SELECTING AN APPROPRIATE THIRD PARTY INTERMEDIARY
It is the responsibility of Caterpillar’s business personnel to select prospective Third Party Intermediaries in a methodical, transparent and documented fashion. It is critical for business personnel to (i) document the business justification for selecting the prospective Third Party Intermediary; (ii) document the expertise and resources that the prospective Third Party Intermediary brings to the role it is proposed they will undertake; and (iii) interview the prospective Third Party Intermediary to confirm that the third party has a good reputation in the community, understands Caterpillar’s business values and agrees to conduct itself accordingly.
Every Caterpillar employee, and those of its subsidiaries and controlled affiliates, has an obligation to report any potentially illegal or questionable conduct about a third party to their regional attorney and to an anti-corruption attorney in the Securities, Tax & Regulatory Section of the Legal Services Division located in Peoria, IL. The contact information for such attorneys can be located in the Anti-corruption Toolkit, found at http://codeofconduct.cat.com/anticorruption