Global Reporting Initiative (GRI)

The Global Reporting Initiative is one of the world’s most widely used reporting frameworks for performance on human rights, labor, environment, anti-corruption, and corporate citizenship. More than 1,500 organizations from 60 countries use these guidelines to produce annual sustainability reports. GRI Guidelines apply to corporations, public agencies, smaller enterprises, non-government organizations (NGO’s), industry groups and others.

Eaton is committed to the GRI Framework for reporting the company’s sustainability performance. Sustainability reports based on this framework can be used to demonstrate organizational commitment to sustainable development, to compare organizational performance over time, and to measure organizational performance with respect to laws, norms, standards and voluntary initiatives.

GRI offers three Application Levels: A, B & C, with “A” representing the highest level. Eaton applies a self-declared GRI Application Level of C+, with a goal to steadily improve performance towards the A level. Below you’ll find a full GRI Standard Disclosures Index for Eaton’s 2010 sustainability reporting.

GRI Standard Disclosures Index

Strategy and Analysis 1.1 Statement from senior decision-maker       From the Chairman 1.2 Description of key impacts, risks & opportunities       Annual Report, Pages 3-5       Strategy and Direction       Form 10K       CDP Responses, Pages 4-25

Organizational Profile 2.1 Organization's name       Our Company 2.2 Major products       Fast Facts       Products and Services 2.3 Operational structure and major divisions       Business Groups 2.4 Location of headquarters       Fast Facts 2.5 Countries of operation       Locations 2.6 Nature of ownership       Fast Facts 2.7 Markets served including geographic breakdown/sectors served/customers       Markets 2.8 Scale of organization including number of employees, net sales/revenues       Fast Facts 2.9 Significant changes during reporting period       Annul Report, See:Acquisitions of Businesses, Pages 32-35 2.10 Awards       Awards and Recognition

Report Parameters 3.1 Reporting period       2009 3.2 Date of previous report       March 2008 3.3 Reporting cycle       Annual 3.4 Contact point       Contact Eaton 3.5 Process for defining report content       Metrics 2010 3.6 Boundary of the report       Metrics 2010 3.7 Limitations on the scope or boundary of the report       Environmental, Health & Safety Performance, Pages 18-21 3.8 Basis for reporting on joint ventures, etc. See: Data availability and joint venture agreement. 3.9 Data measurement techniques, basis of calculations and       assumptions        Metrics 2010 3.10 Restatements of information          Environmental, Health & Safety Performance, Pages 18-21 3.11 Significant changes from previous reporting periods   See:  None 3.12 GRI Content Index table  See: GRI index 3.13 Restatements of information  See: Policy and practice for seeking independent assurance for report

Governance, Commitments & Engagement 4.1 Governance structure including committees       Corporate Governance 4.2 Indicate whether chair of highest governance body is also an executive officer       Board of Directors 4.3 Director independence       Board of Director's Governance Policies 4.4 Mechanisms for shareholders and employees to provide recommendations/direction to highest governance body       Shareholder Communications to the Board 4.5 Linkage between compensation and organization's performance for members of highest governance body/senior executives       Proxy Statement-Executive Compensation pages 14-31 4.6 Boundary of the report       Process for the Board to ensure conflicts of interest are avoided 4.7 Processes for determining qualifications and expertise for members of the Board See: Board of Director's Governance Policies; Director Nomination Process 4.8 Mission and values statements, codes of conduct, principles relevant to economic, environmental and social performance, and status of implementation       Global Ethics (links to Code of Ethics, Ethics Guide) 4.9 Procedures of highest governance body for overseeing economic, environmental and social performance including compliance, codes of conduct       Governance Committee Charter 4.10 Processes for evaluating performance of governance body with respect to economic, environmental and social performance   4.11 Explanation of how precautionary approach/principle is addressed by organization   4.12 Externally developed, voluntary economic, environmental, and social charters, sets of principles, or other initiatives           Affiliations and Memberships 4.13 Significant memberships in associations and/or advocacy organizations See: Affiliations and Memberships; Strategic Partnerships 4.14 List of stakeholder groups          Policy 4.15 Basis for identification and selection of stakeholders with whom to engage          Policy 4.16 Approaches to stakeholder engagement, including frequency and type          Policy 4.17 Key issues raised through stakeholder engagement and how organization has responded

Economic Performance Indicators Management approach Environment, Health & Safety; EHS Program EN4 Indirect energy consumption Metrics EN5 Energy saved EHS Program EN6 Initiatives to provide energy-efficient or renewable energy based products Helping Our Customers EN5 Energy saved EHS Program EN8 Total water withdrawal Waste and Water Management, Page 19-21 Metrics EN16 Direct and indirect greenhouse gas emissions Greenhouse Gas Emissions, Page 18, 20-21 Metrics EN18 Initiatives to reduce greenhouse gas emissions EHS Program EN22 Waste Waste and Water Management, Page 19-21 Metrics EN26 Initiatives to mitigate environmental impacts of products Eaton Green Solutions

Labor Performance Indicators  Management approach Workplace LA3 Employee benefits Benefits