Insider Trading and Securities Market Abuse

Preventing Insider Trading

OUR WAY

We never use or share inside information about Clarios, its parent company or any other company for the purpose of trading on the stock market.

WHY WE PUT VALUES FIRST

In the course of our work, we may have access to information about Clarios, its parent company or other companies, which could potentially be useful to investors. Doing the right thing means showing that we can always be relied on to protect information entrusted to us. “Inside” information consists of details that an investor would consider important in making an investment decision; it is also known as material, non-public information. Using this information for our own benefit or sharing it for the benefit of others is called insider trading. It’s illegal because it provides an unfair advantage and distorts financial markets. Insider trading laws are enforced aggressively, often resulting in heavy fines and imprisonment for those convicted.

WHAT OUR WAY LOOKS LIKE

We prevent insider trading by:

• Understanding and adhering to our Insider Trading Policy
• Never using inside information to trade shares in the parent company of Clarios, the public debt of Clarios, or any other publicly traded company — unless and until such information has been made public and the market has had a chance to digest it
• Not sharing inside information with anyone outside the company, including family members, relatives or friends
• Sharing inside information with colleagues only on a need-to-know basis
• Taking care to protect inside information from accidental disclosure by being careful with company documents and talking discreetly in open spaces
• Avoiding “tipping” — passing along material, non-public information about any company to anyone who may trade while being aware of such information