Code of Conduct GM’s Code of Conduct —Winning with Integrity— reinforces our commitment to a work environment founded on mutual respect, trust and accountability. It outlines the policies and obligations that guide our business conduct, and includes employee guidance on various reporting mechanisms available to report safety and other concerns (e.g., Speak Up For Safety, Awareline). Our Code of Conduct also emphasizes GM’s Non-Retaliation Policy . It applies across our company, at every level, including supervisors, senior leaders and Board members, and extends to subsidiaries that GM controls. We expect third parties, including suppliers, to act in a manner that is consistent with the principles and values outlined in our GM Supplier Code of Conduct when conducting business with, and on behalf of, GM. We expect GM employees working with our third parties to hold third parties accountable. Our Code of Conduct is available in nine languages (including English); our Supplier Code of Conduct is available in 13 languages (including English); and certain compliance policies are available in multiple languages to ensure they are understood by employees and third parties in all locations where GM does business. Our Code of Conduct governs how our employees are expected to act: displaying integrity in the workplace, in the marketplace and in their communities when representing GM, and it guides the conduct of our daily business ETHICS CONT. practices worldwide. In 2022, we refreshed the Code of Conduct to add our “Be Inclusive” behavior, a new CEO leadership message and other relevant and timely content. To ensure the effectiveness of our Code of Conduct, we regularly conduct independent third-party assessments of GM’s compliance program against the Department of Justice and other applicable laws, regulations and rules. We also regularly conduct compliance risk assessments. Our Code of Conduct publicizes various points of contact for employees with questions or concerns, including local leadership, Human Resources, labor representatives, the GECC, Legal Staff, GM Audit Services and our Awareline. GM maintains a robust conflict of interest disclosure process that applies to all salaried employees and members of the Board. Employees are required to complete an electronic conflict of interest questionnaire at least once during their employment and keep it updated as their personal circumstances change. Board members who are not employees provide written disclosure of any actual or potential conflicts of interest at least once a year. To ensure compliance awareness continues throughout the year, our GECC team develops compliance and ethics messages on a regular basis, underscoring the importance of these topics. Skip Navigation Introduction Reducing Emissions Design for Environment Technology Customers Safety Diverse Workforce Human Rights Supply Chain Communities Governance 2021 SUSTAINABILITY REPORT 115

General Motors Sustainability Report - Page 116 General Motors Sustainability Report Page 115 Page 117