Code of Business

Conduct and Ethics

We connect and protect

DEAR NVENT COLLEAGUES:
This is an exciting time for nVent. We’re a new company … with a deep legacy.

Central to that legacy is a dedication to our values. These six values

(Absolute Integrity, Accountability for Performance, Respect and Teamwork,
Customer First, Innovation and Adaptability, and Positive Energy) serve as
the bedrock of who we are and how we work.

The values are reflected in our Code of Business Conduct and Ethics,
which dates back more than four decades. The Code gives specific
guidance on how we interact with customers, business partners,
investors and each other.

It’s up to all of us to understand and comply with the Code. It is designed

to help you better understand your responsibilities regarding regulations,
international laws and ethical business standards. It also will help you know
where to turn should you have concerns.

At nVent, we succeed by maintaining the highest level of integrity through

open, honest and fair dealings.

Thank you for your dedication to learning and living the Code each and
every day.

Beth Wozniak
Chief Executive Officer
nVent
CODE OF CONDUCT
TABLE OF CONTENTS
nVent VALUES
Application Of the nVent Code of Business Conduct and Ethics...........................................................3

Commitment to Values at nVent...................................................................................................................4

HOW WE COMPLY
Asking for Help and Raising Concerns........................................................................................................6

Promoting A Positive Workplace and Respecting Others.......................................................................8

Protecting Our Employees and the Environment.................................................................................... 10

POLICIES
Conflicts of Interest....................................................................................................................................... 12

Gifts and Business Entertainment............................................................................................................. 14

Doing Business With Integrity..................................................................................................................... 16

Financial Integrity.......................................................................................................................................... 20

Protecting and Managing Property, Information and Records............................................................22

SPEAK UP RESOURCES
Helpline Numbers.......................................................................................................................................... 24

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APPLICATION OF THE NVENT CODE OF
BUSINESS CONDUCT AND ETHICS
At nVent, all of us, regardless of where we conduct business, are expected to incorporate our
Values into our daily work activities and abide by the principles outlined in the Code.

OUR COMMITMENT TO COMPLIANCE

As a global company incorporated in Ireland, publicly traded on the New York Stock Exchange, and with
businesses operating all over the world, there are international laws, regulations, and global standards
that apply to all of us. In addition to these international laws and standards, we are committed to
following the local laws of each country where we do business. Where local laws may conflict with our
principles, you should seek input from the Legal Department.

The nVent Code of Business Conduct and Ethics applies to all employees, part-time employees,
contractors, executives and our Board of Directors.

The information within the Code is supplemented by any corporate, business or regional policies
related to the content discussed within the Code. The Code offers general guidelines only and is
subject to local law. It is not intended to be all inclusive.

As an employee of nVent, you will be asked to sign a commitment statement that you have read and
understand the nVent Code of Business Conduct and Ethics and that you will act in full compliance
with the Code.

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COMMITMENT TO VALUES AT NVENT
At nVent, success alone is not enough. We deliver on our values of Customer First,
Accountability for Performance, and Innovation & Adaptability. And we do it through
Positive Energy, Respect & Teamwork, and Absolute Integrity. Our values are the
heartbeat of our company.

• Views situations through the customer’s eyes and in

the context of customer needs

CUSTOMER FIRST • Strives to make it easy for customers to do business

with nVent
We make it easy for customers to do business
• Focuses on improving our levels of quality, service,
with nVent and are tenacious about and satisfaction
meeting customer commitments.
• Is tenacious in meeting commitments to internal and
external customers

• Demonstrates commitment to do what it takes

to get results; operates with speed, urgency, and

ACCOUNTABILITY FOR determination

PERFORMANCE • Perseveres in the face of challenges and barriers;

resilient in response to setbacks; follows through on
We commit to high standards of performance and commitments
demonstrate personal ownership for getting the job done. • Takes responsibility for own development; uses
success and failures as learning experiences to fuel
future success
• Owns results and takes responsibility for
consequences of actions, good or bad

• Identifies important emerging trends; anticipates and

prepares for changes in the business and industry
INNOVATION AND • Adapts to change with agility and flexibility
ADAPTABILITY • Is open to new ideas; supports and
We actively pursue continuous improvement, adapting to encourages innovation
changing circumstances and applying new ideas • Solves problems creatively and drives continuous
improvement

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 • Is aware of his/her mood and adjusts accordingly
to have a positive impact on others

POSITIVE ENERGY • Is fully present and attentive in discussions with others;
refocuses quickly if distracted
We display a positive outlook and take responsibility
• Contributes to an optimistic and energizing
for our impact on others. environment; assumes others have positive intentions
• Displays and instills pride in being an nVent employee

• Builds alignment for plans, decisions, and actions;

collaborates well with others

RESPECT AND TEAMWORK • Listens and strives to understand the perspectives

and experiences of others
We treat others with respect and openness;
• Treats others with respect; conveys appreciation
we collaborate and align with others for team success.
to others for their value and contribution to the team
• Provides useful feedback and coaching to others
to support their effectiveness and success

• Acts with the highest level of ethics and integrity;

models the nVent values
ABSOLUTE INTEGRITY • Treats others in a fair and equitable manner
We are committed to honest and ethical
• Communicates with openness and candor
business practices in our dealings with customers, business
• Takes action to positively impact safety and health
partners, investors, communities, and each other.
in own work environment and community

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ASKING FOR HELP AND RAISING CONCERNS
nVent is committed to creating an environment where employees are encouraged to Speak Up, ask
for help and raise concerns. Open communication contributes to a transparent, collaborative and
honest working environment.

WHEN TO SPEAK UP NON-RETALIATION AND CONFIDENTIALITY

Whenever any of us observes or suspects something improper We will not tolerate retaliation in any form against employees
or unethical, we have an obligation to take action and to Speak for raising concerns or making good-faith reports about
Up. But how do we know when to Speak Up or if an action or possible breaches of law, Policy or ethical violations. All nVent
behavior is inappropriate? The following six questions provide employees are encouraged to Speak Up, seek guidance and
simple guidelines for making these judgments. If you cannot report any actions that could potentially harm our employees,
answer yes to all of these questions, you should Speak Up and our company, our shareholders or our reputation. nVent will
ask for help. take all steps possible to ensure that every report is handled
confidentially. All reports of violations will be taken seriously
• Is the action consistent with this Code of Business Conduct
and Ethics? and addressed promptly.

• Is the action consistent with our Values?

• Is the action legal?

• Would I be comfortable if this decision or action was Speak Up Resources

made public?
If you have a question related to nVent policies or if you
• Would I want it done to me? observe or suspect something improper or unethical has
• Would the actions be perceived positively by my family, peers, occurred, Speak Up.
employees, and nVent shareholders? Raise the concern with your manager or Human
When you Speak Up, you provide our company with information Resources (HR) representative. If you are not
that is necessary to remedy a potentially harmful situation. comfortable speaking with your manager or HR,
While you may be reluctant to get involved, failure to report a other available resources include:
concern could have substantial consequences. It could result • Legal and Compliance teams
in financial or reputational damage to nVent, employee injury • nVent Ethics Helpline on page 24
and, in some cases, termination or criminal action against an • www.nVentEthics.com
employee or the company. So when in doubt, Speak Up!
• Office of Business Conduct and Ethics:
A completely confidential resource for our employees,
suppliers, investors or customers to raise and address
compliance concerns.
Phone: 1.800.472.8868
Email: [email protected]
Address: 1 665 Utica Ave., Suite 700,
Minneapolis, MN, 55416
• Policies: For a complete set of corporate workplace
policies, including detailed policies related to topics
in the Code of Business Conduct and Ethics,
visit mynVent.

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Q&A
Q: I think a colleague of mine has violated the Code of Business Conduct and Ethics and maybe even
the law. I want to do the right thing and Speak Up, but I am concerned that doing so could hurt my career.
What should I do?

A: nVent prohibits retaliation against anyone for reporting a concern in good faith. Retaliation can include
termination, compensation reduction, demotion, undesirable work assignments, or threat of physical or mental
harm. If you have seen something you believe is wrong, Speak Up. nVent will treat your report as confidentially as
possible and will protect you from retaliation.

Q: How can the company protect me from retaliation?

A: nVent takes allegations of retaliation very seriously. This means educating employees and management on
what retaliation looks like and ensuring they understand the consequences. If an allegation of retaliation is
substantiated, the company will discipline the individuals involved up to and including termination.

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PROMOTING A POSITIVE WORKPLACE
AND RESPECTING OTHERS
We are committed to ensuring a positive, diverse and inclusive work environment
where all employees treat one another with dignity and respect. We do not tolerate
discriminating behavior or harassment in our workplace.

VALUING DIVERSITY AND PROMOTING INCLUSION PREVENTING HARASSMENT

We value diversity in our workforce, supplier base and Acts of harassment will not be tolerated. This includes any
customers. As a global company, we believe that diversity conduct or statements made on the basis of protected
contributes to the success of our business. We value the status that are intimidating, hostile, or abusive. Examples of
unique contributions of individuals with varying backgrounds harassment include:
and experiences. We believe an inclusive culture allows our • Unwelcome conduct — whether verbal, physical or visual,
employees to contribute their best. and whether committed in person or some other way
nVent is committed to equal opportunity and fair treatment for (e.g., via e-mail) — that is based on a person’s protected
all. The company prohibits discrimination on the basis of age, status. Protected status includes, but is not limited to, race,
race, disability, ethnicity, marital or family status, national origin, color, religion, gender, age, national origin, disability, sexual
religion, gender, sexual orientation, veteran status, genetic orientation, genetic information, and veteran status.
information, gender identity, medical condition or any other
• Racial, ethnic, religious, or sexual jokes.
characteristic protected by law. This principle extends to all
• Abusive language, intimidation, undermining or deliberately
decisions relating to recruitment, hiring, training, placement,
impeding a person’s work.
advancement, compensation, benefits, and termination.
• Physical aggression or other acts related to violence, including
intimidation, bullying, stalking or threatening comments.

• Unwelcome sexual advances or requests for sexual favors.

• Any other actions that unreasonably disrupt or interfere with an

To promote an inclusive workplace: employee’s work performance.
• Welcome differences — including race, gender,
Our Policy applies to all nVent employees and contractors, plus
background, language, education, functional expertise,
etc. Differences bring about creativity and innovation. anyone who does business with nVent, including business

• Be free of bias and open to new approaches, partners, customers and suppliers. This Policy also applies
perspectives and experiences. to work-related settings and activities outside of the workplace.
• Be respectful in all interactions — in person or otherwise.

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OUR RESPONSIBILITY TO OUR COMMUNITIES Q&A
As nVent employees, we must make socially responsible Q: I am just a few years from retirement and recently
decisions and do what’s right for our global communities. In applied for a new position. It was a position awarded to
addition to our commitment to diversity, fair treatment and a much younger applicant, who in my opinion was less
equal opportunity, we strive to be good corporate citizens. qualified for the job. I am now concerned that I was not
nVent expects this same commitment from our business hired for the new position because of my age. Is this
partners, customers and suppliers. Some principles we age discrimination?
follow to demonstrate good corporate citizenship include: A: If you feel that you have been subjected to
• Providing clean and safe working conditions. unfair treatment, you should Speak Up. Reach out to a
contact listed within the Speak Up Resources on page 6.
• Providing fair wages and benefits according to local
The company will conduct an investigation regarding
laws and practices.
the matter and follow up with you once the investigation
• Not tolerating human rights abuses including, but not
is complete.
limited to, child labor.
Q: Our department is under great pressure to meet our
• Giving priority to business partners, suppliers and
quarterly targets. My manager is constantly yelling at
contractors who share nVent’s commitment to socially
us, using abusive language and making threats.
responsible business practices. For more information,
I don’t really think that my manager would harm us,
see the nVent Supplier Code of Conduct located on:
but it makes me uncomfortable. What should I do?
www.nVent.com/en/contact-us#downloads.
A: nVent’s work environment must be free from harassment
including intimidating language. If threatening language is
used in your workplace, Speak Up. Reach out to a contact
listed on page 6.

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PROTECTING OUR EMPLOYEES AND
THE ENVIRONMENT
nVent is committed to protecting employees and the environment by engaging in responsible
business practices. We comply with applicable environment, health and safety laws, permits and
requirements wherever we work.

COMMITMENT TO A SAFE WORKPLACE

We are committed to preventing workplace injuries with the goal that
A few simple guidelines that we can all
all of us will leave work in the same healthy, uninjured condition as we
apply in our daily work activities include:
arrived. We all have a responsibility to prevent injury and illness in the
workplace by following these guidelines: • Conserve water and minimize waste.

• Put safety first. If you see any potentially unsafe situations, Speak Up • Recycle waste materials that cannot be eliminated.
by immediately telling your supervisor. • Properly dispose of any remaining waste materials.
• Always follow established safety procedures. • Reduce greenhouse gases by using energy
• Watch out for the safety of your colleagues — tell them if they efficiently. For example, turn off office
are doing something unsafe. electrical devices (such as lights, computers
and radios) when not being used.
• Maintain an environment free of illegal or controlled
substances that could impair judgment on the job. • Minimize the amount of packaging used.
Where packaging is required, make sure
• Maintain an environment that is free of weapons or potentially
that it is made from recyclable materials.
dangerous devices.
• Operate in a manner that is in compliance with all
nVent will investigate all incidents, injuries and near misses with the
Environmental, Health & Safety laws and regulations
objective that permanent corrective actions are implemented and the
and all nVent requirements.
root cause is never repeated.

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RESPECTING THE ENVIRONMENT PRODUCT QUALITY AND SAFETY
We strive to eliminate harmful environmental impacts by nVent seeks the highest product quality, safety and
minimizing our emissions, waste and water usage. performance at all times. Our business, reputation and
We are committed to protecting the environment by success depend on our commitment to compliance with
engaging in responsible business practices. government and industry standards.

For this reason, all records regarding quality matters

must be accurate and complete. If you suspect or become
aware of a product quality or safety issue, Speak Up.

Q&A
Q: My manufacturing facility has a major order to fulfill. We are running at 100% capacity and are under
a great deal of pressure to get the shipment out. One of the plant machines seems to be operating
incorrectly and may not be safe, but if we shut down the machine, we will miss the shipment deadline.
What should I do?

A: Speak Up. You need to immediately report the issue to a supervisor and ensure the equipment is safe prior to
continuing production. Safety always comes first! See page 6 for Speak Up resources.

Q: One of my colleagues just learned that his position is being eliminated and he seems very angry about it.
In fact, I’ve heard him making comments that sound like threats against the company. What should I do?

A: No threats against our company or an employee should be ignored or go unreported. If you feel that your
colleague is making threats, or if you witness any violent behavior, you should Speak Up. Contact your local
Environmental, Health & Safety team or Human Resources. If those people are unavailable or non-responsive,
reach out to a contact listed within the Speak Up Resources section. If the situation escalates and involves an
immediate or urgent threat of harm, you should contact local law enforcement officials.

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CONFLICTS OF INTEREST
Every day, many of us work with suppliers, customers and others who do business with nVent.
It’s important that each decision, and any related action, be based on the needs of the company —
not on personal interests or relationships.

SEEK GUIDANCE FAMILY AND PERSONAL RELATIONSHIPS

Most conflicts of interest can either be avoided entirely or be You should never hire, supervise or have influence over a family
resolved easily if they are properly disclosed to nVent. If you are member or close personal relation within the company unless
ever in doubt about whether an activity may create a conflict prior approval is explicitly provided by nVent management. If
of interest, please Speak Up and seek guidance from your you have a family member who has a third-party relationship
manager or Human Resources. The company will work with you with nVent (as a vendor or customer, for example), you must
to determine the appropriate course of action. disclose this information to the company. Additionally, you must
disclose if a family member is employed by a third party, is on
its Board of Directors or is a shareholder or significant investor
OUTSIDE EMPLOYMENT of a company doing business with nVent.
Although in some cases it may be acceptable for you to work
outside of nVent, such employment must never interfere with
FINANCIAL INVESTMENTS
your responsibilities to our company. Outside work must not
involve an nVent competitor nor should it involve the use of If you or an immediate family member have any significant
nVent tools, vehicles or other nVent property (including but financial interest in an nVent supplier, customer consultant
not limited to computers, software and customer information). or competitor, you must notify your local Human Resources
If you are considering outside employment with an nVent Department and disclose the information through the proper
business partner (such as a supplier or a customer), you need reporting channels.
prior approval from your manager. For more information, see our Conflicts of Interest, Gifts and
Entertainment Policy on mynVent.

Conflict of Interest Reporting Guidelines

All conflicts of interest, or even potential conflicts of
interest, must be reported to www.nVentEthics.com.
The company will work with you to determine if a conflict
exists and devise the appropriate course of action.

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Q&A
Q: I’m the logistics manager at our manufacturing location, and I know that my brother’s company can
provide transportation services to nVent at a much better rate than our current provider. Shouldn’t I try
to get nVent a better deal, even if the new company is owned by my brother?

A: All nVent employees must follow our company’s sourcing and procurement procedures for engaging a
new supplier. It may be possible to do business with your brother’s company, but only if the procedures
are properly followed. Additionally, you must disclose your family relationship and remove yourself from
all negotiations. It’s important that all of our business dealings be fair. All employees must avoid even the
appearance of impropriety, and doing business with our family members can be interpreted as favoritism.

Q: O
 ur group recently hired an employee to fill an open position and I have subsequently learned that the
new employee is my supervisor’s daughter. Is this allowed?

A: Although relatives and spouses may sometimes work in the same building or department at nVent, relatives
and spouses should never hire, manage or supervise one another without first receiving approval from
nVent management. In this case, your supervisor’s relationship with his daughter may very well threaten
his objectivity and conflict with the interests of the company. If you have questions or concerns regarding
conflicts of interest, or if you witness a potential conflict, Speak Up. Reach out to a contact listed within the
Speak Up Resources on page 6.

Q: One of my team members leaves early every Thursday and Friday so he can go to his other job. We
typically are working in the field so I don’t think our supervisor knows. This doesn’t seem fair to me
because he gets paid for the full week. What should I do?

A: nVent employees may accept outside employment only if it does not affect their work at nVent and if it
complies with business or regional-specific practices. In this case, a team member is being paid by nVent and
not fulfilling his obligations. We encourage you to Speak Up. Reach out to a contact listed within the Speak Up
Resources on page 6.

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GIFTS AND BUSINESS ENTERTAINMENT
While customs and practices can vary among cultures, sharing modest gifts and entertainment is
often an important way of creating goodwill and establishing trust in business relationships. We
have a responsibility to make sure our business gifts and entertainment practices are reasonable
and consistent with nVent policies, industry codes and local laws.

BUSINESS ENTERTAINMENT Please see the Conflicts of Interest, Gifts and Entertainment
Policy for specific monetary limits for giving and receiving
Modest and appropriate meals and entertainment may be
accepted or provided by nVent employees if the primary gifts on mynVent. All gifts over the limits specified

purpose of the meal or entertainment is business-related. in this Policy must be reported at www.nVentEthics.com
for pre-approval.
The employee, as well as the customer, supplier, contractor or
partner, must be present; otherwise, the meal or entertainment
must be treated as a gift. PROVIDING GIFTS AND ENTERTAINMENT
If you provide gifts, meals or entertainment, you must ensure TO GOVERNMENT OFFICIALS
that your expense reports and records accurately reflect the Dealing with Government Officials requires special attention.
associated cost. Under no circumstances may nVent employees offer gifts,
meals or entertainment to any Government Official without
proper authorization, as outlined within our Anti-Bribery and
GIVING AND ACCEPTING GIFTS
Corruption Policy and related procedures.
Lavish spending on business gifts is unacceptable. It can
For more information, see our Conflicts of Interest, Gifts
create the perception that we are trying to obtain or give
and Entertainment; Anti-Bribery and Corruption; and
favorable business decisions by providing individuals with
Procedures Governing Interactions with Government
personal benefits. Whether we are the giver or recipient, to
ensure we do not create a perception of impropriety, gifts Officials policies on mynVent.

and entertainment must be:

• Infrequent and not excessive in value

• Directly related to building customer or supplier relationships

• Never in cash Gift Reporting Guidelines:

• Never tied to a potential contract or business tender All gifts exceeding the monetary limits specified
within the Conflicts of Interest, Gifts and
• Logo items whenever possible Entertainment Policy must be reported to
www.nVentEthics.com for pre-approval.
• Reported in accordance with our Conflicts of Interest, Gifts
and Entertainment Policy The gift report will be routed to the appropriate
business HR and legal representatives for approval.

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Q&A
Q: I was invited to a golf outing sponsored by one of
our suppliers. Several industry leaders will be
there. Can I attend?

A: Because this outing is business-related, you could

attend with your manager’s approval. However, if
a contract is currently under negotiation with the
supplier, you should discuss with your manager
whether or not it is appropriate for you to attend.

Q: Over the course of a year I typically receive

multiple tickets to sporting events from one of my
large vendors. Is it acceptable for me to receive
these tickets?

A: If you receive multiple gifts from a single person

or entity over the course of a year, they must be
reported if, in aggregate, the total value exceeds the
thresholds set forth in the Conflicts of Interest, Gifts
and Entertainment Policy. You can report these gifts
at www.nVentEthics.com. Regardless of value, you
should always use good business judgment and
report the gifts to your manager.

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DOING BUSINESS WITH INTEGRITY
nVent’s reputation depends on doing business honestly. We forbid bribery, believe in fair
competition, and respect the laws of international trade.

ANTI-BRIBERY INTERNATIONAL TRADE

At nVent, we compete solely on the basis of our product/ nVent is committed to compliance with all applicable
service quality, pricing and reputation. We forbid offering or international trade laws and regulations, including those
accepting bribes or other unlawful payments as a way to get governing the imports and exports of goods, software,
new business or to retain existing business. Bribes can take technology, technical data and services across national
many forms, including: borders, and compliance with economic sanctions.

• Money, gifts or gratuities Imports and Exports of Goods, Services and Data
International trade controls may apply to any import or
• Kickbacks
export activity, including transmission of electronic data.
• Unwarranted rebates or excessive commissions
Trade Controls and Political and Economic Sanctions
• Unusual or disguised allowances, expenses, or political
Various government trade controls and sanctions restrict
or charitable contributions
nVent from directly or indirectly engaging in trade with certain
• Offering jobs to customers, their family members or friends countries, entities, vessels and persons. As a multinational

• Anything else of value corporation, we are required to comply with trade controls
and sanctions. We must also screen transactions and
Bribery is prohibited not just for all nVent employees, but also
business partners against all relevant watch lists and report
for third parties that conduct business on our behalf. In short, if all boycott requests to a manager or the International
we can’t do it, neither can they. You are required to know your Trade Compliance team.
business parties and not do business with those who pose
International laws related to trade sanctions and boycotts are
unreasonable corruption risk to nVent. If you are unsure whether
complex and can be confusing. If you are unsure of what to do,
a business partner poses unreasonable corruption risk to nVent, Speak Up. Seek legal guidance from nVent’s Legal Department
go to the Compliance Portal and complete the Third-Party Risk when faced with an unclear trade sanction or boycott situation.
Management Screening Process. And, as always, exercise
For more information, see our Anti-Bribery & Corruption
your best judgment, ask questions and be alert to any and all
Policy, Procedures Governing Interactions with Government
red flags.
Officials, and Other Third Parties, and International Trade
Policy on mynVent.

DEALING WITH GOVERNMENT OFFICIALS

Dealing with Government Officials requires special attention.
Under no circumstances may nVent employees offer gifts,
meals or entertainment to any Government Officials without
proper authorization, as outlined within our Anti-Bribery and
Corruption Policy and related procedures.

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Q&A
Q: What “red flags” should I watch for when dealing with third parties?

A: Watch for anything that makes you doubt your agent or other third party’s credibility or intention to comply
with the anti- bribery laws. This includes close relationships with the government, undisclosed subagents
or subcontractors, undue secrecy, being told “not to ask,” inflated invoices or unusual rebates, unexplained
expense reports, unusual payments (to third parties or in third countries), off-books accounts or “slush
funds,” or anything else that is not quite right. Never be afraid or reluctant to challenge something that does
not make sense to you or that appears suspicious. Don’t simply accept claims that “this is how we do it here.”
Always report your concerns to nVent’s Legal Department promptly.

Q: One of our suppliers has recently begun to deliver sub par product. However, our purchasing manager
has not done anything about it because the supplier gives him 1% of all sales under the table.

A: Speak Up. The manager’s behavior, as well his relationship with the supplier, is improper and against nVent
policies. Receiving a kickback or accepting any personal benefit from a third party in exchange for favorable
treatment is a violation of the Code of Business Conduct and Ethics and is potentially a violation of the law.
See Speak Up resources on page 6.

Q: We were recently bidding on a project to do work on an oil pipeline and were told that the project would
only be awarded to us if the customer could visit our plant in the United States and bring his family for a
stopover at Disney World. Winning the project would mean a lot of money for the company, and the trip
expenses would be relatively small by comparison. Should we do this?

A: Whereas the plant visit may be acceptable, the trip to Disney World is not permitted and is a form of bribery.
Under no circumstance should we pay for a customer’s family members to travel with him or her or for a trip
to Disney World or any other destination unrelated to nVent’s business.

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FAIR COMPETITION Q&A
nVent is committed to a fair global market. In all dealings Q: I ran into a salesman from one of our
with our competitors, customers and suppliers, we must act competitors at a business lunch last week and
honestly, impartially and in compliance with fair competition we started swapping stories about how hard it’s
laws and regulations. Employees working in marketing, sales, been to make quotas this year. He hinted that,
purchasing, or acquisitions must be especially aware of the since we are both likely to respond to a lot of the
applicable laws and regulations in the countries where same requests for proposals, we’d have a better
they do business. Violations of fair competition laws may chance of meeting our quotas if we both agreed
carry significant penalties for our company and for the in advance to carve out certain territories. This
individuals involved. arrangement would make sense, wouldn’t it?

Given the complexity of competition laws and regulations, you A: No. When competitors agree in advance to allocate
should contact nVent’s Legal Department for guidance if you bids, customers or markets or to set production
have questions about potential fair competition issues. amounts, they are violating fair competition laws,
For more information, see our Antitrust Policy which could lead to significant penalties.
on mynVent.
Q: I work at one of nVent’s U.S. facilities and
frequently deal with foreign customers to answer
questions and provide technical support. Are my
e-mails to these individuals considered exports
In the spirit of fair competition, nVent employees
under the law?
must avoid:

• Price Fixing: Competitors coordinating prices instead of A: This could be a violation of international export
competing freely and independently against one another laws. Before sending technical data via e-mail to
a foreign jurisdiction, consult with a member of
• Dividing Territories: Competitors agreeing to divide
the International Trade Compliance team or
customers, products or geographical areas in which they
Legal Department.
will not compete against one another, including agreeing
on quota limits or market share

• Bid Rigging: Competitors agreeing to coordinate bids or

engaging in collusive tendering

• Abuse of Dominant Market Power: Abusing a large

market share position to engage in practices that normally
would be difficult or impossible with stronger competition
(e.g., the ability to maintain prices above normal
competitive levels or to impose sales conditions that
customers would not otherwise accept)

The laws governing fair competition can be complex.

Consult with a member of the nVent Legal Department if
you have questions regarding specific business practices.

18
“
At nVent, we succeed
by maintaining the
highest level of integrity

”
through open, honest
and fair dealings.
­
— Beth Wozniak
Chief Executive Officer
nVent

19
FINANCIAL INTEGRITY
nVent is committed to having honest, accurate and timely financial records and dealings.
The company prohibits any action that may obscure our financial activities from our stakeholders.

FRAUD If we learn that we have made a financial error that affects a

customer or supplier, we must proactively disclose the error
As nVent employees, we are expected to be truthful and
and correct our mistake.
forthright in all interactions and communications. Engaging
in fraud, which is the act of intentionally cheating, tricking, Adherence to these standards protects us and our company
stealing, deceiving or lying, is dishonest and generally criminal. from fines and other serious legal consequences.
Intentional acts of fraud are subject to strict disciplinary action.
It’s important to understand what fraud entails so you can
BUYING AND SELLING STOCKS — INSIDER TRADING
recognize and avoid it. Examples of fraudulent activity include:
We are committed to maintaining a fair market for buying
• Submitting false expense reports
and selling company stock. nVent’s Policy and relevant laws
• Forging or altering checks prohibit all of us from buying and selling nVent stock or any
• Misappropriating assets or misusing company property other kind of public security based on inside information.

• Inflating sales numbers by shipping inventory known to be It is also illegal and unethical to provide such information about
defective or non-conforming nVent to other individuals or companies so that they may gain.
We are also prohibited from trading in stock or other securities
• Making an entry in company records that is deliberately
of customers and suppliers based on inside information.
not in accordance with proper accounting standards
In the course of your work at nVent, you may learn material,
non-public information about nVent or other companies that
FINANCIAL ACCOUNTING, RECORDKEEPING could affect a decision whether or not to buy, sell or hold
AND REPORTING securities. If you trade securities while you have this material,
nVent’s financial accounting, recordkeeping and reporting non-public information, it violates insider trading laws.
policies require all of us to demonstrate the highest standards For more information, see our Insider Trading Policy on
of honesty and transparency. All of nVent’s financial records mynVent.
must be:

• Complete and accurate

• Properly documented

• Fair and objective

• Shared only with proper authorization

20
Q&A
Q: I’ve noticed that our payroll manager has added employees to the system, but I haven’t seen them appear
on the new hire list. I suspect that the payroll manager may have created false employee names and may be
routing the employee paychecks to his personal account. What should I do?

A: When something does not look right, such as company records that don’t appear accurate, you should Speak Up.
Concerns regarding fraud should never go unreported. See page 6 for Speak Up resources.

Q: A colleague saw our boss out with her family at a new restaurant in town last Saturday night. The following
Monday, my boss handed me a receipt from the very same restaurant for Saturday night and told me she was
expensing the meal as a business dinner. This doesn’t look right to me, but I’m afraid I’ll get in trouble if I
refuse to put the receipt on her expense report. What should I do?

A: You should immediately alert the company to your suspicion that your boss is seeking reimbursement for
non-business expenses. We understand that it takes courage to report your superior, but it’s important to Speak Up
see page 6. Please know that nVent’s Non-Retaliation Policy protects employees from retaliation of any kind.

Q: What is considered inside information?

A:  Inside information is any information that is not publicly known that could influence a decision to buy or sell stock.

Q: I work in the Maintenance Department and overheard a conversation today in the lunchroom where I learned
that nVent is just days away from closing on a major acquisition. Can I call my parents and tell them to buy
nVent stock?

A: Informing your parents of the acquisition prior to it becoming public knowledge is against nVent Policy and against
the law. This action is considered insider trading. All inside information regarding our company that is not public
knowledge must be kept confidential.

21
PROTECTING AND MANAGING PROPERTY,
INFORMATION AND RECORDS
Our physical assets and intellectual property are vital to nVent’s business, and we have a duty to
protect them. We must manage company records responsibly and protect private records and
proprietary information, whether they belong to our company, business partner, customer or employee.

PHYSICAL ASSETS AND COMMUNICATION SYSTEMS

Each of us is responsible to help ensure that nVent’s physical property,
including our buildings, vehicles, equipment, information systems and These are some examples of proprietary
supplies, is not damaged or misused. information that you may come across in
your role at nVent:
nVent’s communication systems, including those for e-mail and our
company-provided Internet, are the property of nVent and must be • Company financial information
used appropriately and legally. We should not access, download, • Customer lists and agreements, market share
store or distribute any material that is illegal, offensive or could data and supplier agreements
reflect negatively on nVent’s image and reputation. Each of us must
• Drawings for current or potential new products
also exercise discretion and use care when drafting and responding to
e-mails to ensure that our communications are professional • Financial information about potential acquisitions
and appropriate. • Intellectual property such as trademarks, patents
All communications, data and information sent or received using and copyrights
company property while you are employed at nVent are company Here is how you can help protect proprietary
property and are not private communications. nVent owns and/ information:
or controls access to all communications equipment, including
• Log out, shut down or lock your computer
computers, software, e-mail, voice mail, conferencing equipment and
before leaving it unattended.
office supplies. Where permissible, nVent reserves the right to monitor
all communications, including Internet usage, and employees should • Don’t let others use your passwords or

not consider such communications to be personal or private. access cards.

• Do not allow unauthorized individuals into

nVent’s facilities or buildings.
PROPRIETARY INFORMATION AND
• Make sure visitors are accompanied in
INTELLECTUAL PROPERTY
work areas where proprietary information
nVent’s business, technical and financial information is very valuable may be available.
and must be protected. As nVent employees, we must maintain the
• Don’t leave proprietary information out in the
confidentiality of our intellectual property and confidential information.
open in your work area, in a conference room
We all have a responsibility to protect the intellectual property or
or on a printer or fax machine.
confidential information of customers, vendors or others who provide
such information to us under nondisclosure or similar agreements • Do not download or install unauthorized
and a responsibility to use the information only for the purposes for software or freeware on your computer.
which we have agreed.

Any technical innovations, discoveries, system designs, or technical

enhancements conceived or authored by an employee of nVent are
the sole property of, and must be disclosed to, the company. You may
not disclose such intellectual property or other nVent confidential
information to others even after you leave the employment of nVent.

22
RECORDS MANAGEMENT Q&A
Our records are valuable assets that contain information about Q: More than once I’ve walked by a colleague’s
nVent’s businesses, initiatives, operations and history. nVent work area while she was at lunch and noticed
employees must maintain accurate and complete records (in hard confidential drawings of a prototype displayed
copy or electronic media). We also must comply with recordkeeping across her computer monitor. What should I do?
requirements, discard records no longer needed for legal or
A: Your colleague is making a common mistake. By
operational reasons in accordance with the company’s records
leaving her workstation open, your colleague runs
schedules, and suspend the destruction of records as instructed by
the risk of losing proprietary information. Speak
the Legal and Tax Departments because of litigation, government
with her regarding the behavior. If the behavior does
investigation or audit.
not change, Speak Up see page 6 and raise the
concern with your manager.
DATA PRIVACY
Q: I found a copy of the company’s recent earnings
We are expected to respect the privacy and protect the data of our
statement in the copy room. It was labeled
customers, suppliers and employees. We will collect, process, store
CONFIDENTIAL: NOT READY FOR DISTRIBUTION
and transmit such data lawfully, for proper business purposes only,
across the top of the statement. What should
and maintain appropriate safeguards to prevent unauthorized use or
I do?
disclosure of the data.
A: The earnings statement contains sensitive,
For more information, please see nVent’s Privacy Policy and
proprietary information that must be protected.
Standards on mynVent.
Do the right thing and bring the statement to your
manager. You should not discuss the information
EXTERNAL COMMUNICATIONS with others within your business or outside of

It is the company’s Policy to communicate openly and actively the company.

with the news media and investment community. We recognize

Q: I was approached by a reporter who heard me
nVent’s responsibilities as a public company to provide complete,
talk at a local conference on outsourcing certain
timely, accurate and objective information about its financial and
product lines to other countries. Would it be
operational performance, as well as its strategy and prospects.
wrong for me to share my disagreement with the
For more information, see our Records Management Policy, company’s position on outsourcing with
Personal Data Protection Policy, Global Employee Notice, the reporter?
and External Communications and Disclosure Policy on
A: While your response to the reporter may be your
mynVent.
own opinion, you need to be sure that all media
inquiries are referred to a company designated
media relations representative. You should not
respond to the reporter on behalf of nVent.

23
SPEAK UP TO ETHICS HELPLINE
If you know of or suspect any illegal or unethical behavior, you should report the concern
via the Ethics Helpline or www.nVentEthics.com. To report over the phone, use the toll-free
number that is designated for your country below.

HelpLine Numbers are Available 24 hours/7 days a week.

Country Type Number Country Ty pe Number

United States Toll Free 800-472-8868 India Toll-Free 000-800-100-3273

DTFS (Calling Codes) Indonesia Mobile 007-803-011-4437

Chile Group/Covered 800-472-8868 Italy Toll-Free, Mobile Enabled 800-787-115

Czech Republic Group/Covered 800-472-8868 Kazakhstan Toll-Free 8-800-333-3512

Russia Group/Covered 800-472-8868 Mexico Toll-Free 1-800-083-1038

Saudi Arabia Group/Covered 800-472-8868 Netherlands Toll-Free, Mobile Enabled 0800-023-1198

United Arab Emirates Group/Covered 800-472-8868 Norway Toll-Free 800-1-5421

Turkey Group/Covered 800-472-8868 Poland Toll-Free 00-800-111-3997

Shared Lines Romania Toll-Free, Mobile Enabled 0-800-895-995

Australia National 1-800-987-636 Singapore National 800-1301-147

Austria National 0800-297-407 Spain Toll-Free, Mobile Enabled 900-977-663

Belgium Toll-Free, Mobile Enabled 0800-71-720 Sweden Toll-Free, Mobile Enabled 020-793-185

Brazil Toll-Free, Mobile Enabled 0800-891-5884 Switzerland Toll-Free, Mobile Enabled 0800-562-684

China National 400-120-9077 Thailand National 00-1800-132-040-052

Finland Toll-Free 0800-9-15443 United Kingdom Toll-Free 0800-032-5546

France Toll-Free 805 0800-909-260 Lithuania Toll-Free 8-800-30868

Germany Toll-Free, Mobile Enabled 0800-182-4524 Japan Mobile 0800 0800-919-5833

Hong Kong Toll-Free 800-903-282 Dedicated Lines

Hungary Toll-Free 06-800-13508 South Korea Toll-Free 080 0030-813-1350

24
OFFICE OF BUSINESS
CONDUCT AND ETHICS
1665 Utica Ave., Suite 700
Minneapolis, MN 55416
Tel +1.800.472.8868

[email protected]
nVentEthics.com

Code - 18 - English