Polaris Code of Business Conduct and Ethics

Commonly Asked Questions

General Questions about Reporting

Q: When should I report a violation or suspected violation of the
Code of Business Conduct and Ethics (Code)?

You should report a violation of the Code as soon as you are aware of
it.


Q: Can I remain anonymous?

Yes. Whether you report internally or through EthicsPoint, you can
report anonymously. To ensure a report is anonymous, EthicsPoint does not
trace phone calls and does not maintain any identifying electronic
information from on line reports. If you want to remain anonymous in an
internal report, you should send an anonymous letter to the Compliance
Officer listed in the Code.


Q: What if I am uncertain if an incident violates the Code?

You should ask your manager, supervisor, Human Resources
Department or others identified in the Internal Reporting section of the
Code, or you may ask the question through EthicsPoint.

Q: What will happen to me if I file a report?

Polaris encourages you to report suspected violations of the Code or
the law, and prohibits retaliation against anyone who, in good faith, reports a
violation of the Code or cooperates in an investigation. This is true
regardless of whether the underlying report is found to be correct or results
in corrective action. If you feel that you have been retaliated against, you
can report this through EthicsPoint or through others identified in the
Internal Reporting section of the Code. Reports about routine human
resources matters should not be reported through this system. You should
continue to work through your Human Resources department on these types
of matters.
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions


Q: Where do I report?

You have several options for reporting. You can report directly to
your manager, supervisor or Human Resources Department at your location.
If you do not feel comfortable reporting to one of these individuals, you may
contact the Compliance Officer listed in the Code. You may also make
reports by telephone or online through the Polaris Business Ethics Hotline
which is managed by an independent third-party provider, EthicsPoint.
From the U.S. or Canada, dial 1-888-219-3550, and outside of these
countries, dial this same number along with your country code which is
posted on the EthicsPoint reporting page under the link International
Dialing. You can reach this page through the Reporting Violations link on
the Polaris employee intranet site under Business Ethics. You may report
online by clicking the Reporting Violations link on the Polaris employee
intranet site under Business Ethics, or, by contacting EthicsPoint directly at
www.ethicspoint.com.

Q: What is EthicsPoints role?

EthicsPoint role is take reports over the phone or through the online
hotline and then to make the reports available to Polaris personnel to
investigate the report. By using EthicsPoint, Polaris can make sure reports
can be made 24 hours per day worldwide. The EthicsPoint system also
makes it easier for reports to be made anonymously, if necessary.

Q: How does Polaris investigate reports?

Polaris will start an appropriate investigation using internal and/or
external resources. The information in your report will be shared with
investigation team members that need to be informed to conduct an
appropriate investigation. All investigation team members will take steps to
ensure the information is kept confidential. However, to conduct a complete
and thorough investigation, information about the report may have to be
disclosed.




Polaris Code of Business Conduct and Ethics
Commonly Asked Questions

Q: How do I monitor progress on my report?

If you report to internal sources, you can simply ask the person you
reported to and that person will provide you as much information as is
appropriate. If you make a report through EthicsPoint, you will be assigned
a unique code called a "report key" and you will be asked to create a
password. Write down your report key and password and keep them in a
safe place because Polaris will not have access your report key or password.
We encourage you to use your report key and password to periodically
check your report for feedback, questions or updates. You may do this
either online or by phone by contacting EthicsPoint.
Questions about Code Standards
General
Q: My manager or supervisor has asked me to do something that I
think is illegal or which violates the Code. What should I do?
You should report the issue through EthicsPoint or to the Compliance
Officer listed the Code.
Q: I have seen some conduct at the office that I think is illegal but it is
not addressed in the Code. What should I do?
If you suspect illegal behavior, you should report it or talk with your
supervisor or manager about it. No Code could possibly address every
situation. You are responsible for understanding the laws applicable to your
job and abiding by the policies in place at your work site. The bottom line
is that you have to exercise good judgment and high ethical standards at all
times whether or not an issue is specifically addressed in the Code.
Harassment Free Workplace
Q: My co-worker has been making unwelcome remarks of a sexual
nature which make me uncomfortable. What should I do?
Polaris prohibits any type of harassment by team members and we
encourage you to report such behavior.
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions



Safety, Health and Environmental

Q: While unloading a trailer, I spilled a container of cleaning solvent.
If I clean it up, do I need to do anything else?

Yes. You should immediately report any spill of hazardous or
potentially hazardous material to the Environmental Manager at your
location.
Conflicts of Interest
Q: I have been asked to serve as a consultant for one of our vendors
during off hours. Can I do this?
Serving as a consultant for another company that does business with
Polaris can create a conflict of interest. Consequently, you must receive
approval from Polaris prior to agreeing to serve as a consultant. Raise the
issue with your supervisor, who will then take the issue to the appropriate
people for consideration.
Polaris Confidential Information
Q: A friend asked me if I could confirm an internet blog which
claimed that Polaris is adding certain features to its ATVs for the next
model year. Should I tell him what I know?
No. Product plan and product launch information is confidential and
proprietary information of Polaris and should not be discussed with anybody
outside of Polaris unless Polaris has already been made that information
public. If you have questions on whether an issue has been made public,
please contact your manager or the appropriate Corporate Marketing
Manager.
Q: I received a call from someone outside Polaris asking me to
confirm the financial condition of one of our business units. What
should I do?
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions

You should refer the caller to Investor Relations. The request could
be asking for confidential financial information that cannot be disclosed at
this time.
Confidential Information of Others
Q: Is it acceptable for me to collect information about competitors?
Gathering public information about competitors is both a necessary
and an appropriate business practice, but you are prohibited from gathering
competitive information in an illegal or unethical manner. For example,
information obtained from public sources (i.e. newspapers, press releases,
documents filed with the government, technical publications) is permitted.
You should never, however, obtain competitive information through
deceptive techniques such as misrepresenting your identity or company
affiliation, by offering a financial inducement to receive the information.
You also should not ask former employees of competitors to divulge
confidential or proprietary information of their former employers.
Competitive information that is marked as confidential, trade secret or
proprietary, or otherwise appears to be a competitors internal document,
should be treated with caution. If you believe you have inappropriately
received any documents or information of this nature, do not circulate or use
the information and contact the Polaris Legal Department immediately.
Use of Polaris Assets
Q: There is a lot of wood and other material stacked up outside my
facility. Can I take it home so it doesnt get wasted?
No, unless you get approval from your supervisor. Any material at a
Polaris facility (other than employees personal property) is owned by
Polaris and may not be taken without receiving prior approval from a
supervisor.
Insider Trading
Q: I have received information about Polaris financial performance
which is not yet public. Can I tell my friend about this information so
that he can take advantage of it by trading in Polaris stock?
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions

Absolutely not. This is considered inside and non-public
information which cannot be disclosed. Trading stock on this information,
or providing tips to others to do so, is a serious violation of U.S. securities
laws and possibly other countries laws as well.
Financial Integrity and Disclosure
Q: I believe that certain Polaris expenses are not being accurately
recorded on Polaris books. What should I do?
You should report the issue. Polaris complies with all applicable
securities laws and regulations, accounting standards, accounting controls
and audit practices. False or misleading entries, unrecorded funds or assets,
or payments without appropriate supporting documentation and approval are
strictly prohibited.
International Business
Q: One of our distributors in a foreign country has informed me that
it paid a government official to get a meeting to pitch the sale of our
vehicles. Is that ok?
No. The Foreign Corrupt Practices Acts (FCPA) makes it a crime
for any U.S. company, any employee of a U.S. company, and any subsidiary
of a U.S. company, to use bribery as a way to gain favor with any foreign
government official in the connection with any sale of U.S. products. The
law applies whether the act takes place inside, or outside, of the U.S. if it
relates to the sale of Polaris product. You should report this violation, either
internally or through EthicsPoint.
Gifts, Favors, Gratuities and Vendor Relations
Q: I have been offered a free shot gun by one of our vendors. Can I
accept it?
No. You cannot accept gifts, loans or other favors from anyone doing
business with Polaris or who wishes to do business with Polaris unless they
are infrequent, of nominal value and are normal and customary given the
business circumstances. You should discuss all gifts you are offered with
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions

your manager because, in some situations, it may never be appropriate to
accept a gift of any value.
Antitrust and Fair Competition
Q: I have been asked to tell a dealer that it must stop discounting its
product or Polaris will be forced to consider other options. Is that
okay?
No. Under the antitrust laws, dealers are free to set their prices for
reselling product at any level they choose. If Polaris either agrees with the
dealer, or coerces the dealer, to sell at certain prices, it would be illegal
price-fixing. Any such conduct by Polaris personnel would be a violation of
the Code. You should contact the Polaris Legal Department if you have any
questions.
Q: A dealer complained to me about another dealers low prices and
asked me what Polaris was going to do about it. What should I say?
Tell them that Polaris will do nothing. Under antitrust laws in the
U.S. and foreign jurisdictions, dealers set their own price level and Polaris
cannot do or say anything that could be considered an agreement between
Polaris and a dealer to charge a specific retail price, or to take action against
a discounting dealer. The best approach is to avoid discussions with dealers
about retail pricing of other dealers. If the issue comes up in person, stop the
discussion immediately, tell the dealer that these discussions are illegal and
move on to a different topic. If the dealer will not move to another topic,
stop the conversation and leave. If the communication comes in written
form, do not circulate or respond to the communication. Rather, send the
communication to the Polaris Legal Department to determine an appropriate
response.
Compliance with Law, Government Activities and Service
of Legal Documents

Q: I know a government agency has been investigating certain
product issues at Polaris. I have documents that relate to those product
issues, but I have never been asked to provide them. Can I destroy
them?
Polaris Code of Business Conduct and Ethics
Commonly Asked Questions


No. Documents that relate to a pending government investigation or
pending litigation may not be destroyed. Whenever you think you have
documents relating to these matters, you should contact the Polaris Legal
Department to determine the right way to handle those documents.

Vendor Standards

Q: I was at a supplier yesterday and she told me that the supplier
paid off a government official to avoid customs and duties on the parts
they supply to us. I know this saves Polaris money, but is it ok?

No. Polaris will only do business with people who conduct business
ethically and legally. All suppliers and vendors must comply with the
standards in the Code and the law. Paying off government officials is
bribery and violates the law. You should report this conduct immediately.

Q: A dealer told me that one of the ways he has increased retail is by
helping consumers provide false information to get consumer financing.
Is this a problem for Polaris, or just for the dealer?

This is problem for Polaris too. A dealer who engages in fraud or
who otherwise breaks the law when selling Polaris products violates both the
standards of the Code and its Dealer Agreement with Polaris. J ust as with
any supplier or vendor, Polaris will only do business with people who
conduct business ethically and legally. You should report any illegal
conduct by dealers to your manager, Dealer Development or the Polaris
Legal Department.