Ethical Business Practices

Our Corporate Compliance Office ensures the company has a comprehensive program to promote the company’s culture of compliance and ethics within our dynamic global business. The Corporate Compliance Office is part of Ford’s Office of the General Counsel and works with many other areas of the company to ensure an effective compliance program. Our compliance program is overseen by a committee of senior management and the Audit Committee of the Board of Directors.

The compliance program raises awareness of the company’s commitment to ethical practices, helps define corporate guidelines to operations through Policy Letters 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 legal risk assessments, and provides training and education on key legal and ethical risk areas. The Corporate Compliance Office works with outside consultants to review different aspects of the compliance program and implements appropriate improvements. In the past two years, the company’s Code of Conduct Handbook and risk assessment process have been externally reviewed. Currently, our Corporate Compliance Office is working to set up comprehensive, region-specific compliance systems in our newest region, Ford Middle East and Africa.

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 Policy Letters, Directives and standards for Ford personnel. It is available in 14 languages. The online version, available to company personnel, includes active links to the original source documents, thus providing a single source for the relevant information.

The Handbook outlines requirements for our employees and those working on behalf of the company 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 non-manufacturing employees and most contract personnel around the world are required to certify that they have reviewed the Handbook.

Training

To reinforce information contained in the Code of Conduct Handbook, we introduce new mandatory online training courses on a regular basis for our global nonmanufacturing employees and other targeted personnel. The courses focus 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, such as bribery. Recent courses have also covered the topic of protecting personal and company information. A new Code of Conduct online training course was introduced in December 2012. As of April 8, 2014, nearly than 95,000 individuals, or approximately 91 percent of those invited, had completed the course.

Reporting Violations

Another component of our compliance program is an infrastructure that encourages and allows for the reporting of any potential violations of our Policy Letters and Directives, and any violations of laws related to the business. Our nonmanufacturing work force and contract personnel are regularly reminded of their responsibility to report any known or suspected violation of the law or company policies. There are many ways for individuals to report such violations, including direct communications to a member of one of the control groups – such as the General Auditors’ Office, Human Resources, or the Office of the General Counsel – as well as telephone tip lines and email. All of our plants have posters describing how our manufacturing work force can centrally report. In addition, non-manufacturing employees must either report potential conflicts of interest, or attest (annually) that they do not have any conflicts of interest to report.

We assess compliance with our ethical standards through regular legal audits that cover a range of topics relating to legal requirements and internal policies.

Anti-Bribery/Anti-Corruption

Part of Ford’s philosophy as a company is to manufacture products close to where our consumers are located. We have 65 plants worldwide, and all of the countries in which these plants are located have their own business-related laws, with varying levels of enforcement and differing cultural norms. It’s essential to us that we conduct our business according to the highest ethical standards in every location in which we operate, and that we not acquiesce to local norms where those norms do not meet our high standards. We have clear policies in place relating to bribery and corruption, as well as procedures for reporting any breaches of those policies.

In 2012, we strengthened the anti-bribery/anti-corruption portions of our Global Terms and Conditions for non-production suppliers. In 2013, we expanded those same stronger provisions to the Global Terms and Conditions for production suppliers. Furthermore, we worked with one of our joint ventures in Asia to enhance their anti-bribery policies. In 2012 and 2013, we had portions of our anti-bribery program tested at several global locations, to be sure our anti-bribery program is effective in each area of the globe. We also continued to train key individuals throughout the company – those who may encounter bribery or corruption issues in the course of their work – in how to recognize and avoid problems.