CNH Industrial NV

Evaluation of Disclosure Controls and Procedures

Our management, with the participation of our principal executive officer and our principal financial officer, has evaluated the effectiveness of our disclosure controls and procedures (as defined in Rules 13a‑15(e) and 15d‑15(e) under the Securities Exchange Act of 1934, as amended, or the Exchange Act) as of the end of the period covered by this Quarterly Report on Form 10-Q. Based on the evaluation of our disclosure controls and procedures as of September 30, 2024, our disclosure controls and procedures were effective as of September 30, 2024.

Previously Identified Material Weakness in Internal Control over Financial Reporting

As previously disclosed in our 2023 Annual Report. management identified control deficiencies related to the design and implementation of information technology (IT) general controls in the areas of user access limits and segregation of duties related to multiple enterprise resource planning (ERP) applications that resulted in a material weakness.

Management's Remediation of the Previously Identified Material Weakness

In response to the identified material weakness, we, with the oversight of the Audit Committee of the Board of Directors, took actions to remediate the material weakness in internal control over financial reporting. Such remediation actions included the design, implementation, and testing of the following new and updated controls, processes and procedures:

1. We enhanced our IT general controls framework that addresses risks associated with user access and security, application change management and IT operations.

a. Management performed review of all users with privileged access, validated as appropriate and corrected user access when inappropriate.

b. Management performed look-back review of actions taken by users identified with inappropriate access to assure no actions were taken by the user that would be deemed inappropriate.

c. Designed a new control to review privileged access as a continuous monitoring procedure.

d. Management has redesigned and enhanced controls around the usage and monitoring of the firecall accounts.

2. We implemented compensating controls and provided focused training for control owners to help sustain effective control operations relating to segregation of duties to strengthen user access controls and security.

As a result of the remediation activities and implementation of the new controls described above, we have remediated the material weakness as of September 30, 2024.

Changes in Internal Control over Financial Reporting

As described above, the Companyhas taken steps to remediate the material weakness noted above. Other than in connection with these remediation steps, there have been no changes in our internal control over financial reporting during the three months ended September 30, 2024, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

Limitations on Effectiveness of Disclosure Controls and Procedures and Internal Control over Financial Reporting

Our management does not expect that our disclosure controls and procedures or our internal control over financial reporting will prevent all errors and all fraud. A control system, no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met. Further, the design of a control system must reflect the fact that there are resource constraints, and the benefits of controls must be considered relative to the costs. Because of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any, within our company have been detected.