Ethical Business Practices

Our Compliance Office has a comprehensive program in place to guide compliance with Ford Policies and Directives as well as key legal requirements. The Compliance Office is part of Ford's Office of the General Counsel. Our compliance program is overseen by a senior management compliance committee and the Audit Committee of the Board of Directors. The compliance program includes a variety of activities. The program raises awareness of the Company's commitment to ethical practices, defines corporate practices through Policies and Directives, ensures an infrastructure that allows for the reporting of Policy violations or business-related legal violations through a number of avenues worldwide, oversees the investigation of such reports, conducts risk assessments, and provides training and education on key legal and ethical risk areas.

Our Policy Letters and Directives formally establish expectations for our employees and others working on behalf of the Company, and our Code of Conduct Handbook is the fundamental tool for communicating these expectations.

The Code of Conduct Handbook, our chief ethical guidance document, is a compilation of the most important and relevant Policies, Directives and standards for Ford employees. It is available in 14 languages. The online version includes active links to the original source documents, thus providing a single source for the relevant information. The Code of Conduct Handbook underwent a major revision in 2007 to make it easier to understand and use as a reference manual.

The Handbook outlines employee behavior requirements and provides background resources for a wide range of business-related situations, including:

• The workplace environment
• Gifts, favors and conflicts of interest
• Use of company assets and data safeguarding
• Integrity of financial records
• Product quality, safety and environmental matters
• Intellectual property
• Working with governments (political activities)
• Competition and antitrust laws
• International business practices

All salaried employees and most contract personnel around the world are required to certify that they have reviewed the new Handbook.

To reinforce information contained in the Code of Conduct Handbook, we introduced a new mandatory online training course in 2009 for our global employees and other targeted personnel. The course focuses on ethics, conflicts of interest, gifts and favors – topics on which we have long provided employee training – as well as touching on additional issues that have global applicability. Through 2008, more than 98,500 individuals, approximately 90 percent of those invited, completed the previous training course. Similar results are anticipated for the new course.

In furtherance of our commitment to business ethics and compliance, every year we roll out mandatory online compliance training on important risk areas. Not only do these courses increase awareness, they also help our employees worldwide understand and access resources that enable responsible behavior and enhance regulatory compliance. Recent courses covered the topics of anti-bribery, internal controls and insider trading.

During 2008, we reviewed all of our 89 policies and directives, determining which were up-to-date, which required revision and which were obsolete and could be deleted. We also combined related policies. The result was a streamlined set of approximately 70 up-to-date policies and directives.

Another component of our compliance program is an infrastructure that allows for the reporting of any potential violations of our Policies and Directives, and any violations of laws related to the business. Our nonmanufacturing workforce and contract personnel are regularly reminded of their responsibility to report any known or suspected violation of the law or Company Policy, as are our manufacturing workforce in plants through posters. There are many ways for individuals to report known or suspected violations, including direct communications to a member of one of the control groups – such as the General Auditors Office or the Office of the General Counsel – as well as telephone tip lines in many regions, email and Company intranet sites.

We assess compliance with our ethical standards through regular legal audits that cover a range of topics relating to legal requirements and internal Policies. These are in addition to audits regularly conducted on issues such as workplace health and safety.

In addition, we are currently analyzing our North American, South American, Asia Pacific Africa and Ford of Europe business units for risks related to corruption. When we become aware of any "red flags" that indicate there may be issues regarding allegations of, or suspected, corruption, we investigate and take appropriate actions as necessary based on the outcome of the investigation and situation.