Magna Code of Conduct and Ethics

To report suspected violations of Magna’s Code of Conduct and Ethics,

Gifts,Meals,and Entertainment

Our relationship with all of our business partners must be based on integrity and sound business

judgment. As a result, if we give or receive gifts or entertainment, we must be careful not to compromise,

or appear to compromise, our commitment to fair dealing and to making decisions that benefit Magna.

In our business relationships with customers or suppliers, it is acceptable to give or receive business gifts or

entertainment as long as they are reasonable, occasional and of modest value. Any gift or entertainment that we

provide must be recorded accurately and transparently in our expense reports and Magna’s books and records.

Because of increased legal risks, we must all take special care when dealing with

Offering gifts or entertainment to government officials requires written approval from certain authorized

persons in Magna. A discussion of the approval needed, as well as additional information about gifts and

entertainment can be found in our

Q: One of our suppliers has offered to fly me to see my favourite team play in the

championship. Is that okay?

A: No. Our business decisions must always be motivated solely by Magna’s best

interest. Accepting this extravagant gift would give the impression that you may

favour that supplier in future sourcing decisions. You may only accept business

gifts and entertainment that are reasonable, occasional and modest in value. If you

are ever in doubt, check with your General Manager or a Legal Compliance expert.

Q: A government auditor who has conducted environmental audits on my division

several times over the years is having a child next month. I would like to give him

a bottle of whiskey as a present. Would that be permitted?

A: Giving a gift or entertainment to a government official requires extra caution and

approval from an authorized person. You should speak to your General Manager

or a Legal Compliance expert.

Outside Positions

To help Magna succeed, we must devote our full time and attention to our jobs during working hours.

Therefore, you may not accept outside commitments that would reduce the time and attention you can

devote to your job.

Unless it has been discussed with a supervisor and the necessary authorizations have been obtained, you

are prohibited from accepting paid or unpaid positions that might pose a conflict of interest with Magna or

give that impression.