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.
We take great pride in our reputation as an ethical company, and we share the responsibility for supporting and strengthening our high-integrity culture.
Committed to doing business right
Everywhere that Eaton does business, we are committed to doing business right, which includes:
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:
Training clarifies and reinforces these expectations at all levels of the company:
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.
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 select matters are reported to the Board’s governance committee.