Ethics and Integrity

PolicyA Guide for Visteon Employees

Our Vision

Partner with our customers to help them build the best vehicles in the world.

We will apply our automotive intellect to design and produce components,

systems and modules that appeal to drivers and passengers around the world.

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Integrity ● Safety ● Customer ● People ● Innovation ● Profitability ● Citizenship

Letter from Donald Stebbins, President and CEO........................ 3

Visteon Values .............................................................................. 4

Visteon Behaviors ........................................................................ 5

Ethics and Integrity Policy............................................................. 6Diversity and Inclusion............................................................. 6Safety, Health and the Environment ........................................ 6Product Safety and Quality ...................................................... 6Company Property and Information ........................................ 7Books, Records and Filings ..................................................... 7Intellectual Property, Confidentiality and Privacy..................... 8Insider Trading ......................................................................... 8Conflicts of Interest .................................................................. 9Fair Dealing and Competition .................................................. 10International Business and Government Regulations ............. 10

Summary ...................................................................................... 11

Ethics Hotline Phone Numbers .................................................... 12

Contents

Leading by Example

Visteon has made great strides shaping into a lean and productive company throughrestructuring efforts, improving operations and growing our business. This

transformation is only made possible through the diligence and a concertedeffort of our greatest asset – our employees. Despite the challengingenvironment in which we operate, one thing must remain steadfast – ouremployees' commitment to maintaining the highest degree of integrity andethical behavior and to our values as outlined in this policy. This applies to

employees at all levels, as well as members of Visteon's board of directors. I amproud not only that Visteon is making progress, but that we are achieving it by

doing things the right way in all aspects of our business.

Every day – whether at work or outside the workplace – our actions create an impression withour customers, our colleagues and our communities. How we conduct ourselves determineshow we are viewed. At Visteon, we pride ourselves on operating under the guidingprinciples that we call our values. They include: innovation, safety, customer, people,profitability and citizenship. Additionally and most importantly, the one value thattranscends all others, is integrity.

I urge you to review these important principles outlined in this policy and reflect onhow they impact you personally and in your work. I'm confident that by conductingourselves with integrity, we can maintain high ethical standards while achieving solidbusiness results that will lead to Visteon's success.

Sincerely,

Donald J. StebbinsPresident and CEO

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Visteon Values

Innovation Our people’s creativity and their ability toanticipate the market and leveragetechnology will give us a competitiveadvantage.

IntegrityWe demand the highest ethical standards ofourselves and others.

SafetyWe will not compromise in providing a safework environment for our employees andsafe products for our customers.

Customers We will earn the trust and satisfaction of ourcustomers by exceeding their expectations.

People We will create an inclusive workenvironment where all employees cancontribute to their fullest capability.

ProfitabilityWe are committed to providing value to ourshareholders by building a high-performingbusiness.

Citizenship We will act to protect the environment andadd value to the community.

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Visteon Behaviors

Foster a Safe and Healthy

Environment Provide customer solutions that fostersafety and environmental health, andsafeguard others' safety above all otherpriorities.

Demonstrate Business

KnowledgeDemonstrate an in-depth understanding ofour business, our markets, our internal andexternal customers, competitors, partnersand suppliers.

Demonstrate AccountabilityTake action, take responsibility anddemonstrate integrity.

Build a Stronger Visteon Teach, learn and respect others, recognizeindividual and team contributions, and valuediversity.

Communicate Effectively Build an environment that encourages opendialogue and communicate clearly anddirectly.

Diversity and InclusionVisteon is committed to creating andmaintaining an environment in which allemployees are treated with respect anddifferences are highly valued.

At Visteon, we work to foster an inclusiveenvironment that provides equal opportunityto our employees, customers, suppliers andthe community at large. By creating acorporate culture that is free of harassment ordiscriminatory treatment of any form, everyemployee can have the opportunity tocontribute fully to the business success ofVisteon.

Safety, Health and the

EnvironmentAt Visteon, the health and safety of eachindividual is of primary importance.

Visteon is committed to practices thatgenerate safe workplace actions, conditionsand procedures, and we continually work to

develop and maintain a safe andhealthy operating environment.

Visteon also is a responsible

corporate citizen, protecting and conservingthe natural environment. We comply with allaccepted environmental standards – meetingand often exceeding applicable regulatoryand legal requirements. We continually areimproving our environmental performance,working to minimize the creation of solid andliquid waste and eliminating other practicesthat could have a harmful impact on theenvironment. We describe our commitment tosocial responsibility and sustainabledevelopment in a Corporate SustainabilityReport that can be found on our corporateWeb site at www.visteon.com.

In addition, we encourage and support theinvolvement of our employees in localenvironmental issues as they strive to make adifference within our communities throughvolunteerism and philanthropy.

Product Safety and QualityBecause all our actions can impact Visteonproducts and services, we all share thecommitment to, and responsibility for, safetyand quality in the products we make.

Visteon is committed to design, engineer andmanufacture products that meet orexceed all applicable laws, regulations,voluntary standards and industrypractices. Acknowledging the trustcustomers and consumers place inus, we strive to produce high-qualityproducts and services with a

commitment to continuousimprovement in product performance.Through this dedication, we cancreate products that consistently earnhigh marks for safety.

Ethics and Integrity Policy

Employees have an affirmative obligation to report knownor suspected violations of the Ethics and Integrity Policy.

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Company Property and

InformationAll employees are responsible forsafeguarding Visteon’s assets from misuse ormisappropriation, whether those assets areintangible, such as business information andintellectual property, or tangible, such asequipment or supplies.

Company records, property, technicalinformation, communications and businessopportunities constitute valuable assets thatcan be critical to Visteon’s performance andcompetitive advantage. These materials arethe property of the company and – like allassets – should be safeguarded againstmisuse or misappropriation and used only tofurther Visteon’s business objectives.

Safeguarding these assets includes taking theappropriate steps to prevent and identifyaccidental disclosure. These responsibilitiesand restrictions apply equally to electronicinformation methods (e-mail, Internet, etc.)and prohibit accessing or creating anyelectronic communications that contradictVisteon's personnel policy.

Books, Records and FilingsEmployees are required to keep accuraterecords and provide full, fair, accurate, timelyand understandable disclosures in theperiodic reports filed by the company withregulators and in our public communications.

Visteon’s relationship with its shareholdersand the investment community is built uponour reputation for honesty and integrity infinancial and related reporting. We must makeevery effort to ensure that informationcontained in documents filed by thecompany with governmental orregulatory bodies, includingthe Securities andExchange Commission,and in other company

communications is complete, fair, accurate,timely and understandable. In addition, weare each required to ensure the accuracy ofany records we develop or review, includingfinancial records, expense reports andengineering or other technical documents.

It is Visteon's policy to cooperate ingovernment investigations and inquiries. Allsubpoenas, summonses, informationrequests relating to legal proceedings, orother inquiries or communications from a lawenforcement officer or agency, a court or alawyer should be referred immediately to theLegal Department. This includes interviewrequests, document requests or any otherrequests about an investigation or litigation.

Destroying or altering a document with theintent to impair the document’s integrity oravailability for use in any governmentinvestigation or legal proceeding is a crime.Documents relevant to any pending,threatened, or anticipated litigation,investigation, or audit shall not be destroyedfor any reason. Any belief that companyrecords are being improperly altered,destroyed or otherwise treated inconsistentlywith Visteon’s Record Retention Policy shouldbe reported to the Legal Department.

In addition to being a violation of this policy,efforts to mislead or coerce independentauditors or members of the internal auditstaff concerning issues related to audit,accounting or financial disclosure canhave serious legal consequences,including criminal penalties.

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Intellectual Property,

Confidentiality and PrivacyVisteon is often entrusted with confidential orproprietary information by customers,suppliers and other business contacts. Thisinformation should be safeguarded in thesame manner as Visteon information.

Inventions, ideas and other forms ofintellectual property are a vital part ofVisteon’s success. As a result, we are diligentabout protecting valuable companytechnology through patents, trade secretprotection, copyrights, trademarks or othersuch methods. Visteon is equally committedto avoiding the unauthorized use of theintellectual property of other companies orindividuals.

Visteon also protects corporate data andknowledge through a comprehensive set ofglobal IT policies. These policies provideguidance on safeguarding the company’sbusiness information and assets fromunauthorized access or disclosure and ensurethat information transmitted over ourcommunication systems is properly controlled.

Insider TradingBy protecting confidential and proprietaryinformation from unauthorized disclosure, wenot only protect valuable company assets –we also help ensure compliance with insidertrading laws.

One example of a misuse of Visteoninformation and a violation of the law isinsider trading. Insider trading occurs whenan individual uses material nonpublicinformation acquired in the course ofemployment to buy or sell stock or othersecurities. It is unethical and unlawful to usesuch information or to disclose it to others(such as family members or friends) whomight use it in buying or selling Visteonsecurities or the securities of any othercompany. Also prohibited are “tips” about acompany with which Visteon might have apending transaction, such as an acquisition ora strategic alliance, if information about thetransaction is not yet known to the public.

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Conflicts of InterestEmployees should avoid conflicts betweenpersonal and Visteon interests. If actual orapparent conflicts are unavoidable, seekguidance on the best course of action andfully disclose any transaction or relationshipthat reasonably could be expected to give riseto a conflict.

Employees are expected to exercise goodjudgment and the highest ethical standards inour activities on behalf of Visteon and also tobe mindful that our activities outside thecompany impact how Visteon is viewed byothers. We should avoid any actions,investments or interests which reflectunfavorably on ourselves or the company.More specifically, employees should avoidany action that has the potential orappearance of impacting the companyadversely or interfering with our objectivityabout what is in Visteon’s best interest.

Examples of potential conflicts of interestinclude but are not limited to:

• Having more than a 2.5 percent financialinterest in a competitor, customer, supplieror other for-profit entity doing business withVisteon;

• Outsourcing work to a company in which arelative has a position of leadership orstands to make a monetary gain;

• Having a consulting, managerial oremployment relationship with a competitor,customer, supplier or other entity doingbusiness with the company;

• Acquiring property rights that Visteon has ormay reasonably have an interest in;

• Accepting gifts, entertainment or otherfavors of more than nominal value (which inno case should exceed a fair market valueof $50.00 U.S.) from those who do business– or seek to do business – with Visteon;

• Accepting cash, product or servicediscounts, loans or co-signaturearrangements for you or your family fromsuch individuals;

• Accepting offers to pay for travel, lodging orsimilar accommodations;

• Soliciting any gifts, entertainment or otherfavors;

• Any form of adult entertainment.

Employees also must be aware of customerand supplier policies regarding gifts andentertainment, and abide by such policies.Visteon recognizes that some forms ofcorporate-sponsored entertainment can be alegitimate way to build stronger workingrelationships. Keep in mind that businessentertainment should be legal, reasonable,infrequent and justifiable. A modest businesslunch or dinner, which is occasionally pickedup by one party, is generally acceptable, but astanding lunch or dinner date in which thesupplier always pays is not. Season tickets toa sporting event also would not beappropriate, but an occasional invitation tosuch events is acceptable. Gifts of alcohol arenot allowed in many countries. Any questionsregarding the appropriateness of a gift orfavor, or an offer of entertainment should bedirected to the Legal Department.

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Fair Dealing and CompetitionWe seek to compete strongly and deal fairly.We avoid taking unfair advantage throughmanipulation, theft, concealment, abuse ofconfidential information, misrepresentation orother unfair practices.

Visteon policy, as well as antitrust laws,prohibits price fixing, unfair competition or anyother activity which unfairly impacts orrestricts competition in the marketplace.Seeking or receiving competitive informationor gaining a competitive advantage throughillegal means is prohibited. Activities thatmight give rise to violations of antitrust lawsand a breach of Visteon policy include, butare not limited to:

• Discussions with competitors about prices,costs, production levels, bids or biddingpractices, territories, limits on import orexport, distribution channels or customers;

• Restrictions on a customer’s ability to sell orlease a product at or above price.

Antitrust and fair dealing issues can be verycomplex. Determining what action ispermissible and what is improper can behighly technical and dependent on marketstructure. Whenever any doubt exists, pleasecontact the Legal Department.

International Business and

Governmental RegulationsIt is expected that all employees, includingagents and representatives of Visteon, willcomply with all applicable laws in everycountry in which Visteon does business, aswell as with all applicable laws againstdiscrimination and harassment and lawsprohibiting child and forced labor.

One of the most significant laws that will beencountered by persons involved ingovernment or international business marketsis the Foreign Corrupt Practices Act (FCPA).The FCPA applies to all employees or otherrepresentatives of Visteon anywhere in theworld where Visteon does business. TheFCPA prohibits offers of, or payments to,foreign officials, political parties or candidatesfor political office, to obtain preferentialgovernmental treatment. This prohibitionextends beyond monetary payments andincludes offering anything of value not only togovernment officials, but also to theirrepresentatives or family members. Undercertain limited circumstances, nominalpayments to facilitate government services towhich Visteon is legally entitled are not inviolation of the FCPA.

Even to the extent that such payments maybe legal and customary in a particular countryin which Visteon does business, they may notbe made without advance approval of theLegal Department. Legal Departmentapproval is also required whenever Visteonemployees or other representatives arecontemplating giving gifts or political orcharitable contributions to governmentrepresentatives or foreign officials.

Several laws restrict the countries in whichVisteon can operate, as well as theinformation or products that it can export.Before making a business entry into any newcountry, consult the Legal Department.

SummaryIntegrity is about people doing the right thing– not looking for personal gain or to rewardothers by taking advantage of ambiguity oruncertainty in the law or in this policy. We areeach expected to not only champion thepolicy, but also to protect it – questioning andreporting any practice or activity that conflicts,or appears to conflict, with the company’sethical standards. Those who reportsuspected violations of this policy will helpfurther the business interests of Visteon andensure that the public continues to regardVisteon as a company committed to integrity.

Visteon encourages the communication ofconcerns relating to the lawful and ethicalconduct of business, and financial reporting,accounting practices, internal controls oraudits. It is Visteon’s policy to protect thosewho communicate bona fide concerns fromany retaliation for such reporting. Confidentialand anonymous mechanisms for reportingconcerns are available and are describedbelow.

All employees, including company executives,officers and senior level managers, as well asmembers of Visteon’s board of directors, areexpected to conduct their activities in compliance with this policy. Those who

engage in conduct that is contrary to theethical standards set forth in the policy maybe subject to discipline, up to and including,termination of employment. In addition, ifcircumstances warrant, the company maynotify the appropriate authorities.

If you are in a situation that you believe mayinvolve or lead to a violation of this policy, youhave a duty to disclose the situation and seekguidance.

Employees who have questions or concernsregarding compliance should discuss themwith their managers, Human Resources, orJohn Donofrio, senior vice president, generalcounsel and chief compliance officer.

A global hotline is available as a resource forresolving any questions or concernsemployees might have about Visteon’s ethicalstandards and for communicating with theaudit committee of Visteon’s board ofdirectors if discussions with management,Human Resources or the Legal Departmenthave not resulted in a satisfactory resolution,or if there is concern about using suchavenues of communication.

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This policy constitutes the Company’s Code of Business Conduct and Ethics in compliance with the requirements ofthe New York Stock Exchange and Section 406 of the Sarbanes Oxley Act of 2002 and is designed to promote

honest, ethical and lawful conduct by all directors and employees (including officers) of the Company. Any waivers ofthis policy for directors and executive officers may be made only by the Board of Directors. Any such waivers shall be

promptly disclosed to shareholders as required by applicable law and/or stock exchange regulation.

Visteon Corporation

One Village Center Drive Van Buren Township, MI 48111 USA

June 2008

Reports of policy violations or suspected violations can be made by calling the

appropriate Visteon's ethics hotline based on country of origin.

Country Dialing Pattern

United States 866-218-5326

Canada 866-218-5326

Argentina 0-800-444-1034

Australia 1-800-67-6184

Brazil 0800-891-3682

Czech Republic 800-142-551

China 10-800-711-0332

China 10-800-110-0332

Germany 0-800-180-0783

Hungary 06-800-15-294

Japan 00531-11-4853

Japan (ITJ) 0044-22-112455

Korea (KTA) 00798-1-1-008-1450

Korea (DACOM) 00308-11-0459

Mexico 001-866-218-6326

Philippines 1-800-1-111-0912

Portugal 800-8-11129

Spain 900-97-1026

Sweden 020-79-2363

Thailand 001-800-11-008-1450

Taiwan 00801-10-3989

United Kingdom (BT) 0800-917-0538

United Kingdom (MCL) 0800-056-4513

Italy 800-784872

India 000-800-100-1042