Bombardier : Code of Ethics

BBD.B.TO

Our Code of Ethics

Table of contents

A word from our Chief Executive Officer

Who must follow the code?

How is the code governed?

Foundation of the code

Committing to the code Following the law

Upholding the world's largest sustainability initiative

Our responsibilities

What employees must do What management must do

Other bombardier policies and procedures Reporting potential violations of the code Cooperating with internal reviews and investigations Penalties for violations

Who to contact

Ethics and compliance office

Bombardier's reporting system

Ambassadors

Promoting a healthy and sustainable workplace

Equal employment opportunities

Harassment

Health and safety

Environment

3

Safeguarding our property

18

4

Company property

18

5

Intellectual property

18

Protection of confidential data and information

18

6

Data privacy

19

6

Acting with professionalism in our communications

20

7

Social media

21

7

Communications with others

22

8

Public communication

22

9

Cyber-security

23

10

Use of bombardier it resources

25

12

Upholding sound business practices

26

13

Securitiy laws and insider trading

26

13

Anti-corruption

28

13

Gifts and entertainment

29

14

Donations, sponsorships and requests for funds

30

14

Fraud

30

Conflicts of interest

31

14

Money laundering

31

14

Books and records

31

15

Dealing responsibly with third parties

32

15

Competition law compliance

33

15

Customs, export control and embargo compliance

34

16

Governments and lobbying

34

17

Political activities

34

A word from our Chief Executive Officer

Bombardier has repositioned itself as a pure-play business aviation company with clear goals: to deliver exceptional value to our customers and predictable financial performance to our shareholders through a highly engaged and inclusive workforce. We focus our efforts on bringing the same exceptional performance that has defined our aircraft to every aspect of our company and each customer interaction.

To achieve this, we must strive to be an organization that is truly people and customer-centric; that values performance, operational excellence and team spirit. A company that is transparent and authentic at all times and at every level.

This Code of Ethics ("the Code") is our roadmap to put these values into action. Our mutual success depends on each of us making the right individual choices every day. A single bad choice made by just one person can damage the reputation of our entire company. That's why it is so important that all of us strictly adhere to this Code and reaffirm our commitment to acting with the highest ethical principles in everything we do.

We earn our customers' business by delivering exceptional experiences. But we earn their respect by doing so with personal and professional integrity. By exemplifying the principles outlined in the Code, we will promote a winning culture where talented people want to work; where suppliers are honoured to have our business; and where customers trust us to deliver on our commitments.

I'm counting on you to share and live the values of our Code of Ethics and to help our company achieve sustainable success.

Éric Martel President & CEO

BOMBARDIER CODE OF ETHICS

3

Who

must follow the Code?

Our CODE OF ETHICS, which sets the global standards for our business and activities, applies to all members of the Bombardier community, including the Board of Directors, management and employees at every level, in every country and from every Bombardier legal entity (including joint ventures where Bombardier has a majority/controlling interest).

Management and employees are also expected to comply at all times with all Bombardier policies, directives and procedures. Bombardier suppliers, service providers and consultants are expected to adhere to Bombardier's Supplier Code of Conduct when dealing with or acting on behalf

of Bombardier.

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How

is the Code governed?

BOMBARDIER'S ETHICS AND COMPLIANCE OFFICE has implemented a governance structure to ensure that the principles of this Code are observed, promoted and managed effectively throughout the organization. The Ethics and Compliance Office oversees Bombardier's efforts to promote an ethical work environment and business practices of the highest ethical standards.

All Bombardier employees holding managerial positions have a responsibility to ensure that the Code is actively distributed, understood and followed within their teams.

BOMBARDIER CODE OF ETHICS

5

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Disclaimer

Bombardier Inc. published this content on 10 February 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 10 February 2022 22:57:01 UTC.