2021 SUSTAINABILITY PROGRESS REPORT | Cummins Inc. ETHICS AND COMPLIANCE BY THE NUMBERS 59 In establishing the policy, Cummins assessed the company’s risk for violations, determining the greatest risk exists deep in the company’s supply chain. Outside vendors providing services such as catering or cleaning were also identified as areas to watch. All of these areas receive extra attention and oversight from the company. The Ethics and Compliance function is working to develop additional ways to monitor these often less visible elements of the company’s operations. Cummins is committed to supply chain transparency and ensuring its partners, especially in high risk areas, adopt measures to mitigate human rights risks. Suppliers are required to sign response forms agreeing to comply with the company’s Supplier Code of Conduct, which also specifically prohibits forced and child labor. Cummins will work with suppliers to either develop a plan for compliance or a strategy for exiting their relationship with the company. If any inappropriate behaviors or conditions viewed as systemic or critical are observed during supplier audits, the situation is reviewed with the Cummins Legal function for appropriate action. KEEPING HUMAN RIGHTS TOP OF MIND Cummins has long been committed to protecting human rights, both within the company and across its supply chain. For many years, the Cummins Code of Business Conduct has stated the company “will not tolerate child or forced labor anywhere and we will not do business with any company that does.” In 2018, Cummins officially adopted a separate Human Rights Policy to reinforce where the company stands on this important matter. The Cummins Human Rights Policy specifically prohibits all forms of compulsory labor, as well as human trafficking. It applies to the company, its joint ventures, affiliated companies, and Cummins’ suppliers. If Cummins doesn’t have a controlling ownership interest or management responsibility with a related entity, the policy states it will take steps to require compliance. In 2019, Cummins implemented company-wide training on human rights for employees working within the company’s supply chain. Cummins also began integrating provisions of the policy directly into the Eyes Open Audits conducted primarily by employees in the Purchasing function when visiting suppliers to check on worker safety, environmental concerns and other issues. ABOUT THE POLICY Here’s a quick look at Cummins’ Human Rights Policy: ADOPTION: Completed in December 2017, after a thorough review, the policy was officially published in January 2018. CONTENTS: The policy specifically precludes human trafficking and exploitation, forced labor, child labor, bonded and prison labor, and supports foreign and migrant worker rights. IMPACT: The policy applies to Cummins entities in which the company has a controlling ownership interest or management responsibilities, including subsidiaries and joint ventures. INSPIRATION: The policy was guided by the Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact and the U.N.’s Guiding Principles on Business and Human Rights. SUPPLIERS: Cummins commits to supply chain transparency, pledging to work with suppliers and partners in high-risk locations to mitigate the risk of human trafficking and other human rights violations. TO LEARN MORE: You can learn more about the policy’s origin and see a copy of the policy in the Newsroom at cummins.com. Percentage of complaints substantiated by investigators in 2021. 49 1,575 Ethics investigations undertaken by Cummins investigation team in 2021. 65,000+ Ethics and Compliance training course completions in 2021. 10 th Anniversary celebrated by Ethics and Compliance function in 2022. ETHICS AND COMPLIANCE // 30,384 Ethics certifications completed by office and salaried/exempt employees in 2021.