ETHICS CONT. Reporting Concerns GM encourages our employees to speak up and provides resources to do so. An internal “Report Concerns” site makes it easy for employees to identify the most effective way to quickly report their concern. In cases where an individual is uncomfortable reporting through other established internal channels, we maintain a global toll-free hotline. The Awareline is operated by an independent third party and allows employees and others to confidentially report concerns of misconduct by the company, our management, supervisors, employees or agents. Reports can be made in more than a dozen languages, 24 hours per day, 7 days per week, by phone, web or email. Reports may be made anonymously, where permitted by law. In 2021, GM received 4,170 reports to the Awareline, of which 3,048 were classified as allegations, and the remaining reports were suggestions, inquiries or other miscellaneous issues. GM tracks all reports of misconduct— whether made to the Awareline or through some other channel—in a case management system that facilitates efficient investigation, follow- up and compliance trend analysis. The case management system allows GM to follow up with individuals who submit Awareline reports anonymously, while preserving the reporter’s anonymity, to help GM better investigate and remediate anonymous allegations. Allegations of misconduct are reviewed and prioritized based on a number of factors, including the type of misconduct, the position of the alleged wrongdoer within the company and whether the allegation entails any potential violations of law. High-priority cases receive special scrutiny and review; a cross-functional committee meets monthly to discuss their investigative progress and resolution. There is also a quarterly review process to determine which cases, if any, require reporting to the Board or Audit Committee, as well as processes in case a particular allegation requires more immediate reporting. The chief compliance officer also provides regular updates to the Audit Committee on key GECC priorities and accomplishments and trends in Awareline submissions and Investigations. Speak Up!, GM’s Non-Retaliation Policy, protects GM employees from retaliation when they raise a concern in good faith. GM’s most recent Ethical Culture Survey, as well as industry benchmarking data, shows that the majority of misconduct reports are made to an employee’s manager. To help our GM managers in such circumstances and to provide additional guidance regarding GM’s Non- Retaliation Policy, the GECC has developed a website that provides helpful compliance tools for managers, including compliance toolkits on various topics, compliance moments to use at meetings, quick reference compliance guides and other materials. GM also makes available a scenario-based “What Would You Do?” course for managers. In 2021, the GECC developed and is piloting a post-investigation antiretaliation survey to initiate outreach to known reporters following an investigation to identify and respond to potential retaliation and improve the investigative process. These materials help GM managers create a safe and open reporting environment for their teams. Supplier Due Diligence GM’s success depends in part on building positive business relationships with reputable and ethical suppliers that meet our business needs. GM maintains a Supplier Code of Conduct that sets forth our expectations for ethical conduct as well as a risk-based due diligence program for our suppliers and business partners. GM’s due diligence activities consider, among other things, safety, reputation, human rights, integrity, business requirements, compliance with laws and GM’s expectations for adherence to Winning with Integrity. We engage in continuous risk assessment, using a variety of tools and cross-functional resources to better understand and mitigate risk. We provide resources to our suppliers through our GM SupplyPower portal and other channels to ensure open communication and to help suppliers understand our expectations and improve their operations. Learn more in Supporting Supplier Responsibility . 2021 Types of Allegations Received CATEGORY PROPORTION OF ALLEGATIONS Accounting, Auditing and Financial Reporting Fraud relating to accounting procedures, internal controls or auditing matters 0.1% Business Integrity Examples: Fraud, conflicts of interest, corruption 5.6% Human Resources, Diversity and Workplace Respect Examples: Interpersonal conflicts, harassment, discrimination, retaliation 66.8% Environment, Health and Safety Examples: Threats and violence, substance abuse, environmental concerns, workplace safety 13.3% Misuse, Misappropriation of Corporate Assets Examples: Theft, property damage, information or IP loss, computer misuse 14.2% Skip Navigation Introduction Reducing Emissions Design for Environment Technology Customers Safety Diverse Workforce Human Rights Supply Chain Communities Governance 2021 SUSTAINABILITY REPORT 116
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