Ethics & compliance

Our reputation as a highly ethical enterprise is a powerful distinguishing characteristic and a key competitive advantage. Our promise of doing business right reflects our unwavering commitment to the highest ethical practices and standards of behaviour. It is how we conduct ourselves in our interactions with each other, our customers and the communities that we serve.

Committed to doing business right
Everywhere that Eaton does business, we are committed to doing business right, which includes:

• Ethical standards for our people
• Environmental stewardship of our facilities
• Fair treatment and the health and safety of employees
• Local support of the communities in which we live and work

Eaton's Code of Ethics consists of twelve fundamental principles of ethical behaviour. It forms the foundation for our culture. Our employees, officers and directors all have the personal responsibility to read, know and comply with these principles in the performance of their duties.

Along with the Code of Ethics, we provide employees with a detailed Eaton Ethics Guide containing concrete examples and practical guidance on ethical decision-making. It is translated into 34 local languages and made available to all Eaton employees worldwide. Every new employee at Eaton receives training on the Code of Ethics as part of the on-boarding process, and employees are required annually to read and reaffirm in writing their commitment to the principles of the Code of Ethics.

Leaders set the tone and drive the culture. To ensure that our commitment to integrity is ingrained in our DNA, our Leadership Attributes—the behaviours we expect from all employees—include:

• We are ethical
• We play by the rules 
• Acting with integrity
• We are proud of our actions

Training clarifies and reinforces these expectations at all levels of the company:

• Our executive, advanced and future leader training programmes include “Leading with Ethics” as key segments.
• Training on the Eaton Business System (EBS), which is how we work at Eaton as an integrated operating company, includes ethics and compliance and abiding by Eaton’s fundamental principles of ethical behaviour as foundational elements.
• Each year all leaders are required to provide their direct reports about in-person training on the principles of our Code of Ethics and Doing Business Right.  
• We implement a robust online annual training curriculum to targeted audiences addressing critical compliance subjects. Designed to provide practical guidance on how to apply our principles and policies, the curriculum features mandatory instruction on anti-corruption laws, antitrust principles, data protection, global trade management, anti-harassment, and other key legal and regulatory areas.
• When mistakes happen or close calls are averted, we take the opportunity to help employees learn from them. Woven into our annual training offerings is a rich library of scenarios, presentations and video resources based on actual events.

Emerging economies often offer high growth opportunities, but can also present elevated risks of corruption and misconduct.  To manage this risk and enable our businesses to pursue opportunities with greater confidence, we employ a comprehensive anti-corruption strategy.

• Our policies prohibit bribes, kickbacks, inappropriate gifts or entertainment, and any other form of corrupt payment. They apply worldwide with no exceptions and without regard to any perceived custom, local practice or competitive conditions.
• Our robust online and in-person annual training curriculum ensures that our employees know our policies, know the law, and know the behaviour we expect. The training provides employees with the necessary tools for applying our policies in their daily responsibilities.
• Through a robust initial screening and life-cycle monitoring process, we ensure our agents and distributors worldwide share our commitment to integrity.

Led by a Board-elected officer and senior vice president, the Global Ethics and Compliance team consists of experienced US and international lawyers and other professionals. To ensure the highest levels of visibility and independence, the Global Ethics and Compliance programme is managed directly by the Governance Committee of Eaton’s Board of Directors, with the active, visible and consistent support of Eaton’s senior management.

We also recognise the need to dedicate resources and develop deep expertise in compliance areas that are of particular importance to our operations as a global manufacturing company. In addition to our Global Ethics and Compliance team, Eaton also maintains teams of professionals dedicated to health, safety and environmental issues, global trade management, government contracting, tax, internal audit, law, Sarbanes-Oxley compliance, supply chain management, data protection and privacy, as well as other significant regulatory areas. These teams work collaboratively with the Global Ethics and Compliance office to manage risk and preserve our reputation for integrity.

Eaton’s Help Line is a dedicated resource for employees to ask a question, raise a concern or report questionable conduct or business practices. The Help Line is staffed 24/7/365 and available in every language and in every country in which Eaton does business. Subject to local law, any person may openly or anonymously ask a question or report an ethical concern or potential or actual legal violation by phone, email, through an online form, via letter, or in person, all without fear of retaliation.  Allegations of misconduct or questionable business practices, regardless of source, are investigated as appropriate. Ethics and compliance matters reported to the Global Ethics and Compliance office are monitored, tracked and reported to the Board’s governance committee.

We monitor the effectiveness of our ethics and compliance programme, including our communications and training elements, by leveraging existing audits, surveys and other tools to assess execution, learning and application. We periodically undertake a detailed gap analysis to measure our effectiveness against best practices and changing business environments. Our Internal Audit teams routinely include ethics and compliance matters within the scope of their audits. And we monitor the rapidly evolving regulatory landscape, ensuring that our leaders and employees stay informed and up to speed on matters of importance. 

Supporting an ethical culture requires constant vigilance. We cannot, and do not, stand still. To focus resources where they are needed most, we conduct an annual assessment of our key ethics and compliance-related risks. Every business unit, every region and every corporate function participates in this formal process. Risks are measured using standard evaluation criteria. Results are consolidated and reviewed by senior leadership and presented to the Board. We then use this data to tailor our training offerings and programme elements and to set our areas of focus for the year.