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STANDARDS OF BUSINESS CONDUCT & ETHICS

I Autoliv Standards of Business Conduct & Ethics, 2015 v.2.0

Letter from our chairman, president & ceo and the executive management team

Dear Colleagues,

Over the past six decades, Autoliv has grown to become the global leader in automotive safety. Our success is based on a passion for saving lives and the continuous innovation of new technologies. We operate in 28 different countries across the world, and the products we make save more than 30,000 lives every year. While our work is important, how we go about our daily activities matters just as much.

Performing our work in an ethical and lawful manner is what the Standards of Business Conduct and Ethics (our “Code”) sets out to teach us every day. No matter our geographical location, the fundamental values found within the Code supplement our sound judgment through helpful guidance and practical examples. We refer to the Code regularly and use it as a guide to help make the best possible decision, particularly in complex or challenging situations. We ask that each of you do the same.

Of course, the Code is not the only tool to help strengthen the focus on our future business strategies of Q5, 1P1P, and Innovation. Detailed policies and procedures further unite our operations. If you have questions about any business practices you observe, there are internal resources available for support, including on LifeNET. Additionally, if you suspect that something you’ve seen or heard about contradicts Autoliv’s Code, then please speak up to others at Autoliv, such as your manager or a Human Resources, Legal, or Compliance representative. Speaking up with a sincere report of potential wrongdoing will not be penalized. Retaliation is always prohibited at Autoliv.

We appreciate each and every one of you taking the time to read and uphold this Code. We look forward to more years of positive life-saving work at Autoliv.

Sincerely,

Jan Carlson, Chairman, President & CEO, and the Executive Management TeamAutoliv Inc.

Autoliv Standards of Business Conduct & Ethics, 2015 v.2.0 II

our vision, our mission, our vaLues

OUR VISIONTo substantially reduce traffic accidents, fatalities, and injuries.

OUR MISSIONTo create, manufacture, and sell state-of-the-art automotive safety systems.

OUR VALUESLIFE We have a passion for saving lives.

CUSTOMERS We are dedicated to providing satisfaction for our customers and value for the driving public.

INNOVATION We are driven for innovation and continuous improvement.

EMPLOYEES We are committed to the development of our employees’ skills, knowledge and creative potential.

ETHICS We adhere to the highest level of ethical and social behavior.

CULTURE We are founded on global thinking and local actions.

III Autoliv Standards of Business Conduct & Ethics, 2015 v.2.0

I LETTER FROM OUR CHAIRMAN, PRESIDENT & CEO AND THE EXECUTIVE MANAGEMENT TEAMII OUR VISION, OUR MISSION, OUR VALUES

01 INTRODUCTION01 OUR CODE’S PURPOSE02 EXPECTATIONS FOR MANAGERS: LEAD BY EXAMPLE02 YOUR PERSONAL RESPONSIBILITIES: FOLLOW OUR CODE02 SPEAK UP: “RAISE YOUR HAND FOR INTEGRITY”

Non-RetaliationInvestigations And Discipline

05 Q5: QUALITY IN FIVE DIMENSIONS06 BEHAVIOR: Adhering To The Highest Ethical Standards

Respect in the WorkplaceHuman Rights and Corporate Social ResponsibilitySafety in the WorkplaceHandling Conflicts of InterestGifts and Entertainment

16 PRODUCTS: Our Passion For Saving LivesOur Quality CommitmentUsing Company ResourcesConfidential InformationProtecting Our Intellectual PropertyProtecting Third Party InformationCommunicating Our AchievementsKeeping Accurate Records

24 CUSTOMERS: Achieving Zero Defects And Best Value For All Our CustomersDealing Fairly With Our CustomersCompeting Fairly

26 SUPPLIERS: Quality Products Depend On Quality MaterialsSupplier Expectations: The Highlights of Our Supplier Code of ConductDealing With Third Parties

28 GROWTH: Developing Our People, Growing The Company, Saving More LivesEmployeesEducation: Bringing Our Values To LifeAnti-Corruption And Anti-BriberyPrivacy ProtectionInsider TradingInternational Trade

33 ORGANIZATIONAL GOVERNANCE34 WAIVERS

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Autoliv Standards of Business Conduct & Ethics, 2015 v.2.0 01

introduction

OUR CODE’S PURPOSEAs One Autoliv, our ethical culture is demonstrated through our commitment to upholding our Values, adhering to the law, and fostering a culture where all employees act with the highest ethics and integrity, where ethical breaches are not tolerated, and where employees are empowered to speak up. At Autoliv (“our Company” or “the Company”), we live our values every day - because how we conduct business is very important for a company in the business of saving lives. We are all fully committed to maintaining and further developing our strong culture of ethical conduct.

Autoliv’s primary goal is to Save Lives. Our products never get a second chance. This is why we can never compromise on quality. Q5 is the journey for shaping a proactive quality culture of zero defects. Q5 means quality in five dimensions: customers, products, suppliers, growth, and behavior. Our Q5, 1P1P, and Innovation strategies cannot be successful without our commitment to ethics and the principles embedded in our Standards of Business Conduct and Ethics (our code of conduct, or “Code”). Our Code provides guidance for making decisions that reflect our commitment to upholding our Values and complying with the laws and regulations that apply to the work we do around the world. We are committed to having the right people in the right positions making the right decisions.

This Code sets forth the principles that guide our day-to-day operations - it aims to preserve our shared interests as well as the interests of the companies we work with, and the consumers who use our products. The Code is a benchmark we can use to measure our conduct against the principles of fairness and equity our Company is committed to maintaining. The Code is not a contract, and it may be changed from time to time. The most recent version is available on our website. All Autoliv employees, directors, and corporate officers are accountable for following this Code. Further, we expect that any individual or entity acting on our behalf will also comply with Autoliv’s policies and procedures, including this Code, as well as the laws and regulations in the places where they operate.

For further details, see the Standards of Business Conduct and Ethics Guidelines (Autoliv Standard 310), the Corporate Governance Guidelines of Autoliv, Inc., the Code of Conduct and Ethics for Directors of Autoliv, Inc., and the Code of Conduct and Ethics for Senior Officers of Autoliv, Inc. (Autoliv Standard 311, Appendix A). These Standards and all others are available on the Autoliv Intranet (LifeNET) and Autoliv.com.

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02 Autoliv Standards of Business Conduct & Ethics, 2015 v.2.0

EXPECTATIONS FOR MANAGERS: LEAD BY EXAMPLEHolding a management position at Autoliv means accepting additional responsibilities. Autoliv expects our managers to demonstrate a strong commitment to leadership and practice ethical behavior. If you are a manager, you should act as an extension of the Executive Management Team (EMT) by sharing in the “Tone at the Top” commitment to ethical behavior, and:

• Lead by example,

• Reward integrity,

• Encourage ethical decision-making,

• Create a working environment where everyone feels comfortable asking questions and reporting potential problems,

• Prevent retaliation against those who report concerns, and

• Promptly and confidentially escalate reports from employees to the appropriate personnel.

YOUR PERSONAL RESPONSIBILITIES: FOLLOW OUR CODEOur reputation for acting ethically and responsibly is built one decision at a time, every day, by each of us. Our Code, together with our Company policies, gives us the information we need to perform our jobs ethically. It is your responsibility to know and comply with the policies, laws, and regulations that apply to the work you do and the decisions you make.

SPEAK UP: “RAISE YOUR HAND FOR INTEGRITY”Why is it important to report?Each of us is expected to support the ethical standards of Autoliv. If you witness behavior that gives you cause for concern or that may represent a breach of our Code, raise the issue immediately. Doing so will enable Autoliv to promptly address the issue, preferably before it becomes a violation of law or a risk to health, safety, security, or Autoliv’s reputation. Violations of our Code can impact all of us, not just those involved in the behavior, which is why raising your hand is so important.

introduction

WHAT SHOULD I REPORT?Potential violations that should be reported include but are not limited to:

• Accounting or Auditing Irregularities or Misrepresentations

• Antitrust or Competition Violations

• Actual or Potential Conflicts of Interest

• Child or Forced Labor

• Corporate Opportunity to Advance Personal Gain

• Destruction of Property and Theft

• Improper Disclosure of Confidential Information

• Drug or Alcohol Abuse

• Environment, Health, and Safety Concerns

• Falsification or Destruction of Information

• Fraud or Embezzlement

• Inappropriate Gifts and Entertainment, Bribes, or Kickbacks

• Discriminating , Inappropriate, Abusive, or Harassing Behavior

• Inappropriate Use or Misuse of Company Resources

• Quality Concerns

• Retaliation

• Threats or Physical Violence

• Trading on Inside Information

• Unfair or Illegal Employment Practices


What should I report?Actual or potential violations of policies, laws and regulations, Autoliv Standards, or this Code that you believe have occurred or are about to occur should be reported immediately.

Whom should I contact?

• Your Manager, or another Manager you trust

• Human Resources Representative

• Legal Representative

• Compliance Representative

• Autoliv Helpline - see LifeNet or pg 35 for the full list of numbers by country

Consider going to your manager or supervisor first, since he or she is most likely to be familiar with your work responsibilities and conditions. That said, any of the representatives listed above are open to you if you have a question or concern. Remember, by providing as much information and detail as possible when you report an issue, you are helping our Company resolve it.

You can also report concerns about suspected issues to the Autoliv Helpline at the numbers listed by country in this document and on LifeNET. The Helpline is operated by an independent third party. It is a multilingual service, and there is no charge for the call. Reports can be made confidentially 24 hours a day, 7 days a week.

You may also go online at helpline.Autoliv.com to seek guidance through our web-based reporting tool.

helpline.Autoliv.com



Non-retaliationWe believe that reports, investigations, and constructive feedback play an important role in making our Company a great place to work. At Autoliv, we are committed to protecting individuals who make a report or participate in an investigation in good faith. “Good faith” means that you honestly provide all the information you have when making a report or participating in an investigation. It does not matter if you realize later that you were mistaken or if the incident reported was not a violation after all.

Retaliation, harassment, and reprisals of any kind are not tolerated at Autoliv. In addition, no employee will be adversely affected because they refused to carry out a directive they believe constitutes fraud or a violation of the Code, laws, or regulations. If you know or suspect that retaliation has occurred or is occurring, report the situation to a Legal representative, to a Compliance representative, or to the Autoliv Helpline.

Investigations and disciplineAutoliv takes all reports of misconduct seriously. We will act promptly in our investigation, remedy any problem, and prevent it from happening again. Our Company makes every effort to ensure that investigations are consistent, comprehensive, and as confidential as possible. If requested, you are expected to cooperate in any investigation of possible wrongdoing.

If the investigation reveals that misconduct has occurred, Autoliv will respond as appropriate or necessary, consistent with the law. Depending on the circumstances, this may include training or disciplinary action, including termination of employment. Additionally, Autoliv may report the misconduct or the results of the investigation to proper authorities.

For more information on how Autoliv handles the investigation process, refer to the Investigations Policy.

introduction



Q5: QuaLity in five dimensions

BEHAVIOR: ADHERING TO THE HIGHEST

ETHICAL STANDARDS

CUSTOMERS: ACHIEVING ZERO DEFECTS AND BEST

VALUE FOR ALL OUR CUSTOMERS

PRODUCTS: OUR PASSION FOR

SAVING LIVES

GROWTH: DEVELOPING OUR PEOPLE, GROWING THE COMPANY, SAVING MORE LIVES

SUPPLIERS: QUALITY PRODUCTS DEPEND ON QUALITY

MATERIALS

Quality in all dimensions - Q5 - is the journey that shapes an Autoliv culture with zero defects and the best value for all our customers. Q5’s goal is to firmly tie together quality with value in all our processes, including our Code, for all our employees.


RESPECT IN THE WORKPLACEDiversity and inclusionWe are committed to ensuring a positive and diverse working environment, where all employees respect one another, value each of our colleagues’ contributions, and treat each person fairly. We do not tolerate any form of discriminating behavior or harassment in our workplace.

Diversity involves appreciating people as individuals and for the contributions they make. When we view each other with respect for our backgrounds and individual differences, we can draw on the varied skills each of us offers.

As One Autoliv operating in many countries, Autoliv treats everyone - including employees, candidates, customers, suppliers, partners, contractors, shareholders, and communities - with integrity and respect. We encourage unique viewpoints and contributions. Always uphold the value Autoliv places on diversity by conducting yourself in a professional manner at all times and adhering to high ethical standards for how you treat others.

Non-discriminationAutoliv will foster the skills, knowledge, and potential of our employees. Autoliv does not discriminate against any employee or applicant for employment because of age, race, religion, color, gender, disability, national origin, marital status, pregnancy status, sexual orientation, gender identity, or any other criteria or characteristic prohibited by law or otherwise irrelevant for the position. This principle extends to all decisions relating to hiring, promotion, transfer, recruitment, termination, benefits, rates of pay, other forms of compensation, and selection for training. Making employment decisions based on any of these personal characteristics is against our Code and is illegal in most countries where we operate.

behavior: adhering to the highest ethicaL standards

Q: Hanna manages an assembly line in one of our production facilities. Most of her co-workers are male, and they often ask Hanna if she needs help lifting items or if the job is “too tough” for her. At first, Hanna thought they were just being polite, but lately their comments have been more frequent. She has started to wonder if they really think she cannot do her job because she is a woman. What should she do?

A: It can be difficult to know when courtesy ends and harassment begins, but Hanna may be right that her co-workers’ behavior is inappropriate. She should raise her concerns to her supervisor or Human Resources, who will investigate and determine whether harassment has occurred. All Autoliv associates should feel comfortable approaching their supervisors or Human Resources representatives to discuss harassment concerns. Even if you are not certain the behavior is harassment, but you are uncomfortable with the behavior, it is always best to ask for help.


Preventing harassmentAll employees must treat each other with courtesy, consideration, and respect. We do not tolerate harassment of any kind. Harassment can unreasonably interfere with an individual’s work performance or create an intimidating or offensive work environment. What constitutes harassment may differ somewhat between different cultures, and you must be careful not to assume that your local standards are globally acceptable. Harassment can include racial, ethnic, religious, or sexual jokes, sexual advances or requests for sexual favors, bullying, abusive language, physical aggression, intimidating or violent behavior, disparaging comments, or otherwise unwelcome and inappropriate conduct - whether verbal, physical, visual, or electronic, and whether committed in person or in some other way.

For more information on workplace conduct, see the Autoliv Respect in the Workplace Standard.


• Provide fair and equitable wages, working hours, benefits, and other conditions of employment in accordance with applicable laws,

• Recognize and respect employees’ right to freedom of association and collective bargaining,

• Provide humane and safe working conditions,

• Prohibit forced or child labor, and

• Promote a workplace free of discrimination and harassment.

Community involvement and developmentWe believe it is in everyone’s best interest for Autoliv to contribute to the wellbeing of the communities in which we operate. Community involvement projects are relevant to the local business operations and interests in each respective region, location, and facility. These initiatives should benefit the communities where the Company operates. Examples include education, culture and arts, civic development, health and human services, and safety projects. In most cases, these projects are commenced by Autoliv employees around the world, who understand their communities and their needs. Employees take part in a wide range of volunteering activities, and contribute to charities and projects worldwide.

HUMAN RIGHTS AND CORPORATE SOCIAL RESPONSIBILITYAutoliv strives for excellence in its treatment of employees, and is committed to offering fair terms and conditions of employment. Our Values, Code, talent development strategies, and employment policies support the principles contained in the United Nations Universal Declaration of Human Rights and the International Labour Organization Fundamental Principles and Labour Standards. We strive to:



Child labor and forced laborWe employ people in accordance with legally established minimum ages in the country where work is performed. Employing any person below the age of 15 is prohibited, except when the work is appropriate for the age, allowable by local legislation, and clearly beneficial to the individual employed.

Similarly, we do not allow forced, bonded, or involuntary labor. Any association with the Company should be an expression of free choice. Anyone employed by the Company or any of its partners should be allowed to resign their employment at any time.

Environmental standardsWe respect the needs and concerns of the communities in which we live and work. As One Autoliv, our goal is to develop products that protect people in auto accidents and prevent accidents without negatively impacting the environment during the development and production process. To meet this goal, Autoliv has adopted an environmental policy that applies to all aspects of the Company’s operations. The purpose of the policy is to ensure that Autoliv is environmentally responsible and commits itself to continual environmental improvement and prevention of pollution in our activities, products, and services through the reduction of energy consumption and greenhouse gas emissions, increased use of renewable energies, appropriate waste management, water stewardship, environmental testing, and training of employees. Autoliv is committed to a positive impact on the environment and complying with relevant environmental legislation and regulations.

For more information, see the Environmental Policy.

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SAFETY IN THE WORKPLACESafety is more than an element of our business - it is our business, in both the marketplace and the workplace. Our goal, as a Company, is to protect the health and safety of employees, visitors, and contractors and comply with applicable regulatory requirements. We provide understanding, awareness, support, and the necessary tools to identify and mitigate potential health and safety risks in our facilities, and we continually seek opportunities to make new and existing facilities inherently safer. We all have a responsibility to prevent injury and illness in the workplace by adhering to safety guidelines and policies. If a workplace accident happens or if you see a potential safety concern, you should report it immediately in accordance with your facility’s Health and Safety Management System or contact the Autoliv Helpline.

For more information, see the Health and Safety Management System Standard.

Substance abuseIn order to maintain a safe workplace, our Company prohibits the misuse of alcoholic beverages or prescription drugs, or selling, purchasing, transferring, using, or possessing illegal drugs on Company premises or while on Company business. You are expected to perform your job duties free from the influence of any substance that interferes with your ability to safely perform your job. If you have a drug or alcohol problem, you are encouraged to seek assistance. You can contact your local Human Resources to learn of assistance programs in your area.


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Q: Anton works at one of our full-scale testing tracks, where his team is testing a new airbag. He notices that some of his co-workers do not always perform full safety checks on the vehicles before every crash test. When he raises his concerns to a co-worker, she tells him that it is not a big deal - nothing ever goes wrong, so there is no reason to worry. Should Anton accept this explanation?

A: No. We have a responsibility to our fellow co-workers to make sure we follow proper safety procedures every time. Anton is right to be concerned about his teammates’ behavior. He should raise the issue - before something does go wrong.


Non-violenceAutoliv has zero tolerance for workplace violence. We are prohibited from engaging in any act that could cause another individual to feel threatened or unsafe. This includes verbal assaults, threats, or any expressions of hostility, intimidation, aggression, or hazing. Our Company also prohibits the possession of weapons in the workplace. To the full extent permitted by local law, this prohibition extends to Company parking lots as well as our facilities. Our zero-tolerance policy for workplace violence applies to behavior on Company premises, as well as to the behavior of our employees engaged in Autoliv business anywhere in the world outside of our premises. If you ever see or know of any situation involving violence, threats, or intimidation, protect your co-workers by reporting the incident immediately. If you are concerned about the immediate safety of yourself or that of others, contact local authorities, police, or emergency services.

HANDLING CONFLICTS OF INTERESTWhen conducting business, the best interests of Autoliv should be foremost in the minds of everyone who works for the Company, including all employees, directors, agents, and contractors. Many of us work with suppliers, customers, government officials, and others who do business with Autoliv on a daily basis. A conflict of interest arises when your personal activities and relationships interfere, or may appear to interfere, with your ability to act in the best interest of Autoliv. This could involve outright dishonest situations (such as fraud or kickbacks) - but may also involve less obvious situations such as the ones described in the following sections.

Autoliv trusts employees with information about Company activities and with Company funds and property. Use of any of these in a way that conflicts with Company interests is not permitted. You are required to disclose actual and potential conflicts of interest to Compliance - most conflicts of interest can be avoided entirely or resolved easily when disclosed.

For more details, see the Conflicts of Interest Standard and the Related Person Transaction Policy.




Corporate opportunitiesWe cannot make objective decisions for Autoliv if we are competing with our Company. In order to do the right thing for Autoliv, you may never take advantage of opportunities developed on the Company’s behalf for your own personal profit. This includes not pursuing business or investment opportunities discovered through the use of Company property or information. Similarly, you may not assist friends, family members, or others in taking such business or investment opportunities for personal gain.

Outside activities and financial interestsIf you have an independent business venture or another job outside your work at Autoliv, there are a couple of ways this can create a conflict. First, working for an Autoliv competitor, supplier, or other business partner can easily present a conflict by dividing your loyalties between your responsibilities at Autoliv and your outside endeavor. Further, any outside work should not interfere with your duties at Autoliv, including the quality of your work and your overall professionalism. Holding a significant financial interest in one of Autoliv’s competitors, customers, or suppliers could also create a divided loyalty. A significant financial interest is one that is large enough (generally, greater than 1% ownership) that it creates the appearance of a conflict of interest. This also applies to financial interests held by a member of your household or immediate family.


Q: Collette and Daniel work in different departments at an Autoliv manufacturing facility, and they have been dating for about six months. When Daniel is transferred to a new position, however, Collette becomes his supervisor. So far they have kept the relationship a secret from everyone at work, and they feel confident that they will be able to keep their personal and professional lives separate, so they decide not to tell their co-workers that they are dating. Are they making the right decision?

A: Autoliv does not disallow close personal relationships between employees, but it is prohibited for a supervisor and an employee to date. Close personal relationships can lead to favoritism (or even the appearance of favoritism), which could make it harder for everyone involved to make good decisions for Autoliv. In this situation, Daniel and Collette need to speak to a manager or Human Resources representative to decide how to handle this potential problem. It is possible that one of them could be moved to a different team so that neither one reports to the other.


Working with family membersWhen two Autoliv employees have a personal or family relationship - especially if they also have a reporting relationship - the subordinate may seem to receive preferential treatment or favoritism. Our policy is to simply prevent this from happening: you should never be placed in a position where you have direct decision-making authority over a family member, or vice versa. Similarly, managers should avoid close personal (e.g. dating) relationships with direct reports. Remember, the important thing is to avoid even the appearance of bias. If such a situation arises, disclose the facts to your manager promptly.

You should also inform Compliance if any member of your immediate family works for one of Autoliv’s suppliers, distributors, or competitors. If you are in such a situation and your job entails procurement or contracting, you must not participate in supplier selection or contract negotiations. Remember that even the appearance of undue influence can harm our Company.


GIFTS AND ENTERTAINMENTSharing gifts and entertainment with customers is often an important way of creating goodwill and establishing trust in business relationships. However, when employees make or are involved in decisions affecting Autoliv, they must make those decisions with integrity, honesty, independence, and objectivity. We are obliged to seek the most technically efficient, cost-effective, and high quality products and services and to evaluate the same using consistent and unbiased standards. We do not give or accept gifts or provide hospitality (e.g. meals, travel, or entertainment) where doing so is illegal or inappropriate. In those circumstances where it is legal and appropriate to give or receive a gift and/or hospitality, it must be modest in value and nature. When in doubt, do not exchange gifts or entertainment unless it is in accordance with Autoliv policy, including:

• In compliance with local law

• Given free of any intention of influencing or inducing any advantage through improper performance, or in explicit or implicit exchange for favors or benefits

• Given in our Company’s name

• Infrequent

• Reasonable in value and given at an appropriate time

• Proper and in accordance with local customs

• Given openly, not in secret

• Not cash or cash equivalents, such as gift cards

• For a business purpose

• Approved appropriately and in line with the monetary thresholds outlined in our policy

• In the case of entertainment, both parties are present at the event and the purpose of the meeting is to discuss business.


Q: Feng has been negotiating a contract renewal with a supplier. After the contract is signed, the supplier’s representative takes Feng out to dinner. They are careful to choose a reasonably priced restaurant and keep the conversation focused on the next steps in their business relationship. Does this violate Autoliv’s gifts and entertainments policy?

A: Since the dinner takes place after the contract has been awarded, Feng probably has not done anything wrong. However, he should make certain that the dinner is not extravagant, his supervisor is aware of it, and he and the supplier’s representative primarily discuss business. It is fine to exchange reasonably priced gifts and entertainment with our business partners, as long as we follow the guidelines in our Code and do not let these courtesies sway our judgment in our business decisions. If you are ever worried about accepting or offering a gift, check with the Legal Department.


In all situations, we have a responsibility to ensure that our business gifts and entertainment practices are reasonable in form and nature, and consistent with Autoliv policies, industry codes, and local laws. They must also be fully, appropriately, and properly accounted for in our respective internal expense systems and not disguised as other expenses. For guidance on gifts and entertainment for government officials, see the “Relationships with government officials” section.

For more detail, see the “Giving and Receiving Gifts” section of the Anti-Corruption and Anti-Bribery Standard.

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OUR QUALITY COMMITMENTWe seek the highest product quality, safety, and performance at all times. Our business, reputation, and success depend on our commitment to compliance with contractual specifications as well as government and industry standards.

Safety is at the forefront of everything that we do. As a supplier of automotive safety products, our Company is subject to certain regulatory and reporting requirements that may require us to provide information to governmental agencies. Generally, where any of us has reason to believe that a product could impact safety or violate a regulation or safety standards - whether through information from a customer, receipt of a claim or notice, or through professional observation - it is imperative that we report the matter immediately to the Autoliv Quality Department. It is not necessary to wait until you have complete confidence in your understanding of the situation. What is most important is reporting what we suspect to our internal team without delay.

For a list of situations or circumstances that require immediate disclosure, and additional information about the requirements and process for reporting, refer to the Product Safety Reporting Actions Policy.

products: our passion for saving Lives



Q: Emma, an accountant at Autoliv’s corporate office, likes to gamble online during her lunch breaks, using her work laptop. She is always on-task during work hours, and her boss is very happy with her performance. Is Emma doing anything wrong?

A: Yes. Even though Emma is performing well at her job and accomplishing her duties at work, she is still violating our Code by using Company resources for inappropriate personal activities. It is never okay to gamble or look at inappropriate material on the Internet while using Autoliv property.


USING COMPANY RESOURCESCompany resources include all Autoliv purchased, acquired, and owned physical property, information, data, records, and intellectual property, such as brands, inventions, designs, and copyrights. Company resources should always be used for Autoliv’s benefit, not for personal gain or for the benefit of outside organizations. When acquiring or disposing of Company assets, be sure that you have the proper authorization and act in accordance with Autoliv policies and applicable laws and regulations. By using assets properly and securing them against loss or misuse, we can ensure these assets maintain their value and usefulness.

It is important to avoid any personal activities during work hours that would interfere with your work or prevent you from fulfilling your job responsibilities. Company property, including computers and equipment, should not be used for outside businesses, or for illegal or unethical activities such as gambling, pornography, or other offensive activities. Only Company approved software should be installed on Autoliv computers or equipment. If you are unsure if software is approved, contact the Information Technology Helpdesk.

In order to determine what Information can and cannot be shared outside the Company, we are required to classify all Information as one of the following: Public, Internal, Confidential, or Secret.

• Public: Information that is circulated freely in public (e.g. press releases, marketing material, external Company website (www.autoliv.com))

• Internal: Information internal to the Company (e.g. employee announcements, phone lists, some information on LifeNet)

• Confidential: Information that, if revealed, could be detrimental to the activities, assets, or image of the Company (e.g. production planning, sales or purchasing quantities or prices, budget plans, financial data, employee personal data, risk analysis)

• Secret: Information that could seriously damage the activities, assets, or image of the Company if inappropriately released; in general, there are strict rules for access/communication and circulation of Secret Information (e.g. strategic planning, stock-price-sensitive new developments, prototypes, quotations, unpublished patent applications or invention disclosures)


CONFIDENTIAL INFORMATIONProtecting confidential information about Autoliv activities, performance, products, or plans is critical to our Company’s competitive position and reputation. Company Information includes any information, data (digital, paper, or other format), or physical property (e.g. prototypes, fixtures, etc.) created, possessed, handled, owned, or controlled by the Company, regardless of source, whether it is generated internally by its employees or externally by business partners of the Company.

How do we handle confidential information appropriately?We all have a responsibility to protect Confidential Information. We should not disclose Internal or Confidential Information to anyone outside the Company except when disclosure is required for business purposes and is subject to a written agreement. Stock price-sensitive or material non-public Autoliv Company Information should never be shared with family or friends. We should not disclose stock price-sensitive or material non-public Information to fellow Autoliv employees unless they have a business reason to know. We have an obligation to protect the Company’s stock price-sensitive or material non-public Information at all times, including outside of the workplace and after our employment with Autoliv ends.

Disclosing stock price-sensitive or material non-public Company Information could also constitute insider trading (see the “Insider Trading” section of this Code), which can have very serious consequences for you and the Company.

For more details, see the Autoliv Communication and Data Classification Standards.


www.autoliv.com

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PROTECTING OUR INTELLECTUAL PROPERTYNew inventions, processes, works of authorship, technology advances, or unique solutions to business problems (“Intellectual Property”) developed or discovered during the scope of employment with Autoliv must be identified and disclosed to management. This will enable the Company to take appropriate measures to protect our Intellectual Property under applicable patent, trademark, copyright, or proprietary information laws and regulations. It is also important that we do not use, disclose, or market any invention until we have applied for patent protection, as this may result in the forfeiture of the Company’s Intellectual Property rights.

Some Autoliv Confidential Information may be considered Autoliv Intellectual Property or a trade secret. Trade secrets cover Autoliv Information where:

• Such Information is not generally known to the public,

• Autoliv enjoys an economic benefit because the Information is not publicly known, and

• Autoliv takes reasonable, documented efforts to maintain its secrecy.

Disclosure of Autoliv trade secrets is never acceptable. They should be shared only in extremely limited situations, and subject to Company President approval and strict contractual limitations.


PROTECTING THIRD PARTY INFORMATIONSometimes we may receive confidential information about the companies we work with - information that is not public knowledge. We have a duty to protect this information, just as we protect Autoliv’s Confidential Information.

For more information, please refer to the Autoliv Data Classification Standard, the Data Protection Policy and the Privacy Policy.

COMMUNICATING OUR ACHIEVEMENTSWe use internal and external communications to provide information about Autoliv and our operations. It is very important that information about Autoliv, our products, our business interactions, our financial performance, and inquiries made by a journalist or the media are commented on publicly only by those specifically authorized to do so. Unless you are specifically authorized to speak on behalf of the Company, you should direct any inquiries to the Corporate Communications or Investor Relations teams. In all communications, you should take care to be professional and to avoid making inappropriate or unsupportable comments.

For more detail see the Autoliv Communications, Legal Matters, and Data Classification Standards.




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Q: Arun works in one of our research facilities, and he is very active on social media. Last week, he posted, “Proud to work for Autoliv! We are developing a new night vision system that will save thousands of lives someday.” Is this okay?

A: No, it is not okay. Arun may post that he is proud to work at Autoliv - but we have to protect confidential or proprietary Company Information, including information or comments about prototypes or research. All employees need to refrain from posting pictures or descriptions of products that are still in the research or development process. Arun should never talk about confidential or proprietary Company Information, or that of our suppliers or customers, on any social media sites or Internet forums.


Responsible use of social mediaSocial networks have become a large focus of global culture. In personal use of social media, Company employees enjoy the same rights of free speech as all other private contributors. We have a responsibility to be mindful when using such networks so that the comments, opinions, or information we post on otherwise seemingly innocent sites, including social media sites, do not inadvertently appear to reflect the opinions of Autoliv.

When using social media, please keep in mind the following Autoliv Standards and:

• Respect the confidentiality of Autoliv’s Confidential Information and Intellectual Property,

• Respect financial disclosure laws by ensuring the confidentiality of stock price-sensitive and material non-public Information, and

• Do not represent yourself as a spokesperson for Autoliv or make comments that could reasonably seem to be the official position of Autoliv without prior authorization in accordance with Autoliv policy.

For more detail, see the Autoliv Communications Policy and Guidelines Standard.





KEEPING ACCURATE RECORDSWe all record information of some kind, whether we design new products, record our work hours, or sign contracts with suppliers. When these records are accurate, our Company is able to make informed decisions about how to run our business and plan for the future. Likewise, by following all standards, policies, and applicable laws that apply to us, and by implementing proper controls, we ensure the protection of our Company’s assets and the accuracy and completeness of our reports.

Our collected records also help Autoliv fulfill our external obligations, such as financial disclosures, safety reporting, government required reports, documents subject to litigation, and other filings. The integrity of Autoliv’s record keeping, record retention policy, and reporting systems is of utmost importance in order for us to comply with financial, safety, or other critical reporting regulations.

For more details, see the Autoliv Financial Manual, Autoliv Records and Information Management Standard, and for specific guidance see the respective standard located in the Autoliv Corporate Standards database.

FraudAutoliv expects employees to always act with honesty and integrity. Fraud is the misuse of Company resources or intentionally concealing, altering, falsifying, or omitting information for personal benefit or the benefit of others. Examples of fraud include altering Company reports to meet productivity goals, overstating time worked to earn more pay, falsifying time reports for being late or absent from work, or misstating financial information in our Company’s books and records.


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Q: Sato works in Accounts Payable and received transportation invoices to pay without supporting documentation. Her co-worker tells her, “We never receive supporting documents from that company - we have worked with them for years and have a good relationship. Go ahead and pay the invoices without the support.” It would be easier to just pay the invoice, but Sato cannot be sure that the invoices are accurate without verifying the supporting documents. Should she go along with her co-worker’s suggestion?

A: Both Sato and her co-worker want to do what’s best for the Company by paying invoices on time, but verifying the invoices is her responsibility to control the accuracy of the payments, which can prevent overpaying or even fraud. We all have to keep accurate records for the work we perform and our areas of responsibility. Sato should request the supporting documentation before processing the payment, and, if anyone objects, she should speak to her manager.


Record information managementVarious legal and contractual obligations require retaining certain documents, drawings, electronic records (including emails), and other information (records) for a defined period after the record is created. It is very important for all employees to understand which of the records created should be saved and for how long. This includes keeping some records that the Legal Team has told us to retain until we are notified that they are no longer needed (what we call a legal hold). Important aspects of the Company’s record information management are maintaining access to valuable information, promoting sharing and transfer of information, reducing overall costs related to records management, ensuring compliance with existing government and legal requirements, and complying with record requirements related to litigation, government investigations, or audits.

For more details, see the Autoliv Records and Information Management Standard.

Appropriate use of Autoliv technologyAll Internet, Intranet, and e-mail activities are to be conducted primarily for legitimate Autoliv business purposes. Employees should remember that the Company owns and will exercise its legal right to monitor, inspect, disclose, and delete all electronic files (including e-mails) and records on Company systems. For this reason, we should keep in mind that we should have no expectation of privacy with respect to any such files and records other than that mandated by law. It is also important to remember that all online and e-mail activities, intentionally or not, are easily transferable and potentially public in nature.

For more detail, see the Autoliv Information Technology Standard.



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DEALING FAIRLY WITH OUR CUSTOMERSWe must treat our customers fairly. Communicating truthfully and accurately about our products and services is an essential part of our commitment to our customers. We all must make sure that our marketing materials are truthful and complete, our prices are determined independently in light of costs, market conditions, and competitive prices, and our contracts are negotiated in good faith.

COMPETING FAIRLYAutoliv is committed to supporting a fair global market. We compete with intensity by creating the best technologies and selling the best products at the most competitive prices. We should only use legitimate means of obtaining competitive information, respect the confidential and intellectual property rights of our competitors and other third parties, and always comply with antitrust and competition laws.

We also ensure that no unlawful agreements - whether verbal or in writing - are made between Autoliv and our competitors concerning prices, customers, territories, or markets. We promote our products independently, on their own merits, and without unfair and inaccurate comparisons with our competitors’ products.

In all dealings with our competitors we must act honestly and in compliance with antitrust and fair competition laws and regulations - for example, those prohibiting price fixing, boycotts of suppliers, and cartels. An informal or implied understanding between you and a competitor or business partner, even one where intentions are harmless, could be a problem for you and our Company. Stay alert for these situations at meetings or conferences, and if any of these topics arise, stop the conversation immediately and report it to the Autoliv Legal Department.

Given the complexity of competition laws and regulations, you should contact the Autoliv Legal Department for guidance if you have questions about potential fair competition issues or suspect a violation of these laws.

For more details, see the Autoliv Antitrust and Competition Standard.

customers: achieving zero defects and best vaLue for aLL our customers

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Q: At a trade convention, Emilio, an Autoliv sales representative, runs into a friend who works for a competitor. They catch up over dinner, and the conversation turns to work. Emilio’s friend says, “It is a shame we cannot work together on pricing to benefit both our companies,” and winks. Emilio shrugs. The two salesmen did not agree to anything. Did they do anything wrong?

A: Sometimes even a casual remark can seem like an unfair agreement to an onlooker, and we want to be clear about where we stand. Emilio should remind his friend that it is not appropriate for them to discuss pricing - and that, regardless, even when business is difficult, Autoliv is committed to fair competition and independent pricing. Emilio should also speak to his manager or to the Legal Department to discuss how he can handle the situation better if faced with a similar conversation in the future and make sure there are not any further steps he needs to take.


Handling competitive informationKnowing what our competitors are doing can help us plan our own strategies, but we still have to be fair. Competitive intelligence should only be obtained fairly and ethically from publicly available sources such as media reports, trade journals, annual reports, governmental filings, or speeches by company executives. Competitive intelligence should never be obtained through misrepresentation, trespassing, theft, invasion of privacy, obtaining information from anyone who has an obligation to keep information confidential, or asking co-workers about previous employers.


SUPPLIER EXPECTATIONS: THE HIGHLIGHTS OF OUR SUPPLIER CODE OF CONDUCTAs One Autoliv, we strive to adhere to all laws and regulations, and we expect the same from suppliers, agents, consultants, or joint venture partners (“Third Parties”) with whom we work. Further, we expect Third Parties to comply with the laws and regulations in the places where they operate and Autoliv’s policies and procedures, including our Business Conduct and Ethics for Suppliers (Supplier Code of Conduct), and to commit to upholding Autoliv’s social, ethical, and environmental standards in operating their businesses:

• Human Rights and Working Conditions, including the areas of Health and Safety, Child Labor and Forced Labor, Fair Working Conditions, Non-Harassment and Non-Discrimination, Freedom of Association and Collective Bargaining, and Conflict Minerals

• Environment & Sustainability, by conducting business in an environmentally friendly and responsible manner, and complying with all applicable environmental laws and regulations

• Business Conduct and Ethics, including in the areas of Antitrust and Competition, Anti-Corruption, Anti-Money Laundering, Conflicts of Interest, Export Controls, Protection of Intellectual Property, and Respect for Company and Personal Data

Suppliers play a key role in helping us manage our global supply chain in a socially responsible manner. If you suspect that human rights or other violations are occurring in the Autoliv supply chain, you have a responsibility to discuss your concerns with a member of management immediately.

For more details, see our Standards of Business Conduct and Ethics for Suppliers.

suppLiers: QuaLity products depend on QuaLity materiaLs

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Q: Daniela works in supply chain management, and she has received reports that a supplier that manufactures one component of Autoliv’s most popular seatbelt might be forcing employees to work unpaid overtime. What can she do to stop this?

A: Daniela should contact her supervisor immediately with her concerns. Autoliv relies on many different suppliers and manufacturers to make our products, and we require all of them to follow our Supplier Code of Conduct, which includes fair labor standards. If you ever think there might be a human rights concern in our supply chain, do not be afraid to speak up.


DEALING WITH THIRD PARTIESAs a Company, we are obligated to establish the experience, capability, integrity, reputation, and commercial stability of any Third Party with whom we engage. Therefore, before entering into any contract with a Third Party, a reasonable investigation (due diligence) into the background, reputation, and business capabilities of the individual or business should be performed. Be alert for “red flags” such as the Third Party was recommended by a government official, the Third Party is a candidate for political office, there is no clear business purpose for engaging the Third Party, the Third Party requests a cash payment up front or special pricing considerations, or we are asked to hire individuals or enterprises that may be connected to governmental officials or their family members.

For more information, refer to the Third Party Policy, and consult the Legal Department with any questions.



EMPLOYEESAutoliv is committed to creating a respectful, positive, and diverse working environment. Dedicated to the business of saving lives, we are also responsible for securing the safety, health, and wellbeing of our employees. Attracting, developing, and retaining highly skilled employees is a top priority for the Company, and we are committed to the development of our employees’ skills, knowledge, and creative potential. We invest in our people to encourage personal growth and development. We recruit internally to benefit from internal experience and providing development opportunities for the individual. Autoliv supports creativity, entrepreneurial behavior, and result-oriented actions to encourage our culture of openness, trust, and initiative. We believe that by respecting each other and working together, we achieve better results. As part of fostering our culture of continuous improvement, Autoliv values everyone’s ideas and initiatives.

EDUCATION: BRINGING OUR VALUES TO LIFEEducation is a critical aspect of supporting employees in understanding Company expectations and policies related to our Code. Autoliv requires employee education regarding our Code to ensure that all employees are aware of, understand, and adhere to the principles that we have established. The goals of the Business Conduct and Ethics Education are to provide a continuing communication channel for compliance matters, to deliver compliance messages to employees, to train and educate employees on their compliance responsibilities, and to support our Code and the compliance program. Training is designed to facilitate employees’ understanding of compliance responsibilities and the importance of complying with laws, regulations, and our Code. It is delivered in various ways, including e-learning and face-to-face training.

growth: deveLoping our peopLe, growing the company, saving more Lives

Q: Kyung, who works in logistics, has run into trouble getting some manufacturing supplies to clear customs. His local customs broker tells him, “You will have to pay the officer a little extra on the side, if you want to receive those goods soon. It is just the way things work around here.” Kyung wants to get the supplies to the plant, but he knows it is important to always follow the law. Should he make the additional payment?

A: No, Kyung should not make this payment. Our Company policy is that we never pay bribes or facilitation payments - even small payments like the one this official is asking for. If you are unsure about whether a potential payment qualifies as a bribe or facilitation payment, do not be afraid to contact the Legal Department. It is always better to ask and be certain.


ANTI-CORRUPTION AND ANTI-BRIBERYBecause we value ethical business practices, we do not accept or offer any form of bribery. Bribery is giving or offering to give anything of value to an individual to improperly influence a business decision or government action. We must never offer, request, accept, or indicate willingness to make or accept such a payment, benefit, or anything similar. Bribery is prohibited, not just for all Autoliv employees, but also for Third Parties who conduct business on our behalf. Autoliv takes bribery and corruption very seriously, and any employee or representative who violates this policy will be subject to disciplinary action up to and including termination of employment and legal action.

Similarly, we do not provide or accept kickbacks or facilitation payments. These and other improper payments go against our values, and are against the law. Kickbacks are the return of a sum received (or due to be received) as part of an agreement to foster or arrange business. Facilitation payments are small payments used to facilitate government actions, such as processing an operating license. Although these facilitation payments may be allowed in some countries, we do not allow facilitation payments at Autoliv. If someone requests such a payment from you - or any other improper payment - report the incident and seek guidance from the Legal Department.

For more detail, see the Autoliv Anti-Corruption and Anti-Bribery Standard.




Relationships with government officialsIf you interact with government officials on Autoliv’s behalf, be aware that laws and regulations governing what gifts and entertainment companies may provide to government officials can be very restrictive. Therefore, at Autoliv, we are also restrictive. Meals, gifts, and travel may not be offered to or accepted from government officials without prior consent. Entertainment is strictly prohibited. A government official can be a national or local government official or employee, a political candidate, or an official or employee of a government-owned or government-controlled entity.

For more detail, see the Autoliv Anti-Corruption and Anti-Bribery Standard.

Political and charitable activitiesEach country in which Autoliv operates has restrictions on political contributions by companies. In general, do not offer anything to a government official - directly or indirectly - in return for favorable treatment. While employees can make personal contributions to a political party, committee, or candidate of their choice, they may not in any way directly or indirectly involve Company funds or other resources for such contributions. Autoliv resources (whether cash or otherwise) may be used for political contributions only with prior approval of the Autoliv General Counsel.

Autoliv supports our community involvement in donating our time and resources for worthy causes. Autoliv Legal must be consulted in advance of any request for a donation to a government-affiliated charity.

For more information, see the “Political Donations, Charitable Donations and Sponsorships” section of the Autoliv Anti-Corruption and Anti-Bribery Standard.






PRIVACY PROTECTIONWe each provide certain personally identifiable information to Autoliv. Personally identifiable information, or personal data, is information that can be used on its own or with other information to identify a living individual, such as name, address, telephone number and other contact details, résumé or CV, salary, and statements of opinion or intention. Autoliv is committed to respecting all employees’ privacy rights, and we take precautions to protect everyone’s personal data from unauthorized access, use, retention, and/ or disclosure. If you work with this type of information, you have a responsibility to collect, process, and store such information in accordance with the law and all Autoliv requirements.

For more details, see the Data Protection Policy.

INSIDER TRADINGAutoliv’s Insider Trading policy provides guidance and additional safeguards against unintended violations of securities trading laws and includes restrictions on when employees may trade in Autoliv shares.

While the precise laws vary between countries, insider trading involve buying or selling a company’s stock based on inside information about that company. Inside information can be any fact that is both material (meaning that it impacts the value of the company’s stock) and non-public (meaning that it has not been disclosed to the public). Insider trading is generally a very serious breach of the law. It exposes the individual concerned to very serious civil and criminal penalties and can make Autoliv stakeholders and the general public lose trust in the Company.

Keep in mind that the restriction on trading in shares when we have access to inside information is not specific to Autoliv. It could also relate to one of our customers or suppliers. As an example, if you know that Autoliv is giving a large order to “ABC Corp.,” you are likely not allowed to trade shares of ABC Corp., nor may you tell anyone else to do so.

For more details, see the Autoliv Standard Insider Trading Policy.



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INTERNATIONAL TRADEExports and importsIt is Autoliv’s policy to comply with all applicable export, import, and trade compliance laws in all countries in which Autoliv conducts business.

Business should not be undertaken in any jurisdiction that is subject to an embargo or comprehensive trade restriction without a review by the Autoliv Legal Department.

For more details, see the Export Control Policy.

Boycotts and sanctionsSimilarly, we are responsible for following anti-boycott laws. For instance, you may encounter requests for Autoliv to participate in illegal boycotts against certain people or countries, often in bills of lading and other shipping documents. If you are asked to support or participate in a boycott, report what you know to the Legal Department.

We also need to be aware of certain trade sanctions. Trade sanctions can limit or even prohibit us from doing business with certain countries, entities, or individuals. We are committed to following the sanctions that apply to us.





Our Company has implemented a variety of policies, codes, and standards to define how we do business. The Autoliv Corporate Standards (AS) define common global policies, based on customer requirements, external standards and regulations, as well as best practices and collective knowledge developed by employees. Our Chairman, President & CEO, General Counsel, and Corporate Compliance Officer are responsible for ensuring that compliance and ethics-related Standards are kept up to date.

Autoliv Corporate Standards are managed by Corporate Quality, with each Autoliv Standard created, reviewed, released, and stored according to a defined procedure. In each facility, the Autoliv Standards are implemented by the appropriate function(s), according to the expectations contained in each standard.

Adhering to Autoliv Standards is crucial to ensuring consistent processes and behaviors and supporting our status as a true global Company. We are all responsible for understanding, respecting, and following Autoliv Standards.

All Autoliv Standards are stored in the Autoliv Corporate Standards database that can be found on LifeNET.

organizationaL governance

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Generally, no one is exempt from any provision of this Code, regardless of position. However, in certain limited circumstances, the CEO together with Corporate Compliance may waive the applicability of a provision of this Code for employees. Any waiver of this Code for executive officers or directors may be authorized only by our Board of Directors or, to the extent permitted by the rules of the New York Stock Exchange, a committee of the Board of Directors and will be disclosed to stockholders as required by applicable laws, rules and regulations.

waivers


heLpLine numbers by country

Country Toll Free Number Access Code (only applicable where listed)

Brazil 0800-892-1870Canada 1-888-978-6858China - North 10-800-711-1177China - South 10-800-110-1099Estonia first dial: 800-12001 then dial: 888-978-6858France 0800-91-0501Germany 0800-183-0846Hungary 06-800-20-219India 000-800-100-1556Indonesia 001-803-1-002-6647Italy 800-870279Japan 00531-11-0186Japan 0066-33-830414Republic of Korea 00308-13-2721Malaysia 1-800-81-6363Mexico 001-888-978-6858Netherlands 0800-022-2534Philippines 1-800-1-111-0683Poland 0-0 800-111-1990Romania first dial: 0808-03-4288 then dial: 888-978-6858Russia first dial: 8^10-800-110-1011 then dial: 888-978-6858Russia first dial: 363-2400 then dial: 888-978-6858Russia first dial: 8^495-363-2400 then dial: 888-978-6858Russia first dial: 363-2400 then dial: 888-978-6858Russia first dial: 8^812-363-2400 then dial: 888-978-6858South Africa 0800-999-753Spain 900-98-1288Sweden 020-790854Sweden - Stockholm 020-109123Taiwan 00801-10-4402Thailand 001-800-11-002-6647Tunisia 80 10 16 16Turkey first dial: 0811-288-0001 then dial: 888-978-6858United Kingdom 0808-234-0961United States 1-888-978-6858

AUTOLIV HELPLINEWeb address: helpline.Autoliv.com

PHONE NUMBERS BY COUNTRY:


Every year, Autoliv’s products save over 30,000 lives

Autoliv, Inc.Visiting address: Klarabergsviadukten

70, World Trade Center, Entrance C6

Mail: P.O. Box 70381SE-107 24 Stockholm

SwedenTel: +46 (0)8 587 20 600

[email protected]

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www.autoliv.com

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