conflicts of interest impacting any business dealings with Autoliv.

Counterfeit Parts

All suppliers must work to minimize the risk of introducing counterfeit parts and materials into deliverable products. To support this commitment, they must establish meaningful processes to detect counterfeit parts and materials.

Should a supplier become aware of counterfeit parts or materials impacting their dealings with Autoliv, they must report this to Autoliv immediately.

Data Privacy & Confidential Information

All suppliers must follow applicable data privacy laws and have appropriate systems, training, and controls in place to help ensure that personal data is only collected, used, stored, and deleted in accordance with these obligations. All suppliers must also ensure these data privacy obligations are followed by their own suppliers for any personal data shared by Autoliv with them or for any personal data they may collect regarding work involving Autoliv.

If a supplier becomes aware of a breach of personal data impacting Autoliv, they must report this to Autoliv without undue delay or as contractually agreed.

In addition to specific data privacy requirements, all suppliers must respect and protect entrusted confidential and sensitive information with due care. They must also ensure the cybersecurity of its operations by understanding the risks and implementing sufficient controls.

All suppliers must report any suspected or alleged impermissible use of such sensitive and confidential information which could have a negative impact on Autoliv.

Export Controls & Sanctions

All suppliers must stay up to date with the global trade, export control, or economic sanction laws that impact their business dealings. These laws can cover a wide range of activities, and all suppliers must maintain appropriate systems and controls to support their adherence.

Should a supplier become aware of a breach or possible breach of any trade, export control, or economic sanction laws impacting their dealings with Autoliv in any way, they must report this to Autoliv immediately.

Fair Competition

All suppliers must comply with applicable competition and antitrust laws. All suppliers must avoid business practices that unlawfully restrain competition, including through price fixing, bid rigging, market allocation, and improper exchange of competitive information, whether with competitors or via their own suppliers. When interacting with competitors of Autoliv, all suppliers must not disclose any sensitive Autoliv information or facilitate such exchange.

All business statements and communications should be truthful and accurate.

Financial Responsibility & Accurate Records

All suppliers must maintain accurate business records across all elements of their business operations involving Autoliv from product inspections, time recording, and safety reporting through to financial accounting and environmental reports. All suppliers must act in accordance with generally accepted accounting principles, and the accounting records must show the nature of all transactions in a correct and non-misleading manner. This includes following obligations regarding expected disclosures of financial and non-financial information in accordance with applicable regulations and prevailing industry practices.

Responsible Sourcing of Materials

All suppliers are required to ensure that sourcing of materials and services to Autoliv is managed in an ethical, sustainable, and socially conscious manner. Sourcing policies should be aligned with the principles established by the International Labour Organization (ILO) and the United Nations Guiding Principles for Business and Human Rights (UNGPs). All suppliers must conduct appropriate due diligence to ensure any items sourced to Autoliv do not contribute to human rights abuses or ethical violations or negatively impact the environment.

These commitments must be supported and evidenced by appropriate due diligence across the entire supply chain, particularly regarding minerals and metals (e.g., cobalt sourcing details). Due diligence work must be available for Autoliv inspection upon request, and all suppliers must be willing to support Autoliv efforts to gain maximum transparency and traceability for all critical raw materials. Autoliv requires all smelters for cobalt and conflict minerals (3TG) to be compliant with the Responsible Minerals Assurance Process (RMAP), RMAP Conformant or Active, or open to RMAP audit.

Responsible Tax Practices

All suppliers must pay all tax obligations, meet relevant payment deadlines, and fully comply with all relevant tax laws and accounting rules and regulations in the tax jurisdictions in which they operate. All suppliers are expected to be open and transparent with tax authorities about their tax liability.