CATERPILLAR’S

CODE OF CONDUCT

OUR VALUES IN ACTION

A MESSAGE FROM OUR CHAIRMAN AND CEO......................

WINNING THE RIGHT WAY.............................................

OUR MISSION, OUR PURPOSE........................................

REPORTING RIGHTS & RESPONSIBILITIES..........................

NO RETALIATION.........................................................

SAFETY....................................................................

Demonstrating Care................................................................................7

Learning and Improving Together.........................................................7

Preventing Serious Injuries....................................................................8

Sharing a Mindset...................................................................................8

INTEGRITY................................................................

Conflicts of Interest...............................................................................10

Fair Competition....................................................................................10

Free Trade..............................................................................................11

Financial Reports and Accounting......................................................11

External Communications....................................................................12

Inside Information..................................................................................13

Improper Payments...............................................................................14

TEAMWORK. ............................................................ 15

Respect and Non-Harassment............................................................16

Fairness and Non-Discrimination........................................................16

Global Respect......................................................................................17

Strong Collaboration.............................................................................17

EXCELLENCE. ........................................................... 18

Product and Service Quality...............................................................19

Work Environment.................................................................................19

Risk Management.................................................................................20

COMMITMENT. ......................................................... 21

Personal Responsibility........................................................................22

Protection of Assets..............................................................................22

Confidential Information.......................................................................23

Technology.............................................................................................24

Personal Privacy....................................................................................24

Public Matters........................................................................................25

Government Contracts.........................................................................25

Sustainability..........................................................................................26

Environmental Responsibility..............................................................26

Human Rights........................................................................................27

ENTERPRISE POLICIES &

ADDITIONAL INFORMATION. ......................................... 28

TABLE OF CONTENTS

Caterpillar Company Code of Conduct Handbook — page 3

A MESSAGE FROM OUR

CHAIRMAN AND CEO

At Caterpillar, we build a better, more sustainable world. From disaster recovery and building

the world’s infrastructure to delivering critical minerals and reliable energy, our collective

actions improve the lives of others.

Our global Caterpillar team is united by our mission of solving our customers’ toughest challenges

and our commitment to Winning the Right Way. Our Values of Safety, Integrity, Teamwork,

Excellence and Commitment guide our actions every day.

Our Code of Conduct defines Our Values and provides direction on implementing them in our

daily work. Guided by Our Values, we hold ourselves and each other accountable to the highest

standards, ensuring our decisions are consistently ethical and responsible. The Code describes

what we stand for as Caterpillar employees and how we conduct ourselves with customers,

dealers, suppliers and one another.

The expertise and dedication of our incredible people drive our success and make Caterpillar a truly

special place to work. Thank you for upholding our legacy by reading and understanding our Code

and speaking up when you have questions or concerns. Living by Our Values every day helps us all

Win the Right Way. Together we’re building on our strong foundation to create an even better future.

JOE CREED

Chairman and Chief Executive Officer

Caterpillar Company Code of Conduct Handbook — page 4

WINNING THE RIGHT WAY

The words in this Code of Conduct define us. Despite our differences — in geography, culture,

language and business — we are one Caterpillar, one company united by these common principles

with a shared commitment to Winning the Right Way and the highest standards of conduct.

While we operate within the framework of the laws and regulations that apply to our business, we

hold ourselves to a higher standard. Our responsibility extends beyond compliance; Our Values —

Safety, Integrity, Teamwork, Excellence and Commitment — guide everything we do. By following

the Code, we create a work environment we all can take pride in, a company respected and admired

by others and a world made better by our actions. Winning the Right Way means that we uphold the

reputation of one of the world’s greatest companies — and strengthen it for tomorrow. Together, we

are strengthening our values-based culture to carry us forward to even higher levels of success.

This Code of Conduct applies to the daily activities of employees of Caterpillar Inc., its subsidiaries

and affiliates worldwide and members of its Board of Directors. We all have a personal responsibility

to understand the Code, apply it consistently and live Our Values. If we lead others, we are also

responsible for setting the example of what it means to Win the Right Way.

SAFETY. INTEGRITY. TEAMWORK. EXCELLENCE. COMMITMENT.

Caterpillar Company Code of Conduct Handbook — page 5

OUR MISSION, OUR PURPOSE

OUR MISSION

OUR PURPOSE

Solving our customers’ toughest challenges.

We build a better, more sustainable world.

Every day, we empower our customers with innovative products, services and digital solutions. 

We support those building the infrastructure of tomorrow, those mining the materials that make it

happen and the energy providers who shape communities and connect people.  

By integrating advanced technology into our solutions, we help our customers optimize

productivity, safety and efficiency. Our solutions are designed from the start with digital and

technology integration, helping customers achieve their sustainability goals and build what’s next.

Caterpillar Company Code of Conduct Handbook — page 6

REPORTING RIGHTS

& RESPONSIBILITIES

Winning the Right Way requires us to hold ourselves and one another accountable for our actions.

When you speak up, you actively shape our culture where high ethical standards are non-negotiable.

If you become aware of any violation of the

Code,

enterprise

policy or procedure

or applicable

law,

you must report it immediately.

Caterpillar has many reporting resources available to you, including:

• Your supervisor

• Local management

You always have the option to contact the Office of Business Practices (OBP) using the contact information below.

Online Reporting:

https://caterpillar.ethicspoint.com

By Email:

BusinessPractices@cat.com

By Mail:

Caterpillar Inc.

Office of Business Practices

100 N.E. Adams Street

Peoria, IL 61629-6485 (USA)

Call Collect Helpline:

+770-582-5275 (language translation available)

CONTINUED >

Toll free Helpline:

Caterpillar maintains toll-free Helpline

numbers in many countries.

• Inside Canada, the United States and the U.S. Virgin

Islands, call 1-800-300-7898.

• International toll-free OBP Helpline numbers

currently in effect for other countries are available

on caterpillar.com. Language translation services

are available for those numbers.

• You may remain anonymous when you call from a

country where anonymous reporting is allowed.

• Local or corporate human resources teams

• Legal services teams

Caterpillar Company Code of Conduct Handbook — page 7

REPORTING RIGHTS

& RESPONSIBILITIES

(CONTINUED)

You must report responsibly and only when you reasonably believe there has been a violation,

and not where the report is intended to be harassing or is based solely on personal opinion.

Violations of Caterpillar policies, procedures or this Code will be addressed promptly and

effectively. Violations may result in disciplinary action up to and including employment separation

in accordance with company policy and applicable law.

NO RETALIATION

Speaking up takes courage, and we are committed to helping you feel safe and supported

in doing so.

Caterpillar has a zero-tolerance policy for retaliation. We strictly prohibit any form of retaliation —

including unfair treatment, demotion and exclusion from opportunities — against anyone

who raises concerns or reports potential misconduct in good faith.

If you believe you are experiencing retaliation, report it immediately. We will take all appropriate

and necessary actions to address and resolve the matter.

Caterpillar Company Code of Conduct Handbook — page 8

SAFETY

SAFETY IS AT THE CORE OF WHO WE ARE

It drives us to protect what matters most — our people. We speak up when we see a way to make things safer, and we listen

to each other — learning together and improving as one team. We prevent serious injuries by focusing on tasks that can lead

to serious harm and measure our success by the presence of controls and safeguards to protect our workers when things go

wrong. We are built to care, fueled by learning and powered to prevent.

CARE. LEARN. PREVENT.

Caterpillar Company Code of Conduct Handbook — page 9

SAFETY

WE DEMONSTRATE CARE AND FEEL SAFE TO SPEAK UP

WE LEARN TOGETHER TO CONTINUOUSLY IMPROVE

Demonstrating care is our foundation.

• We recognize how we respond matters.

• We build trust and respect with each other by actively listening, showing empathy

and staying curious to learn from those closest to the work.

• We support an open and caring culture where employees feel empowered to

speak up by remaining humble and seeking to understand.

Learning and improving is vital.

• We foster a learning culture where we learn together from our mistakes and successes.

• We seek to understand the context when things go wrong rather than assign blame.

• We see our people as the experts and recognize that those closest to the work have

the best knowledge of how work can be done successfully.

• We use their insights to strengthen our controls and safeguards.

WE PUT SAFETY IN ACTION WHEN…

Caterpillar Company Code of Conduct Handbook — page 10

WE PREVENT SERIOUS INJURIES BY FOCUSING ON HIGH ENERGY

OUR ACTIONS MATCH OUR WORDS

Preventing serious injury is critical.

• We recognize that people make mistakes and things will go wrong at times.

• We work to control high energy tasks and improve the presence of safeguards —

so that even when things do not go as planned, our people are protected.

• We define safety success as the presence of controls and safeguards rather than

the absence of injuries.

Safety is a shared mindset we integrate in all that we do.

• We engage everyone — employees, leaders, contractors and visitors — in our safety program.

• We see safety as a state of mind that we embrace at work, on the road and at home.

• We recognize proactive safety actions and share stories to learn from each other.

SAFETY

HOW WE RESPOND MATTERS

Safety is at the core of who we are, and how we respond to concerns directly impacts how much we can learn from one

another. Speaking up about safety is not just important, it’s essential. It’s how we build trust, improve controls and ensure that

everyone goes home safely, every day. Leaders play a vital role in fostering a learning culture by staying curious, encouraging

open dialogue and creating space for others to speak up. When individuals feel safe to raise concerns, we unlock the

opportunity to learn, grow and prevent harm.

Caterpillar Company Code of Conduct Handbook — page 11

INTEGRITY

INTEGRITY IS THE FOUNDATION OF ALL WE DO

DO THE RIGHT THING

It is a constant. Those with whom we work, live and serve can rely on us. We align our actions with our words and deliver

what we promise. We build and strengthen our reputation through trust. We do not improperly influence others or let them

improperly influence us. We are respectful and behave in an open and honest manner. In short, the reputation of the enterprise

reflects the ethical performance of the people who work here.

Caterpillar Company Code of Conduct Handbook — page 12

INTEGRITY

WE AVOID AND MANAGE CONFLICTS OF INTEREST

WE COMPETE FAIRLY

Separating personal interests from company business builds trust.

• We avoid activities that create, or even appear to create, a conflict of interest.

• We recognize that conflicts of interest arise when personal, family or other relationships

make it hard to fairly represent Caterpillar.

• We understand roles involving company spending, hiring or access to confidential

information carry a higher risk of conflicts of interest.

• We only exchange gifts and entertainment that are reasonable in value and comply with

all laws and our policies and procedures.

Fair competition is fundamental to free enterprise.

• We observe antitrust and competition laws where we do business.

• We avoid arrangements with competitors, dealers, distributors, suppliers and customers

that restrict competition.

• We do not engage in discussion or agreements with competitors about price, terms of sale,

quantities sold or allocating customers.

• We do not make agreements with other companies on wages, benefits or hiring.

WE PUT INTEGRITY IN ACTION WHEN…

Caterpillar Company Code of Conduct Handbook — page 13

WE SUPPORT FREE TRADE AND FOLLOW INTERNATIONAL TRADE LAWS

WE CREATE ACCURATE AND COMPLETE FINANCIAL RECORDS AND REPORTS

Free trade fosters competition, drives continuous improvement and helps us better serve

our customers globally.

• We support and promote policies that enhance global competition and reduce or

eliminate trade and investment barriers.

• We follow applicable international trade laws including import and export controls

regulations, sanctions and anti-boycott laws.

• We comply with trade laws and regulations in the countries where we do business.

Building trust with investors, creditors, regulatory authorities and others depends on the integrity

and accuracy of Caterpillar’s financial and accounting information.

• We create accounting and financial records that accurately reflect the data and facts.

• We all share the responsibility to create true, correct and complete financial records

and follow internal controls.

• We apply the same standards of integrity and transparency to our internal financial reporting

and management reporting tools as we do to our external reporting.

INTEGRITY

Caterpillar Company Code of Conduct Handbook — page 14

WE ARE HONEST, CLEAR AND RESPECTFUL IN OUR COMMUNICATIONS

Transparency is essential for building trust with one another and with our stakeholders.

• We take our responsibility as a public company seriously, communicating with all

stakeholders in a respectful, fair and honest manner.

• We make full, timely and accurate disclosures to the U.S. Securities and Exchange

Commission and to other governmental and regulatory agencies.

• We maintain consistency in our public communications, releasing messages

transparently and impartially, without favoring any group or individual.

• We understand that only designated spokespersons may communicate on behalf of

Caterpillar or respond to requests for information from the media, governments,

analysts and stockholders.

INTEGRITY

Caterpillar Company Code of Conduct Handbook — page 15

WE HANDLE ALL COMPANY INFORMATION THE RIGHT WAY

Protecting inside information is important to establishing trust with one another, our stakeholders

and the public at large.

• We do not use “material” inside information about Caterpillar for personal gain, provide it to

others or use it to trade in Caterpillar securities.

• We do not trade in the securities of a third party (including dealers, suppliers, customers or

competitors) if we possess their material inside information, nor do we advise others to do so.

• We are all responsible for following Caterpillar’s insider trading policy. This includes our

families and others with access to inside information.

Inside information

is non-public company information — such as financial data, technical

materials or future plans — that could have significant value to others. It may be considered

material if an investor would consider it important when making an investment decision, and it

must be kept strictly confidential.

INTEGRITY

Caterpillar Company Code of Conduct Handbook — page 16

WE REFUSE TO MAKE IMPROPER PAYMENTS

Our reputation for honesty and integrity is built on our ethical conduct.

• We will not influence the acts or decisions of any public officials, or other corporations or

private citizens, either directly or indirectly, through improper payments such as bribes or

kickbacks.

• We understand how to recognize potential bribes and kickbacks and will report any requests

for improper payments or inappropriate business courtesies immediately.

• We carefully manage our relationships with third parties and dealers and conduct due

diligence as required by our procedures.

• We record all financial transactions accurately and honestly.

INTEGRITY

HOW WE RESPOND MATTERS

Integrity is the foundation of all we do. When you speak up about misconduct or concerns, you help build trust across

the organization. We recognize mistakes can provide opportunities to learn and grow together. Leaders listen, take

action and lead by example — showing what it means to Win the Right Way through honesty and trust.

Caterpillar Company Code of Conduct Handbook — page 17

TEAMWORK

WE HELP EACH OTHER SUCCEED

We are a team, sharing our unique talents to help those with whom we work, live and serve. The diverse thinking and

decision making of our people strengthens our team. We respect and value people with different opinions, experiences and

backgrounds. We know that by working together, we can produce better results than any of us can achieve alone.

WIN TOGETHER

Caterpillar Company Code of Conduct Handbook — page 18

TEAMWORK

WE TREAT OTHERS WITH RESPECT AND DO NOT TOLERATE

INTIMIDATION OR HARASSMENT

WE TREAT PEOPLE FAIRLY AND PROHIBIT DISCRIMINATION

A commitment to respect, trust and dignity helps everyone achieve their full potential.

• We create and foster a work environment free of intimidation and harassment.

• We have the right to expect a positive working environment.

• We have the responsibility to speak up and ask for change if we observe behavior that

does not align with Our Values.

A productive and motivated workforce thrives when everyone is treated fairly and equitably.

• We respect and recognize the contributions of all employees and stakeholders.

• We build trust by selecting and placing employees based on their qualifications, considering

accommodations as appropriate.

• We make employment decisions without regard to race, religion, national origin, color,

gender, gender identity, sexual orientation, age and/or physical or mental disability.

• We follow all laws that prohibit discrimination everywhere we do business.

WE PUT TEAMWORK IN ACTION WHEN…

Caterpillar Company Code of Conduct Handbook — page 19

WE OPERATE INCLUSIVELY WITHIN OUR COMPANY AND AROUND THE WORLD

WE BUILD STRONG BUSINESS RELATIONSHIPS

When people with diverse backgrounds, talents and experiences work together, they drive

innovative solutions and achieve superior results.

• We embrace the unique talents, skills, abilities, cultures and experiences of all individuals.

• We build trust by seeking out and being receptive to various points of view.

• We work to positively impact the people and communities we serve.

Having strong, mutually rewarding business relationships is critical to our success and the success of our customers.

• We engage in meaningful and honest conversation with external stakeholders, including governmental

and non-governmental organizations.

• We strengthen relationships with dealers and distributors through trust, open and direct communication

and shared success.

• We work closely with suppliers throughout the entire lifecycle of our products and solutions to enhance

the value of our products and services, overseeing their commitment to our ethical principles.

TEAMWORK

HOW WE RESPOND MATTERS

Teamwork means helping each other so we can succeed together. Great teams thrive on diverse thinking.

Speaking up with unique perspectives or concerns strengthens our team. We value open dialogue, and

leaders are committed to taking action to achieve results we cannot reach alone.

Caterpillar Company Code of Conduct Handbook — page 20

EXCELLENCE

WE SET AND ACHIEVE AMBITIOUS GOALS

The quality of our products and services reflects the power and heritage of Caterpillar — the pride we take in what we do and what

we make possible. We are passionate about people, process, product and service excellence. We are determined to serve our

customers through innovation, continuous improvement, an intense focus on customer needs and a dedication to meet those needs

with a sense of urgency. For us, Excellence is not only a value; it is a discipline and a means for making the world a better place.

BE THE BEST

Caterpillar Company Code of Conduct Handbook — page 21

EXCELLENCE

WE COMMIT TO THE BEST SOLUTIONS FOR OUR CUSTOMERS

WE CREATE A WORKPLACE WHERE EXCELLENCE CAN GROW

Our continued success depends on exceeding the expectations of our customers and standing

behind everything we do.

• We build our reputation for Excellence by listening to customer needs and delivering

solutions that help them succeed.

• We take personal pride in all the products and services we provide, committing to the highest

quality and value.

• We act with a sense of urgency to deliver value, utilizing continuous improvement methodologies.

• We make decisions and work to enhance customer satisfaction and promote their loyalty.

Our work environment is designed to promote personal achievement, continual learning and a

feeling of self-worth for every employee.

• We actively seek and share viewpoints to achieve excellence and drive innovation.

• We respect the right of every employee to express good-faith opinions about how to

improve their own performance and the performance of the company.

• We are responsible for giving our best efforts, learning from success and setbacks, and actively

seeking opportunities to develop our abilities and contribute fully to Caterpillar’s success.

WE PUT EXCELLENCE IN ACTION WHEN…

Caterpillar Company Code of Conduct Handbook — page 22

WE MANAGE RISK FOR ENTERPRISE SUCCESS

Managing risk requires everyone to take an enterprise point of view and help identify and handle

the opportunities and challenges that affect our entire company.

• We speak up immediately when we see a potential problem or risk that could impact

our business.

• We make decisions that benefit the entire company and seek better ways to work —

through improved processes, safer practices and innovative ideas.

• We strengthen our products, services and operations by sharing ideas and lessons

learned across teams.

EXCELLENCE

HOW WE RESPOND MATTERS

Excellence means setting and achieving ambitious goals. When we speak up to improve a process, product, quality or

service, we spark innovation and create opportunities to grow. Leaders bring this to life by turning challenges into action

and helping their team move forward.

Caterpillar Company Code of Conduct Handbook — page 23

COMMITMENT

WE EMBRACE OUR RESPONSIBILITIES

Individually and collectively, we make meaningful commitments — first to each other, and then to those with whom we work,

live and serve. We understand and focus on the needs of our customers. We are responsible members of our communities who

are dedicated to safety and care for our environment, and we manage our business ethically. We know it is both our duty and our

honor to carry the Caterpillar heritage forward.

OWN THE OUTCOME

Caterpillar Company Code of Conduct Handbook — page 24

COMMITMENT

WE PROTECT OUR ASSETS, BRANDS AND INNOVATIONS

WE TAKE PERSONAL RESPONSIBILITY

Our assets matter to the company.

• We protect all company assets — tangible and intangible — from loss, theft, damage or misuse.

• We do not employ individuals to gain access to the sensitive information or trade secrets of others.

• We respect the valid intellectual property rights of others and commit to using company assets in

a way that builds trust with our partners.

• We keep all trade secrets and sensitive information strictly confidential, including data belonging

to the company, customers, dealers and suppliers — both during and after our employment.

• We share company information only after confirming appropriate controls are in place to

safeguard our interests.

Our reputation depends on consistently honoring commitments to our customers, partners and one another.

• We gain a deep understanding of customer needs, follow through on what we promise

and deliver a superior customer experience.

• We take ownership of our results and are personally accountable for meeting both individual

and shared goals.

• We use good judgment and avoid any interaction that might disparage or damage our reputation.

• We follow company policies and procedures and comply with the law.

WE PUT COMMITMENT IN ACTION WHEN…

Caterpillar Company Code of Conduct Handbook — page 25

WE KEEP CONFIDENTIAL INFORMATION SAFE

Information is an important asset that requires protection.

• We treat all confidential and proprietary information with care, whether it belongs

to Caterpillar, a customer or a business partner.

• We access and use confidential information only when it is necessary to perform our job.

• We handle confidential information with respect and do not share it with anyone who

is not authorized.

• We only share confidential information outside the company when necessary and legal

protections are in place.

Examples of confidential information include information that has not been disclosed to the

public, such as trade secrets, financial data, new product or service development plans and other

corporate and/or personal information.

COMMITMENT

Caterpillar Company Code of Conduct Handbook — page 26

WE USE TECHNOLOGY THE RIGHT WAY

WE RESPECT PEOPLE’S PRIVACY

Electronic communication and technology play a vital role in how we conduct

our business every day.

• We use electronic communication and systems for legitimate business activities.

• We keep our access and credentials secure.

• We use the internet and company systems in a way that supports a positive,

professional business climate.

• We use good judgment when communicating on social media, making it clear that our

personal views are not Caterpillar’s, and we do not share confidential information.

• We use company technology, including artificial intelligence (AI) tools, in a responsible

and professional manner consistent with the Code and company policy.

Recognizing and respecting people’s privacy is essential to how we conduct business.

• We collect and process personal information only as needed or appropriate for fair and

lawful business purposes.

• We take care to appropriately protect the security and confidentiality of personal information

that we collect and process.

COMMITMENT

Caterpillar Company Code of Conduct Handbook — page 27

WE RESPONSIBLY ENGAGE ON PUBLIC POLICY ISSUES

WE FOLLOW THE LAW WHEN WORKING WITH GOVERNMENT ENTITIES

As a leading global manufacturer and U.S. net exporter, Caterpillar actively participates in the

public policy process, advocating for key issues that align with our purpose and the execution of

our strategy.

• We work with policymakers to support issues that help our business grow and create value

for customers, shareholders and communities.

• We support our employees’ respectful participation in the political process.

Unique rules apply to contracts with governments and state-owned enterprises.

• We act in a way that honors our contractual commitments and complies with applicable

laws for transacting with these customers.

• We hold ourselves accountable to meet these unique obligations by acting with

honesty and integrity.

COMMITMENT

Caterpillar Company Code of Conduct Handbook — page 28

WE ARE COMMITTED TO SUSTAINABILITY

WE FOCUS ON ENVIRONMENTAL RESPONSIBILITY AND WASTE PREVENTION

We take pride in our legacy of providing our customers with innovative products and services

for more than 100 years.

• We help our customers fulfill society’s need for infrastructure, including shelter, clean water,

transportation and reliable energy.

• We innovate so customers have products, services and solutions that improve the

sustainability of their operations.

• We leverage technology and customer insight while investing in new products,

technologies and services.

• We promote remanufacturing to extend product life.

• We help customers achieve their sustainability-related objectives.

Our commitment to environmental stewardship guides our operations.

• We are committed to further reducing greenhouse gas emissions from our operations.

• We support business processes that reduce waste, improve quality and promote the efficient

use of resources in our locations.

• We follow environmental laws and regulations and expect our suppliers and dealers

to do the same.

COMMITMENT

Caterpillar Company Code of Conduct Handbook — page 29

WE CARE ABOUT HUMAN RIGHTS

Caterpillar is committed to respecting internationally recognized human rights principles

throughout our extended value chain.

• We follow applicable local labor laws and expect those with whom we work to do the same.

• We do not condone and we strive to eliminate all forms of forced labor, child labor and

discrimination in the workplace.

• We encourage any party to report situations where they have good faith belief that actions

are inconsistent with our commitment to protecting and promoting human rights.

COMMITMENT

HOW WE RESPOND MATTERS

Commitment means owning our responsibilities and the outcome. We show it by speaking up about issues that

impact our customers, communities or the environment, and by promoting a culture rooted in ethics and compliance.

Leaders model excellence and inspire all of us to carry the Caterpillar heritage forward with accountability and care.

Caterpillar Company Code of Conduct Handbook — page 30

ENTERPRISE POLICIES & ADDITIONAL INFORMATION

Enterprise policies, procedures and other more detailed company policies, as well as additional information and guidance on this

Code of Conduct, are available to employees on the Win the Right Way website. The Code of Conduct is available to the public at

https://www.caterpillar.com/Code-of-Conduct.

The Enterprise Policies in force at the time this Code of Conduct was published are:

• Antitrust

• Advocacy and Political Contributions

• Conflicts of Interest

• Data Privacy

• Enterprise Facilities

• Human Rights

• Improper Payments

• Intellectual Property Rights

• Protection of Assets

• Providing and Receiving Travel, Gifts and Entertainment

• Public Communications

Caterpillar Company Code of Conduct Handbook — page 31

SAFETY

CARE. LEARN. PREVENT.

INTEGRITY

DO THE RIGHT THING

TEAMWORK

WIN TOGETHER

EXCELLENCE

BE THE BEST

COMMITMENT

OWN THE OUTCOME

Caterpillar Company Code of Conduct Handbook — page 32

respective logos, “Caterpillar Corporate Yellow,” the “Power Edge” and Cat “Modern Hex” trade

dress, as well as corporate and product identity used herein, are trademarks of Caterpillar Inc.

01-042102-00

Caterpillar Company Code of Conduct Handbook

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