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24

MAGNA INTERNATIONAL | CODE OF CONDUCT AND ETHICS

The Good Business Line

If you are aware of a violation of this Code, or any related policies, you can always speak to your

supervisor or a Legal Compliance expert.

You can also contact Magna’s

Good Business Line

. You can submit a report online at

www.magnagbl.com

or you can look up the local, toll-free phone number for your country. This service is provided through

an independent, outside company and is available 24 hours a day, 365 days a year. Unless otherwise

prohibited by law (in which case you will be informed before you make your report), you can report your

concerns anonymously. However, please provide sufficient details so your concern can be investigated

effectively.

You should never hesitate to make a

good faith

report of a concern about any violations of the Code

of Conduct and Ethics. We prohibit anyone from retaliating against an employee who reports genuine

concerns in good faith. Retaliation can take many forms and includes being penalized, discharged,

demoted, suspended, threatened or harassed. We will not tolerate any such retaliatory actions taken

against a person who has reported a genuine concern about a violation of the Code of Conduct and Ethics.

Our

Policy on Anti-Retaliation

provides more information on this issue.

Q: I think my supervisor may be violating the Code, but I’m worried that

reporting his behaviour may negatively affect my employment. Will

Magna protect me if my supervisor finds out I reported his conduct?

A: Yes. Our

Policy on Anti-Retaliation

prohibits your supervisor from

taking retaliatory action against you and protects employees like you

who make good faith reports about violations of the Code.

Q: What happens when I report a violation using the

Good Business Line?

A: When we receive a report through the

Good Business Line ,

we

perform a thorough investigation to determine whether the Code has

been violated. We take care to conduct the investigation responsibly

and seek help from experts when appropriate. Any report of a

Code violation is initially reviewed by our

Good Business Line

Administrators (made up of Magna’s Chief Compliance Officer, Vice

President of Enterprise Risk Management, and at least one member

of the Corporate Legal department.) The Administrators determine

whether an investigation is needed and whether it should be handled

by the corporate office or at the group level. If an investigation is

required, it is conducted by a dedicated investigation team. The

results of the investigation are reported to the Good Business Line

Administrators along with recommendations for corrective and

disciplinary actions.