Stellantis NV

As reported in the Code of Conduct, the Group was committed to conducting our government and public institution relations, including lobbying, in accordance with applicable laws and ethics rules as well as in full compliance with the Code and any applicable local procedures. Political contributions by the Group were only allowed where permitted by law and must be authorized at the appropriate level within each Group company. In 2020, no contributions were made to political parties.

Stellantis also shifted its lobbying approach toward a more direct and transparent interaction with citizens and stakeholders supporting the Freedom of Mobility Forum. Planned for early 2023, the forum will be a meeting of passionate problem solvers committed to fact-based discussion addressing how we can bring sustainable mobility in the face of global warming implications. [...] The ESG Committee: The function of the ESG Committee is to assist and advise the Board of Directors and act under authority delegated by the Board of Directors with respect to monitoring, evaluation and reporting on the sustainable policies and practices, management standards, strategy, performance and governance globally of the Company and its subsidiaries. [...] Stellantis' risk management system includes action plans and quality indicators, which are audited by the Risk Department of the Company. Corporate Social Responsibility (CSR) macro risks and issues are also embedded in the Top Risks process through interviews of a significant number of managers and top managers. The relevant actions are reflected in the mitigation plans implemented in operational divisions and included in training programs as needed."
"Stellantis Public Affairs practices adhere to the UN Global Compact recommendations toward responsible contributions to public debate. Our relationship with governments is respectful, proactive and transparent. In line with Stellantis CSR commitments, the Company takes part in public debate on a wide range of issues, including those related to the automotive industry, ecology and the environment, transportation and mobility, data protection, road safety, regional development and international trade. [...] In order to regulate its practices and make them clear to external contacts, Stellantis has adopted a specific charter for relations with public institutions. Furthermore, the Company has determined a specific delegation of authority applicable to Public Affairs to determine (1) how Corporate positions are defined and (2) which Professional Memberships Stellantis adheres to. The senior leaders of all regions have received a training on both documents and are responsible to inform their team accordingly. Both the charter and the delegation of authority apply to Stellantis employees who interact with public authorities (governments, parliaments, administrations, local authorities, etc.). They are to carry out their activity with probity and integrity, following the principles outlined in the charter and summarized below: - Control of practices: Per Stellantis delegation of authority, new positions taken on the most significant topics are approved by the CEO and debated in the Strategy Council. Moreover, Stellantis' positions on public issues are aligned with Dare Forward 2030. The Public Affairs Department is placed under the authority of the General Counsel who reports directly to the CEO. As outlined in section 2.4 related to "climate governance", all senior executives have incentive plans based on the CO2 performances of the Company, hence, the public positions taken by Stellantis are aligned with the climate change ambition of the Company. At an operational level, the managers in the Public Affairs Department are tasked with upholding the Stellantis Code of Conduct and the Charter with Public Institutions and to ensure that their teams do as well. New members of the Public Affairs Department are trained on the governance of Public Affairs and the corporate policies that apply to Public Affairs. Incentive plans for the Public Affairs Department include, as part of their goals, meeting the Company strategic plan which cite Stellantis' environmental objectives. The Public Affairs Department may be audited by the Internal Audit Department which acts independently. Stellantis' audit plan is based on a risk assessment process and is updated at regular intervals throughout the year. If, pursuant to the risks assessment, they were identified as being risky, they would be added to the audit plan. [...] Transparency: For each CSR macro risk, the Company outlines its public position in the CSR report. Contributions to public debates are in line with the described position, taking into account the local context. In order to ensure transparency in its dealing with public authorities, the Company complies with the international rules governing influential practices. Stellantis reports as required by law the activities and interactions between Stellantis and authorities and complies with the obligation of disclosure in the relevant registers of interest. For instance, in the U.S., federal lobbying is regulated by the U.S. Congress. Stellantis files quarterly reports that disclose spending on relevant activities and the specific topics addressed in interactions with particular public officials. Similarly, we register in the transparency register in the EU, in France and in Germany. [...] Political neutrality: Stellantis applies a policy of political neutrality; it does not make financial contributions to political parties or political candidates, in conformance with the Code of Conduct and the Charter for relations with Public Institutions.

Stellantis reviews all its professional memberships and associations every year and aims to ensure alignment with our positions. When there are divergences of opinion between Stellantis and the associations we are members of, processes are in place to escalate the issue to a higher decision level. [...] The Global Corporate Office and Public Affairs Officer, has an oversight for Stellantis Public Affairs activity globally. The Public Affairs' budget is reviewed and approved by the Global Corporate Office and Public Affairs Officer, who reports directly to the CEO. Stellantis' positions on public issues are aligned with our strategic plan Dare Forward 2030. Any new positions taken on the most significant topics are debated in the Strategy Council and reviewed by the CEO. [...] All members in the Public Affairs Department are tasked with upholding the Stellantis Code of Conduct and the Group Public Affairs Charter, both of which are available on our website. New members of the Public Affairs Department are fully trained on the governance of Public Affairs and the corporate policies that apply to Public Affairs. The Company has determined a specific Delegation of Authority applicable to Public Affairs to determine (1) how Corporate positions are defined and defended by the Public Affairs team and (2) which Professional Memberships Stellantis is aligned to. The senior leaders of all regions are fully trained on both documents and are responsible for informing their teams accordingly.

Stellantis also shifted its lobbying approach toward a more direct and transparent interaction with citizens and stakeholders supporting the Freedom of Mobility Forum. Planned for early 2023, the forum will be a meeting of passionate problem solvers committed to fact-based discussion addressing how we can bring sustainable mobility in the face of global warming implications.

The Company monitors legislation and regulations, contributing its expertise to the development of regulations and standards that matter to customers, communities and stakeholders. To regulate its practices and to foster transparency and integrity with external parties, Stellantis has adopted a specific charter for relations with public institutions and a delegation of authority for Public Affairs department. This charter and delegation of authority applies to Stellantis employees who interact with public authorities, requiring them to conduct their activities with probity and integrity while adhering to the principles of good governance, transparency, and integrity. All senior leaders are trained on these documents and are responsible for informing their teams. [...] In 2024, a new Global Head of the Public Affairs department was appointed and supports the IEC. All members of the Public Affairs department are tasked with upholding the Stellantis Code of Conduct and the charter, with new members fully trained on the governance and corporate policies. The compensation incentive plans for the Public Affairs department include environmental objectives. [...] Stellantis upholds transparency in dealings with public authorities by complying with relevant rules, standards, and guidelines. The Company provides reliable and accurate information by reporting activities and interactions with authorities and complying with disclosure obligations. [...] We are listed in the relevant transparency registers in the U.S., France, and Germany, with the specific registration identification numbers disclosed below: - Germany: register identification number R002372 (Lobby Register Bundestag.de); - France: register identification number (Fiche Stellantis – Hatvp.fr); and - U.S.: registration House identification number 40881 and Senate identification number 400460283.

The ESG Committee is responsible for monitoring and evaluating reports on the Company's sustainable development policies and practices, management standards, strategy, performance and governance globally. It is also responsible for reviewing, assessing and making recommendations regarding strategic guidelines for sustainability-related issues and reviewing the annual CSR Report. In 2023, climate change-related topics have been addressed by the Committee in its meetings. An induction session was organized to present the different solutions for CO2 emission compensation. [...] The Strategy Council meets monthly, to direct the strategy regarding vehicle CO2 emissions and to review on a quarterly basis the overall Carbon Net Zero roadmap with the Top Executive Team. The main objectives are to: Share the forecast of vehicle CO2 emission average for short, medium and long-term in different countries and geographical areas (especially where CAFE/CO2 regulation exists, such as in the U.S., Europe, China, Brazil, Japan, Korea, India, Australia, etc) and decide on action plans; Share the scenarios on hypotheses worked out by the Company's experts: using internal data related to Stellantis' current technologies using external data related to climate scenarios and market trends (regulation assumptions, energy mix evolution, uptake of electrified vehicles, etc.) covering risks regarding the supply chain including shortages. Approve global action plans and make the necessary decisions to achieve Stellantis Carbon Net Zero roadmap consistently with the Dare Forward 2030 strategic plan. The range of attendees demonstrates that the CO2 issue is at the core of Stellantis activities and strategy: the CEO is the Chairman of the Strategy Council. Top Executive Team members from Planning, Manufacturing, Purchasing & Supply Chain, General Counsel, Human Resources & Transformation, Finance, Regions, Brands and Engineering also participate. The frequent briefings of Top Executive Team members during the Strategy Council meetings about climate-related topics such as Life Cycle Assessment or carbon neutrality are meant for top managers to be up-to-date regarding climate change-related impacts."
"Stellantis Public Affairs practices adhere to the UN Global Compact recommendations toward responsible contributions to public debate (SDG 16). Our relationship with governments is respectful, proactive and transparent. In line with Stellantis CSR commitments, the Company takes part in public debate on a wide range of issues, including those related to the automotive industry, ecology and the environment, transportation and mobility, data protection, road safety, regional development and international trade. [...] Furthermore, the Company has determined a specific delegation of authority applicable to Public Affairs to determine (1) how Corporate positions are defined and defended by the Public Affairs team and (2) which Professional Memberships Stellantis is aligned to. The senior leaders of all regions are fully trained on both documents and are responsible for informing their teams accordingly. Both the charter and the delegation of authority apply to Stellantis employees who interact with public authorities (governments, parliaments, administrations, local authorities, etc.). They are to carry out their activity with probity and integrity, following the principles outlined in the charter and summarized below: Promoting good governance and control of practices: As outlined in Stellantis' delegation of authority, new positions taken on the most significant topics are debated in the Strategy Council and reviewed by the CEO. Moreover, Stellantis' positions on public issues are aligned with Dare Forward 2030. In 2023 the Public Affairs Department was placed under the authority of the Global Corporate Office and Public Affairs Officer who reports directly to the CEO. As outlined in section 2.4 related to "climate governance", all senior executives have incentive plans based on the CO2 performances of the Company, hence, the public positions taken by Stellantis are aligned with the climate change ambition of the Company. At an operational level, the members in the Public Affairs Department are tasked with upholding the Stellantis Code of Conduct and the Charter with Public Institutions. New members of the Public Affairs Department are fully trained on the governance of Public Affairs and the corporate policies that apply to Public Affairs. Incentive plans for the Public Affairs Department include, as part of their goals, meeting the Company strategic plan which cite Stellantis' environmental objectives. The Public Affairs Department may be audited by the Internal Audit Department which acts independently. Stellantis' audit plan is based on a risk assessment process and is updated at regular intervals throughout the year. If, pursuant to the risks assessment, they were identified as being risky, they would be added to the audit plan. Transparency and Integrity: For each CSR macro risk, the Company outlines its public position in this CSR report. Contributions to public debates are in line with the described position, taking into account the local context. To ensure transparency in its dealing with public authorities, the Company complies with the relevant rules, standards, and guidelines governing influential practices. Stellantis provides reliable and accurate information by reporting as required by law the activities and interactions between Stellantis and authorities and complies with the obligation of disclosure in the relevant registers of interest. For instance, in the U.S., federal lobbying is regulated by the U.S. Congress. Stellantis files quarterly reports that disclose spending on relevant activities and the specific topics addressed in interactions with particular public officials. Similarly, we register in the transparency register in the EU, in France and in Germany. In addition, Stellantis is implementing an internal system for tracking interactions between the global public affairs teams and public authorities in all regions we operate. There are no external investigations, against Stellantis, on allegations of breaches regarding transparency and integrity of engagement practices with public authorities. Political neutrality: Stellantis applies a policy of political neutrality; it does not make financial contributions to political parties or political candidates, in conformance with the Code of Conduct and the Charter for relations with Public Institutions.

The governance for our lobbying activity can be found on our website. [...] Stellantis reviews all its professional memberships and associations every year and aims to ensure alignment with our positions. When there are divergences of opinion between Stellantis and the associations we are members of, processes are in place to escalate the issue to a higher decision level.

The Public Affairs Department, under the responsibility of the General Secretary, is responsible for the accountability of the Group's positions concerning climate change and GHG emissions. [...] The Executive Vice President, Programs and Strategy, holds direct and specific responsibility on corporate CO2 emission average, and provides orientation for the development of new vehicles and in particular low-carbon vehicles. Being the head of the Automotive Programmes Department, which translates Groupe PSA strategy into product plans, it ensures their implementation by steering the development of vehicle and subassembly programmes with the responsibility for their economic performance. [...] Several climate issues falls into the scope of the Executive Vice President, R&D, who supervises the research and development of low emissive technologies as well as the reduction of the impact on air quality of the Group's technologies, the wise use of material in the vehicle life cycle and the consumption measurement protocol in real-driving conditions across the organisation. [...] The Executive Vice President, Global Purchasing and Supplier Quality, is also involved in reducing the Group's CO2 footprint. The GPSQ department monitors the environmental performance and CO2 emissions of suppliers and uses local sourcing as a way to enhance CO2 performance of Groupe PSA. [...] The Executive Vice-President, Industrial, coordinates the deployment of Groupe PSA environmental policy for manufacturing and research sites as well as within logistics policies. In addition, with its Industrial Environment Department, the Executive VP manages an annual investment plan that ensures plant operations are compliant with regulatory changes, while mitigating pollution and environmental risks. In addition to product strategy, which emphasizes the development of low-carbon vehicles, the Executive Vice-President Industrial focuses the Industrial Department on programs and actions to reduce the Group's carbon footprint notably through a reduction of direct energy consumption and the Supply chain on efficient transportation models. [...] The Executive Vice-President Quality, is responsible for the Group's Quality Policy and the Conformity Of Production of the homologated vehicles. [...] The Executive Vice President, Human Resources and Transformation contributes to the Company's transition to a low-carbon economy through the attraction of talents, the upscaling of employees and the co-construction of the Company's future via social dialogue with employees' representatives. In addition, the Human Resources Department is widely developing teleworking and on-line meetings to reduce the carbon footprint linked to employees commuting daily from home to the workplace or travelling between company locations. Real Estate assets are also managed to minimize their carbon footprint and their resilience to physical risks. This EVP is responsible for the compliance of the Group's emission declarations to the authorities and also supervises the Protection, Audit, and Risks department in charge of the Group's risk management and internal control. [...] The Executive Vice-President, Mobility and Connectivity Services, has an essential role in the implementation of new mobility solutions and the development of Free2Move, Groupe PSA new mobility brand, with the ambition to make it the preferred mobility service provider for customers. [...] Finally, across the regions and brands, consistency on climate change is also ensured at the Executive Committee level, since the Executive Vice-Presidents of the Group's geographical business regions or brands are in charge of implementing climate action plans in their area of responsibility and ensuring the achievement of the objectives set by the Executive Committee."
"The Public Affairs Department ensures the harmonisation of the Group's positions across the countries in which it operates. [...] Headed by a Head of Public Affairs and Government Relations, this department is placed under the authority of the General Secretary who reports directly to the Chairman of the Managing Board. [...] The Public Affairs Department is tasked with the following missions: [...] • identifying policy trends impacting Groupe PSA at an early stage; [...] • preparing and coordinating the Group's public affairs positions in collaboration with the business lines and ensuring that these positions and their underlying arguments are recorded and in line with the positions outlined in the CSR report; [...] • responding to request for dialogue with national and local public authorities, as well as with non-governmental stakeholders (trade unions, NGOs, citizens' associations, etc.), in particular by sharing the expertise necessary to make them aware of and understand the Group's positions; [...] • staying current with legislation and keeping the Group informed so that the Group may exercise its duty of care. [...] Groupe PSA has adopted a Charter for responsible relations with public institutions, in addition to the existing Code of Ethics to which all employees are subject. This Charter applies to employees of Groupe PSA who interact with public authorities (governments, parliaments, administrations, local authorities, etc.). They formally undertake to carry out their activity with probity and integrity and to respect transparency and political neutrality. [...] The Group's organisation of the process for relations with public institutions is in line with the associated Corporate Rule, which was approved by the Executive Committee. At an operational level, the managers in the Public Affairs Department have embraced the Group Code of Ethics, the Code and the Charter for responsible relations with public institutions and have expressly pledged to uphold its principles. Training outlining these rules was rolled out again in 2020 with all people who have contact with public authorities. [...] The Charter for responsible relations with public institutions, which is public and available on the Group's website, defines the principles that all Group employees carrying out relations with public institutions formally commit to following. It is built around the four following fundamental commitments: 1. Transparency, 2. Ethical values and Anti-corruption, 3. Political neutrality, 4. Dialogue. In line with the Charter for responsible relations with public institutions, the positions defended by Groupe PSA are officially recorded and the main positions are outlined in the CSR report.

###### 1.3 CSR GOVERNANCE [...] Stellantis CSR Global Office reports directly to the Executive Vice President (EVP) – Chief Communications and CSR Officer, who is a member of the top executive team and reports to the Chief Executive Officer. The role of the CSR Global Office is to: - ensure that Stellantis N.V. makes necessary corporate CSR public disclosures; - support dialogue with stakeholders (including investors) on ESG matters; - engage in assessment processes with CSR rating agencies; - watch CSR disclosure related legal requirements and stakeholders expectations, applicable to Stellantis N.V. Stellantis CSR Global Office oversees a CSR network composed of subject matter experts: the CSR Champions and CSR Correspondents, who represent the global functions of the Company. The CSR Champions work to ensure that the CSR issues under their responsibility are considered appropriately in the decisions of their Division. They: - directly report to the relevant EVP; - propose the CSR Ambition and the CSR Targets to the EVP for approval; - organize, monitor and consolidate the CSR commitments and key messages; - ensure the Company's CSR results with improvement actions align with stakeholders' expectations. The CSR Correspondents focus on proper and reliable disclosure of qualitative and quantitative information for the CSR issues under their responsibility. They: - manage their network of expert contributors to collect and consolidate facts and figures covering the reporting scope; - deliver their sections of the CSR disclosures; - support the CSR Global Office when answering external requests from stakeholders, particularly ESG rating agencies; - propose internally actions to improve performance based on weaknesses identified with the support of the CSR Global Office. The EVPs play a key role in the Company's CSR roadmap: they validate the medium- and long-term CSR visions, ambitions and targets for the CSR issues that are under their responsibility and are responsible for the achievements. Top Management incentives are set to align as much as possible with the diverse stakeholders' interests."
"Stellantis closely monitors its relationships with public authorities with the intention of ensuring that the Company interacts with government officials in a transparent, responsible and ethical way. In Europe, for example, the Company allocated a budget of approximately €1.7 million to its public affairs activities in 2021. The Company follows the guidelines issued by the European Commission and European Parliament for reporting on Stellantis's European activities. Accordingly, this amount includes: - personnel costs based on a full-time equivalent (50% of the total personnel costs); - the office and administrative expenses (100% of the costs, except for mobility costs covered at 50%); - the costs related to professional associations (25%); - externalization costs (100%). In the United States, federal lobbying is regulated by the U.S. Congress. Stellantis files quarterly lobbying reports that disclose spending on lobbying activities and the specific topics that its registered federal lobbyists addressed in interactions with particular public officials. The amount spent on lobbying that is reported for 2021 is €3.4 million, which includes: - labor costs (including G&A costs) for hours spent lobbying (100%); - amount paid to trade associations that the trade associations use for lobbying (100%); - amount paid to third party lobbying firms (100%); and - travel, meals, and other expenses incurred while lobbying (100%). The chart below details Stellantis's consolidated contributions for lobbying activities in 2021: (in € million) **2021 contribution** Internal 2.9€ Trade Associations and Consultancy 2.2€ Political contributions **Total contribution** **5.1€**"
"The Global Purchasing and Supply Chain department (GPSC) is the interface between Stellantis and its suppliers. The GPSC is responsible for meeting all legal and regulatory requirements under its scope and to require that all suppliers are fully compliant with Company policies to reduce the risk of exposure to the Company. This is its major duty of care toward supplier management across the globe. To support the direction of the GPSC, the Global Purchasing and Supply Chain EVP is a direct report to the CEO, and a member of the Top Executive Team, and as such, a member of the company's strategy council. [...] Governance is in place with monthly Purchasing and Supply Chain Leadership Team Meetings, hosted by the Chief Global Purchasing and Supply Chain Officer to monitor supplier CSR performance during sourcing.

Stellantis has established a comprehensive governance structure to oversee its sustainability reporting processes. The Audit Committee assists and advises the Board of Directors on the integrity of the Company's disclosures and reports on environmental, social, human rights and governance factors (collectively referred to as "sustainability reporting"). This is conducted in accordance with applicable reporting standards, ensuring the adequacy and effectiveness of the Company's internal controls in relation to sustainability reporting. In 2024, Stellantis formed the Sustainability Reporting and Disclosure Steering Committee, comprised of Senior Management, to monitor environmental, social, and governance disclosures are accurate, complete, fairly presented, timely, and compliant with applicable laws and regulations. Additionally, the committee considers relevant market practice, data collection requirements and voluntary reporting frameworks. [...] Stellantis upholds transparency in dealings with public authorities by complying with relevant rules, standards, and guidelines. The Company provides reliable and accurate information by reporting activities and interactions with authorities and complying with disclosure obligations. We are listed in the relevant transparency registers in the U.S., France, and Germany, with the specific registration identification numbers disclosed below: - Germany: register identification number R002372 (Lobby Register Bundestag.de); - France: register identification number (Fiche Stellantis – Hatvp.fr); - U.S.: registration House identification number 40881 and Senate identification number 400460283. [...] Stellantis applies a policy of political neutrality, and it does not make financial contributions to political parties or political candidates, in conformance with the Code of Conduct and the Charter for relations with Public Institutions. [...] The Stellantis Audit and Compliance team oversees the operational procedure for all third-party due diligence, including industry association memberships. The Stellantis Third-Party Due Diligence Program has been established to identify the risk to Stellantis of doing business with specific third parties, to quantify such risks, to conduct due diligence reviews relative to the risk that is identified and to provide relevant information to Stellantis business functions. The scope of the program includes all Stellantis business partners, but due diligence is performed only for partners that meet certain risk criteria. The risk criteria are set by the Due Diligence Core Team ("DD Team") reporting to the Chief Audit and Compliance Officer. Our current criteria combine functional risk, jurisdictional risk and financial risk. [...] The governance and control of lobbying practices is outlined in the charter and in the Public Affairs' delegation of authority. The main topics covered by our public affairs activities are: - environment and climate change: Stellantis' positions on public issues are aligned with our Dare Forward 2030 strategic plan strategy and the public positions taken by Stellantis align with the climate change targets of the Company. All senior executives have a long-term incentive plan containing a component relating to the CO2 performances of the Company; - vehicle safety: Stellantis is involved in developing the framework of ISO and participates with recognized organizations in the rulemaking process and implementation of new regulations and standards regarding vehicle safety, such as the UN Economic Commission for Europe corresponding working groups; - regional development and international trade: Stellantis supports the World Trade Organization rule-based system and encourages international trade deals. Trade agreements foster innovation, growth and wider customer choices at lower prices.

In this first Climate Policy Report, Stellantis provides a methodology and insight into our governance for our climate and sustainability policy engagement with all stakeholders. The 'Stellantis Way' process is designed to provide a clear vision of our global climate policy engagement, both directly with public authorities and indirectly through our relevant industry association partners. This review is the result of working group activity between Corporate Affairs, Communications, ESG, Investor Relations, and CO2 offices. It will be updated on a regular basis. [...] Stellantis Public Affairs activity is captured within the Stellantis Code of Conduct outlining our work with Governments, how we provide information, our anti-bribery stance, and lobbying and political contribution approach. [...] Our Public Affairs Charter supplements the Code of Conduct by providing additional detail and guidance on the application of Public Affairs in daily practice. [...] Stellantis' Public Affairs department does not determine Stellantis' company positions on specific topics in which we engage with public authorities but supports management in those interactions, with a view to ensure proper and effective engagement whilst preserving the Company's freedom to act. Our internal delegation of authority process instructs that any new positions, or any reiteration of positions or provision of information in support of positions already public, impacting relationships with any Government, NGOs, other stakeholders at regional or global level are approved by Regional Chief Operating Officer or Executive Chairman, respectively. [...] The Stellantis Audit and Compliance team oversees the operational procedure for all third-party due diligence, including industry association memberships. The Stellantis Third-Party Due Diligence Program has been established to identify the legal and reputational risk to Stellantis of doing business with specific third parties, to quantify such risks, to conduct due diligence reviews relative to the risk that is identified and to provide relevant information to Stellantis business functions. [...] For each topic, the industry association's climate policy position alignment with Stellantis climate policy position was assessed and categorised to being aligned, partially aligned, misaligned, or no public statement. In the event of partial alignment or misalignment between Stellantis climate policy position and industry association climate policy position, the working project group agreed on measures to be taken to improve alignment. As published in the Stellantis Public Affairs Charter, when a trade association seeks to take a position inconsistent with that of Stellantis, the Public Affairs department will engage with the trade association to convey the position of Stellantis to mitigate any inconsistency or misalignment. Depending on the circumstances, Stellantis may decide to advocate separately for its own position on the topic. Stellantis regularly reviews its memberships in trade associations or public interest bodies and may from time to time decide to join or exit a trade association.

###### 1.3 CSR GOVERNANCE [...] Stellantis CSR Global Office reports directly to the Executive Vice President (EVP) – Chief Communications and CSR Officer, who is a member of the top executive team and reports to the Chief Executive Officer. The role of the CSR Global Office is to: - ensure that Stellantis N.V. makes necessary corporate CSR public disclosures; - support dialogue with stakeholders (including investors) on ESG matters; - engage in assessment processes with CSR rating agencies; - watch CSR disclosure related legal requirements and stakeholders expectations, applicable to Stellantis N.V. Stellantis CSR Global Office oversees a CSR network composed of subject matter experts: the CSR Champions and CSR Correspondents, who represent the global functions of the Company. The CSR Champions work to ensure that the CSR issues under their responsibility are considered appropriately in the decisions of their Division. They: - directly report to the relevant EVP; - propose the CSR Ambition and the CSR Targets to the EVP for approval; - organize, monitor and consolidate the CSR commitments and key messages; - ensure the Company's CSR results with improvement actions align with stakeholders' expectations. The CSR Correspondents focus on proper and reliable disclosure of qualitative and quantitative information for the CSR issues under their responsibility. They: - manage their network of expert contributors to collect and consolidate facts and figures covering the reporting scope; - deliver their sections of the CSR disclosures; - support the CSR Global Office when answering external requests from stakeholders, particularly ESG rating agencies; - propose internally actions to improve performance based on weaknesses identified with the support of the CSR Global Office. The EVPs play a key role in the Company's CSR roadmap: they validate the medium- and long-term CSR visions, ambitions and targets for the CSR issues that are under their responsibility and are responsible for the achievements. Top Management incentives are set to align as much as possible with the diverse stakeholders' interests." [...] "###### 2.4 CLIMATE GOVERNANCE AND DECISION BODIES TO LEAD ACTIONS [...] Stellantis N.V. has a one-tier management structure: the Board of Directors is responsible for management and strategic direction of the Company as well as oversight and control. The CEO is supported by the Top Executive Team aiming to secure worldwide profitable growth for Stellantis. Within this governance structure, the Board of Directors considers subjects that link to the strategic plan. Climate being a key topic, the Board of Directors ensures that the strategy fits with Stellantis long-term vision and climate resilience, but also that related risks and opportunities stemming from the effects of climate change are properly identified and managed. The CEO and the Strategy Council are responsible for defining the overall environmental strategy, including Climate related policies. The CEO reports to the Board of Directors. Major strategic projects with significant impact on the CO2 emissions of the Company or its products are being brought to the Board of Directors for review and decisions. Those projects can be related to vehicle CO2 emissions reduction, as well as product planning or new mobility offers with CO2 emission reduction targets. Other major projects that can be impacted by the consequences of climate change, such as location of new sites, are also reviewed by the Board. The Board reviews the related financial implications of strategic projects with significant impact on CO2 emissions, such as the CAPEX or strategic transformation needed to implement these projects. The Board discusses these projects for approval after being informed about aspects such as CO2 emission consequences and expected changes in the future mobility market. During Board meetings, Stellantis' strategic climate commitments, their implementation and their progress vs targets, are presented to the Board of Directors, in order to deliver relevant information on the climate-related CSR issues impacting the organization. [...] The ESG Committee is responsible for monitoring and evaluating reports on the Company's sustainable development policies and practices, management standards, strategy, performance and governance globally. It is also responsible for reviewing, assessing and making recommendations regarding strategic guidelines for sustainability-related issues and reviewing the annual CSR Report. In 2021, climate change-related topics have been addressed by the Committee in its meetings."
"Stellantis closely monitors its relationships with public authorities with the intention of ensuring that the Company interacts with government officials in a transparent, responsible and ethical way. In Europe, for example, the Company allocated a budget of approximately €1.7 million to its public affairs activities in 2021. The Company follows the guidelines issued by the European Commission and European Parliament for reporting on Stellantis's European activities. Accordingly, this amount includes: - personnel costs based on a full-time equivalent (50% of the total personnel costs); - the office and administrative expenses (100% of the costs, except for mobility costs covered at 50%); - the costs related to professional associations (25%); - externalization costs (100%). In the United States, federal lobbying is regulated by the U.S. Congress. Stellantis files quarterly lobbying reports that disclose spending on lobbying activities and the specific topics that its registered federal lobbyists addressed in interactions with particular public officials. The amount spent on lobbying that is reported for 2021 is €3.4 million, which includes: - labor costs (including G&A costs) for hours spent lobbying (100%); - amount paid to trade associations that the trade associations use for lobbying (100%); - amount paid to third party lobbying firms (100%); and - travel, meals, and other expenses incurred while lobbying (100%). The chart below details Stellantis's consolidated contributions for lobbying activities in 2021: (in € million) **2021 contribution** Internal 2.9€ Trade Associations and Consultancy 2.2€ Political contributions **Total contribution** **5.1€**"
"For instance, in France, the Company, through its Public Affairs Department and the trade association Union des Marques, is following current developments of legislative proposals related to the "climate and resilience" bill and the Mobility Orientation Law. [...] Stellantis's brands, through their engagement in local and national advertiser associations, look for opportunities to participate in workshops on legal developments (i.e., environmental requirements in advertising, right for customers to refuse to be contacted by brands, etc.) and external stakeholders' expectations in terms of responsible communications and marketing to eliminate misleading advertising and unfair competition in the field of commercial communications."
"The Global Purchasing and Supply Chain department (GPSC) is the interface between Stellantis and its suppliers. The GPSC is responsible for meeting all legal and regulatory requirements under its scope and to require that all suppliers are fully compliant with Company policies to reduce the risk of exposure to the Company. This is its major duty of care toward supplier management across the globe. To support the direction of the GPSC, the Global Purchasing and Supply Chain EVP is a direct report to the CEO, and a member of the Top Executive Team, and as such, a member of the company's strategy council. [...] Governance is in place with monthly Purchasing and Supply Chain Leadership Team Meetings, hosted by the Chief Global Purchasing and Supply Chain Officer to monitor supplier CSR performance during sourcing. [...] Stellantis reinforces that employees, suppliers, dealers, consumers and other stakeholders can and should report any concerns of alleged situations, events, or actions that may have been inconsistent with the Stellantis Code of Conduct and request advice about the application of the Code. [...] Stellantis has introduced a comprehensive toolkit to measure the social and environmental performance of its suppliers and to identify any shortcomings or risks. The suppliers questioned or audited systematically receive an analysis of their performance. For suppliers who do not achieve the required standard, a corrective action plan is put in place. Suppliers that do not improve or collaborate with Stellantis might ultimately be excluded from the Stellantis's supplier panel.

The Stellantis Code of Conduct was approved by the Board of Directors of Stellantis N.V. in March 2021. It applies to the members of the Stellantis Board of Directors, Stellantis' officers, full-time and part-time employees, temporary and contract workers. Stellantis also expects its stakeholders, including suppliers, dealers, distributors, and joint venture partners, to act with integrity and in accordance with the Code. It is the responsibility of all workforce members to report suspected or potential violations of the Code of Conduct. [...] To reinforce ethics and compliance communications, the Global Ethics and Compliance Committee oversees a multi-year training plan. [...] Reporting Concerns - Integrity Helpline After Stellantis merged the former PSA and FCA whistle-blower systems, the current Stellantis Whistleblowing Policy, known as the Integrity Helpline, is a global tool to register concerns, as well as gifts and entertainment that deviate from the policy, disclose conflicts of interest or to request advice about Company policies, anonymously if so desired by the reporter and if permitted by law. [...] Internal Audit and Compliance Department includes regulatory compliance and the Ethics and Compliance Program within the scope of its annual audit plan. Pursuant to the department's risk assessment process, the department may choose to review adherence to policies dealing with competition, anti-corruption, data privacy, export controls and other compliance-related topics. At appropriate times, the Company selects external parties to conduct audits of specific functions. External Audits performed by independent auditors include topics such as Integrity Helpline, emissions-related regulatory compliance, environmental health and safety, and energy management systems. [...] The Stellantis whistleblower channel is available 24/7 by phone or web and is designed to ensure that any suspected violations of our Code of Conduct can be reported, received, and resolved properly and efficiently. Our "Always with Integrity" campaign highlights the availability of the reporting system for all types of concerns, including vehicle safety and regulatory concerns. This system continues to be provided by a specialized independent service provider and used for reporting investigations by trained and skilled resources.