United Technologies Code of Ethics

United Technologies

Only parts concerning employees are extracted from the code


Introduction
Corporate Principles
Standards of Conduct

2.1 Equal Employment Opportunity
2.2 Workplace Environment
2.3 Drug and Alcohol Use
2.4 Employee Privacy
2.5 Open Communicaton
2.6 Employee Development
2.7 Compensation and Benefits

6.1 Compliance
6.2 Reporting Violations

Introduction

Our Code of Ethics, comprised of our Corporate Principles and these Standards of Conduct, governs our business decisions and actions. The Code is an expression of fundamental values and represents a framework for decision-making. The Code is further explained and implemented in policy clarification circulars and policies included in the Corporate Policies Manual. The integrity, reputation, and profitability of United Technologies ultimately depends upon the individual actions of our employees, representatives, agents and consultants all over the world. Each is personally responsible and accountable for compliance with our Code. In addition, any representatives, agents or consultants utilized by the Corporation shall be prohibited from acting on its behalf in any manner which is inconsistent with the standards of conduct applicable to employees under the Code of Ethics.

These Standards of Conduct serve to assist in defining our ethical principles and are not all-encompassing. The Standards must be interpreted within the framework of the laws and mores of the jurisdictions in which we operate, as well as in light of UTC policies and good common sense. Reasons such as "everyone does it," or "it's not illegal" are unacceptable as excuses for violating our Standards. We must each be mindful of avoiding at all times, on and off the job, circumstances and actions that give even the appearance of an impropriety or wrongdoing which could discredit the Corporation.

These Standards of Conduct will be enforced equitably at all organizational levels.

CORPORATE PRINCIPLES

United Technologies is committed to the highest standards of ethics and business conduct. This encompasses our relationship with our customers, our suppliers, our shareowners, our competitors, the communities in which we operate, and with each other as employees at every organizational level. These commitments and the responsibilities they entail are summarized here.

Our Customers
Our primary responsibility is to those who use our products and services. We are committed to providing high quality and value, fair prices and honest transactions. We will deal both lawfully and ethically with all our customers.

Our Employees
We are committed to treating one another fairly and to maintaining employment practices based on equal opportunity for all employees. We will respect each other's privacy and treat each other with dignity and respect irrespective of age, race, color, sex, religion, or nationality. We are committed to providing safe and healthy working conditions and an atmosphere of open communication for all our employees.

Our Suppliers
We are committed to dealing fairly with our suppliers. We will emphasize fair competition, without discrimination or deception, in a manner consistent with long-lasting business relationships.

Our Shareowners
We are committed to providing a superior return to our shareowners and to protecting and improving the value of their investment through the prudent utilization of corporate resources and by observing the highest standards of legal and ethical conduct in all our business dealings.

Our Competitors
We are committed to competing vigorously and fairly for business and to basing our efforts solely on the merits of our competitive offerings.

Our Communities
We are committed to being a responsible corporate citizen of the worldwide communities in which we reside. We will abide by all national and local laws, and we will strive to improve the well-being of our communities through the encouragement of employee participation in civic affairs and through corporate philanthropy.

STANDARDS OF CONDUCT

Employees

2.1 Equal Employment Opportunity

It is UTC policy to afford equal employment opportunity to qualified individuals regardless of their race, religion, color, national origin, age, sex, handicap or other factors not related to UTC's legitimate business interests.

This policy applies to all phases of the employment relationship, including hiring new employees, promotions, selection for training programs, compensation administration and benefit programs.

2.2 Workplace Environment

UTC is committed to providing its employees a workplace that is free from recognized safety and health hazards and a work environment free from discrimination, harassment or personal behavior not conducive to a productive work climate.

The management of each UTC entity worldwide is responsible for establishing and maintaining UTC approved policies which assure compliance with this commitment.

2.3 Drug and Alcohol Use

All UTC entities worldwide will abide by applicable laws and regulations relative to the possession or use of alcohol and drugs. UTC policy prohibits the illegal use, sale, purchase, transfer, possession or presence in one's system of drugs, other than medically prescribed drugs, while on Company premises.

Similarly, UTC policy prohibits the use, sale, purchase, transfer or possession of alcoholic beverages by employees while on Company premises, except as authorized by the Company.

2.4 Employee Privacy

United Technologies operates on the firm belief of respect for employee privacy and dignity. It is UTC policy to acquire and retain only employee personal information that is required for effective operation of the Corporation or that is required by law in the jurisdictions in which we operate. Access to such information will be restricted internally to those with a recognized need to know.

United Technologies will comply with all applicable laws regulating the disclosure of personal information about employees. In any location where applicable law does not regulate the release of such information, the Company will adopt policies designed to protect such information from unreasonable disclosure.

The Corporation's respect for employee privacy normally precludes any concern relative to personal conduct off the job, unless such conduct impairs the employee's work performance or affects the reputation or legitimate business interests of the Corporation.

2.5 Open Communicaton

UTC will provide its employees with timely information on business results, product performance, customer relations and employee achievements. Communication channels will be provided that encourage self-expression and open dialog relative to employee opinions, attitudes and concerns.

The Corporation is committed to supporting the UTC Ombudsman's authority to review employees' concerns and to ensure proper management response. No retribution will be taken against any employee for contacting the UTC Ombudsman, any level of supervision, the Legal Department, the Business Practices/Compliance Officer, or Human Resources representatives to express concerns with business policies or practices. However, the use of these communication channels to report a wrongdoing will not absolve an employee from accountability for personal involvement in such wrongdoing.

2.6 Employee Development

The Corporation is dedicated to promoting employee self-development through assistance in improving and broadening work-related skills.

2.7 Compensation and Benefits

UTC compensation programs and levels will be based on attracting, motivating, and retaining competent, dedicated personnel. Compensation and benefits programs will be consistent with remaining competitive in our worldwide marketplaces.

Employee Responsibilities

6.1 Compliance

It is the responsibility of all UTC employees to comply with these Standards of Conduct and implementing policies. Any questions of applicability or interpretation should be addressed to cognizant supervision, the entity legal counsel, or the UTC Business Practices/Compliance Office.

Failure to comply with these Standards and associated UTC policies will result in appropriate employee sanctions, to be determined by the cognizant operating management in conjunction with the UTC Business Practices/Compliance Office. As with all disciplinary matters, principles of fairness and equity will apply.

6.2 Reporting Violations

It is each employee's personal responsibility to bring violations or suspected violations of the UTC Standards of Conduct to the attention of their supervision, the legal department of their operating entity, or to the UTC Ombudsman, as appropriate. UTC policy prohibits any retribution against employees for making such reports.

Corporate Business Practices Office: (860) 728-6484
Corporate Ombudsman Office: 1-800-843-8595