Our Integrity and Compliance Helpline
Honeywell places the
highest value on the integrity of the Company and each of its directors,
officers, employees and representatives. All directors, officers and
employees and all representatives, including all agents, consultants,
independent contractors and suppliers of Honeywell, are responsible for
complying with all applicable laws and regulations in each country in which
the Company does business and for knowing and complying with this Code of
Business Conduct and other policies of the Company. Violations of law or
this Code or other policies of the Company are subject to discipline, which
may include termination. Business units are responsible for ensuring that
their policies and practices are consistent with this Code.
The policies in this
Code apply across Honeywell, in all businesses and in all countries. If a
local law conflicts with a policy in this Code, you must comply with local
law. If a local custom or practice conflicts with a policy in this Code,
you must comply with the Code.
Your business or
region may have policies and practices that require more of you than
required by this Code; the same may be true of local law. In all of those
instances, you must follow the stricter policy, practice or law. Think of
this Code as a baseline, or a minimum requirement, which must always be
followed unless doing so would violate local law. If the applicable law
conflicts with the Code, but could permit different alternatives, you must
choose the one most closely aligned with the Code requirement. If in doubt,
contact a member of the Law Department.
this Code of Business Conduct to its employees worldwide for their guidance
in recognizing and resolving properly the ethical and legal issues they may
encounter in conducting the Company's business. The Code and its terms may
be modified or eliminated at any time by the Company. Directors, officers
and employees and other representatives of the Company are responsible for
being familiar with its contents. The most current version of the Code is
available on the Honeywell website. The Code does not include all of the
policies of the Company.
Your rights as an
employee and the Company's rights as an employer are governed by the laws
of the country of employment, the work rules of your employing unit and
your individual written employment contract, if any. This Code is intended
to clarify the Company's rights and expectations as an employer, but does
not add to or subtract from employee rights or in any way create any
contractual employment rights for employees. In the United States and many
other countries, employment by Honeywell is employment at will. This means
that you have the right to terminate your employment at any time and for
any reason, and the Company may exercise the same right, subject to
applicable law or existing contract rights. Where local country laws
pertaining to employment contain requirements that differ from the
provisions of this Code, these country laws prevail for an employee while
working in that country.
circumstances, an employee may seek approval of actions that otherwise
would not be compliant with the Code. Approval of any action not compliant
with the Code must be sought in advance and may be granted only by the
Chief Executive Officer or General Counsel of the Company. Waivers of this
Code for members of the Board of Directors or for executive officers of the
Company may be granted only by the Board of Directors or a responsible
Committee thereof, and must be promptly disclosed to shareowners. When a
waiver is granted, the Board or responsible Committee shall ensure that
appropriate controls are in place to protect the Company and its
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Our Relationship with the Company and Each Other
important resource is its employees -- our people around the world whose
skills, energy and commitment to excellence and the Company's vision and
values are the source of the Company's character and central to its
leadership and success.
We Respect the Individual and Diversity
recognizes the dignity of each individual, respects each employee, provides
compensation and benefits that are competitive, promotes self-development
through training that broadens work-related skills, and values diversity
and different perspectives and ideas.
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We Live Our Values
of the Company to the outside world, and regardless of the pressures
inherent in conducting business, we will act responsibly and in a manner
that will reflect favorably on us and the Company. We will carry out our assignments
guided by the principles set forth in our vision and values and in
compliance with this Code of Business Conduct and our corporate policies.
- The Company will provide training and educational
materials, including this Code and various legal and other compliance
materials, so that we are informed of Honeywell's integrity standards
and our requirement to comply with all laws, Company policies and this
- The Company will provide the organizational
structure and communication channels through which employees can
report suspected violations of this Code or other Company policy.
Additional information related to reporting violations can be found
under the section of this Code titled "Our Integrity and Compliance
- To the extent possible, the Company will maintain
the confidentiality of communications about suspected violations that
are made in good faith, except where law or policy may require
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We Avoid Conflicts of Interest
Each of us and our
immediate families should avoid any situation that may create or appear to
create a conflict between our personal interests and the interests of the
Company. A conflict of interest may arise when a director, officer or
employee takes actions or has interests that may make it difficult to
perform his or her duties and responsibilities to the Company objectively
- A conflict, or appearance of a conflict, might
arise, for example, by accepting a gift or loan from a current or
potential customer, supplier or competitor; owning a financial
interest in, or serving in a business capacity with, an outside
enterprise that does or wishes to do business with, or is a competitor
of, the Company; serving as an intermediary for the benefit of a third
party in transactions involving the Company; using confidential
Company information or other corporate assets for personal profit,
conducting business for another enterprise during our normal working
hours or using Company property to conduct business for another
- A conflict of interest may also arise when a
director, officer or employee, or a member of his or her immediate
family, receives improper personal benefits as a result of his or her
position in the Company, such as gifts or loans from an entity or
person with whom the Company does business.
- We will take necessary steps to avoid improper
reporting relationships and not directly or indirectly supervise or
report to persons with whom we have a family or a close personal
- Directors, officers and employees are prohibited
from taking for themselves personally opportunities that are
discovered through the use of Company property, information or
position; from using company property, information or position for
personal gain; and from competing with the Company.
- If a conflict of interest or appearance of a
conflict of interest develops, the employee must report the matter in
writing to a member of the Law Department or the Honeywell Integrity
and Compliance Office and a member of the leadership team of the
business in which the conflict arises to determine what actions need
to be taken to eliminate the conflict of interest.
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We Invite Full Participation and Support
committed to an all-inclusive work culture. We believe and recognize that
all people should be respected for their individual abilities and
contributions. The Company aims to provide challenging, meaningful and
rewarding opportunities for personal and professional growth to all
employees without regard to gender, race, ethnicity, sexual orientation,
physical or mental disability, age, pregnancy, religion, veteran status,
national origin or any other legally protected status.
- This policy applies to all phases of the employment
relationship, including hiring, promotions, demotions, transfers,
layoffs or terminations, compensation, use of facilities and selection
for training or related programs.
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We Work in a Positive Environment
to provide all employees an environment that is conducive to conducting
business and allows individuals to excel, be creative, take initiatives, seek new ways to solve problems, generate opportunities
and be accountable for their actions. The Company also encourages teamwork
in order to leverage our diverse talents and expertise through effective
collaboration and cooperation.
- The Company prohibits the manufacture,
distribution, sale, purchase, transfer, possession, or use of illegal
drugs in the workplace, while representing the Company outside the
workplace or if such activity, whether taking place outside or inside
the workplace, affects our work performance or the work environment of
the Company. The Company prohibits the consumption of alcohol that
affects our work performance or the work environment of the Company.
- The Company prohibits all forms of harassment of
employees by fellow employees, employees of outside contractors or
visitors. This includes any demeaning, insulting, embarrassing or
intimidating behavior directed at any employee related to gender,
race, ethnicity, sexual orientation, physical or mental disability,
age, pregnancy, religion, veteran status, national origin or any other
legally protected status.
- The Company specifically bans unwelcome sexual
advances or physical contact, sexually oriented gestures and
statements, and the display or circulation of sexually oriented
pictures, cartoons, jokes or other materials. It also prohibits
retaliation against any employee who rejects, protests, or complains
about sexual harassment. A complaint procedure is available to
employees to report sexual harassment.
- The Company prohibits employees from engaging in
any hostile physical contact, intimidation, threats of such actions or
violence, or any other actions that may be considered threatening or
hostile in nature while on Company premises, at a Company-sponsored
function, while representing Honeywell or acting on its behalf.
- The Company encourages open, timely communications
that help us achieve organizational goals, share information, increase
understanding, participate in the decision-making process, enhance our
pride in the organization and provide recognition for our work-related
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We Do Not Employ Child or Forced Labor
- Honeywell does not and will not employ child labor.
Honeywell defines a child as anyone under the age of sixteen. If local
law is more restrictive than Honeywell policy, Honeywell will comply
with the letter and spirit of the local law. However, even if local
law allows Honeywell to employ people who are younger than sixteen,
the Company will not do so.
- Honeywell does not and will not employ forced labor.
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We Provide a Safe Workplace
It is Honeywell's
policy to establish and manage a safe and healthy work environment and to
manage its business in ways that are sensitive to the environment. The
Company will comply with all regulatory requirements regarding health,
safety and protection of the environment.
- To help safeguard ourselves and others and our
facilities, the Company will conduct and support research on the
effects of materials and products it handles or sells; share promptly
any information it may obtain relative to any found hazard; conduct
preventive safety and loss prevention and occupational health
programs, and require that equipment and operating practices meet all
applicable regulatory requirements.
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We Respect Each Other's Privacy
our privacy and therefore maintains only those employee personnel and
medical records necessary for business, legal or contractual purposes.
Access to those records and the information contained therein shall be
limited to those with a need to know for a legitimate business purpose.
- Every employee has the right to see his or her own
- The Company will not interfere in our personal
lives unless our conduct impairs our work performance or adversely
affects the work environment or reputation of the Company.
- The Company will comply with all applicable laws
regulating the disclosure of personal information about employees.
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We Safeguard Company Property and
assets is the responsibility of all directors, officers and employees and
Company representatives. We must use and maintain such assets with care and
respect while guarding against waste and abuse. Honeywell's ability to
serve its customers requires the efficient and proper use of the Company's
assets and resources. These include not only physical property, plant
equipment and inventory, but other tangible assets such as securities and
cash, office equipment and supplies, and information systems. It also
includes intangible property such as software, patents, trademarks,
copyrights and other proprietary information and know-how.
- We will use Company assets according to all Company
policies and procedures, comply with security programs that help
prevent their unauthorized use or theft, and abide by all regulations
or contractual agreements governing their use.
- We will protect from disclosure or misuse all
non-public information pertaining to the Company, including
unannounced product and business and financial information,
acquisition and divestiture plans, proprietary technical data,
competitive position, strategies, customers
data, and product costs. Such types of information are considered
trade secrets or confidential information.
- Those of us with access to material non-public
information about the Company that could affect the price of its
securities, such as business strategies, financial results, pending
transactions or contracts, new products, or research results, will not
trade in Honeywell's securities or the securities of other affected
companies, nor will we disclose the information to others until the
information has been disclosed to the public.
- Employees or representatives performing work on
behalf of Honeywell are not entitled to an expectation of privacy with
respect to Honeywell Information Technology resources, except where
provided by local law. All computer data created, received, or
transmitted using Honeywell Information Technology resources is the
property of Honeywell and is not to be considered the private
information of the user. Honeywell reserves the right to examine all
data for any reason and without notice, for example, when violations
of this Code or other Honeywell policies are suspected. By using
Honeywell Information Technology resources, users consent to this
monitoring. When warranted, such data will be disclosed to appropriate
law enforcement agencies. If a user has questions regarding
appropriate use of Information Technology resources, the user should
visit the Global IT Security website or contact Global IT Security,
the Law Department, or a member of the Integrity and Compliance
- We will take actions necessary to safeguard all
passwords and identification codes to prevent unauthorized access to
the Company's information systems resources.
- We will safeguard Honeywell's intangible assets,
such as proprietary information, intellectual property and innovative
ideas. Intellectual property rights, including patents, trademarks,
copyrights, trade secrets and know-how must be planned for and managed
with the same degree of care as any other valuable asset. New concepts
and ideas will be identified for evaluation and protection, as
appropriate, to support the long-term and short-term goals of the
Company. Where appropriate, ideas should be directed to the Law
Department for patent, copyright or trade secret protection.
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We Will Respect the Information of Others
- We will observe obligations of confidentiality and
non-disclosure of confidential information and trade secrets of
others, including suppliers and former employers, with the same degree
of diligence that employees are expected to use in protecting Honeywell's
own confidential information and trade secrets.
- We will respect the legitimate intellectual
property rights of others and will not reproduce or use software or
other technology licensed from suppliers except as permitted by the
applicable license agreement or by law.
- We will not accept or retain unsolicited ideas or
inventions from people outside of Honeywell. Receiving unsolicited
ideas and inventions can expose the Company to claims of
misappropriation of ideas if another organization within Honeywell is
working on something similar or already knew about the idea from a
different source. Employees receiving unsolicited ideas should send
them to the Law Department for handling without reading or sharing
them with others.
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We Maintain Accurate Books and Records and
Report Results with Integrity
financial, accounting, and other reports and records will accurately and
fairly reflect the transactions and financial condition of the Company in
reasonable detail, and in accordance with generally accepted and
Company-approved accounting principles, practices and procedures and
applicable government regulations.
- Transactions of the Company will be executed only
in accordance with management's general or specific authorizations.
- Internal accounting and financial controls and
disclosure controls will be in place and followed to assure that
financial and other reports are accurately and reliably prepared and
fully and fairly disclose pertinent information. The financial
accounts of the Company must be reconciled on a regular basis in
accordance with the applicable accounting controls.
- The Company prohibits false or misleading entries in
its books and records for any reason and will not condone any
undisclosed or unrecorded bank accounts or assets established for any
- We will comply with the Company's disclosure
controls and procedures established to ensure that information which
may be required to be disclosed by the Company under the U.S. federal
securities laws is communicated, reviewed, discussed and evaluated in
a timely manner. All public disclosures shall be full, fair, accurate
- All payments of commissions and discounts will be
made with a separate Company check, draft to the payee or electronic
transmission, except in the case of rebates, where credit memoranda
- No employee will authorize payment knowing that any
part of the payment will be used for any purpose other than what is
described in documents supporting the payment.
- Expenses incurred by employees in performing
Company business will be reimbursed through the filing of expense
reports, which must be documented accurately and completely.
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I am working on a
product alliance between Honeywell and another company. The market
potential of both companies could be greatly expanded. Can I trade in the
securities of Honeywell or the other company?
information is non-public because neither company has
released it to the public, and the information also could affect
the price of the securities of both companies. You may trade only after
the information has been released to the public. Trading in the other
company's securities may be inappropriate even after disclosure if it
could be perceived to create a conflict of interest.
An employee has a
home business that includes building parts for assembly line
manufacturing processes. The employee would like to offer to build parts
for Honeywell since he knows exactly what the Company needs in its
This would be a
conflict of interest. We need to be aware of the many different types of
conflicts of interest that can exist and make every effort to avoid such
situations. We also need to remember that the perception of a conflict
can be just as damaging to our reputation. If you are unsure whether or
not a situation poses a conflict or would like to ensure that a specific
situation is compliant with policies, contact a member of the Law
Department or your supervisor.
from outside the Company send jokes to my Honeywell e-mail address. I
don't ask them to send them to me but the jokes are sent anyway.
You might not
request the jokes to be sent, but you can request that your friends not
send the jokes. An occasional greeting over e-mail from a friend is like
a personal phone call; it should be infrequent, brief and not interfere
with your job responsibilities. But, e-mail is unlike a personal phone
call in that there is no guarantee that it is private. E-mail can be
stored on Company servers and networks. Do as much as you can to police
your e-mail so that it is appropriate. Be aware of our policies on use of
computers, e-mail and the Intranet and Internet and also aware that our
company policy indicates that employees have no right to privacy related
to information systems resources.
A problem that
could impact product safety is discovered during routine production line
testing. It may not be serious, but the group is not sure.
selling the product could mean potential injury to the user or our
employees. Safety related issues must be driven to a conclusion. You
should advise your quality assurance person or HSER manager of your
concern. Quality, engineering and HSER can conduct a risk assessment to
determine the seriousness of the defect and potential of injury to
customers or employees. If serious, notify the Product Integrity
Committee (PIC) for product safety issues for controls, aerospace or automotive
products or The Risk Assessment Committee (TRAC) with respect to chemical
product or process risks. An assessment of the risks can be made by
experienced professionals and appropriate action can then be taken so
that the Company can meet its legal and ethical responsibilities.
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Our Relationship with Our Customers
many of the world's most distinguished industrial enterprises as well as a
multitude of governmental bodies and individual consumers
for whom we design, develop, manufacture and market quality products and
We Obey All Laws and Regulations
relationships are critical to Honeywell. In meeting our customers' needs,
the Company is committed to doing business with integrity and according to
all applicable laws. Products must be designed, produced, installed and
serviced to internal standards and to comply with external regulations, the
standards of the appropriate approval entities, and any applicable
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We Provide Quality Products and Services
Committed to being a
Six Sigma Company, we strive to provide products and services that meet or
exceed our customers' expectations for quality, reliability and value, and
to satisfy their requirements with on-time deliveries.
- When our products, systems or components are
manufactured or assembled according to our customers' specifications,
there will be no change in design, material content or process, or
substitution of parts, unless clearly authorized in writing by the
customer or permitted under the terms of the contract or by regulation.
- Where inspection or testing is required to confirm
conformance to specifications, there will be no misrepresentation of
data or falsification of records.
- Our products should be designed to meet all
applicable government standards and regulations.
- No product or system that has been used, other than
in normal pre-sale testing, will be resold as new equipment.
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We Seek Business Openly and Honestly
Sales are the
lifeblood of the organization, and we will market our technologies,
products and services fairly and vigorously based on their proven quality,
integrity, reliability, delivery and value.
- Honeywell strictly prohibits bribes, kickbacks or
any other form of improper payment, direct or indirect, to any
representative of a government, labor union, customer or supplier in
order to obtain a contract, some other commercial benefit or
government action. The Company also strictly prohibits any employee
from accepting such payments from anyone.
- Reasonable business entertainment and customer
gifts of nominal value are permitted, including traditional
promotional events, as long as what is offered is consistent with
usual business practice, cannot be construed as a bribe or a payoff,
is not in violation of any law and would not embarrass the Company or
individual if disclosed publicly. Customer entertainment and gifts
must be discussed in advance with your supervisor. If you have any
question about the propriety of any entertainment or gift, consult
with a member of the Law Department.
- Where a customer or potential customer notifies
Honeywell of a policy or preference to prohibit or limit gifts to the
customer's employees, Honeywell will respect the customer's policy or
- It is Honeywell's policy to avoid any misstatement
of fact or misleading impression in any of its advertising,
literature, exhibits or other public statements. All statements made
in support of our products and services should be true and supported
- We will communicate clearly and precisely, either
orally or in writing, so that our customers understand the terms of
our contracts, including performance criteria, costs and schedules.
- We will seek all marketing data properly and
legally, and we will not obtain or use any government classified or
sensitive information from any source where there is reason to believe
that the release of the information is unauthorized. If you are in
doubt, contact a member of the Law Department.
- We will comply with the domestic and international
antitrust and competition laws of all countries where we do business.
These laws protect the free enterprise system and encourage vigorous,
but fair, competition. Among other stipulations, these laws prohibit
any formal or informal understanding, agreement, plan or scheme among
competitors that involves prices, territories, market share or
customers to be served and activities or agreements that unfairly
restrict competition. All mergers, acquisitions, strategic alliances,
and other types of extraordinary business combinations should receive
timely legal review to assure that they do not raise concerns of
market dominance or improper coordination among competitors. Likewise
the Company's routine business and licensing plans should be conducted
so that we compete aggressively, but within the law.
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We Follow Accurate Billing Procedures
It is the Company's
policy to reflect accurately on all invoices to customers the sale price
and other terms of sales for products sold or services rendered. Every
employee has the responsibility to maintain accurate and complete records.
No false, misleading or artificial entries may be made on Honeywell's books
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We Safeguard the Property of Others
the tangible and intellectual property of others which may be used in
fulfilling work assignments, and we will comply with all regulations or
contractual requirements governing the use of such property. We will obtain
the tangible and intellectual property of competitors only through lawful
- We will not accept or retain classified materials
to which we are not entitled or for which there is no need.
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We Comply with Government Procurement
In addition to the
provisions of this Code and other Honeywell policies, employees working
with any governmental entity in any country have an obligation to know,
understand and abide by the laws and regulations that apply to the conduct
of business with government entities in that country.
- If a government agency, whether national, state or
local, has adopted a more stringent policy than Honeywell's regarding
gifts and gratuities, Honeywell employees and representatives must
comply with that more stringent policy.
- Honeywell employees should contact a member of the
Law Department for additional relevant corporate and business unit
policies governing gifts and gratuities for government customers.
- The U.S. Foreign Corrupt Practices Act
("FCPA") prohibits Honeywell from making a payment or giving
a gift to a foreign government official, political party or candidate
or public international organization ("foreign official")
for purposes of obtaining or retaining business. The FCPA applies to
Honeywell everywhere in the world we do business. A violation occurs
when a payment is made or promised to be made to a foreign official
while knowing that the payment will be used to unlawfully obtain or
maintain business or direct business to anyone else. Almost every
country in which Honeywell operates has laws of a similar nature.
Employees should contact a member of the Law Department with
- We will not give or encourage anyone else to give
inducements of any kind to any government employee, or to any supplier
under government or non-government contracts or subcontracts, in order
to gain any business advantage or contract.
- Managers will be aware of and comply with conflict
of interest laws and regulations covering government procurements,
including circumstances under which current or former government
employees may be offered, or can accept, employment with the Company.
- In transactions involving the U.S. government, we
will adhere to the provisions of the Truth in Negotiations Act, and we
will make certain that cost and pricing data are current, accurate,
complete, properly disclosed, documented and retained in appropriate
- It is Honeywell's policy to use consultants, sales
agents or other professional service independent contractors only for
legitimate, legal purposes.
- With respect to government contracts, only costs
properly chargeable to the government contract will be billed to the
- Care will be taken to avoid mischarging of costs,
including cross-charging of costs between contracts, charging direct
costs as indirect costs or any other similar mischarging.
- Employees working directly on government contracts
or subcontracts must be particularly diligent in recording their time,
correctly indicating hours worked and the projects to which time is
- All employees whose costs are allocated to
government contracts or subcontracts must identify any expenses that
are not allowable, paying special attention to such categories as
alcohol, business meals and entertainment.
- In any government procurement process, we will not
improperly obtain, use or disclose government source selection or
proprietary information, such as sealed bid prices, technical
evaluation plans, competitive range determinations or ranking of
- We will not accept nor retain government classified
materials to which we are not entitled or for which there is no need.
- When we do accept or retain government classified
materials, we maintain those materials in accordance with the laws
pertaining to those materials. In the U.S., U.S. government classified
information may be received and maintained only at "cleared"
facilities, locations specifically covered by a Security Agreement.
Employees with government security clearances who have access to
classified data will safeguard that data according to government
regulations, including applicable agency procedures.
- We will not use without proper approval any
government-owned equipment to support non-government production or
divert government-owned or other customer-owned materials from their
intended contractual use.
- Should an improper practice or irregularity occur
within the Company, Honeywell is committed to making all necessary
corrections and taking prompt remedial action to prevent recurrence.
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As a global
Company we process many orders for our international customers wherever
we operate. Are there things we need to be aware of?
Employees in such
a position need to be aware of export control laws that apply to the
product being shipped and the location of the international customer. We
should be particularly concerned if the order contains technical data or
information, military products or support services, or parts that could
be used for purposes other than the normal expected use. Contact the Law
Department for more information.
arises for the Company to do business in another country, but a local
official expects special fees and other compensation for the business.
even if normal under local custom, could violate the U.S. FCPA. Employees
should comply with local law and follow guidelines as stated in our
policies to comply with the U.S. FCPA.
While working with
a customer to integrate new technology into a system, you gain knowledge
of a competitor's capabilities and future application, which is not
Be cautious. Prior
to doing anything with the information, you need to make sure the
information you receive is not proprietary. If it is proprietary, or you
are not sure, contact the Law Department.
There is a trade
association meeting next month. Are there any concerns about discussing
our chances of receiving a contract award with other bidders who will be
concerns. We are committed to complying with antitrust and competition
laws of all nations where we do business. We should not discuss contract
awards, prices, bids, terms, or similar proprietary business information
with employees of competing firms.
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Our Relationship with our Suppliers
suppliers are our partners in Six Sigma Plus. The high caliber of the
materials, goods and services they provide is linked directly to the
quality, reliability, value and prompt delivery of the Company's products
to our customers and, thus, to customer satisfaction.
We Seek Long-Term Relationships
We will strive to
build long-term relationships with our suppliers and award business based
on their ability to meet our needs and commitments, their reputations for
service, integrity and compliance, their high standards for quality and
delivery and their prices.
- Where the government, or a government contractor or
subcontractor, directs our purchase to a particular source, we will
abide by and document that selection.
- We will provide the same information and
instructions to each competing supplier for a proposed purchase.
- We will not reproduce software that is licensed to
us by a supplier nor will we incorporate it into our own internally
developed software unless we are expressly permitted to do so by
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We Will Not Be Influenced by Gifts
We will not be
influenced by gifts or favors of any kind from our suppliers or potential
suppliers. The Company expects each employee to exercise reasonable
judgment and discretion in accepting any gratuity or gift offered to the
employee in connection with employment at Honeywell.
- It is Honeywell policy to discourage the receipt of
gifts either directly or indirectly by employees as any gift may be
misconstrued as an attempt to influence business decisions. This does
not apply to unsolicited promotional materials of a general
advertising nature, such as imprinted pencils, memo pads and calendars
as long as what is given is accepted without any express or implied
understanding that the recipient is in any way obligated. Gifts of
nominal value are permitted, provided they are given as a gesture of
professional friendship, and do not involve a Company commitment
having to do with the transaction of business. Such gifts must be
reported to your supervisor. If you have any questions regarding the
propriety of accepting a gift, consult with a member of the Law
- Presentations of a ceremonial nature in keeping
with national custom may be permitted as long as what is accepted is
not in violation of any law, cannot be construed as a bribe or a
payoff and would not embarrass the Company or individual if disclosed
- In no event should a gift be accepted from a
supplier or potential supplier during, or in connection with, contract
- An occasional meal or entertainment in the normal
course of business relations, paid for by a supplier or potential
supplier, is permitted provided that a representative of the supplier
is in attendance and such hospitality is not excessive or unusual in
nature. When practical, hospitality should be reciprocated.
- Where a supplier or potential supplier notifies
Honeywell of a policy or preference to prohibit or limit gifts to the
supplier's employees, Honeywell will respect the supplier's policy or
- Gifts shall not be solicited from suppliers for
Honeywell functions or employee awards.
- It is never acceptable to solicit gifts,
gratuities, or business courtesies for the benefit of a Honeywell
employee, family member or friend.
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asks for your opinion of a Honeywell supplier's capabilities.
Providing an opinion, whether good or bad, is not a good idea. If the
opinion is negative, we could face a defamation claim from the supplier.
If the opinion is positive and the supplier does not meet the
expectations of the other company, they might think we misled them.
Either politely refuse to discuss our relationship with the supplier or,
if you do provide comments, make sure they are fact-based rather than
opinion-based or conclusory.
spouse has recently accepted a position with one of Honeywell's
Company policy is
not intended to interfere in our personal lives. However, this situation
could be a problem if the employee plays a role in selecting the spouse's
company as a supplier, or if you have to deal with that company on behalf
of Honeywell. Report this relationship in writing to your supervisor,
human resource representative or member of the Law Department and excuse
yourself from participating in decisions or negotiations with your spouse
and the supplier. Some situations may require additional steps to avoid
the potential conflict.
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Our Relationship with Others
As a corporate
citizen in communities around the world, Honeywell abides by local laws,
supports civic organizations, encourages employee involvement in worthwhile
causes and conserves nature's valuable resources.
We Comply with Local Laws
businesses globally where laws, customs and social requirements may be different
from those in the United States. It is Company policy to abide by the
national and local laws in each country and community in which we do
business. In the event that an employee becomes aware of any conflict
between local laws and U.S. law, consult the Law Department promptly.
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We Do Not Make Improper Political
generally may not to be used for political contributions, directly or
indirectly, in support of any party or candidate.
- Wherever lawful, however, the Company may
contribute to an occasional local initiative or referendum campaign
where Honeywell's interests as a company are directly involved. Any
such payments, however, require advance clearance from the Law and
Government Relations Departments.
- As interested citizens, Honeywell employees are
free to make individual, personal contributions to candidates of their
choice, and those eligible may also participate in the Honeywell
International Political Action Committee (HIPAC). All U.S. citizens
and green-card employees are eligible to participate. To determine if
you are eligible to participate in the HIPAC, please contact the
Honeywell Government Relations Department in Washington, D.C. or the
general counsel of your business unit. HIPAC officers are responsible
for ensuring that the Company's administrative and financial support conform to Federal Election Commission
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We Protect the Environment
Honeywell abides by
all applicable health, safety and environmental laws and regulations in
countries and communities in which we operate, and, where those are
considered inadequate, we will abide by the
Company's own standards. For a copy of the Honeywell Health, Safety,
Environment & Remediation Policy and Commitment Statement, contact a
member of the HSE&R organization.
- The Company is committed to make health, safety and
the environment an integral aspect of our design of products,
processes and services and of the lifecycle management of our
- The Company will utilize management systems to
apply a global standard that provides protection of human health and
the environment, including compliance with applicable laws and
regulations. We notify customers, suppliers and the public about the
safe use of our products and related environmental issues throughout
- The Company will identify, control and endeavor to
minimize the use of hazardous materials, and will endeavor to reduce
- The Company will conduct prevention and control
programs to safeguard employees and the public and will review the effectiveness
of these programs through its assurance process, environmental audit
and other systems.
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We Require Those Representing the Company
to Act With Integrity
When it is necessary
to engage the services of an individual or firm to consult for or otherwise
represent the Company, special consideration must be given to avoid any
situation that may create, or appear to create, a conflict of interest between
Honeywell and the person or firm employed.
- The Company will enter into representation or
supplier agreements only with companies believed to have a record of
and commitment to integrity. Efforts will be taken by Honeywell to
ensure that suppliers, agents, consultants, independent contractors
and representatives are aware of this Code. Questions related to
sourcing or related agreements should be directed to Materials
- The Company will seek to inform our suppliers,
agents, consultants, independent contractors, and representatives of
their responsibility to act on behalf of Honeywell consistent with the
Code, other Honeywell policies and any applicable law or regulation.
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We Comply with Antiboycott
comply with laws that prohibit activities associated with organized foreign
economic boycotts, including refusing to do business with boycotted
countries, their nationals or blacklisted companies; furnishing information
about the Company's or any person's past, present or prospective
relationship with boycotted countries or blacklisted companies; furnishing
information about any person's race, religion, sex, national origin, or
membership in or support of charitable organizations supporting a boycotted
country; discriminating against individuals or companies on the basis of
race, religion, sex or national origin; and paying, honoring or confirming
letters of credit containing prohibited boycott provisions.
- Under U.S. antiboycott
legislation, Honeywell is required to report the receipt of any
request to participate in an international boycott. Requests are often
found in letters of credit, shipping instructions, certificates of
origin and other contract-related documents. The receipt of a boycott
request must be reported immediately to Honeywell's International
Trade Compliance Office.
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We Comply with Export Control and Import
comply with all Export Control and Import laws and regulations that govern
the exportation and importation of commodities and technical data,
including items that are hand-carried as samples or demonstration units in
luggage. Honeywell will screen new customers and suppliers to ensure that
they do not do business with prohibited entities. It will obtain export
licenses and other government approvals prior to exporting products and technology
controlled by the U.S. Government. Failure to comply with these laws could
result in heavy fines or the loss or restriction of Honeywell's export or
import privileges, which, in turn, could seriously and adversely affect a
significant portion of the Company's business.
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protection laws are complex, so how do I know when to be concerned about
a particular situation?
The laws are
complex, but you don't need to understand every detail before you report
an environmental concern. In general, all materials should be properly
labeled, used, stored and transported, and waste substances must be
recycled or disposed of properly. If you use specific materials on your
job, you should understand their properties and hazards and wear
appropriate safety gear when the duties require you to do so. If you are
Is there a need to
review all international transactions for boycott requests?
Review of all
international transactions is required to ensure compliance. If you find
one of these requests, contact the Law Department or International Trade
Coordinator immediately. Remember also that U.S. antiboycott
regulations apply everywhere. Violations of antiboycott
laws anywhere in the world could negatively impact Honeywell.
With respect to
public officials, what lobbying efforts are appropriate, and are gifts
and gratuities allowed?
In the U.S.,
lobbying efforts should always be coordinated through the Government
Relations Department. In many countries, including the U.S., gifts and
gratuities to government officials are restricted, and in some instances
prohibited, by law. If in doubt, contact a member of the Law Department
and consult with related corporate and business unit policies. If gifts
are not prohibited, you should be aware of any value or monetary limitations.
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Our Integrity and Compliance Program
organizational structure has been established to coordinate, implement and
oversee compliance with the Code of Business Conduct and with the Honeywell
corporate policies, procedures and standards on which it is based.
A Personal Responsibility
Compliance is, first
and foremost, the individual responsibility of every employee. Every
director, officer and employee of the Company has the personal
responsibility to know and understand this Code of Business Conduct and the
other policies of the Company relevant to his or her job or position. The
Company fosters an environment in which integrity issues and concerns may
be raised and discussed with supervisors or with others without the fear of
- It is the Company's responsibility to provide a
system of reporting and access when an employee wishes to report a suspected
violation, or to seek counseling, and the normal chain of command
cannot, for whatever reason, be used. In this way, the Integrity and
Compliance Program provides a resource to preserve the integrity of
each and every employee and of the Company.
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The Corporate Responsibility Committee
Responsibility Committee of the Board of Directors shall have oversight
responsibility for the Honeywell Integrity and Compliance Program.
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The Corporate Integrity and Compliance
Integrity and Compliance Council shall provide policy leadership for the
Company's Integrity and Compliance Program and report to the Corporate
Responsibility Committee of the Board of Directors. Members of the
Corporate Integrity and Compliance Council shall include an
Integrity and Compliance Officer from each strategic business unit
and key functional areas. The Chairperson of the Council shall be the
corporate Vice President, Global Compliance.
- Responsibilities of the Council include: developing
and approving Integrity and Compliance policies, standards, practices
and procedures; reviewing and approving Integrity and Compliance
training; monitoring compliance with Company policies and with laws
and regulations; evaluating trends arising from Integrity and
Compliance investigations; and reporting to the Corporate
Responsibility Committee of the Board of Directors.
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The Business Unit Integrity and Compliance
Each business unit
shall appoint an Integrity and Compliance Officer
who shall determine the appropriate organizational oversight structure to
assure effective implementation of Integrity and Compliance responsibilities
within the business unit.
- Responsibilities of the business unit leadership
function include: ensuring business unit compliance with Company
policies, laws and regulations by overseeing self-governance
activities; assessing compliance risks for the business unit; tracking
and reviewing trends in data relating to the business unit's Integrity
and Compliance investigations and taking steps to address those
trends; developing, delivering and tracking Integrity and Compliance
training; reporting periodically to the Corporate Council on the goals
and results of Integrity and Compliance activities of the business
unit; assuring a healthy integrity environment, including maintenance
of a free and open atmosphere that facilitates the reporting of
alleged violations without fear of retribution; providing advice and
counsel to employees regarding Code of Business Conduct and other
ethical inquiries raised by an employee; and conducting investigations
of misconduct allegations and determining appropriate, consistent
disciplinary actions for violations of Company rules or standards of
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The Integrity and Compliance Office
Integrity and Compliance Office shall be headed by the corporate Vice
President, Global Compliance, who shall be responsible for the operational
management of the Integrity and Compliance Program and report to the Senior
Vice President and General Counsel. The Office will administer the ACCESS
Integrity and Compliance Helpline including managing the investigation
process and reviewing results of investigations to assure fairness,
timeliness and consistency. The Office will also serve as a resource for
the Company by providing training materials, communications, advice and
guidance on matters related to the integrity of the Company and this Code,
and support for investigations of misconduct allegations.
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Business Conduct Leader Network
The Integrity and
Compliance Coucil has established a Business
Conduct Leader ("BCL") Network to respond to employee's integrity
and compliance inquiries and, when appropriate, investigate allegations of
general workplace concerns. Employees may also raise concerns or seek
advice through the ACCESS Helpline at 800-237-5982, a supervisor, member of
the Law Department or the Integrity and Compliance Office at
- BCLs may be a resource for training and assisting
with implementing integrity and compliance initiatives. To identify
your BCL, contact a member of the Human Resource Department, the
Integrity and Compliance Office or visit the Integrity and Compliance
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supervisors have key roles in the Integrity and Compliance Program and are
expected to demonstrate their personal commitment to the Company's
standards of conduct and to lead their employees accordingly.
- The Company will require an annual Integrity
Certification from all directors, officers and employees in salary
bands 4 and above or the equivalent, plant managers, those in charge
of sales offices and other facilities, and others who may be
designated because of the nature of their work, stating that they have
read and that they understand the Code of Business Conduct. These
employees must attest that they have complied with the Code, brought
it to the attention of everyone under their supervision whose act or
failure to act could contribute to a violation of policy, and know of
no violations other than those possible violations disclosed in the
- Law Department, together with senior management of
the businesses and other functions, will determine appropriate
compliance training for employees. Supervisors shall ensure that all
employees under their supervision are aware of and participate in
appropriate compliance training programs.
- Managers and supervisors shall maintain a workplace
environment that ensures compliance with the Code of Business Conduct.
- Managers and supervisors shall be diligent in
considering an individual's character and behavior before appointing
that individual to any position of authority and responsibility.
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employee shall comply with the letter and spirit of the Code of Business
Conduct and with the policies and procedures of the Company, and shall
communicate any suspected violations promptly.
- Employees may confront an ethical issue where this
Code or other Company policy does not expressly provide an answer.
Employees should feel comfortable contacting a member of leadership,
the Integrity and Compliance Council, a member of the Law Department
or using one of the other resources described in this section.
- Employees are encouraged to report violations
through their normal reporting channels, to their business unit's
Integrity and Compliance Officer, to any member of the Corporate
Integrity and Compliance Council or the Law Department.
- In addition, all employees shall have access to one
or more telephone helplines, which will be monitored on a 24-hour
basis by a professional, independent contractor, through which
suspected violations of laws, regulations, Company policies, or the
Code of Business Conduct may be reported. This helpline is not
intended to replace normal supervisory channels for reporting
questionable conduct or seeking advice about appropriate ethical
- Any employee who in good faith raises an issue
regarding a possible violation of law or Company policy will not be
subject to retaliation and their confidentiality will be protected to
the extent possible, consistent with law and corporate policy and the
requirements necessary to conduct an effective investigation. Any
supervisory personnel who retaliates against an employee as a result
of such employee's report of an alleged violation of law or Company
policy shall be subject to disciplinary action, including termination,
and may risk criminal sanctions as a result of such actions.
- Allegations will be investigated by the appropriate
corporate, business unit or department personnel, and upon the advice
and approval of the Law Department, will be reported as appropriate or
required by law to the appropriate authorities. Employees may refer to
the Honeywell Policy Manual, policy titled: Integrity and Compliance
Program, for additional information regarding the investigation
- In order to facilitate implementation of this Code
of Business Conduct, employees have a duty to cooperate fully with the
Company's investigation process and to maintain the confidentiality of
investigative information unless specifically authorized or required
by law to disclose such information.
- It is the policy of the Company that all employees
cooperate fully with all lawful requests for information from
government investigating authorities. A refusal to cooperate in a
government investigation may be grounds for termination. The Law
Department will determine whether a refusal may warrant an exception
to the rule in particular circumstances. The Law Department has the
sole authority to make such a decision.
- Employees shall take all appropriate steps to
comply with all legal requirements and the Company's document
retention guidelines with respect to the preservation of documents in
connection with any Company or government investigation.
- Failure to comply with any responsibilities
established by this Code of Business Conduct may result in
disciplinary action, up to and including termination, as appropriate,
and may also require restitution or reimbursement from the employee
and referral of the matter to government authorities under the
guidance of the Law Department. Discipline may also be imposed for
conduct that is considered unethical or improper even if the conduct
is not specifically covered by this Code.
- No Code or set of values can address every ethical
choice we face in business; no communication system or oversight group
can ensure complete compliance. Each of us must use good common sense
and judgment in our personal conduct.
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Our Corporate Policies
This Code of
Business Conduct is intended to be consistent with and refer to certain key
corporate policies, which are included in the Honeywell Policy Manual. The
Honeywell Policy Manual may provide greater detail than is provided by this
Code or in some instances the Policy Manual may provide additional policies
not covered by this Code. As stated previously regarding this Code,
employees should be aware that any violations of the Honeywell Policy
Manual may result in disciplinary action up to and including termination,
as appropriate, and to the extent that either is legally possible under the
applicable law. Corrective actions may also require restitution or
reimbursement, and to the extent that either is legally possible under the
applicable law, from the employee and referral of the matter to government
authorities under the guidance of the Law Department.
The Honeywell Policy
Manual is maintained by the Office of the Corporate Controller in Morris
Township, New Jersey. Corporate policies can be found on the Honeywell
Intranet or can be obtained through the Human Resources department.
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You observe a
situation that may violate law or company policy and believe that your
supervisor sees it too, but chooses to ignore it. You don't feel you
should report it because you think nothing will be done about the
If you believe the
situation violates law or policy, you have an obligation to report it.
Your supervisor may not be as aware of the problem as you think. However,
even if he or she is aware, the situation needs to be reported so that it
may be corrected. You should report the matter to your HR representative,
the Law Department, or through the Company helpline.
When the pressure
is on to meet goals and projections for the business, it's hard to deal
with rules, regulations and paperwork.
It's true that
there is a lot of pressure to perform and produce. But no matter how much
emphasis our Company puts on making the numbers, the Company doesn't want
you to do it by cutting corners. Rules, regulations and policies are put
in place to ensure that our Company complies with the law, external
standards and internal values. Breaking the law, or stretching a
Honeywell policy, can have adverse effects far beyond the immediate
satisfaction of making the numbers.
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Honeywell Behaviors: Workplace behaviors
differentiate levels of performance at Honeywell. Those who embody and
develop them personally and in others drive personal and business success.
Individuals will be assessed based upon the results they achieve and upon
the degree to which they exhibit the Honeywell Behaviors.
Integrity is a bedrock principle of all our
behaviors. All employees must abide by and uphold the Code of Business
Conduct and all laws. There will be no exceptions.
Growth and Customer
Focus recognizes that we
need to think differently in order to grow. The customer is the cornerstone
of our success. Effective employees do a superb job for customers every day
in quality, delivery, value and technology. They aggressively pursue new
opportunities through superior sales and marketing, globalization and
technology roadmaps supported by Design for Six Sigma.
Leadership Impact means thinking like a leader regardless of
your job, delivering on commitments, and being a role model for others. All
leaders demonstrate passion for their work and care about the people in the
organization. Each employee must be able to: (1) conceptualize an issue,
(2) develop an action plan to address the issue, and (3) execute the plan.
Gets Results requires consistently meeting commitments
to the business and to others. Quickly translate business requirements into
actions by defining "who does what by when" to ensure plans are
Makes People Better encourages excellence in peers,
subordinates and/or managers. Be a positive influence in the development of
Champions Change and
Six Sigma drives continuous
improvement and fosters a Six Sigma mindset to make decisions that are in
the best interest of customers, shareowners, and the organization. It
reflects a constant commitment to do things better. Strongly supports
Design for Six Sigma. Champions change that ensures the long-term strength
of the company regardless of personal impact.
Fosters Teamwork and
Diversity defines success in
terms of the whole team. Employees must understand and capitalize on the
fact that Honeywell's workforce is composed of individuals who represent a
great diversity of values, opinions, backgrounds, cultures and goals.
Recognizes diversity as an important value and develops diverse teams.
Effective team leaders not only meet the expectations of their role as
leaders, but they also set and meet the expectations for team members.
Global Mindset is viewing the business from all relevant
perspectives and seeing the world in terms of integrated value chains.
Taking recognizes that
generating greater returns requires taking greater risks. While using sound
business judgment, has the courage to take action where outcomes are
uncertain but where potential rewards are great. Business decisions often
need to be made based on incomplete information.
Self-Aware/Learner individuals recognize their behaviors and
how they affect those around them. Employees must accurately assess their
own strengths and weaknesses and take action to improve.
Communicator means providing
timely and concise information to others, and using clear and thoughtful
oral and written communications to influence, negotiate and collaborate
effectively. Leaders and employees need to appreciate that effective
communication is about listening and being listened to but is not always
about being in agreement.
Integrative Thinker decides and takes actions by applying
intuition, experience, and judgment to the data available. Demonstrates
ability to assimilate various and conflicting information or opinions into
a well-considered decision. Understands the implications of individual
actions or recommendations on other systems, markets, processes and
means being capable and effective in a particular area of expertise.
Employees must remain aware of advances and current thinking in their
fields and look for ways to apply the latest technologies to their work.
For a more complete
discussion of the Honeywell behaviors and expectations for individual
performance contact your Human Resources representative or go to myhoneywell.com
A • C • C • E • S • S
Our Integrity and Compliance Helpline
YOUR OPPORTUNITY TO
SEEK ADVICE OR TO RAISE CONCERNS ABOUT MISCONDUCT
outside the U.S.
requires a country
found at www.att.com/traveler)
or write to:
P.O. Box 2245
Copies of the Code of Business Conductmay be
obtained by sending a request email@example.com
calling the helpline.