Code of Ethics

Trust. Respect. Integrity.

 Our Commitments
UTC’s Commitments define who we are and how we work. They focus our businesses and move
us forward.

Performance Opportunities

Our customers have a choice, and how we Our employees’ ideas and inspiration create
perform determines whether they choose us. opportunities constantly, and without limits.
We aim high, set ambitious goals and deliver We improve continuously everything we do,
results, and we use customer feedback to as a company and as individuals. We support
recalibrate when necessary. We move and pursue lifelong learning to expand our
quickly and make timely, well-reasoned knowledge and capabilities and to engage
decisions because our future depends on with the world outside UTC. Confidence
them. We invest authority where it needs to spurs us to take risks, to experiment, to
be, in the hands of the people closest to the cooperate with each other and, always, to
customer and the work. learn from the consequences of our actions.

Innovation Responsibility

We are a company of ideas that are Successful businesses improve the human
nurtured by a commitment to research condition. We maintain the highest ethical,
and development. The achievements of environmental and safety standards
our founders inspire us to reach always everywhere, and we encourage and
for the next innovative and powerful and celebrate our employees’ active roles in
marketable idea. We seek and share ideas their communities.
openly, and value differences in experiences
and opinion.
Results

We are a preferred investment because

we meet aggressive targets whatever the
economic environment. We communicate
honestly and forthrightly to investors, and
deliver consistently what we promise. We
are a company of realists and optimists, and
we project these values in everything we do.
£
CEO Message
One world. One code. One set of values.

Dear UTC Colleagues,

At United Technologies, we demand high performance and high integrity from all of our
employees as well as everyone with whom we do business. It is never acceptable to sacrifice
our integrity or values to achieve business success. We are a company committed to always
doing the right thing. No exceptions.

UTC’s Code of Ethics establishes clear expectations for our employees, contractors, suppliers,
vendors and third-parties on how to conduct business in a compliant and ethical manner.
Our Code of Ethics requires, at a minimum, that legal requirements must be satisfied,
financial statements must be complete and accurate, and customers and other stakeholders
must be treated fairly – always.

We understand that our customers have choices – and how we perform determines whether
they choose to do business with us. If you have a question or concern regarding the UTC
Code of Ethics, speak to your supervisor, human resources manager, an Ethics & Compliance
Officer or the legal department. Please know that when reporting suspected violations of our
Code of Ethics in good faith, you will be fully protected should anyone seek to retaliate
against you for doing so. Of course, if you prefer to raise an issue confidentially, you may
always do so by contacting one of our Ombudsman.

Thank you for your personal commitment to upholding the values set forth in our
Code of Ethics.

Sincerely,

Gregory J. Hayes
President & Chief Executive Officer
Table of Contents
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Our Principles — How We Make Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
Our Standards of Conduct — How We Perform . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-15
1. Quality & Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2. Marketing & Selling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3. Protecting Information Belonging to Others . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
4. Protecting Company Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
5. Accuracy of Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
6. Government Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
7. Equal Employment Opportunity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
8. Workplace Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
9. Employee Privacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
10. Employee Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
11. Employee Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
12. Compensation & Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
13. Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
14. Securities Trading & Release of Material, Nonpublic Information . . . . . . . . . . . . . 11
15. Representatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
16. Partners & Suppliers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
17. Shareowner Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
18. Protecting the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
19. Community Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
20. Involvement in the Political Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
21. International Trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
22. Antitrust Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
23. Local Laws & Customs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
24. Citizenship and Human Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Our Code of Ethics — How We Comply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16-17
Complying With this Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Asking Questions & Raising Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16-17
Implementing Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19-20

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Overview
The UTC Code of Ethics applies to UTC and its controlled entities, worldwide. In addition to
stating rules that govern our actions, the Code is an expression of fundamental values and
represents a framework for decision-making. The Code is further explained and implemented
by Code Supplements and by policies contained either in the Corporate Policy Manual or the
Financial Manual.

The underpinnings of ethical business practices at UTC are the following:

We will obey the law.

We will act in good faith.
We will consider the impact of our decisions on our stakeholders and seek fair resolutions.
We will communicate openly and effectively with our stakeholders.
We will seek always to build trust, show respect, and perform with integrity.

The integrity, reputation and profitability of UTC ultimately depend upon the individual actions
of our directors, officers, employees and representatives, all over the world. Each is personally
responsible and accountable for compliance with this Code.

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Our Principles — How We Make Decisions
UTC is committed to the highest standards of ethics and business conduct.

UTC complies with the law, honors its commitments, acts in good faith, maintains its values, seeks to advance
the interests of stakeholders, communicates openly and effectively, and holds itself accountable.

In seeking positive outcomes, UTC’s process for decision-making includes the following steps:
(1) involving the right people, (2) understanding the facts, (3) understanding the legal
requirements, (4) considering the duties owed to stakeholders and the impact of alternative
decisions, (5) comparing alternatives with reference to company values, (6) making a tentative
decision that is lawful and seems best; and (7) asking “Should I?”

For UTC, ethical behavior is built on trust, respect, and integrity.

Trust is the bedrock of business ethics at UTC, because business is built on reciprocity, mutuality
and predictability, and trust is destroyed by deception, cheating, and the failure to keep
commitments. Respect is demonstrated by communicating openly, listening receptively to the ideas
of others, and treating others with dignity. Integrity is a concept of uncompromising adherence to
the Code of Ethics and coherence among actions. Integrity is reflected through honesty,
accountability, and by applying sound methods to address business issues.

At UTC, ethics is the foundation of our performance culture.

PERFORMANCE

The most basic element to success is an Ethical Culture.

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Our Customers Our Shareowners
We will provide high quality and value, We will work to provide a superior return to
competitive prices, and honest transactions our shareowners. We will safeguard the value
to those who use our products and services. of their investment through the prudent use
We will deal lawfully and ethically with and protection of corporate resources, and by
our customers. observing the highest standards of legal and
ethical conduct in all our business dealings.

Our Employees
We will treat employees fairly and use Our Competitors
employment practices based on equal We will compete vigorously, independently
opportunity for all employees. We will and fairly, basing our efforts on the merits
respect the interests of employees in of our competitive offerings.
privacy and treat employees with dignity
and respect. We are committed to providing
safe and healthy working conditions and Our Communities
an atmosphere of open communication
We will be a responsible corporate citizen
for all our employees.
of the communities worldwide in which we
operate. We will abide by all national and
local laws, and we will strive to improve the
Our Suppliers and Partners well-being of our communities through the
We will deal fairly with our suppliers and protection of natural resources, through the
partners. We will seek long-lasting business encouragement of employee participation in
relationships, without discrimination or civic and charitable affairs, and through
deception. corporate philanthropy.
Our Standards of Conduct — How We Perform
The following standards of conduct define our minimum expectations for ethical behavior.
Because these standards cannot anticipate the particular facts of every situation, they must be
interpreted and applied within the framework of the laws and mores of the jurisdictions in which
we operate, as well as in light of UTC’s Commitments, Principles, Code Supplements, policies, and
good common sense. Reasons such as “everyone does it” or “it’s not illegal” are unacceptable
excuses for violating these Standards. We must be mindful of avoiding at all times, on and off the
job, circumstances and actions that give even the appearance of impropriety or wrongdoing which
could discredit UTC.

1. Quality & Safety

UTC’s products must be designed, produced All persons acting on behalf of UTC will
and delivered with the primary consideration abide by the laws relating to improper
of the safety and health of our customers, payments. Sales and marketing services
product users, employees, and others who performed by third-parties outside the United
may be affected. States must comport with UTC’s policy
entitled “Non-U.S. Sales Representatives.”
UTC operating units have the responsibility
to design, manufacture, and deliver quality Business gifts that are customary and
products. All required inspection and testing reasonable in frequency and value are
operations must be completed properly. permitted, generally. A gift is never
permitted if intended in exchange for
These standards are reflected in UTC’s policies favorable treatment or if prohibited
entitled “Quality Assurance Programs” and by the policies of the recipient or
“Product and Services Safety Program.” his/her employer.

UTC will not offer or pay any bribe.

2. Marketing & Selling
These issues are addressed in the
UTC will compete in the global marketplace
Code Supplement entitled “Giving
on the basis of the merits of our products
and Receiving of Business Gifts.”
and services. We will sell our products and
services honestly and will not pursue any
sale that requires us to act unlawfully or in
violation of these standards.

In making comparisons to competitors,

care must be taken to avoid disparaging a
competitor through inaccurate statements.

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3. Protecting Information Belonging
to Others
UTC respects the legitimate proprietary rights QUESTIONS AND ANSWERS...
and trade secrets of our customers, suppliers, and
third parties. UTC will solicit, accept, use, and
Q: Why is product safety so important?
disclose proprietary information belonging to
others only in conformity with UTC’s policies on
A: Working to avoid physical harm to
“Proprietary Information Protection” and
others is a core value. It’s that simple.
“Software License Compliance.”

Q: Why is bribery wrong?

In the highly competitive global marketplace,
gathering information about our competitors and
competing products and services is a necessary A: Bribery is unlawful everywhere,
and routine element of business. In gathering because it destroys the duty of
competitive information, UTC will not utilize any loyalty and destroys trust. Moreover,
improper means such as theft or deception. bribery disrupts the operation of the
See UTC’s Code Supplement entitled “Gathering global, market-based economy,
Competitive Information.” because bribery displaces decisions
that otherwise would be based on
the merits, such as quality and price.
Personal information collected from customers,
UTC wins on the basis of innovation
suppliers and other visitors to UTC’s internet and
and productivity and therefore wins
other sites will be protected in accordance with
when markets operate effectively
UTC’s policy entitled “Privacy of Personal
and efficiently.
Information Collected Online.”

4. Protecting Company Assets IN BRIEF...

UTC’s assets, including tangible assets (such
as facilities, money, equipment, and information • We design, manufacture, and service
technology systems) and intangible assets (such our products so that the rest of the
as intellectual property, trade secrets, invention world can depend on them.
disclosures, sensitive business and technical
information, computer programs, and business • We compete on the merits.
and manufacturing know-how) will be used
properly and as authorized by management. • We sell our products and services
UTC’s assets will not be used for personal gain. honestly.
All business transactions must be authorized by
management and comply with delegations of • We protect UTC’s assets.
signature authority and processes for internal
review and approval.
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Our Standards of Conduct — How We Perform
Additional guidance is contained in 6. Government Procurement
applicable UTC intellectual property UTC will comply with procurement laws and
agreements, UTC’s policy on “Proprietary rules as they apply to UTC’s business with
Information Protection,” and UTC’s governments around the world.
Corporate Policy Manual and Financial
Manual.
UTC takes special care to comply with
the unique and special rules that apply to
contracting with the U.S. Government. At
5. Accuracy of Records all times, UTC will follow the Government’s
All assets, liabilities, revenues, expenses, rules for competing fairly, will honor
and business transactions must be completely restrictions applying to Government
and accurately recorded on UTC’s books employees (e.g., gifts and employment),
and records, in accordance with applicable will deliver products and services that
law, accepted accounting principles, and conform to specifications, will adhere to
established UTC financial policies and government accounting and pricing
procedures. Budget proposals and economic requirements, will claim only allowable
evaluations must fairly represent all costs, and will ensure the accuracy of
information relevant to the decision being data submitted.
requested or recommended. No secret or
unrecorded cash funds or other assets will be The UTC “Policy Statement on Business
established or maintained for any purpose. Ethics and Conduct in Contracting With the
United States Government” contains
UTC will advise customers and suppliers specific guidelines and requirements.
of errors and promptly correct the error
through credits, refunds or other mutually
acceptable means. 7. Equal Employment Opportunity
UTC will treat employees and applicants
The retention and proper disposal of for employment fairly, based only on factors
records and data shall be in accordance related to UTC’s legitimate business interests.
with the UTC policy entitled “Retaining UTC’s policy entitled “Equal
Records and Data” and applicable Employment/Affirmative Action” contains
legal requirements. guidelines and requirements.

UTC strives to assure that it has an enduring

competitive advantage in the quality and
talent of its workforce, and UTC supports
initiatives that foster workforce diversity,
as described in its policy entitled
“Managing Workforce Diversity.”

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8. Workplace Environment
UTC is committed to providing its employees a
workplace that is free from known safety and QUESTIONS AND ANSWERS...
health hazards, and a work environment free
from discrimination, harassment, or personal Q: Why is UTC so insistent on
behavior not conducive to a productive accurate records?
work climate.
A: Inaccurate records don’t tell the
All UTC entities worldwide will abide by story of performance. UTC is
applicable laws and regulations regarding committed to performance.
possession or use of alcohol, drugs, and other
Q: How does government business
controlled substances.
differ from commercial business?

Subject to local law, and subject to approval A: Governments spend public money
by the Human Resources Department (at UTC and thus have layers of highly
Corporate, one of the major UTC Business prescriptive and detailed rules.
Segments, or a business unit reporting directly These rules are intended to assure
to either), local management has authority to fairness in bidding, fairness in
make decisions regarding the serving of alcohol pricing, and standards of quality.
Generally, business arrangements
on UTC premises. UTC prohibits employees
with governments are less flexible
and others from being intoxicated while on
than commercial dealings, and the
company premises. penalties for a breach of the rules
can be severe. UTC honors
UTC prohibits the use, sale, purchase, governmental rules and works to
transfer, possession or presence in one’s uphold public trust.
system of controlled drugs while on company
premises. This prohibition, of course, does not
apply to drugs which are medically prescribed IN BRIEF...
and used lawfully.
• We keep accurate and complete records.

• We strictly follow the special rules of

government procurement.

• We treat each other fairly and

with respect.

• We relentlessly pursue workplace safety.

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 Our Standards of Conduct — How We Perform
Employees with problems such as alcoholism, employee survey, which is generally
drug dependency, or other serious personal conducted every other year and which
and emotional problems will receive solicits input on a wide range of subjects,
opportunities for assistance and treatment. such as compensation, management’s
performance, and business ethics.
Additional information is included in
UTC’s policy entitled “Drug, Alcohol and
Substance Abuse.” Opportunities for 11. Employee Development
assistance and treatment are outlined in the UTC is dedicated to promoting employee
“Employee Assistance Programs” policy. development through assistance in improving
and broadening work-related skills and
lifelong learning. Over and above traditional
9. Employee Privacy learning and training opportunities, UTC
UTC respects the privacy interests of promotes employee development through
its employees. the “Employee Scholar Program.” Under
this program, UTC pays certain costs for
UTC will comply with applicable laws in eligible employees pursuing a degree from a
all jurisdictions where UTC collects, uses, UTC-approved institution. Additional
or discloses employee personal information. information and details regarding conditions
Additional information is contained in the and limitations are included in UTC’s policy
UTC policy entitled “Employee Personal entitled “Employee Scholar Program.”
Information.”

Personal conduct, unrelated to UTC, is not 12. Compensation & Benefits

UTC’s concern, unless such conduct impairs UTC will attract, motivate and retain
the employee’s work performance or affects competent, dedicated people by designing
the reputation or other legitimate business compensation and benefits programs that are
interests of UTC. competitive in our worldwide marketplaces.

10. Employee Communications 13. Conflicts of Interest

UTC will provide its employees with UTC’s directors, officers, employees, and
timely information on business results, representatives must be loyal to UTC and
product performance, customer relations, deal with suppliers, customers and others in a
and employee achievements. Communication manner that avoids even the appearance of a
channels will be provided that encourage conflict between personal interests and those
self-expression and open discussion relative of UTC. UTC’s policy entitled “Conflicts of
to employee opinions, attitudes, and concerns. Interest” further defines conflicts, provides
One channel of communication is the guidance on specific subjects, and identifies

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processes for resolving possible conflicts. UTC’s
coverage includes the following:

The direct or indirect financial or stock QUESTIONS AND ANSWERS...

ownership interest in UTC suppliers,
customers, or competitors; Q: How does UTC protect
employee privacy?
Seeking or accepting gifts or any form of
compensation from suppliers, customers
A: Personal information is protected by
or others doing business, or seeking to
UTC as “Company Private”,
do business with UTC (see the Code meaning that we safeguard it against
Supplement entitled “Business Gifts improper use or disclosure, and we
from Suppliers”); require our contractors to do the
same. We notify employees of the
Directorships, employment by, or
general purposes for which we
voluntary service rendered to another
collect and use personal information,
company or organization; and their options for limiting its use.
A transaction between UTC and a UTC UTC collects, uses, discloses, and
board member, executive officer, significant transfers personal information
consistent with the notice.
shareowner, or a transaction between UTC
and an immediate family member of a
Q: Why does UTC care about gifts
UTC board member, executive officer, or
received by employees?
significant shareowner; and

The personal use of corporate assets A: Gifts from those who seek or do
(including, for example, tangible property, business with UTC could influence an
proprietary information, non-public employee’s decisions or actions. By
information, or business opportunities). obtaining clearance from the business
practices office, problems are avoided.
Actual and potential conflicts must be disclosed
to UTC for review. When in doubt, seek
guidance from the Business Practices office. IN BRIEF...

• We communicate honestly with

14. Securities Trading & Release of all stakeholders.
Material, Nonpublic Information
• We support and pursue lifelong learning.
UTC’s directors, officers, employees and
representatives must maintain the • We are loyal to UTC and avoid
confidentiality of material, nonpublic conflicts of interest.
information (which is understood as
information not disclosed by UTC and which • We appropriately use and
a reasonable investor would consider important protect information.
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 Our Standards of Conduct — How We Perform
in making an investment decision). Such UTC seeks to maximize opportunities for
information will be disclosed only through small, small disadvantaged, minority-owned,
designated spokespersons, who typically woman-owned, veteran-owned, and
would be the most senior UTC officers. historically underutilized businesses to serve
as suppliers and subcontractors, in accordance
UTC’s directors, officers, employees and with its policy entitled “Contracting with
representatives (and their immediate family Diverse Businesses.”
members) must not buy, sell or otherwise
trade securities while aware of material,
nonpublic information. 17. Shareowner Communications
UTC will comply with all laws, rules, and
Specific guidance is included in UTC’s policy regulations regarding the public disclosure of
entitled “Securities Trading and Release of business information. All periodic reports,
Material Nonpublic Information.” filings, and public communications, whether
oral or written, must be full, fair, accurate,
timely, and understandable, with no material
15. Representatives omissions. All public disclosures will be made
All representatives (in addition to directors, in accordance with UTC’s policies on,
officers, or employees) of UTC must act on “Securities Trading & Release of Material
behalf of UTC in a manner consistent with Nonpublic Information,” “Disclosures to
the Code. Investors Under U.S. Securities Laws,” and
“Maintenance of Corporate Governance and
UTC will not use any representative to Financial Data.”
circumvent standards of conduct described
in this Code.
18. Protecting the Environment
UTC will conduct its worldwide operations
16. Partners & Suppliers in a manner that safeguards the natural
UTC purchases equipment, supplies and environment. All required permits will be
services on the basis of merit. UTC’s partners, obtained; the terms of all permits will be
suppliers, vendors and subcontractors will upheld; and efforts will be made to minimize
be treated with fairness and integrity and waste. All entities will conduct their
without discrimination. operations, and design and manufacture their
products, in conformance with the principles
contained in UTC’s policy entitled
Those who deal with suppliers or potential
“Environment, Health and Safety.”
suppliers are subject to UTC’s policy
governing “Conflicts of Interest” and the
Code Supplement entitled “Business Gifts
from Suppliers.”

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19. Community Support
UTC supports organizations and activities of
the communities worldwide in which we reside. QUESTIONS AND ANSWERS...
We will support worthwhile civic and charitable
causes, and employees are urged to participate
Q: Why does UTC uphold stringent
personally. See UTC’s policy entitled
environmental standards, worldwide?
“Charitable and Philanthropic Contributions.”

A: Performing to stringent environmental

standards is fundamental to promoting
20. Involvement in the Political Process and preserving the health of our
UTC will comply with all national, state and employees and our communities –
local laws regulating UTC’s participation in both for today and the future.
political affairs, including limitations on Accordingly, UTC sets aggressive
contributions to political parties, national targets to reduce air emissions, energy
political committees, and individual candidates. and water use, waste, and materials of
concern from our global sites, supply
Those who make contacts on behalf of UTC chain and products.
with political parties, candidates, elected
officials, or governmental officials must comply Q: How do I find the policies referenced
fully with all applicable laws and UTC policies in the Code?
(including this Code and UTC’s policy entitled
“Government Relations”). A: The UTC Corporate Policy Manual
is posted on the Business Practices
UTC will not offer or pay any bribe. home page.

UTC encourages its directors, officers and

employees to be informed voters and to be IN BRIEF...
involved in the political process. Personal
participation in political activities, including
• We do not circumvent the Code.
contributions of time or financial support, is a
personal decision and will be entirely voluntary.
• We treat suppliers fairly and with respect.

• We improve the quality of life in

our communities.

• We protect the natural environment.

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 Our Standards of Conduct — How We Perform
21. International Trade 22. Antitrust Laws
Various governments and multinational UTC will comply with the antitrust laws
organizations control the international (also known as competition laws) of every
movement of certain commodities, jurisdiction in which we do business. We
manufactured products, technical data, and will not engage in bid rigging; we will not
services, and maintain full or partial trade fix prices; we will not allocate markets; and
embargoes and economic sanctions on certain we will not abuse market power.
targeted countries, entities and individuals.
These controls may apply to imports, exports, UTC’s “Antitrust Compliance” policy
financial transactions, investments, and other contains specific prohibitions on
types of business dealings. UTC will comply communicating with competitors regarding
fully with these laws. We must remember that the marketing and sale of our products and
an export of technical data can be electronic, services. For example, we will not discuss
oral or visual, and that an export can take prices, costs, profits, or marketing strategies.
place even without technical data moving
between countries. Some countries also See also the Code Supplements entitled
prohibit or control re-export of items “Antitrust Guide for Employees” and
beyond their original destination. “European Union Competition Law Guide.”
Guidelines for participation in trade
UTC’s policy regarding “Export/Import associations are included.
Controls & Economic Sanctions”
contains specific guidance. See, also, the
Code Supplement entitled “International
Trade Controls: A Compliance Guide.”

Business entities worldwide will comply with

UTC’s policy entitled “Compliance with U.S.
Antiboycott Laws.”

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23. Local Laws & Customs
UTC is a global company serving markets
worldwide, often doing business under laws, QUESTIONS AND ANSWERS...
cultural norms, and social standards that
differ widely across regions and countries. Q: If I’m not shipping products out of
the country, do I need to worry
about rules on international trade?
UTC will abide by the national and local laws
of the countries in which we operate. If a A: Absolutely. These rules are not
conflict arises with respect to laws applicable always intuitive and can apply to
between countries, the Legal Department must email and even to conversations.
be consulted. Because the penalties can be high,
get the training you need and seek
advice from the experts. If you are
UTC will not knowingly facilitate illegal uncertain about whom to ask,
conduct or fraud by others, regardless of contact the business practices office.
local norms.
Q: Why is collusive bidding wrong?

A: Collusive bidding is cheating,

24. Citizenship and Human Rights because it denies customers their
right to buy the right product at the
UTC is committed to good citizenship and right price. Collusion also upsets the
believes that engagement with others improves workings of a market-based
economy, because it interferes with
the human condition. For our employees
decision-making that otherwise
worldwide, UTC assures safe and healthy work should be based on quality and price.
environments, based on the more stringent of UTC wins on the merits, relying on
U.S. standards, local standards, or UTC policies. innovation and productivity, and thus
UTC does not use child labor or forced labor. UTC wins when the market operates
effectively and efficiently.
For our communities worldwide, UTC works
to protect the environment, maximize the
efficiencies of our products, and reduce wastes, IN BRIEF...
emissions, energy consumption, and the use of
materials of concern. As affirmed in other • We honor the Code as more than a
sections of the Code, UTC obeys the law, set of rules. It is a guide that helps
does not discriminate in personnel practices, us deliver on our Commitments.
and does not engage in corrupt practices. In • We obey the law, perform in good
addition to its own commitments, UTC expects faith, communicate openly, and seek
direct suppliers to adopt suitable codes of fair outcomes.
business conduct. See UTC's policy entitled
• We ask questions, raise concerns,
"Corporate Citizenship."
and call attention to problems.

• Put simply, we build trust, show

respect, and perform with integrity.
15
 Our Code of Ethics — How We Comply
Complying with this Code of Ethics Asking Questions & Raising Concerns
Each director, officer, employee and Questions regarding this Code, its application
representative of UTC worldwide must to specific circumstances, and reports of actual
comply with this Code and its implementing or suspected violations can be raised to any
supplements and policies. level of the supervisory chain, the Legal
Department, a Business Practices Officer,
Managers at all levels of UTC are responsible Human Resources, or by contacting a UTC
for creating and fostering a culture of ethical Ombudsman or using DIALOG. A Global
business practices, encouraging open Business Practices Officer at a business unit,
communications, and instilling an awareness a UTC Area Business Practices Officer, or
of and commitment to this Code of Ethics. the Vice President, Global Compliance must
be consulted for any interpretive guidance to
Failure to comply with this Code or any of its be authoritative. All allegations of actual or
requirements will result in appropriate suspected violations must be referred to a
discipline, up to and including discharge. Business Practices Officer, the Legal
Discipline will be determined by the cognizant Department, or Ombudsman/DIALOG,
operating management in conjunction with unless such reporting is prohibited or
the Business Practices office, and principles otherwise restricted by law.
of fairness and equity will apply.
Since 1986, the Ombudsman/DIALOG
program has been available as an alternative
communications channel.

Ombudsman/DIALOG is confidential (by

protecting the identity of the person raising
the issue), neutral (by being the advocate
neither of management nor employees), and
independent (by operating separately from
management). In addition, through the
Ombudsman/DIALOG program, questions
or concerns can be submitted anonymously.

Note: The Vice President, Global Compliance replaced

the Vice President, Business Practices and has all
authority, duties and responsibilities previously vested
in the Vice President, Business Practices.

16
Ombudsman/DIALOG serves only as DIALOG is a companion process, which
a communications intermediary, and operates under the direct control of the
management is responsible for investigating Ombudsmen. DIALOG is a written, two-way,
concerns and for answering questions communications channel and is intended for
that are raised through the program. less complex issues. DIALOG is available
Ombudsman/DIALOG will process worldwide by mailing a paper form (which is
any business-related issue except available from DIALOG boxes located in
those subject to the provisions of a collective various work areas) or by using a secure,
bargaining agreement or those restricted by encrypted, internet-based, electronic system,
applicable law. The identity of a person using eDIALOG, (https://eDIALOG.confidential.utc.com).
Ombudsman/DIALOG will be protected To fully assure confidentiality, company
unless disclosure is compelled by a court of computers should not be used for eDIALOG
law or there appears to be imminent risk of communications.
serious harm. The Ombudsmen and the
DIALOG coordinators are guided by the Each director, officer, employee, and
Code of Ethics and Standards of Practice of representative is personally responsible for
the International Ombudsman Association raising to UTC’s attention any actual or
(http://www.ombudsassociation.org/standards/). suspected violations of this Code of Ethics,
its implementing supplements and policies,
The UTC Ombudsmen, who are trained or any law or regulation. UTC prohibits
mediators, work principally by telephone and any retribution against any person for
can be contacted worldwide by using the reporting anything he/she reasonably believes
toll-free telephone numbers appearing at the constitutes a violation or suspected violation.
end of this Code. The Ombudsmen serve as In addition, UTC prohibits any retribution
communications intermediaries on issues that against any employee who raises, in good
are more complex, such as those having legal faith, any concern with respect to policies or
implications or requiring investigation. practices used within a business. However,
the use of these communication channels to
report wrongdoing will not absolve anyone
from accountability for personal involvement
in any wrongdoing.

UTC employees and others who suspect

irregularities in company accounting, internal
accounting controls, or auditing matters, can
report these matters to UTC by using the mail,
e-mail, and toll-free numbers published on
UTC’s website at www.utc.com. Alternatively,
reports of actual or suspected violations can
be made through Ombudsman/DIALOG.

17
Our Code of Ethics — How We Comply
Implementing this Code of Ethics Waiver of all or part of this Code of Ethics,
This Code of Ethics has been adopted by conflicts of interest, or various other policies
UTC’s Board of Directors and applies issued to implement the Code will be granted
worldwide. “UTC,” as used throughout this only in exceptional circumstances and only
Code, includes UTC’s controlled entities. after approval by the UTC Vice President,
The Code applies to all directors, officers, Global Compliance. Any waivers for directors
employees, and representatives, including and executive officers must be approved by
consultants and agents. both the Vice President, Global Compliance
and the Board of Directors or a Board
committee and will be disclosed promptly as
The UTC Vice President, Global Compliance
required by law, regulation and UTC policy.
is responsible for implementing this Code
through Code Supplements, the Corporate
Policy Manual, and (working with the Finance
Department) the UTC Financial Manual.
Index
Accounting, 8, 17 Diversity, 8

Accuracy of Records, 2, 8 Drug, Alcohol & Substance Abuse, 10

Affirmative Action, 8 Elected Official, 13

Alcohol & Drugs, 10 Employee Assistance Programs, 10

Antitrust, 2, 14 Employee Development, 2, 10

Asking Questions, 2, 16 Employee Privacy, 2, 10

Assets, 7, 8, 11 Employee Scholar Program, 10

Bribery, 6, 13 Environment, Health & Safety, 12

Business Practices, 3, 11, 16, 17, Back Cover Equal Employment Opportunity, 2, 8

Citizenship, 15 Export/Import Controls &

Economic Sanctions, 14
Communities, 2, 4, 5, 13
Fraud, 15
Compensation & Benefits, 2, 10
Gifts, 6, 8, 11, 12
Competitive Information, 7
Government, 2, 8, 9, 13, 14
Conflicts of Interest, 2, 10, 11, 12, 17
Health, 4, 6, 9, 12
Corporate Governance, 12
Human Rights, 15
Corporate Responsibility - see Citizenship
Improper Payments, 6
Customers, 4, 6, 7, 8, 10, 11
Intellectual Property, 7, 8
DIALOG, 16, 17, Back Cover
International Trade, 2, 14
Directors, 3, 10, 11, 12, 13, 17
Investors, 11, 12
Disclosure, 7, 12
Involvement in the Political Process, 2, 13
Discrimination, 5, 9, 12

19
Index

Laws & Customs, 2, 15 Protecting the Environment, 2, 12

Marketing & Selling, 2, 6 Quality & Safety, 2, 6

Ombudsman/Ombudsmen, 16, 17, Records, 2, 8, 9

Back Cover
Reporting, 9, 16, 17
Partners, 2, 5, 12
Representatives, 2, 3, 6, 10, 11, 12, 17
Philanthropy, 5, 9
Retribution, 17
Political Activities, 13
Securities Trading, 2, 11, 12
Privacy, 2, 4, 7, 10
Shareowner(s), 2, 4, 5, 12
Procurement, 2, 8, 9
Suppliers, 2, 4, 5, 7, 8, 10, 11, 12, 13
Proprietary Information, 7, 8, 11
Vendors & Subcontractors, 12
Protecting Company Assets, 2, 7
Workplace Environment, 2, 9
Protecting Information, 2, 7
Contact Information
UTC Global Compliance and Business Practices

UTC Business Practices Officers are located worldwide at UTC’s businesses.

UTC Global Compliance and Business Practices Office at UTC HQ can be reached at
860.728.6485 or [email protected]

Ombudsman/DIALOG

UTC’s Ombudsmen can be contacted toll-free at 800.871.9065

When calling from outside the USA, you must first dial the AT&T Direct access code for
your country, which can be found at www.business.att.com/bt/access.jsp.

A written DIALOG inquiry can be submitted by using the forms available throughout UTC, or
electronically by a secure, encrypted internet connection at https://edialog.confidential.utc.com.

Other Information

The Code and Code Supplements are publicly available on-line at www.utc.com.
The Code, Code Supplements and Corporate Policy Manual are posted for employees on
the UTC Intranet.

For more information about UTC’s corporate responsibility, visit www.utc.com, and click
“Corporate Responsibility.”

The Code is published by UTC Global Compliance and Business Practices Office

United Technologies Corporation

United Technologies Building
Hartford, CT 06101 USA

In addition to English, this booklet is published in Arabic, Bulgarian, Chinese, Croatian, Czech,
Danish, Dutch, Estonian, Finnish, French, German, Greek, Hebrew, Hindi, Hungarian,
Indonesian, Italian, Japanese, Korean, Malaysian, Norwegian, Polish, Portuguese, Romanian,
Russian, Slovakian, Slovenian, Spanish, Swedish, Thai, Turkish Ukrainian, and Vietnamese.
United Technologies Corporation COE-EN 02/2015
United Technologies Building
Hartford, Connecticut 06101 USA