We monitor the effectiveness of our ethics and compliance program, 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 program 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 Eaton does business, we’re committed to doing business right, which includes:
Eaton's Code of Ethics consists of twelve fundamental principles of ethical behavior. 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 our commitment to integrity is ingrained in our DNA, our Leadership Attributes — the behaviors we expect from all employees — include:
Training clarifies and reinforces these expectation at all levels of the company:
Emerging economies often present high growth opportunities, but also can 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 U.S. and international lawyers and other professionals. To ensure the highest level of visibility and independence, the Global Ethics and Compliance program 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 recognize the need to dedicate resources and develop deep expertise in compliance areas 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, and other significant regulatory areas. These teams work collaboratively with the Global Ethics and Compliance office to manage risk and preserve our reputation for integrity.