Polaris Code of Business Conduct and Ethics Commonly Asked Questions

General Questions about Reporting Q: When should I report a violation or suspected violation of the Code of Business Conduct and Ethics (“Code”)? You should report a violation of the Code as soon as you are aware of it. Q: Can I remain anonymous? Yes. Whether you report internally or through EthicsPoint, you can report anonymously. To ensure a report is anonymous, EthicsPoint does not trace phone calls and does not maintain any identifying electronic information from on line reports. If you want to remain anonymous in an internal report, you should send an anonymous letter to the Compliance Officer listed in the Code. Q: What if I am uncertain if an incident violates the Code? You should ask your manager, supervisor, Human Resources Department or others identified in the Internal Reporting section of the Code, or you may ask the question through EthicsPoint. Q: What will happen to me if I file a report? Polaris encourages you to report suspected violations of the Code or the law, and prohibits retaliation against anyone who, in good faith, reports a violation of the Code or cooperates in an investigation. This is true regardless of whether the underlying report is found to be correct or results in corrective action. If you feel that you have been retaliated against, you can report this through EthicsPoint or through others identified in the Internal Reporting section of the Code. Reports about routine human resources matters should not be reported through this system. You should continue to work through your Human Resources department on these types of matters.

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

Q: Where do I report? You have several options for reporting. You can report directly to your manager, supervisor or Human Resources Department at your location. If you do not feel comfortable reporting to one of these individuals, you may contact the Compliance Officer listed in the Code. You may also make reports by telephone or online through the Polaris Business Ethics Hotline which is managed by an independent third-party provider, EthicsPoint. From the U.S. or Canada, dial 1-888-219-3550, and outside of these countries, dial this same number along with your country code which is posted on the EthicsPoint reporting page under the link International Dialing. You can reach this page through the Reporting Violations link on the Polaris employee intranet site under Business Ethics. You may report online by clicking the Reporting Violations link on the Polaris employee intranet site under Business Ethics, or, by contacting EthicsPoint directly at www.ethicspoint.com. Q: What is EthicsPoint’s role? EthicsPoint role is take reports over the phone or through the online hotline and then to make the reports available to Polaris personnel to investigate the report. By using EthicsPoint, Polaris can make sure reports can be made 24 hours per day worldwide. The EthicsPoint system also makes it easier for reports to be made anonymously, if necessary. Q: How does Polaris investigate reports? Polaris will start an appropriate investigation using internal and/or external resources. The information in your report will be shared with investigation team members that need to be informed to conduct an appropriate investigation. All investigation team members will take steps to ensure the information is kept confidential. However, to conduct a complete and thorough investigation, information about the report may have to be disclosed.

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

Q: How do I monitor progress on my report? If you report to internal sources, you can simply ask the person you reported to and that person will provide you as much information as is appropriate. If you make a report through EthicsPoint, you will be assigned a unique code called a "report key" and you will be asked to create a password. Write down your report key and password and keep them in a safe place because Polaris will not have access your report key or password. We encourage you to use your report key and password to periodically check your report for feedback, questions or updates. You may do this either online or by phone by contacting EthicsPoint.

Questions about Code Standards

General

Q: My manager or supervisor has asked me to do something that I think is illegal or which violates the Code. What should I do?

You should report the issue through EthicsPoint or to the Compliance Officer listed the Code.

Q: I have seen some conduct at the office that I think is illegal but it is not addressed in the Code. What should I do?

If you suspect illegal behavior, you should report it or talk with your supervisor or manager about it. No Code could possibly address every situation. You are responsible for understanding the laws applicable to your job and abiding by the policies in place at your work site. The bottom line is that you have to exercise good judgment and high ethical standards at all times whether or not an issue is specifically addressed in the Code.

Harassment Free Workplace

Q: My co-worker has been making unwelcome remarks of a sexual nature which make me uncomfortable. What should I do?

Polaris prohibits any type of harassment by team members and we encourage you to report such behavior.

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

Safety, Health and Environmental Q: While unloading a trailer, I spilled a container of cleaning solvent. If I clean it up, do I need to do anything else? Yes. You should immediately report any spill of hazardous or potentially hazardous material to the Environmental Manager at your location. Conflicts of Interest

Q: I have been asked to serve as a consultant for one of our vendors during off hours. Can I do this?

Serving as a consultant for another company that does business with Polaris can create a conflict of interest. Consequently, you must receive approval from Polaris prior to agreeing to serve as a consultant. Raise the issue with your supervisor, who will then take the issue to the appropriate people for consideration.

Polaris’ Confidential Information

Q: A friend asked me if I could confirm an internet blog which claimed that Polaris is adding certain features to its ATVs for the next model year. Should I tell him what I know?

No. Product plan and product launch information is confidential and proprietary information of Polaris and should not be discussed with anybody outside of Polaris unless Polaris has already been made that information public. If you have questions on whether an issue has been made public, please contact your manager or the appropriate Corporate Marketing Manager.

Q: I received a call from someone outside Polaris asking me to confirm the financial condition of one of our business units. What should I do?

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

You should refer the caller to Investor Relations. The request could be asking for confidential financial information that cannot be disclosed at this time.

Confidential Information of Others

Q: Is it acceptable for me to collect information about competitors?

Gathering public information about competitors is both a necessary and an appropriate business practice, but you are prohibited from gathering competitive information in an illegal or unethical manner. For example, information obtained from public sources (i.e. newspapers, press releases, documents filed with the government, technical publications) is permitted. You should never, however, obtain competitive information through deceptive techniques such as misrepresenting your identity or company affiliation, by offering a financial inducement to receive the information. You also should not ask former employees of competitors to divulge confidential or proprietary information of their former employers. Competitive information that is marked as “confidential”, “trade secret” or “proprietary,” or otherwise appears to be a competitor’s internal document, should be treated with caution. If you believe you have inappropriately received any documents or information of this nature, do not circulate or use the information and contact the Polaris Legal Department immediately.

Use of Polaris’ Assets

Q: There is a lot of wood and other material stacked up outside my facility. Can I take it home so it doesn’t get wasted?

No, unless you get approval from your supervisor. Any material at a Polaris facility (other than employees’ personal property) is owned by Polaris and may not be taken without receiving prior approval from a supervisor.

Insider Trading

Q: I have received information about Polaris’ financial performance which is not yet public. Can I tell my friend about this information so that he can take advantage of it by trading in Polaris stock?

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

Absolutely not. This is considered “inside” and “non-public” information which cannot be disclosed. Trading stock on this information, or providing tips to others to do so, is a serious violation of U.S. securities laws and possibly other countries laws as well.

Financial Integrity and Disclosure

Q: I believe that certain Polaris expenses are not being accurately recorded on Polaris’ books. What should I do?

You should report the issue. Polaris complies with all applicable securities laws and regulations, accounting standards, accounting controls and audit practices. False or misleading entries, unrecorded funds or assets, or payments without appropriate supporting documentation and approval are strictly prohibited.

International Business

Q: One of our distributors in a foreign country has informed me that it paid a government official to get a meeting to pitch the sale of our vehicles. Is that ok?

No. The Foreign Corrupt Practices Acts (“FCPA”) makes it a crime for any U.S. company, any employee of a U.S. company, and any subsidiary of a U.S. company, to use bribery as a way to gain favor with any foreign government official in the connection with any sale of U.S. products. The law applies whether the act takes place inside, or outside, of the U.S. if it relates to the sale of Polaris product. You should report this violation, either internally or through EthicsPoint.

Gifts, Favors, Gratuities and Vendor Relations

Q: I have been offered a free shot gun by one of our vendors. Can I accept it?

No. You cannot accept gifts, loans or other favors from anyone doing business with Polaris or who wishes to do business with Polaris unless they are infrequent, of nominal value and are normal and customary given the business circumstances. You should discuss all gifts you are offered with

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

your manager because, in some situations, it may never be appropriate to accept a gift of any value.

Antitrust and Fair Competition

Q: I have been asked to tell a dealer that it must stop discounting its product or Polaris will be forced to consider other options. Is that okay?

No. Under the antitrust laws, dealers are free to set their prices for reselling product at any level they choose. If Polaris either agrees with the dealer, or coerces the dealer, to sell at certain prices, it would be illegal price-fixing. Any such conduct by Polaris personnel would be a violation of the Code. You should contact the Polaris Legal Department if you have any questions.

Q: A dealer complained to me about another dealer’s low prices and asked me what Polaris was going to do about it. What should I say?

Tell them that Polaris will do nothing. Under antitrust laws in the U.S. and foreign jurisdictions, dealers set their own price level and Polaris cannot do or say anything that could be considered an agreement between Polaris and a dealer to charge a specific retail price, or to take action against a discounting dealer. The best approach is to avoid discussions with dealers about retail pricing of other dealers. If the issue comes up in person, stop the discussion immediately, tell the dealer that these discussions are illegal and move on to a different topic. If the dealer will not move to another topic, stop the conversation and leave. If the communication comes in written form, do not circulate or respond to the communication. Rather, send the communication to the Polaris Legal Department to determine an appropriate response.

Compliance with Law, Government Activities and Service of Legal Documents Q: I know a government agency has been investigating certain product issues at Polaris. I have documents that relate to those product issues, but I have never been asked to provide them. Can I destroy them?

Polaris Code of Business Conduct and Ethics Commonly Asked Questions

No. Documents that relate to a pending government investigation or pending litigation may not be destroyed. Whenever you think you have documents relating to these matters, you should contact the Polaris Legal Department to determine the right way to handle those documents.

Vendor Standards Q: I was at a supplier yesterday and she told me that the supplier paid off a government official to avoid customs and duties on the parts they supply to us. I know this saves Polaris money, but is it ok? No. Polaris will only do business with people who conduct business ethically and legally. All suppliers and vendors must comply with the standards in the Code and the law. Paying off government officials is bribery and violates the law. You should report this conduct immediately. Q: A dealer told me that one of the ways he has increased retail is by helping consumers provide false information to get consumer financing. Is this a problem for Polaris, or just for the dealer? This is problem for Polaris too. A dealer who engages in fraud or who otherwise breaks the law when selling Polaris products violates both the standards of the Code and its Dealer Agreement with Polaris. Just as with any supplier or vendor, Polaris will only do business with people who conduct business ethically and legally. You should report any illegal conduct by dealers to your manager, Dealer Development or the Polaris Legal Department.