SETTLEMENT AGREEMENT BETWEEN AND AMONG GMCo/MLC-IUE-CWA AND USW REGARDING RETIREE HEALTH CARE, LIFE INSURANCE, PENSION TOP-UP, AND MODIFICATION AND GMCO ASSUMPTION OF MLC-IUE-CWA CBASettlement Agreement • September 17th, 2009 • General Motors Co • Motor vehicles & passenger car bodies
This Settlement Agreement (together with the Exhibits hereto, the “Settlement Agreement”), is between General Motors Company (“GMCo”), Motors Liquidation Company (“MLC” formerly known as General Motors Corporation), the IUE-CWA, the Industrial Division of the Communications Workers of America, AFL-CIO,CLC (“IUE-CWA”) and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO,CLC (“USW”). The IUE-CWA and USW also enter into this Settlement Agreement as the authorized representative, as defined in Section 1114(c)(1) of Title 11 of the United States Code (the “Bankruptcy Code”), of those persons receiving retiree benefits, as defined in Section 1114(a) of the Bankruptcy Code, pursuant to collectively bargained plans, programs and/or agreements between MLC and the IUE-CWA or the USW (or an IUE-CWA or USW predecessor) and who are members of the Covered Group, as defined herein. Collectively, the IUE-CWA, the US
