Enterprise Policy

Antitrust

Enterprise Policies apply to the Caterpillar enterprise, including subsidiaries,

majority-owned joint ventures and, following a transition period, newly acquired
companies unless otherwise stated below.

OBJECTIVE
Consistent with Caterpillar's Code of Conduct, this Policy establishes a worldwide policy
governing antitrust compliance and applies to all employees of Caterpillar, its
subsidiaries (“Caterpillar”), wherever located, majority-owned joint ventures, and to the
Caterpillar Inc. Board of Directors.

STATEMENT OF ENTERPRISE POLICY

It is the personal responsibility of each employee and director to comply with the terms
of Caterpillar’s Antitrust Compliance Manuals, as revised from time to time, and all other
relevant antitrust related materials and training supplied by Caterpillar (the “Policies”).
The Policies apply in all countries and territories in which Caterpillar does business and
may be more strict than what local laws require.

Due to the sensitivity in nearly all countries, no Caterpillar employee or director may
reach (or appear to reach) any agreement or understanding with a competitor
concerning any aspect of pricing (including list prices, maximum or minimum resale
prices, advertised prices, price ranges, price formulas, costs, profit margins, credit terms,
discounts, terms of sale, or timing of price changes), output, customers, markets, or
product or service offerings without prior consultation with, approval by, and
documentation by the Legal Services Division.

Each supervisor must ensure that employees reporting to him or her are familiar with
and comply with the Policies, including ensuring that each employee has access to all
current Policies. Caterpillar may conduct periodic audits of compliance with the Policies
consistent with the laws of the jurisdictions in which such audits occur.

Any employee who knowingly participates in, and any supervisor who directs,
authorizes, or knowingly permits a subordinate to engage in, any unlawful activity or any
conduct prohibited by these Policies or any stricter local law, and any employee who
fails to cooperate with any Company investigation of an alleged violation, will be subject
to disciplinary action, including discharge when appropriate.

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Any employee or director who has knowledge of conduct that he or she believes in good
faith may violate any of the Policies should report such information to his or her
supervisor, the Legal Services Division, or anonymously using the Office of Business
Practices Helpline at 1-800-300-7898.

RELATED POLICIES, PROCEDURES AND RESOURCES INCLUDE

The ‘’Fair Competition’’ policy contained within Caterpillar’s Code of Conduct, the Caterpillar
Antitrust Compliance Manual, The EU Competition Law Guide, The Financial Products
Division pricing manual, Solar Turbines Incorporated Worldwide Procedure No. 3, Global
Supply Network Division Purchasing Practice No. 6, and Enterprise Procedure 1:04.

Violation of this Policy may result in disciplinary action up to and including

termination.

Date Issued: September 2009

Date Revised: April 2015
Date Reviewed: April 2015

Contact Information
For questions about or interpretations of the material contained within this
Enterprise Policy, please contact Enterprise_Procedure@cat.com.

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