Global Responsible Purchasing Guidelines

Supplier that may justify immediate termination of the

Foreword contract(s) and consequently of the business
relationship under the applicable terms and conditions
The group of Stellantis companies (“Stellantis”) considers of purchase; or
collaboration with the supply chain an integral part of its success
• Stellantis may require that Supplier implements an action
and, therefore, strives to operate as an integrated team with
plan to put in place corrective actions to bring its
suppliers. The selection of suppliers is based not only on the
performance into line and shall provide Supplier
quality and on competitiveness of their products and services,
support to jointly define the required remedies, as
but also their adherence to social, ethical and environmental
appropriate. If the required remedies cannot be jointly
principles. Your agreement to comply with these Global
defined, Stellantis reserves the right to immediately
Responsible Purchasing Guidelines (the “Guidelines”) is a
terminate, under the applicable terms and conditions of
prerequisite to becoming or continuing to be a supplier to
purchase, the contracts between Stellantis and Supplier
Stellantis (a “Supplier”).1Your acceptance will bind you and any
and consequently the business relationship.
of your affiliates and subsidiaries that provide goods or
services to Stellantis. • if the required remedies are jointly agreed to, Stellantis
may conduct follow up audits to verify implementation
Please sign these Guidelines in the space provided below.
of the jointly planned remedial actions. If such remedial
These Guidelines will be accepted and become effective
actions are not implemented, Stellantis reserves the
immediately upon your signature or, in the absence of your
right to immediately terminate, under the applicable
signature, upon your commencement of any work or services
terms and conditions of purchase, the contracts
for Stellantis.
between Stellantis and Supplier and consequently the
Stellantis takes the 2030 United Nations Sustainable business relationship.
Development Goals as a framework for its actions in the
transition to a more sustainable future.
• Appropriate Grievance Reporting Mechanisms

Stellantis commits to contributing to a decarbonized economy Supplier commits to implement grievance mechanisms (e.g.,
by engaging its talents and assets across its products, plants, whistleblowing lines) accessible to its employees, business
and other facilities. Stellantis is strongly involved in partners, and the public. Such mechanisms will allow
environmental issues (greenhouse gas and pollutant Suppliers’ employees, business partners, and the public to
emissions, recycling, the use of natural resources, circular express concerns without fear of intimidation, harassment,
economy, etc.) and expects not only support from Suppliers retaliation, or violence.
throughout the entire lifecycle of a vehicle but also innovative • Reporting Non-Compliance to Stellantis
proposals contributing to its ambitions announced publicly.
With respect to the goods or services that Supplier delivers to
Stellantis endorses the principles included in the Global Stellantis, Supplier: (i) confirms to have processes in place to
Compact and core International Labor Organization prevent, detect, investigate, mitigate, and remediate any non-
conventions as key elements in the development of these compliance with the requirements set forth in these
Guidelines and commits to respect the OECD Guidelines for Guidelines, working with potentially affected stakeholders as
Multinational Enterprises adopted in 2011 as well as the Guiding appropriate; and (ii) must report any non-compliance with
Principles on Business and Human Rights (“Ruggie Principles") these Guidelines to Stellantis and commits to zero retaliation
approved in 2011 by the United Nations Human Rights Council. against individuals who make reports in good faith. Stellantis
Stellantis is signatory of the United Nations Women's will work with Supplier to resolve any such non-compliance
Empowerment Principles. as necessary, reserving, however, its right to terminate the
business relationship for non-compliance as set forth in the
Supplier selection and retention in the Stellantis
preceding paragraphs.
suppliers panel is guided by corporate and social
responsibility (CSR) criteria The preferred method for reporting non-compliance is the
Stellantis Integrity Helpline, which is available to employees,
• Assessing, Monitoring and Remedial Actions business partners and the public worldwide, via telephone or
Supplier’s social and environmental performance is regularly web. Web access is available at the following link:
assessed by a third party. This assessment covers, amongst www.integrityhelpline.stellantis.com
others, the following topics: environment, labor practices,
working conditions, business ethics and sustainable
procurement. The assessment is used for defining (i) the risk Compliance with social principles
of a Supplier’s non-compliance with the principles set forth in
these Guidelines and (ii) the sites to be audited. • Support and respect the protection of internationally
In the event of non-compliance by Supplier with the principles set proclaimed human rights
forth in these Guidelines: Supplier respects human rights in all countries in which it
• the non-compliance may be considered a material operates, including in geographical areas where human rights
breach of the contract(s) between Stellantis and may not yet be sufficiently protected.

1
But note that your agreement to these Guidelines does not constitute a business award or mean that you have been accepted as a supplier to Stellantis.
Supplier agrees to work towards preventing situations of opportunity and the absence of any policy aimed at, or indirectly
complicity or acts of collusion concerning fundamental human resulting in, discrimination towards them on any basis prohibited
rights violations. by law, including, as applicable, but not limited to, race, gender,
sexual orientation, health condition, disability, age, nationality,
Supplier pledges its commitment to fulfill its responsibility
or religion (in accordance with applicable laws and regulations
towards respecting human rights in its operations and
and consistent with the spirit underlying ILO Convention 111).
throughout its entire supply chain.
• Remuneration
• Uphold freedom of association and the effective
recognition of the right to collective bargaining Supplier is committed to ensuring that remuneration is at least
equal to the minimum amount mandated by applicable laws
Supplier shall: (i) support its workforce’s freedom of association and regulations (and legally guaranteed minimum for a
and the right to be represented by trade unions or other profession, if any) or as set forth in the relevant collective
representatives, in accordance with applicable local legislation bargaining agreements. Supplier is committed to the principle
and consistent with the spirit underlying the ILO that its compensation should seek to provide its workers and
recommendations (ILO Convention 87); and (ii) abstain from their families decent wages to afford reasonable and adequate
forms of anti-union activity that are not consistent with local shelter, food, and other necessities.
legislation. Supplier is committed to good faith collective
bargaining, a key aspect of relations between labor and Supplier is expected to commit to the principle of equal pay for
management (ILO Convention 98). equally valued and productive work, between men and
women (ILO Convention 100).
• Eliminate all forms of forced labor and child labor
• Working hours
No form of labor practice involving forced, compulsory, child
labor, or human trafficking is tolerated. Supplier must not Supplier is committed to complying with applicable laws,
engage in, and will require its suppliers to not engage in, regulations, ILO Conventions 1 and 30, and/or automotive
directly or indirectly, child or forced labor practices. Supplier standards, collective bargaining, and practices applicable in
recognizes the principle of the freedom of choice of those countries where it operates, whichever is strictest,
employment. Labor is deemed to be forced or compulsory: (i) regarding working hours, fair compensation break times and
when it is imposed by means of a threat (withholding of food, periodic days off.
confiscation of land, non-payment of salary, physical violence,
• Respect for health and safety at work
sexual abuse, or non-voluntary prison labor, etc.) (ILO
Conventions 29 and 105) or by illegitimately restricting Stellantis strives for an accident-free workplace. Supplier is
workers’ freedom of movement, for example by denying their committed to implementing effective occupational health and
access to government-issued identity documents; and (ii) in safety policies and procedures that meet or exceed applicable
case of: employment of children in violation of the laws and regulations with the goal of zero workplace safety
International Labour Organization's conventions (ILO incidents. These policies and procedures should be applied at
Convention 138 and 182); participation in state-sponsored Suppliers’ various sites in the form of concrete action plans
compulsory labor transfer programs or programs for the that involve each employee at their level of responsibility in
conscription of laborers; isolation of workers in worker the company, including labor and management
internment camps, and others. Supplier acknowledges the ILO representatives. Supplier employees will have the right to
11 indicators of forced labor and represents that none of such refuse to work in unsafe work conditions without the fear of
indicators shall be present within its supply chain. retaliation (ILO Convention 155).
Supplier acknowledges Stellantis’ initiatives to eliminate • Respect for vulnerable groups
forced labor from its supply chain and agrees to undertake
measures to detect and eliminate forced labor from its own Stellantis recognizes and respects the rights of vulnerable
supply chain. Such measures include identifying the goods it populations around the world such as children, migrant
supplies to Stellantis with and providing trade documentation, workers, minorities, persons with disabilities, indigenous
in the shape and manner requested by Stellantis, when peoples, and women. Suppliers are expected to similarly commit
requested, that traces the goods or its components to protecting the rights of these groups, implement measures to
throughout the Supplier’s supply chain to the original source. address any health and safety concerns specific to these groups
Supplier shall cooperate with Stellantis programs to map the and work to extend them to their supply chain.
Supplier’s supply chain and/or to obtain from that supply chain • Respect for local communities
any specific information/ documentation for goods that
Stellantis purchases from Supplier, including shipping Stellantis requests Supplier to behave in a socially responsible
documents, bills of lading, etc. Supplier understands that time manner by respecting the rights of local communities and
will be of the essence in such requests and agrees to devote indigenous people, including their cultures and traditions in
best efforts and resources to achieve the timelines that each country in which they operate. If needed, the Supplier can
Stellantis may establish for such activities. cooperate with local organizations to facilitate dialogue with
the concerned communities.
• Eliminate discrimination with respect to employment
and occupation • Non-Retaliation

Supplier’s employees must be treated in a fair and non- Stellantis expects Supplier to prohibit retaliation against
discriminatory manner, with the guarantee of equal anyone who makes a good faith report of a violation of policy

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or law. This includes but is not limited to employees, suppliers, throughout the supply chain to focus on land use while having
stakeholders, and human rights defenders. Human rights appropriate monitoring, traceability, and implementation of action
defenders are internationally recognized individuals or groups plans to address these issues and ensure a net-positive impact.
who promote and protect internationally recognized human Stellantis intends to have a deforestation-free supply chain, and
rights and fundamental freedoms through peaceful and legal expects Supplier to take specific measures, including due diligence
means. Supplier commits to neither tolerate nor contribute to throughout its supply chain, to prevent or mitigate the risk of
threats, intimidation, or attacks against human rights deforestation, in alignment with the United Nation’s New York
defenders in relation to their operations to create safe and Declaration on Forests and the OECD-FAO Business Handbook on
enabling environments for civic engagement and human rights Deforestation and Due Diligence in Agricultural Supply Chains.
at local, national, or international levels.
Supplier undertakes to forbid deforestation or land conversion
throughout its supply chain. For the high-risk regions and
Environmental protection supply chains mentioned above, Supplier commits to provide
to Stellantis:
• System of environmental quality management • a detailed mapping of its supply chain (from the “farm”
or “mine” to the plant) that includes the address of each
To minimize the impact of production processes and products
manufacturing site;
on the environment, Supplier should: (i) make every effort to
• a public deforestation-free and land conversion- free
optimize the use of resources and minimize pollution and
commitment, published on its website in a transparent
greenhouse gas (“GHG”) emissions in its production as well as
manner
its supply chain ; (ii) design and develop products taking into
• a time-bound plan with clear actions and milestones to
account the impact they have on the environment and the
meet that commitment;
potential to reduce, re-use and recycle them; (iii) properly
• supply chain management systems in place to deliver on
manage, in compliance with any applicable laws, air emissions,
the commitment;
water discharges, and waste treatment and disposal; (iv) avoid
• regular public reporting of progress; and
the use of potentially dangerous substances (as defined by
• independent verification of the systems used to deliver
current legislation); and (v) apply a logistics management that
the deforestation-free and land conversion-free
takes environmental impacts into consideration.
products.
Supplier must have an Environmental Management System
Stellantis will rely on Suppliers that are actively implementing
(EMS) that complies with local law. Certification of the EMS
deforestation-free supply chains, with tangible results coming
according to international standards (i.e. IS014001, EMAS or
from reliable initiatives and local agreements or partnerships.
equivalent) is strongly recommended for manufacturing
These Guidelines are a component of Stellantis global GHG
processes of large scale or having a significant influence on the
footprint reduction strategy and ambition to be carbon net
environment.
zero by 2038.
• Research and environmental policy
Compliance with ethical principles
Stellantis endeavors to research and promote innovative
technical solutions contributing towards lowering the • Prohibited substances and materials
environmental impact of the vehicles it manufactures.
Consequently, Supplier is committed to adopting a policy in the The supplies, products or goods bought from the Supplier by
field of research to develop its products and bring them up to a Stellantis, whether they are standard or specifically developed
still higher standard in terms of respect for the environment. by the Supplier for Stellantis, must respect legislations or
regulations applicable in the production countries and the areas/
Supplier shall meet the commitment of Stellantis to green countries where the product is sold or used (European Union,
materials by proposing solutions integrating recycled materials etc.), including laws and regulations that require traceability of
and / or materials of natural origin with a lower carbon substances of concern for the protection of health or the
footprint than the original. Moreover, it is committed to environment.
contributing to the objective of recyclability of vehicles
through its material proposals. Supplier must produce a • Prohibited practices
complete material itemization of its goods. Supplier will abstain from conducting, directly or indirectly, any
Supplier undertakes to implement a policy to reduce GHG form of torture, cruel, inhuman or degrading treatment
emissions in order to contribute to Stellantis’ Carbon Net Zero practices, war crimes, crimes against humanity, support of non-
roadmap 8. To this end, it will: (i) communicate each year to state armed groups in any activity related to the supply of goods
Stellantis the GHG emissions related to the production, or services to Stellantis, including but not limited to the
upstream and downstream transport of the goods and services extraction, transportation, distribution and sale of minerals, or
purchased by Stellantis (scope 1, 2 and 3); and (ii) answer Part other serious violations of international law.
Carbon Footprint information requests ensuring its accuracy.
• Material due diligence and fight against the use of conflict
• Prevent deforestation & land conversion minerals
Deforestation and land conversion are two of the key Stellantis seeks to: apply the principles of responsible sourcing
challenges that exacerbate both the climate and biodiversity of parts and components including raw materials and minerals,
crises. Stellantis engages with all its Suppliers globally and exercise its duty of vigilance and participate in the

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development of responsible procurement. Stellantis’ policy is licenses to Stellantis, Supplier will provide to Stellantis the
to establish transparency with Suppliers on the origin of information necessary to ensure compliance with Export
minerals used in particular from conflict affected and high-risk Control & Sanctions Laws, including any potential military use
areas (CAHRA) including but not limited to, tungsten, or military end-user of such goods, Export Control
tantalum, tin and gold (known as “3TG”) as defined by the Classification Number (ECCN), percent (%) of U.S. content, or if
OECD Due Diligence Guidance for Responsible Supply Chains requested, of other country or regional content prior to the sale
of Minerals from Conflict-Affected and High-Risk Areas or Supplier’s start of real production (“SORP”), whichever is
(“OECD Due Diligence Guidance”). earlier. Licenses or other authorizations required for the export
of goods or services, or to conduct business in sanctioned
Supplier is expected to: (i) have or implement policies committing
countries or with sanctioned entities or persons, will be the
to responsible sourcing of minerals and materials; (ii) utilize
responsibility of the Supplier unless otherwise agreed in the
due diligence frameworks and systems consistent with OECD
contract entered into with Stellantis, in which event Supplier
Due Diligence Guidance to conduct due diligence; (iii) and
shall provide all necessary information as may be requested by
require their suppliers to adopt management systems and
Stellantis to request such licenses or authorizations.
practices that are aligned to these Guidelines and the OECD
Due Diligence Guidelines. Supplier will refer to any
recommendation from the legislators about the extension of
the list of materials or risk areas. Compliance with laws
Supplier undertakes to submit in writing to Stellantis the
results of efforts that comply with legally applicable standards
Stellantis expects Supplier to: (i) be fully compliant with all laws
regarding:
and regulations applicable in the countries in which it operates;
• the detailed composition of the materials used in the (ii) have its own Code of Conduct; (iii) and cascade these
manufacturing of the goods supplied as well as any expectations to its own suppliers.
changes in their composition;
• Fair trade practices
• any information necessary to comply with current
applicable laws and regulations (e.g., Dodd Frank Act, Notwithstanding the terms and conditions applicable to
EU conflict mineral regulation) via the latest version of Supplier’s sale of goods or services to Stellantis, contracts,
the Conflict Minerals Reporting Template (CMRT purchase orders or other contractual instruments, Supplier
form); agrees to conduct the following activities.

• the smelter from which raw materials are supplied Supplier agrees to comply with all applicable anti- corruption
either directly or through subcontractors. laws, including, without limitation, the U.S. Foreign Corrupt
Practices Act, the U.K. Bribery Act and the French Loi Sapin 2.
Supplier will: (i) make reasonable efforts, and no less than required Accordingly, the Supplier will not engage in any form of
by law, to achieve compliance in its operations, to support commercial bribery, nor directly or indirectly provide or offer to
Stellantis’ commitment to use risk identification analysis to provide, anything of value to or for the benefit of, any official
support prioritizing the origin tracing activities for additional or employee of a governmental authority or of any
materials and work to implement processes and tools to reach government-owned, government-controlled or government-
this objective; and (ii) undertake remedial measures that affiliated entity to induce such person(s) to violate their official
Stellantis deems adequate to cease sourcing from channels duties in order to grant Supplier any benefit, including obtaining
that are determined to be non-compliant. or retaining any contract, business opportunity or other business
benefit. Supplier will adopt appropriate measures to promote
• Animal Welfare
similar compliance amongst its subcontractors, vendors,
As part of its supply, the Supplier undertakes to respect and to agents or other associated third parties.
ensure that its Suppliers respect the five animal rights
Supplier undertakes to ensure all taxes, fees, royalties for the
formalized by the World Organization for Animal Health (OIE)
extraction of minerals and/or obtaining of raw materials
concerning animal welfare.
and/or the production of goods are paid.
• Export Controls Supplier agrees to know about and comply with any applicable
Supplier agrees to become knowledgeable of and comply with all rule relating to competition, and will implement any anti-
applicable export control and sanctions laws and regulations, competitive practices (cartels, etc.). Supplier must independently
including those of the EU, the United States and any other determine its behavior and its commercial policy on the market
applicable jurisdiction (the “Export Control & Sanctions Laws”). to maintain healthy competition between all players.
Supplier will not violate, and will not cause Stellantis to violate, Supplier undertakes to have processes to prevent, detect and
any Export Control & Sanctions Laws (e. g. by transshipping remediate any conflict of interest, especially any conflict of
goods through, or supplying goods or services from, sanctioned interest that may influence its business with Stellantis.
countries, or with the assistance of any individuals or entities
appearing in export-restricted or sanctions lists). Supplier is Supplier undertakes to have processes and controls in place
aware of the constant change of countries, entities and persons around the giving and receiving of gifts and entertainment
mentioned in export-restricted and sanctions lists and has taken with business partners.
steps to keep up to date with such changes. Supplier undertakes to respond diligently and transparently to
With respect to the goods or technology that Supplier sells or requests for information from Stellantis, whether financial or
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non-financial. information and assistance in line with local legislation.
Supplier will apply appropriate protections for the confidential • Support of small and local suppliers
information it receives from Stellantis, consistently with non-
disclosure agreements, terms and conditions or contractual
In specific circumstances, Stellantis is also committed to
requirements that Stellantis may require for that purpose. supporting small and local suppliers, helping to facilitate
Supplier will also respect the intellectual property rights of technological upgrades and acquisition of long-term assets.
other parties.
Sustainable procurement
Supplier will prohibit any activity that facilitates the production
or trade of counterfeit products or components throughout its
supply chain and will cooperate with Stellantis in any • Supplier relationships with its own suppliers
investigation related to suspected counterfeit activity.
Stellantis expects its Suppliers to cascade the above principles
Supplier will prohibit and have controls in place to detect any throughout their supply chain. The Supplier therefore
activity that facilitates money laundering, the funding of undertakes to: (i) raise its own supplier’s awareness on
terrorism, other criminal activities, or inappropriate financial corporate and social responsibility (CSR) issues; (ii) establish a
activities. responsible procurement policy respecting these Guidelines;
and (iii) implement all due diligence measures with respect to its
• Retention and use of personal data
own subcontracting chain.
Supplier undertakes to comply with the regulations in force
concerning the collection and use of personal data. No use and
treatment other than those provided for in the contracts and Supplier Agreement
applicable laws and regulations may be implemented by the
Supplier. Stellantis expects its Suppliers to conduct a self-assessment of
their compliance with these Guidelines and offers them
technical support toward enhancing their performance.
Training & support to small & local suppliers Supplier acknowledges having read and understood these
Guidelines and agrees to apply them, throughout its
• Training and development company/group If necessary, it commits itself and all its
subsidiaries and affiliates throughout the world that provide
Supplier undertakes to provide appropriate tools for the
goods or services to Stellantis.
development of skills and capabilities to all its employees.
Through the offer of technical support, Stellantis encourages Supplier formally accepts the principle that self- assessment
Suppliers to establish training programs for their employees to questionnaires will be sent out, that they should be completed,
enhance the level of their professional skills. and that audits can be carried out at its various sites, or at those
of its subsidiaries, by Stellantis or by a third party appointed by
Lay-off practices. In dealing with redundancies, Supplier’s
Stellantis for this purpose.
responsible behavior is expected so that, where possible and
within the applicable legal framework, the effects are
mitigated. Each employee affected is to receive appropriate

Company name

DUNS (Global ultimate)

Last name & First name

Function & e-mail

I undertake to comply with the social, compliance, sustainability, training environmental responsibility requirements of
Stellantis as set forth in these Global Responsible Purchasing Guidelines.
Date & Signature / Stamp:

Once signed, upload this document in Orion Suppler Master Data System, send it back to your contact in purchasing department or to the
mailbox: [email protected]

Your signature does not mean that you have been accepted as a Supplier to Stellantis.

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