For Reference Only. Not Valid If Printed

Cummins Inc Corporate Offices Building Box 3005, 500 Jackson St. Columbus, IN 47201

For Reference Only. Not Valid if Printed.

Policies and Procedures

Title: Export Control Policy Doc Number CORP-00-04-00-00 Revision: 7 Department: Approved & Released Implementation Date: Corporate Policies and Procedures 09/18/2011 Area: World Wide

Type of Document: Review Period - 728 Days Policy

1.0. Purpose Cummins Inc. is a global company and must comply with the laws and regulations of all the countries where it does business. This includes laws and regulations regarding exports and other trade matters.

In addition to following the law in the country where you are located, each Cummins location must also follow U.S. export laws and regulations. This is because many of the U.S. laws that apply to Cummins Inc. as a U.S. company also apply to any foreign subsidiary, affiliate or permanent foreign establishment that Cummins Inc. controls.

Export regulations are strictly enforced by law enforcement authorities and carry both criminal and civil penalties.

Export regulations impose restrictions in several important areas:  Comprehensive trade embargoes – including export bans - against several countries;  Very strict restrictions on the export of defense articles: weapons systems, weapons platforms (including tanks and military vehicles), related parts and components, software and technology;  Restrictions on the export of so-called “dual-use” goods, software and technology. These are items that have both a military and civilian use and are often controlled for national security reasons;  Restrictions on the persons and companies we can do business with (as set out in the "banned persons lists"); and  Restrictions on the possible end uses of products in areas such as weapons of mass destruction.

The U.S. regulations are particularly far reaching and include the Export Administration Regulations (EAR), which control all U.S. exports, and the International Traffic in Arms Regulations (ITAR), which control defense articles and services. These regulations impose license requirements on the export of certain products, including parts and components, and software as well as the transfer of technical data. The scope of the products and services covered by these laws generally includes:  All direct exports of U.S. products, technology and services from the U.S.;  Re-exports of U.S. products from any location in the world;  Products manufactured outside the U.S. but having U.S. origin raw materials, software or technology;  Transfer of technical data within the U.S. to a non-U.S. citizen or Permanent Resident Alien located in the United States; and  Technical data, assistance and services provided by U.S. citizens, U.S. permanent residents and employees working in the U.S. to non-U.S. branches of Cummins Inc. 2.0. Scope of Policy

This policy applies to the employees of Cummins Inc. entities worldwide in which Cummins has a controlling ownership interest or management responsibility. This includes subsidiaries, joint ventures, affiliated companies and distributors. If Cummins does not have a controlling ownership interest or management responsibility in the subsidiary, joint venture, affiliated company or distributor, Cummins will take reasonable steps to require that the entity comply with this policy and take reasonable steps to ensure the entity complies with the law. 3.0. Policy Cummins is committed to compliance with all applicable export control restrictions in all parts of its business. This policy is a statement of our commitment and provides guidance to our employees as to how to comply. Cummins recognizes that the complexity of export controls can make compliance difficult. Therefore, this policy attempts to give you the information you need to get assistance or additional information if necessary.

Following are the primary tenets of our policy.

3.1. We are committed to compliance: Our commitment to compliance extends from the most senior management to all of our employees throughout the world. Cummins recognizes that compliance is not only required by law, it also makes good business sense. As demonstrated in our Code of Business Conduct, a company’s reputation for ethical and responsible conduct is its most important and valuable asset. Cummins management will maintain a corporate culture that requires compliance and encourages employees to raise compliance concerns to the highest levels of the company without fear of retaliation.

3.2. We will know where our products are going: The U.S. (and other Governments) frequently impose trade embargoes or sanctions against certain countries as a matter of foreign policy and national security. Cummins will ensure that its products are not sent to any of these countries in violation of the law. Additionally, Cummins has chosen to implement additional restrictions. The restrictions imposed by law and/or Cummins policy are as follows:

No transactions with Cuba, Iran, Myanmar, North Korea, The Republic of South Sudan (South Sudan)*, The Republic of Sudan (Sudan), or Syria without Law Department approval. If you are contemplating a transaction that would result directly or indirectly in a product ending up in one of this sanctioned countries, you must contact the Law Department to determine if the transaction complies with this policy.

*In July 2011, an independent Republic of South Sudan was created.

No military transactions with Cuba, Iran, Libya, Myanmar, North Korea, Sudan, or Syria. There shall be no transaction with any person or organization where the end destination of a Cummins product or service is a military application in Cuba, Iran, Libya, myanmar, North Korea, Sudan, or Syria. In addition, the U.S. Office of Foreign Assets Control as well as other Governments, the European Union and organizations such as the United Nations, administer and enforce various trade embargoes and sanctions in relation to the countries not on the above list. The countries subject to such embargoes and sanctions do change.

You should contact the Law Department if you are unsure whether a country is subject to any embargoes or sanctions. 3.3. We will know our customers and business partners: Many countries have lists of individuals and entities called "Restricted Parties" that are subject to some form of trade sanction. In some cases the individuals and entities have been designated as terrorists or supporters of terrorism. The Company will screen all transactions, including customers, suppliers and business partners, against all applicable government lists. Cummins will investigate thoroughly all warning signs that appear in any commercial transaction.

There shall be no transaction by a Cummins entity where there is any involvement with any person or organization designated as a Restricted Party including by:

o the United States (including those named in the lists found at the U.S. Department of Commerce website: http://www.bis.doc.gov/complianceandenforcement/ListsToCheck.htm ); or

o the government of the country where the Cummins entity is based.

If you are unsure whether a person or organization is designated as a Restricted Party, please contact the Trade Compliance Group. 3.4. We will know our products: We must be aware of the export control status of all of our products, software and related technology. Our U.S. operations will classify products and related technology according to the ITAR and the EAR and keep appropriate records of those classifications and required licenses. Where a product may be subject to the export controls of another country or countries, we will classify our products and technology under those regulations as well.

3.5 We will know what our products are going to be used for: We must be aware of the end use of our products. Export laws prevent or restrict the export of products or services if those products or services are going to be used for certain end uses. These include for military or defence purposes, and missile and/or other weapons of mass destruction manufacture. You should always contact the Law Department if you are dealing with a transaction involving one of these end uses.

Employees should be aware that military sales to Cuba, Iran, Libya, Myanmar, North Korea, Sudan, and Syria are prohibited as set out in section 3.2. In addition, military sales to any country will likely require a license.

Always contact the Law Department when a sale includes any military application in any country to be sure that any required licenses are obtained.

3.6 We will obtain necessary licenses: Cummins will review all exports of product against applicable government regulations and obtain all necessary authorizations or licences. Cummins will also keep records of all required licenses.

The Global Trade Compliance Team is responsible for obtaining licenses when needed. The group may be reached by sending a Note to "ExportCompliance."

3.7 We will prevent unauthorized transfers: Exports of technical data, which include items such as engineering prints, drawings, test data, specifications, and service/repair procedures, from the U.S. raise unique issues because the export of technology can take two forms:

o Actual transfer of controlled technical data to a recipient located outside of the U.S., and

o The "deemed" transfer of technical data where the data is transferred within the U.S. to an individual who is not a U.S. citizen or a permanent resident (green card holder). In this situation, the data is "deemed" to have been transferred to the recipient's home country.

Such exports of technical data may occur by email, by phone, in person, or through the mail. Cummins will maintain processes to ensure that all technical data are protected from unauthorized release or transfer. Cummins will keep detailed records of transfers subject to the ITAR or the EAR.

Other countries may also have similar laws and regulations so you should contact your local lawyer about exports of technical data.

4.0. Where To Go For Assistance All employees are required to comply with the provisions of this policy and the trade laws throughout the world. You may find additional information on this policy and the applicable laws by going to MyCummins and clicking on the Tools and Resources tab and choosing the Legal Services page. Once you click on Legal Self Service on the right side of the screen you can go to Compliance to access Export Control information.

If you become aware of any action that you believe is not consistent with this policy, the applicable law or the Cummins Code of Business Conduct, you are required to seek assistance. You can seek assistance by contacting:  your supervisor;  Your Business leader;  Human Resources; or  The Cummins Law Department.

How to contact the Law Department: If you are outside North America, please contact the EMEA Law Department (located in the U.K.) at 44-1784 231500.

If you are in North America, please contact the U.S. Law Department at 812-377-7856. If you do not know who to contact in the Law Department, simply send a Lotus Note to "Law Department" and you will be contacted by the appropriate attorney.

How to contact the Global Trade Compliance Team: Please send a Lotus note to "ExportCompliance."

5.0. Company Ethics Help Line

If for any reason you are not comfortable taking your concerns to any of the above departments or individuals, you may report any concerns regarding this policy to the Company's Ethics Help Line. Please check MyCummins for the phone number of the Ethics Help Line in your country or call the United States number at 1-800-671-9600. You may also report your concerns through the Ethics Help Line website, which you can access by typing "ethics.cummins.com" on your internet browser.

The Company prohibits retaliation and no action will be taken against you for reporting your concerns. If you wish, you may report your concerns anonymously. 6.0. Company Resources These laws are very complicated and the Company does not expect employees to be experts in this area. Cummins has additional training materials on Export Control laws. If you are an employee who is involved with the selling, shipping or delivery of products or services, you need to make sure that you are familiar with the law and with Company policy. If you believe you or others need additional training or information, please contact the Cummins Law Department to arrange training. The Company will provide you with the information that you need. 7.0. Annual Ethics Certification

All Cummins Inc. employees who must complete the Annual Ethics Certification must certify their compliance with this policy.