Code of Conduct and Ethics

What is the Code?

The Code is a document adopted by the FCA Executive Committee which summarizes the principles of business conduct for the FCA Group and sets down the duties and responsibilities
for senior management, managers and other employees. The Code issued by FCA Group is a key element of the Group's policy for ensuring effective prevention and successful identification of violations of legislation and other state directives or guidelines that apply to the individual areas
of activity.

Who does the Code apply to?

The Code applies to all members of the supervisory board, all senior management, managers and staff of all companies controlled by FCA Group and to all other individuals or companies acting in the name of FCA Group. FCA Group is endeavoring to ensure that, in all companies in which it has a minority holding, Codes of Conduct are used that mirror this Code or, at the very least, do not contradict it. FCA Group's aim is for third parties with whom it already has long-term business relationships, such as advisors, representatives, dealers or suppliers, for example, to see the Code as setting the trend in terms of a standard for business conduct.

Where will the Code be used?

The Code is to be used in all countries where FCA Group has representation. It can be applied to all areas of activity of FCA Group.

How do I get a copy of the Code?

The Code can be viewed by all senior management, managers and all other employees in a suitable format depending on local practices. The Code of Conduct can be viewed on the FCA Group website (www.fiatgroup.com) and downloaded free from the Intranet. Copies of the Code can also be requested from Human Resources, the Legal Department, from Internal Audit Officers or from the Compliance Officer for the area of business in question.

Can the Code be changed?

The Code is reviewed by the FCA Board of Directors. The review takes into consideration, among other things, constructive feedback and suggestions from senior management, managers, other employees and third parties; it also takes account of changes to legislation and best practice in international business, and experience gained from applying the Code. Any changes that are introduced to the Code as a result of this review will be publicized and made available as described above.

Does the Code of Conduct cover all eventualities?

The Code of Conduct reflects the fundamental ethical values that should be upheld by all members of the supervisory board, managers, other employees of FCA Group and individuals or companies acting in the name of FCA Group. The Code is to be read and interpreted with reference to company policies and guidelines of the FCA Group. These policies and guidelines are a core component of the Code and can be viewed on the FCA Group website (www.fiatgroup.com) and on the Intranet.