Navistar Supplier
Code Of Conduct

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CODE OF CONDUCT

Navistar corporate policy states that employees are prohibited from accepting certain gifts or entertainment from suppliers. The purchase and receipt of gifts and entertainment in excess of a nominal value, greater than $100 in cumulative value, is not permitted. Cash gifts or equivalents, (e.g., gift cards) may never be given or received in the course of conducting business. In addition, gifts or entertainment must not be given or received if the intent is to directly influence business decisions. The following list is meant to provide specific prohibited actions and should not be considered exhaustive:

1. Cash, gift cards, or loans.

2. Anything offered in exchange for something from Navistar.

3. A gift that is more than a nominal value (less than $100 in cumulative value for a rolling 12 months).

4. Transportation, travel expenses, or accommodations for trips that are not business related.

5. Donations for parties, including going-away parties.

6. Personal discounts that are not available to all Navistar employees or available to the general public.

7. Personal rebates or refunds that are a result of Navistar purchases.

8. Sponsorship for Navistar events or recreational activities (such as golf, softball, or bowling leagues).

9. Excessive or inappropriate meals or entertainment. Generally, an excessive amount would be an amount Navistar employees would not normally spend on themselves.

10. Alcohol for consumption on Navistar premises.

11. Entertainment where the supplier is not present and/or there is not a legitimate business purpose for the event, except when given as a nominal gift (refer to guideline 3). Supplier will refrain from offering gifts or entertainment to Navistar employees in compliance with the guidelines above. Supplier will not offer gifts or entertainment of any value in an effort to retain existing business or win new business.

Code of Conduct
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©2012 Navistar, Inc.