Supplier Code of Conduct

This Supplier Code of Conduct articulates the expectations of Cruise LLC (“Cruise”, "we," "us") for the conduct of its suppliers and business partners (together, “Suppliers”).

We expect our Suppliers to satisfy their contractual obligations, comply with applicable laws and regulations, and act in a way consistent with the principles and values of this Supplier Code of Conduct. Further, we expect our Suppliers to pass similar expectations through their own supply chains. This Supplier Code of Conduct outlines our expectations in five areas:

I. Business Integrity

II. Workplace Safety & Health

III. Environmental Protection

IV. Human Rights

V. Compliance & Reporting

We also expect our Suppliers to contact us promptly with any question or concern that they have related to issues governed by this Supplier Code of Conduct, subject to any restriction imposed by law. To ask a question or report a concern, Suppliers can directly contact their Cruise Purchasing and Supply Chain representative. In addition, Cruise's Compliance Assurance Reporting System ("CARS") allows Suppliers and others to report—anonymously, if the reporter chooses—concerns around anything illegal, unethical, or unsafe that could impact Cruise. Reports made via CARS can be filed 24 hours a day, 7 days a week by phone at +1-833-887-CARS (-2277) or on the web at www.getcruise.com/hotline.

I. BUSINESS INTEGRITY

a. Anti-Corruption/Anti-Bribery

Suppliers will not tolerate corruption, bribery, embezzlement or fraud in any form. This includes giving or receiving anything of value, including money, gifts or incentives to improperly influence negotiations or any other dealings with governments and government officials, state-owned enterprise employees, customers, or any other third parties.

b. Ethical Behavior

Suppliers will avoid conflicts of interest and operate honestly and ethically throughout the supply chain and in accordance with applicable laws, including those laws pertaining to anti-competitive business practices, respect for and protection of intellectual property, privacy and data protection of company and personal data, export controls and sanctions.

c. Reporting and Non-Retaliation

Suppliers will provide an adequate mechanism for their employees to report integrity concerns, safety issues and misconduct without fear of retaliation. Suppliers will also appropriately investigate reports and take timely corrective action, if needed. Suppliers will prohibit retaliation and have a zero tolerance policy for any instances of retaliation.

d. Stakeholder Engagement

Suppliers will communicate this Supplier Code of Conduct, or a substantially similar code, to their suppliers and subcontractors. Cruise also encourages Suppliers to continuously improve their stakeholder engagement, including by working with local communities to implement projects and strategies that improve the community and those who live there.

II. WORKPLACE SAFETY & HEALTH

a. Occupational Safety & Health

Suppliers will provide for their employees clean, healthy and safe environments that meet or exceed legal standards. Suppliers will have appropriate safety procedures for their employees and will take concrete steps to pursue a goal of zero workplace safety incidents. Supplier employees will have the right to refuse work they regard as unsafe, and Supplier will make available to its employees channels to report any conditions that do not meet these criteria.

b. Emergency Preparedness

Suppliers will institute appropriately detailed plans for potential emergencies and provide guidance to workers on emergency response procedures that will minimize harm to life, environment, and property.

III. ENVIRONMENTAL PROTECTION

a. Environmental Permits and Reporting

Suppliers will obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.

b. Responsible Stewardship & Continuous Improvement

Suppliers will look to conserve resources and protect the communities and environment that surround them. Specifically, Suppliers will endeavor to increase efficiency of resource usage throughout their companies and take measures to reduce their carbon footprint, energy use, water use, wastes, and other emissions.

IV. HUMAN RIGHTS

a. Forced Labor

Suppliers will not use slave, prisoner or any other form of forced or involuntary labor. Suppliers must take reasonable measures to ensure that all of their employees understand the terms of their employment.

b. Child Labor

Suppliers will not use child labor. Cruise has a zero-tolerance policy regarding the employment of children where the age of employment is not in accordance with applicable laws.

c. Human Trafficking

Suppliers will not engage, directly or indirectly, in human trafficking. Cruise prohibits human trafficking abuses.

d. Conditions of Employment

Suppliers will comply with applicable laws regulating work hours, wages and benefits. Suppliers' employees must be paid in a timely fashion that meets or exceeds legal minimum standards.

e. Labor Brokers

If a Supplier must use a labor broker, the Supplier will ensure the broker employs ethical recruitment practices, complies with applicable laws, and does not withhold identity documents.

f. Harassment & Discrimination

Suppliers will not discriminate on the basis of gender, color, race, national origin, religion, sexual orientation, age, veteran status, disability or gender identity. Suppliers' employees shall not be subject to any physical, verbal, sexual or psychological harassment or abuse in connection with their employment. Harassment or discrimination of any kind will not be tolerated.

g. Freedom of Association and Collective Bargaining

Suppliers will comply with applicable laws pertaining to employees’ rights to freedom of association and collective bargaining.

h. Supplier Diversity

Cruise supports enhancing business opportunities for qualified diverse businesses from underrepresented groups including but not limited to: ethnic-minority-owned, woman-owned, LGBT-owned, disadvantaged, and veteran-owned businesses. Suppliers should support diverse businesses throughout their own supply chain, providing equal access and equal opportunities to these businesses.

V. COMPLIANCE & REPORTING

a. Management System

Suppliers will develop and implement appropriate internal business processes and policies to: (1) ensure compliance with applicable laws and this Supplier Code of Conduct; (2) identify and mitigate related operational risks; and (3) facilitate continuous improvement in these regards. Suppliers will be able to demonstrate compliance with this Code upon our reasonable request and will take appropriate action to correct any identified non-compliance.

b. Information Disclosure

Suppliers will accurately record and disclose information regarding their labor, health and safety, environmental practices, business activities, structure, financial situation, and performance, without falsification or misrepresentation, in accordance with prevailing industry practices and as required by law.

Last updated March 4, 2020