Goodyears Supplier Code of Conduct, which was updated in 2021, includes the following provision with
respect to conflict minerals:
Suppliers must source minerals, derivatives of minerals and other raw materials in compliance with applicable laws and
regulations and in a manner that respects human rights. Suppliers must avoid directly or indirectly financing or benefiting armed groups in the Democratic Republic of Congo (DRC) and/or its adjoining countries. Suppliers are required, from time to
time, (i) to certify that all materials and products supplied to Goodyear do not contain tantalum, tin, tungsten, gold or cobalt or (ii) if they do contain those elements, to cooperate with Goodyear to conduct appropriate due diligence,
including determining the country of origin and the source (including the applicable smelter) and chain of custody of those elements.
All suppliers
of components that contain conflict minerals are required to agree to the Supplier Code of Conduct in order to do business with us, and we reserve the right to terminate our business relationship with any supplier found not to be in compliance with
the Supplier Code of Conduct. The Supplier Code of Conduct is specifically incorporated into the terms and conditions of our purchase orders in Americas and Asia Pacific, and is incorporated on the face of our Europe, Middle East and Africa purchase
orders.
In order to increase awareness of conflict minerals issues, we developed internal and external communications aimed at (1) sourcing raw
materials and components in a manner that respects human rights, (2) identifying conflict minerals in our products, (3) collecting information with respect to the country of origin, source and chain of custody of conflict minerals, and
(4) responding appropriately to inquiries from our customers.
Any associate, supplier or customer may choose to report a policy violation, including
a violation of our Supplier Code of Conduct, or raise a question through the Goodyear Integrity Hotline, which is run by an independent service. Reports of policy violations may be made anonymously.
Identification and Assessment of Risks in the Supply Chain
We sent the Responsible Minerals Initiative Conflict Minerals Reporting Template (each a Template and collectively the Templates) to
each of the suppliers that directly supply us with components that contain conflict minerals in order to collect product-level information on all of the smelters in their supply chain, as well as the country of origin, source and chain of custody of
those conflict minerals. Once we received a completed Template from a supplier, we evaluated the Template for completeness and accuracy, and made further inquiries of our suppliers in order to clarify or improve the quality of their responses to us.
Our objective was to identify each of the smelters that placed conflict minerals into our supply chain, which we believed would facilitate our ability to identify the source and chain of custody of the conflict minerals contained in our products.
We are a member of the Responsible Minerals Initiative (RMI), an industry initiative that audits smelters and refiners due
diligence activities, in order to satisfy several of the recommendations outlined in the OECD Guidance. Through our membership in the RMI, we reviewed information provided by the Responsible Minerals Assurance Process of the RMI to
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