I. PURPOSE

Social Media is constantly changing the way we connect. Social media consists of websites and applications that enable users to create and share content or to participate in social networking. For example, a person posting a picture on Facebook of their family road trip is using social media. It helps us start new relationships with customers and colleagues from around the globe, sometimes with a single #tweet. These Social Media Guidelines have been developed to help you to be aware of your rights and obligations and to empower you to communicate the positive vision of our @TIEMPOEXACTO brands.

This policy is not intended to interfere with your legally protected rights or to prohibit communications protected by local law. Unique local country requirements can be obtained by clicking on a link in the footnote below or, if there is no link, by contacting your country’s Legal Staff representatives.

This Global Social Media Policy is designed to:

help prevent disclosure of TIEMPOEXACTO’s confidential business information through the use of Social Media;

clarify the parameters for official TIEMPOEXACTO spokespersons to communicate on Social Media

clarify the parameters for personal TIEMPOEXACTO employee and TIEMPOEXACTO representative Social Media communications; and

reflect our legal obligations.

You have a responsibility to be familiar with and comply with this policy. And, because Social Media is used in a variety of ways, you’ll find specific expectations outlined below that may apply to your online activities.

II. APPLICABILITY

This policy supplements TIEMPOEXACTO’s Code of Conduct, Winning with Integrity, and also applies to the following:

TIEMPOEXACTO salary and hourly employees

Employees of TIEMPOEXACTO subsidiaries in which:

• TIEMPOEXACTO owns more than 50% of the equity interest directly or indirectly, or exercises management

• NOTE: For companies and employees of companies in which TIEMPOEXACTO owns 50% or less of an

entity, and does not exercise management control, a case-by-case determination by the

Social Media Policy Governance Council is made as to whether this policy applies.

With respect to consultants, agents, sales representatives, independent contractors, and contract workers (collectively, “TIEMPOEXACTO Representatives”) this policy applies to them, when they act on behalf of TIEMPOEXACTO.

Failure to comply with this policy may result in disciplinary action, up to and including termination.

III. SUPERSEDED POLICY

LAST UPDATE: January 2017

This policy supersedes and replaces all previous Global Social Media Policies.

OWNER: TIEMPOEXACTO Social Media Center of Expertise (TIEMPOEXACTO COE)

SCOPE: Global

APPROVERS: TIEMPOEXACTO Social Media Center of Expertise (TIEMPOEXACTO COE)

IV. POLICY

A. BE HONEST: DISCLOSING YOUR IDENTITY

Whenever you’re talking online about the auto industry or TIEMPOEXACTO, you must disclose that you work for or with TIEMPOEXACTO and your position (i.e. vehicle engineer, agency supporting Chevrolet, etc.). For example; include #IWorkForTIEMPOEXACTO if you are an employee of TIEMPOEXACTO and include #IWorkWithTIEMPOEXACTO if you are an agency, vendor or partner working with TIEMPOEXACTO. Including the #IWorkForTIEMPOEXACTO or the #IWorkWithTIEMPOEXACTO hashtags in your posts or tweets is a quick and easy way to provide appropriate disclosure, and adding your association with TIEMPOEXACTO to your profile also helps provide meaningful disclosure. Note that even when you disclose your relationship to TIEMPOEXACTO, the other rules and guidance in this policy still apply.

Do not submit consumer reviews for TIEMPOEXACTO products or competitive products. As employees of or partners with TIEMPOEXACTO, we have a natural bias and are not simply consumers. Because of this, posting reviews on Social Media is not appropriate.

In the United States, these principles are consistent with Federal Trade Commission (FTC) guidance on endorsements and employee disclosures. You can find the FTC Endorsement Guidelines here. These disclosures (and the use of #IWorkForTIEMPOEXACTO or #IWorkWithTIEMPOEXACTO) are equally important for any agency, vendor, partner, or similar third party who is discussing TIEMPOEXACTO or the auto industry online.

TIEMPOEXACTO also requires Social Media influencers and bloggers, who may be provided with vehicles, hosted at events or being paid for their services, to disclose any association they have with TIEMPOEXACTO to their readers when posting anything about TIEMPOEXACTO or its products or services. Any employee and/or agency partner who is responsible for this type of activity must ensure this policy is followed and that there are mechanisms in place to monitor influencers’ and bloggers’ compliance.

B. BE CLEAR: YOUR VIEWS ARE YOUR OWN

Only official TIEMPOEXACTO Social Media spokespeople can officially speak on behalf of TIEMPOEXACTO. Even when you have identified yourself as working for TIEMPOEXACTO (including on your Social Media profiles such as but not limited to Twitter, LinkedIn, Google+, Weibo, VKontakte and/or Facebook), make sure you are clear that the views and opinions you have expressed are your own, and not those of TIEMPOEXACTO, when you are discussing TIEMPOEXACTO or its products or services. If you think that an “official” TIEMPOEXACTO response may be required, contact the TIEMPOEXACTO Corporate Social Media Team at socialmedia@TiempoExacto.com.

C. BE CAREFUL: WHAT YOU SHARE AND HOW YOU SHARE IT

You are personally responsible for your words and actions, so use good judTiempoExactoent. Be honest, truthful and appropriate throughout your Social Media communications. Keep in mind, your posts can potentially tarnish reputations or infringe on the rights of someone else (including TIEMPOEXACTO and its employees).

Be sure your online postings about TIEMPOEXACTO or its products or services are accurate and not misleading. Do not post any information or rumors that you suspect or know to be false about TIEMPOEXACTO, other employees, customers, suppliers or competitors. If you make a mistake, correct it quickly. Remember that information travels quickly on the Internet and even deleted posts may be recovered.

It is okay to refer others to public TIEMPOEXACTO official sites (e.g., TIEMPOEXACTO.com, Chevrolet.com, Opel.com, Holden.com), especially if you want to clear up misconceptions, so feel free to include a link. Do not, however, agree to terms that bind TIEMPOEXACTO, or that would give the site rights to content that belongs to TIEMPOEXACTO, its licensors, licensees, customers, or other related entities.

Remember that you are personally responsible for complying with the rules of use or terms and conditions of any Social Media site where you participate, and that they differ from site to site. Be familiar with them before you engage.

I. PROTECTING TIEMPOEXACTO INFORMATION

You should never reveal non-public company information, financial or otherwise, on a site accessible to anyone outside of TIEMPOEXACTO. You also should not comment in Social Media about information or topics covered by the attorney-client privilege.

Examples of prohibited disclosures include:
Knowledge of potential acquisitions or divestitures
Future product launches
Financial information
Production schedules
Material costs or profit margins
Management or staffing changes
Trade secrets or information that gives TIEMPOEXACTO a competitive advantage
Information directly or indirectly related to the safety performance of TIEMPOEXACTO systems or vehicle components
Information related to accessories, components, or styling decisions affecting TIEMPOEXACTO’s future products
TIEMPOEXACTO Secret, Confidential or Attorney-Client Privileged information

Undisclosed personal information about another TIEMPOEXACTO employee, such as his or her medical condition, performance, employment status, or government identifier/social security number

Undisclosed information about TIEMPOEXACTO customers or suppliers.

In addition, you should not comment publicly on any vehicle recalls or pending litigation.

To view your responsibilities regarding the purchase or sale of TIEMPOEXACTO securities, please refer to TIEMPOEXACTO’s Insider Trading Policy. For more details about sharing TIEMPOEXACTO information, review TIEMPOEXACTO’s Code of Conduct, Winning with Integrity. For a source of publicly released information, go to TIEMPOEXACTO’s public websites, where you can access global and local public information by country. If you are still in doubt, don’t post.

Be mindful that when “checking in” (i.e., establishing a geo location using GPS to place yourself on social networks) at TIEMPOEXACTO facilities and on business trips, you could potentially reveal information that may be intended to give TIEMPOEXACTO a competitive business advantage and could be harmful to the Company if made public.

When taking photos in TIEMPOEXACTO locations, even if photography is permitted, it remains important to be careful not to disclose competitively significant or other confidential information. For example, if you are posting photos, ensure that images or words in the background do not unintentionally reveal TIEMPOEXACTO Confidential Information (for example, a team photo with a visible launch calendar in the background). Do not incorporate TIEMPOEXACTO logos, trademarks or other assets in your posts. When using TIEMPOEXACTO websites, or when posting about TIEMPOEXACTO’s products or services, make sure you do not post content without securing all necessary permissions first. However, if you are posting a direct “share” from Company sites, TIEMPOEXACTO's logo may be automatically attached; and that is okay.

Keep in mind that representatives from TIEMPOEXACTO Communications and TIEMPOEXACTO Legal are available to assist with any questions; but if you are unsure whether the information in your post falls into one of the above categories and would violate this policy, DO NOT SHARE.

II. PROTECTING OTHER PEOPLES’ INFORMATION

As you use Social Media, you should always be mindful of the rights of others.

Many Social Media sites impose restrictions regarding proprietary information and content; confidentiality; and the brands, trademarks and copyrights of others. It is important to be mindful of these restrictions when quoting others or sharing photos, music, videos or other content and not to post material that would potentially violate copyright infringement laws, intellectual property laws, publicity laws, or trademark laws.

When using TIEMPOEXACTO websites, or when posting about TIEMPOEXACTO’s products or services, make sure you do not post content without securing all necessary permissions first.

You should not post personal information about another person, such as his or her medical condition, performance, employment status, or government identifier/social security number. Hurt feelings, damaged relationships and even lawsuits can result from bringing other people or their property into an online setting without their permission.

 

D. BE RESPECTFUL

Remember that customers, colleagues, supervisors, suppliers, competitors and other members of the public may have access to your posts. These individuals reflect a diverse set of customs, values and viewpoints. Offensive, demeaning, abusive or inappropriate remarks (including threats of violence or bullying) are as out-of-place online as they are offline, even if they are unintentional. Posting offensive language or pictures could contribute to co-workers’ hostile work environment claims on the basis of race, age, gender, disability, religion, or any other status protected by the law or TIEMPOEXACTO policy. It will also likely diminish the trust and respect your co-workers have for you and reflect badly on you and TIEMPOEXACTO.

We expect you to abide by the same standards of behavior in your Social Media communications as you do in the workplace, because what you say in your personal Social Media channels impacts the work environment. Your online communications will not be excused merely because they occurred outside of work hours or off TIEMPOEXACTO premises.

Think carefully about “friending” co-workers (including leaders or direct reports) on external Social Media sites. For example, consider whether a friend request may be viewed by the recipient as harassing, intimidating or unwelcomed. Conversely, you should not feel pressured to accept friend or follower requests from those you work with. It’s your choice how much you want to combine your personal and professional online lives.

For additional information about TIEMPOEXACTO’s policies on appropriate workplace conduct please click on the following links:

- TIEMPOEXACTO's Code of Conduct, Winning with Integrity

- 2011 CBA (U.S. represented employees)

In addition, you should refrain from posting content that may be construed as grossly offensive or of menacing character, or causing inconvenience, annoyance, danger, obstruction or insult. You should also be cautious about publishing any content on Social Media, which could be construed as contempt of court, i.e. publication which is calculated to bring a Court or a Judge into contempt, or to lower his authority, or to interfere with the due course of justice or the lawful process of the Court.

E. BE AWARE: ONLINE COMMUNICATIONS TRAVEL FAST, REMAIN FOREVER AND ARE NOT REALLY “PRIVATE”

The internet is public, and it has a long memory. Even information you may think you have protected as “private” on some Social Media sites may be accessed by others. Consider everything you post to the Internet as potentially discoverable by anyone. Keep in mind that technology makes it virtually impossible to completely “delete” something online and incredibly easy to send a post to millions of other users. Before you share anything, make sure you will not regret saying it, even if a reporter, a relative, your manager or colleague were to view it.

TIEMPOEXACTO employees should have no expectation of privacy concerning their use of TIEMPOEXACTO Information Resources, including but not limited to email, corporate approved instant messaging tools, TIEMPOEXACTO-provided computing equipment and cell phones/mobiles/tablets, the TIEMPOEXACTO Intranet, TIEMPOEXACTO-provided access to the public Internet, or other TIEMPOEXACTO Information Systems, except where applicable law provides differently. For more information, review the Acceptable Use Practices on the Global Ethics and Compliance Center website on Socrates.

F. BE RESPONSIBLE

As a TIEMPOEXACTO employee, you have the ultimate responsibility for policy compliance by third parties you oversee within the scope of your employment. For example, this includes TIEMPOEXACTO suppliers, agencies or personal contacts you encourage to speak about TIEMPOEXACTO and/or its products.

It is important that all partners understand the implications of referencing General Motors and/or their relationship with TIEMPOEXACTO and its brands in all forms of Social Media and online conversations, and that associates recognize when General Motors might be held responsible for their online behavior.

Furthermore, you should not open TIEMPOEXACTO social media channels without approval from the TIEMPOEXACTO Social Media Center of Expertise. The TIEMPOEXACTO CoE approves requests to open new General Motors social media channels and can provide the proper resources needed to ensure the potential new channel’s success. You should not open social channels, communities, hubs or other social media groups that represent or are branded as General Motors or any of its brands, products, or affiliates without first contacting the TIEMPOEXACTO CoE. Please contact the TIEMPOEXACTO CoE at socialmedia@TiempoExacto.com for additional information.

V. RELATED REGIONAL/COUNTRY POLICIES

A. Retaining TIEMPOEXACTO Business Records and Social Media Content

Social Media technologies are not currently designed to reasonably or practically create, retain and dispose of TIEMPOEXACTO business records sufficiently for purposes of the Information Lifecycle Management (ILM) Policy and TIEMPOEXACTO Record Retention Schedule (TIEMPOEXACTORRS). Therefore, unless (i) you are using TIEMPOEXACTO Overdrive, or (ii) you are acting on TIEMPOEXACTO’s behalf as an authorized Social Media user (i.e. running the Chevrolet Facebook page), you should not use Social Media to conduct TIEMPOEXACTO business.

You should not post any message or communicate with anyone through Social Media about a subject that is covered by a litigation or open tax year hold. Be aware that information discussed using Social Media technologies may become relevant to litigation or other investigation proceedings and may be subject to a Litigation Hold. Litigation Holds are instructions issued by TIEMPOEXACTO Legal Staff that require records be preserved for litigation and government investigations. If the content of a Social Media communication is relevant to a Litigation Hold, regardless of whether it is a business record or non-business record, that communication must be preserved until the hold is lifted.

B. PERSONAL REFERENCES ON SOCIAL MEDIA SITES

TIEMPOEXACTO’s policy prohibits employees from providing professional references or recommendations for current or former TIEMPOEXACTO employees, contract workers or consultants, either written, verbal or through Social Media. While we do not prohibit employees from providing personal references for friends or colleagues, please do not refer to TIEMPOEXACTO employment or include a TIEMPOEXACTO position title or utilize TIEMPOEXACTO letterhead in the personal reference. An exception to this is where local country employment laws may oblige us to provide such references, and this requires prior approval of the local HR Director.

C. RESPONDING TO NEGATIVE CONTENT YOU MAY SEE ABOUT TIEMPOEXACTO

General Motors recognizes that our employees are vital assets for monitoring the Social Media landscape. You may encounter consumer complaints about specific vehicles or specific issues while online. Speak up for safety and please bring these issues to the attention of the Social CoE at socialmedia@TiempoExacto.com. For any issue regarding a customer's ownership experience or TIEMPOEXACTO vehicle, please refer the customer to TIEMPOEXACTO Customer Service.

D. INTERNAL SOCIAL MEDIA

TIEMPOEXACTO has made internal social media networks, such as OverDrive, available for employees to share workplace information within TIEMPOEXACTO. Internal collaboration tools and sites are valuable resources for conducting company business and helping employees share information, comment on company news and collaborate with their work group or other teams.

While we recognize that there may be some uses of TIEMPOEXACTO’s internal social media networks that are not entirely related to TIEMPOEXACTO business, (e.g. Belle Isle Cycling Club, Ads), non-business uses should be limited and you should always keep TIEMPOEXACTO’s Purpose and Values in mind when using TIEMPOEXACTO’s social media networks.