CNH CODE OF CONDUCT: FOREWORD

CNH Global N.V. ("CNH" or the "Company") is an international company that, because of its size, activities and geographical spread, plays a significant role in the economic development and welfare of the communities where it operates.

The Company's mission is to grow and create value by supplying innovative products and services for maximum customer satisfaction with due respect to the legitimate interests of all categories of stakeholders (in the Code, "stakeholder" is taken to mean an individual, a community or an organization who influences the operations of one or more CNH companies and suffers the repercussions. Stakeholders may be internal [for example, employees] or external [for example, customers, suppliers, shareholders, local communities]), fair employment practices, safety in the workplace, and in full compliance with the applicable laws and regulative directives of the countries, in which a CNH company operates.

On the basis of the above principles, CNH is committed to conduct its business in a fair and impartial manner. All business relationships will be established and maintained with integrity and loyalty and without any conflict of interest between business and personal affairs.

To achieve this, the Company requires its employees to comply with the highest standards of business conduct in the performance of their duties as set out in this Code of Conduct ("Code") and the Policies referred to in this Code. The Code is a guide and a support for every employee and should enable him/her to pursue the Company's mission in the most effective manner possible.

The Code constitutes a fundamental element of the CNH internal control organizational model that CNH is committed to establish and develop.

In view of the above, the Company:
  • ensures timely dissemination of the Code throughout the Company and to all recipients of the Code;
  • ensures all updates and amendments to the Code are provided on a timely basis to all recipients of the Code;
  • provides appropriate training, information and consulting support to all in relation to any questions regarding the interpretation of the Code;
  • ensures that any employee who reports violations of the Code shall not be subject to any form of retaliation;
  • imposes fair sanctions proportionate to the violation of the Code and guarantees to enforce such sanctions equally amongst all categories of employees subject to the provisions of law, of contract and of internal regulations in force within the jurisdiction in which it operates;
  • regularly checks compliance with the Code.

The Company welcomes constructive contributions from employees and partners as to the Code's content. The Company shall use its best endeavors to ensure that all consultants, suppliers and any other party who has at any time a relationship with the Company share these commitments. The Company will not engage in or continue any relationship with those who expressly refuse to abide by the principles of the Code.
GUIDE TO THE USE OF THE CODE
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BUSINESS CONDUCT POLICIES
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EMPLOYEES
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EXTERNAL RELATIONSHIPS
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HEALTH, SAFETY & ENVIRONMENT
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ACCOUNTING & INTERNAL CONTROL
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IMPLEMENTATION & ASSURANCE
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APPENDIX A
DEFINITION OF SUBSIDIARY COMPANY

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APPENDIX B
INTERPRETATION AND REPORTING OF VIOLATIONS

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APPENDIX C
CODE OF CONDUCT REQUIREMENTS FOR FINANCIAL OFFICERS

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