Ethics The foundation of GM’s business is: Our Core Behaviors help drive our business decisions and activities worldwide. GM is committed to creating and maintaining an ethical culture and conducts ethical culture surveys across our global workforce to monitor our progress every few years. Our 2020 third-party survey results show that internal perceptions of GM’s ethical culture continue to increase and are higher than the third-party’s 2018–2019 benchmark, which includes responses from over 500,000 individuals across 32 companies. In 2022, for the third year in a row, General Motors was also the only original equipment manufacturer automaker recognized as one of the World’s Most Ethical Companies ® by Ethisphere, a global leader in defining and advancing the standards of ethical business practices. Winning with Integrity is one of our Core Behaviors, and the World’s Most Ethical designation is a testament to our ethical leadership as we continue to transform our company and industry. An ethical business starts at the top. Chair and CEO Mary Barra and other members of our Senior Leadership Team regularly issue messages to all employees emphasizing the importance of our Code of Conduct and their expectation that every employee strive to do the right thing, even when it is difficult. The Board is also committed to upholding the highest legal and ethical conduct in fulfilling its responsibilities. All Board members, officers and employees are expected to act ethically at all times and to adhere to the law, our Code of Conduct and any applicable company policies. The Board, in addition to our eligible salaried employees (e.g., everyone other than those on excused leave), also completes GM’s Code of Conduct training. The Board’s Audit Committee has oversight responsibility for GM’s ethics and compliance program, which promotes a culture of high performance with high integrity by advocating and helping implement the principles of GM’s Code of Conduct—Winning with Integrity. The Global Ethics and Compliance Center (GECC) is led by the assistant general counsel and chief compliance officer, who reports to the executive vice president of global public policy, general counsel and corporate secretary, and indirectly to the Board’s Audit Committee. The chief compliance officer provides regular updates to the Audit Committee. The chief compliance officer meets with the Audit Committee in private sessions without other members of management present at least once per year. The GECC prevents, detects and helps correct violations of law and corporate policies and helps promote our ethical business culture. The GECC seeks to align GM’s ethics and compliance program with the recognized elements of an effective compliance program and primarily manages GM’s Code of Conduct; Non-Retaliation Policy; conflict of interest disclosure process; investigations; ethics and compliance training and communications; global policy development; compliance assurance; risk-based third-party due diligence; whistleblower line; anti-corruption compliance assurance in GM strategic transactions; and other anti-corruption risk areas. Regional compliance officers are established in each of GM’s operating regions to help ensure compliance and ethics globally. We also have a network of compliance liaisons, as well as other compliance personnel located throughout GM who provide guidance to employees and answer ethics and compliance questions. Additional global structures and oversight are in place for safety, export compliance, antitrust compliance, data/cybersecurity compliance, records management compliance and other risk areas. The Role of Ethics Compliance Liaisons In 2021, we launched a new Compliance Liaison program to help further localize compliance into business units and to serve as an additional knowledgeable resource for identifying compliance issues. Compliance liaisons are GM team members supporting business units and regions who help detect, prevent and resolve potential compliance issues across the company. Our Vision A World with Zero Crashes, Zero Emissions and Zero Congestion Our Core Values Customers, Excellence, Relationships and S e ek Tr u th Our Eight Core Behaviors Be Inclusive, Think Customer, Innovate Now, Look Ahead, One Team, Be Bold, It’s On Me, and Win with Integrity Skip Navigation Introduction Reducing Emissions Design for Environment Technology Customers Safety Diverse Workforce Human Rights Supply Chain Communities Governance 2021 SUSTAINABILITY REPORT 114
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