OUR GROUP POLICIES

1 OUR GROUP POLICIESR olls-Royce Holdings plc Version , February 2021: Updated POLICIES on 1) Product Safety, and 2) Conflict of Interest and personal relationships Operate Safely Trusted to Deliver Excellence Act with Integrity01 Rolls-Royce Holdings plc GROUP PoliciesIntroductionContentsIntroduction Foreword on risk management 03 Health, Safety & Environment 05 Security 06 Product Safety 07 Quality 09 Charitable Contributions & Social Sponsorships 11 People 15 Conflict of Interest 23 Inside Information and Share Dealing 24 Data Privacy 26 Confidential Information 28 Intellectual Property 29IT Acceptable Use 34 Anti-Bribery and Corruption 36 Gifts and Hospitality 38 Know Your Partner 42 Export Control 43 Lobbying and Political Support 45 Speak Up 47 Glossary 49 Important Notes:Breaches of any of the GROUP POLICIES are not acceptable and may result in disciplinary action up to and including employees are encouraged to speak up if they know of, or suspect, a breach of any of the GROUP POLICIES .

2 Further guidance can be found in our Speak Up Policy. Save by expressly agreed exception, these GROUP POLICIES apply worldwide. In the event of a conflict between a GROUP Policy and applicable local laws, local laws shall prevail. In the event there is no conflict between the GROUP Policy and applicable local laws but the GROUP Policy imposes a higher standard and/or more onerous requirements than local laws, the higher standard and/or more onerous requirements of the GROUP Policy shall note that in some locations, some POLICIES have not yet been adopted. If in doubt about whether a particular policy applies you should refer to your local Engine Room pages or HR all large multinational companies, our shareholders, regulators, customers, suppliers, partners, fellow colleagues and the communities in which we operate expect us to be clear on the values we hold that underpin the type of company we want to be. Our GROUP POLICIES , in conjunction with Our Code, define our values, supporting principles and the expectations we place on all of our people in order to maintain consistent standards across the GROUP when carrying out particular activities in our day-to-day work.

3 Our Code and the GROUP POLICIES form a key part of the Rolls-Royce Framework. All of them are mandatory, so need to be understood and followed by everyone at Rolls-Royce. By doing so, and helping colleagues do so, we will together ensure that we can be at our best and adhere to our values:OPERATE SAFELYTRUSTED TO DELIVER EXCELLENCEACT WITH INTEGRITYMark GregoryGeneral Counsel 02 Rolls-Royce Holdings plc GROUP PoliciesIntroductionINTRODUCTIONOPERATE SAFELYTRUSTED TO DELIVER EXCELLENCEACT WITH INTEGRITYP ioneering companies push boundaries, take risks and make great things happen. But risk taking needs to be done sensibly and openly. We need to take risks where we can create value and then manage those risks to protect value and our reputation. Managing risk effectively is critical to our ongoing success and resilience as it: provides competitive advantage by creating and protecting value through improving the decisions we take; supports us to deliver reliably to our customers and sustainably improve our cash generation; and improves our other stakeholders confidence in our ability to achieve our strategic risk management system aligns with our vision and supports our desired ethical and lean high performance culture.

4 It makes the risks that matter visible to inform the right actions to be taken to make the best use of our resources. Managing risk is every employee s responsibility. Our GROUP POLICIES and our risk management system set the standard that enables us to live up to our values and be at our complying with these POLICIES and using our risk management system we can ensure that Rolls-Royce is a successful, resilient and sustainable business. IMPORTANT NOTES: Breaches of any of the GROUP POLICIES are not acceptable and may result in disciplinary action up to and including employees are encouraged to speak up if they know of, or suspect, a breach of any of the GROUP POLICIES . Further guidance can be found in our Speak Up Policy. Save by expressly agreed exception, these GROUP POLICIES apply worldwide. In the event of a conflict between a GROUP Policy and applicable local laws, local laws shall prevail. In the event there is no conflict between the GROUP Policy and applicable local laws but the GROUP Policy imposes a higher standard and/or more onerous requirements than local laws, the higher standard and/or more onerous requirements of the GROUP Policy shall note that in some locations, some POLICIES have not yet been adopted.

5 If in doubt about whether a particular policy applies you should refer to your local Engine Room pages or HR Holdings plc GROUP PoliciesIntroductionFOREWORD ON RISK MANAGEMENT04 Rolls-Royce Holdings plc GROUP PoliciesOperate SafelyOPERATE SAFELYH ealth, Safety & Environment 05 Security 06 Product Safety 07 Quality 09A. Policy valuesWe are committed to taking care of our health, our safety and the environment ( HSE ), operating safely and creating an environment where each of us can be at our best. We believe that a safe and healthy workplace, that also minimises our environmental impact, is a better place for our people, our customers and our business. Our HSE performance is fundamental to our success and is an integral part of how we work every day. B. PrinciplesWe expect the highest standards of behaviour for protecting our own and others health and safety and the environment in which we operate.

6 We take personal and collective responsibility, along with our suppliers, contractors, joint ventures and other partners, to: operate safely in all our business activities and operations; create a working environment that supports employee wellbeing, with an aspiration towards zero work-related ill health, accidents or harm to people; and prevent or minimise any adverse environmental impact from our activities, products and services, support the sustainable use of resources, and strive for no environmental ExpectationsEach one of us will: take accountability to reduce risks and impacts throughout our activities, products and services; integrate HSE into our business processes and decision making; meet our high standards, ensure compliance with legal and other requirements and drive towards best practice; and speak up if concerned about an activity or decision, including stopping work that we think may be unsafe, and seek advice and support when are committed to engaging and communicating openly with all key stakeholders, and to driving continual improvement through appropriate targets and goals.

7 We believe that high levels of HSE performance are fundamental to doing business with our customers, delivering value for our shareholders and supporting the communities in which we more information including related GROUP procedures, control standards, guidance and HSE contacts see the HSE Engine Room05 Rolls-Royce Holdings plc GROUP PoliciesOperate SafelyHEALTH, SAFETY AND ENVIRONMENT 06 Rolls-Royce Holdings plc GROUP PoliciesOperate SafelySECURITYThis Policy contains information about our security arrangements and therefore is not suitable for external Holdings plc GROUP PoliciesOperate SafelyPRODUCT SAFETYA. Policy valuesRolls-Royce provides mission critical products that people s lives depend on. Our commitment to the safety of our products is therefore at the heart of our Operate Safely core we deliver to a customer is our product - hardware, software, services and documentation, whether delivered separately or integrated into PrinciplesFive principles govern our approach to product safety:1.

8 Leadership commitment and accountabilityOur leaders champion product safety and prioritise it so that safety-related tasks get the right attention, time and resources. We make accountability for product safety clear and ensure people understand what they are accountable Level of product safetyWe design our products to achieve a high level of safety consistent with their application, always ensuring that we meet or better the relevant company, legal, regulatory and industry requirements. We assess what could go wrong and put controls in place to meet the required safety levels throughout the product lifecycle and reduce the safety risks so far as is reasonably practicable. We evaluate how human and organisational factors can introduce risks to product safety and use our understanding when setting our Maintaining and improving product safetyWe are committed to the continuous improvement of product safety and actively engage in setting industry standards and good practice.

9 We measure our performance and rigorously investigate and resolve safety-related issues, systematically embedding the learning from these back into our practices and processes. Everyone is encouraged to report any product safety Conforming productRobust quality is an essential building block of product safety and by following our processes we ensure that our products and those of our suppliers conform to their Holdings plc GROUP PoliciesOperate SafelyPRODUCT SAFETYC. ExpectationsAlways speak up about a product safety concern if you see one, report it if you have any doubt and remember, we are committed to treating everyone fairly and without prejudice in accordance with Our Code. Always follow the parts of the Rolls-Royce Management System applicable to your role. You should feel able and supported to perform the tasks assigned to you. If you are being asked to do something which you do not feel qualified and/or experienced enough to do you should discuss with your sure you attend the Safety Awareness training appropriate to you.

10 For additional guidance, GROUP Procedures, product safety documents and key contacts please access: Product Safety Management System Manual Safety and Product Assurance Engine Room5. Safety awareness and competenceEveryone who works in Rolls-Royce shares responsibility for product safety and we have to be mindful of the safety implications of our actions. Training is provided so that our people understand the Rolls-Royce Product Safety Policy and processes and can fulfil their collective and personal principles are the foundation of our Product Safety Management System which is governed by the Company Product Safety Assurance Policy valuesFor more than a hundred years Rolls-Royce has built its reputation and expanded its business through the pursuit of engineering excellence. We provide mission critical power systems that our customers depend PrinciplesRolls-Royce is a long term business and year in, year out, we invest in facilities, technology and outstanding people so that we can constantly improve the quality and efficiency of our products and services towards our vision of Pioneering the Power that Matters.