Center for the Study of Ethics in the Professions at IIT

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STATEMENT OF PRINCIPLES

Cummins is committed to quality, innovation and integrity. This commitment is possible because each member of Cummins follows the highest standards of ethical conduct. These standards are embodied in the Cummins Code of Business Conduct. Individual integrity and strong corporate culture are the best assurances that this Code will be followed.

The Code of Business Conduct is an important foundation for Customer Led Quality. Our pursuit of Customer Led Quality will lead to Cummins being the best there is in products, customer support and business operations, and, as a result, growing our profitability to the benefit of all of our stakeholders.

Our success in realizing Customer Led Quality depends in large part on the trust that our stakeholders - customers, employees, suppliers, shareholders and the countries and communities in which we live and work - have in Cummins.

Our aim is that Cummins will be known as trustworthy in all respects. This means that all Cummins people throughout the world must:

• Obey the law.
• Be honest - present the facts fairly and accurately.
• Be fair - give everyone due regard and respect.
• Be concerned - care about how Cummins' actions affect others and try to make those effects as beneficial as possible.
• Be proactive - take the initiative to address issues before they become problems.
• Be responsible - particularly as a citizen of the communities and societies in which we operate

• Use good judgment - avoid actions and circumstances that may appear to compromise good business judgment or create a conflict between personal and company interests.

Following these principles on a rare occasion may mean losing some business in the short term. This is a regrettable but acceptable outcome. Over the long haul, this type of behavior will gain us business. People respect and trust this type of behavior, Wish more institutions embodied it, and will reward it.

Integrity is the foundation of Cummins' relationships with customers, suppliers, shareholders, competitors, partners, our communities, and each other. It provides us the opportunity to meet the needs of our customers better than our competitors. All members of Cummins - directors, officers and employees, distributors, subsidiaries and affiliates - continually work to develop and protect this critical asset through their everyday activities.

Integrity in everything we do is essential to Cummins' ability to provide an excellent and sustainable long term return to our shareholders, and to be able to satisfy the needs of all of Cummins' stakeholders.

Our commitment to integrity means that we will exceed the minimum requirements of the law and industry practices. This (ode serves as a daily guide to our behavior as employees of Cummins and identifies conduct that is not permitted during employment with Cummins. Violations at any level will not be tolerated, and in some cases could result in dismissal as well as in civil or even criminal liability for the company, individuals, or both.

Some of the areas of conduct are very technical. Many are supported by specific policies in the Cummins Policies and Procedures ((PPS) system, which are available in Documaster or in hard copy at every Cummins entity around the world. Applicable policies, including their Documaster designation, are listed below. If you have any questions about any Cummins policy, do not hesitate to call the person designated in that policy.

Although some areas may be technical or the policies detailed, keep in mind these basic guidelines: If

• You are uncomfortable With a particular action,

• You would be unwilling to tell persons you love and respect,

• You would not want to see it reported on the front page of your major newspaper,

then DON'T DO IT. Instead, ask your supervisor for guidance under this Code of Conduct, or contact the Vice President

If you feel pressured, DON'T DO IT and get guidance. You may also make anonymous inquiries by calling the confidential "Ethics Help Line" at the appropriate number for your location.

SPECIFIC AREAS OF CONDUCT

Conducts Concerning Our Customers Suppliers and Competitors

Customer Satisfaction
We are dedicated to meeting or exceeding the expectations of our customers better than any of our competitors. We will provide our customers with products, information and support that yield a comparative advantage. Customer satisfaction will be the measure of our success. At every opportunity we will take the step that delights our customers. This is our objective.

Cummins' Products
Cummins' products are an extension of the Company itself. In all aspects of the design, manufacture, sale and support of our products, we will provide the highest levels of qualify and innovation. We are committed to making available safe products, which meet the performance, durability and reliability needs of our customers. As part of our dedication to environmental stewardship, our products will meet or surpass appropriate emission standards for the country in which the product is sold.

Terms of Commercial Transactions
Cummins competes on a straight commercial basis everywhere in the world. Our employees will do nothing in search of business they would not reveal willingly or publicly to any other member of Cummins, any government official, or any member of society. Conducting our business with integrity - honestly and fairly - will earn repeat business from our customers and help us achieve our goal of Customers for Life. For additional guidance, see Cummins "Ethic Standards" policy

Cummins' Competitors
Cummins will compete vigorously with its competitors, but always with integrity.
Employees should not disparage our competitors or our competitors' products. In addition, our employees should not fraternize with our competitors if such conduct would give even the appearance of a potential agreement between Cummins and a competitor.
Cummins respects the confidential nature of certain information of its competitors. Never accept confidential information about our competitors. If you receive any such information or any person offers you any confidential information, contact the Law Department. Cummins will always return any such information to the competitor.

Supplier Selection/Conflicts of Interest
All of Cummins' employees are expected to use non-discriminatory practices throughout the supplier selection process. Every employee is expected to avoid any situation in which his or her interests (or those of his or her family) may conflict with the interests of the Company. Every employee with a financial interest in any actual or potential supplier or customer must disclose that interest to his or her supervisor immediately and, if applicable, in his or her annual Ethics Certification Statement.
Receipt and Giving of Gifts
In general, employees should neither accept nor offer gifts to customers or suppliers unless the gifts are designated as part of a recognized business event.
Gifts exceeding US $50 in value may be given or accepted only with the concurrence of an employee's supervisor. All gifts (except minor promotional token items) not reported and approved by the employee's supervisor must be reported annually on the Ethics Certification Statement.

Antitrust and Competition Laws
Employees must comply with antitrust laws of the United States and the competition laws of other countries in which we do business. These laws cover agreements among competitors, agreements with resellers, price discrimination, and other acts that may unfairly reduce competition.

Government Contracts
Because Cummins is a supplier to federal, state and local governments around the world, Cummins employees are expected to comply with all laws and regulations relating to government contracts and to cooperate fully with investigators and auditors who require information in connection with such contracts.

Import/Export Controls and Boycotts
Cummins transacts business on a global basis. Each Cummins employee involved with the sale or shipment of products across international borders is expected to understand and comply with the import/export control restrictions of all countries in which we do business.
Cummins will do business with entities in other countries based solely on commercial considerations. We will not become involved in disputes between countries by participating in boycotts, unless the boycott is imposed by a country that has jurisdiction over our products. We may be required to report boycott requests to relevant government authorities even if we do not cooperate with the request. For additional guidance, contact the Law Department.

Equal Employment Opportunity/Diversity
Cummins is an equal opportunity employer. We make employment decisions without regard to race, color, religion, sex, age, national origin, disability or any other characteristic irrelevant to the job. The company's recruitment, hiring, transfer, promotion and compensation policies will he non-discriminatory. Quite apart from legal requirements, diversity of backgrounds makes Cummins stronger and is essential to our operating as a world-class competitor.

Treatment of Each Other At Work
Each employee will treat every other employee, customer, vendor and others met in the course of work with dignity and respect. Harassment of any type in the workplace will not be tolerated.

Safe Working Environment
Cummins is committed to maintaining at each company facility a workplace free from recognized hazards, which cause or are likely to cause physical harm to our employees. Prevention of occupationally related injuries and illnesses is the responsibility of every Cummins employee. All employees are expected to report unsafe or hazardous working conditions immediately to their supervisors. No retaliatory action or other reprisal shall be taken as a result of an employee's making a good faith report.

Drug and Alcohol Policy
Possession, sale, use or being under the influence of illegal drugs (including prescription drugs except in strict adherence to the prescription) or alcohol while on Company property, or during work hours, is strictly prohibited. Alcohol may be permitted during certain company-sponsored events with the advance approval of a company officer.

Company time
Full-time, regular exempt employees may not hold full- or part-time positions or directorships outside the company without express permission from their manager and disclosure in their annual Ethics Certification Statement.

Conducts Concerning Our Employees

Shareholder Value
Cummins is committed to providing an excellent sustainable long-term financial return to our shareholders and to protecting and improving the value of their investment through prudent application of corporate resources and by observing the highest standards of legal and ethical conduct in all our business dealings.

Securities Law Compliance
Non-public information about Cummins or other companies that could affect the price of Cummins' stock or investors' decisions must be held in strict confidence. No one with access to material, non-public information may buy, sell or advise others regarding such stock until the information has been publicly released. For additional guidance, contact the Law Department.

Accuracy of Financial Records/Financial Representations
Each employee must report all corporate transactions accurately and truthfully, including receipts, disbursements, and the nature and purpose of transactions. Invoices, quotations, receipts and other statements reflecting charges, prices, product descriptions, terms or business intentions, must be complete and accurate. It is against Company policy knowingly to supply false or misleading financial information regarding the company to any person. We will cooperate fully with auditors and under no circumstances withhold information from them.

Responsible Citizenship
Cummins is committed to improving the communities in which we operate and to being a responsible citizen of society. Cummins entities and the Cummins Engine Foundation will actively support initiatives designed to improve the communities in which we live in and work.

Employee Participation in Community Activities
Consistent with the above, Cummins encourages all employees to take part in community activities. In doing so, however, it is essential that employees speak only for themselves and do not imply that they are speaking for or making commitments on behalf of the Company, unless authorized to do so by appropriate Cummins officials.

 

Conducts Regarding Our Facilities and Property

Environmental Compliance
It is the policy of Cummins to manage and operate its business in ways that are protective of the environment and that conserve both energy and natural resources. In addition to compliance with all applicable environmental laws and regulations, Cummins recognizes excellence in environmental management as among the highest corporate priorities. In some cases, this may mean Cummins Will do more than the low requires.

Computer Equipment/Copyrights
The Company's computer hardware, software and data may be used only by authorized personnel for Company business, and provisions and copyright restrictions will be respected. Company computer assets may be used on a limited basis with the approval of an employee's supervisor to support an employee's work with community agencies and organizations.

Other Company Property
Company property, equipment and facilities may not be used for anything other than Company business without prior permission of the employee's supervisor.

Confidential and Proprietary Information
Employees frequently have access to confidential or proprietary information owned by or concerning the Company. No employee shall disclose such information to any person, except persons Within the Company who need to know. Employees shall use all reasonable efforts to protect and safeguard such information. Similarly, Cummins employees will respect confidentiality new employees have to their former employers.

Conducts Regarding Political Campaigns and Government Officials

Personal Participation

Personal participation in political activities must be separated from corporate activities. The Company's name, property, including stationery, and work time must not be used in connection with such activities. Payments to Government Officials

Employees must not make, promise, authorize or arrange any payment or gift of any kind to any U.S. political party or candidate, government or military employee or agent, or their families anywhere in the world, as part of their transaction of business on behalf of Cummins. Nominal gratuities may be permissible in limited situations, but not consulting with your supervisor and other appropriate Company personnel.