Page 43 - GuideEnglish

Using inside information for stock trading purposes
Employees with access to confidential information are not permitted to use or
share that information for stock trading purposes. Using nonpublic information
for financial benefit is illegal as well as unethical, and may subject you and
others to civil and criminal penalties, including fines and imprisonment.
Family and friends
A conflict of interest may arise if you, your spouse, a relative or a close personal
friend works for, or has a financial interest in, a supplier or potential supplier
to Eaton, an Eaton customer, a potential customer or a competitor. It is also a
conflict of interest for you to hire a relative or close personal friend to work for
Eaton in any capacity. Even the appearance of a conflict of interest must be
avoided. If you have a relative or friend working for a supplier, potential supplier,
customer, potential customer or competitor, tell your supervisor, so potential
problems can be discussed and avoided.
Board membership
No employee may serve on the board of
directors or similar body for any for-profit
company, except Eaton subsidiaries or
affiliates, without the express approval of
Eaton’s chairman and chief executive officer.
Board appointments for Eaton subsidiaries
are handled through prescribed channels.
The chairman’s approval is not required for
employees serving on nonprofit boards or
in community organizations. Employees
interested in liability protection for their
service on nonprofit boards or in community
organizations should contact the executive
vice president and general counsel.
Gifts to or from Eaton customers
or suppliers
Inappropriate or excessive gifts or
entertainment to or from Eaton’s customers
or suppliers can create a conflict of interest.
Refer to Eaton’s Gift and Entertainment Policy
for specific guidance and reporting obligations.
Actual conflicts
of interest need
not be present
for a problem to
arise. The mere
appearance of a
conflict must be
avoided. If you
are unsure about
what you can or
cannot do in this
area, get help.