The Guide to Ethical Conduct - Tyco

1 The Guide to Ethical Conduct Doing the Right Thing Guide A Message from Contents George Oliver, CEO. Message from CEO .. 3 Doing Business with Integrity .. 16 Dear Colleague, A . Anti-Bribery Our Commitment to Ethics at Tyco .. 4 B . Fair Competition Every day, our customers rely on us Our Guide to Ethical Conduct It's our expectation that after reading A . Application of the Guide to Ethical Conduct C . International Trade to protect and safeguard their people explains and defines the values the Guide , you will have a better and property and trust that we are that we share as Tyco employees . understanding of your individual Asking for Help and Raising Concerns.

2 6 Financial Integrity .. 20 committed to the highest standards It spells out the right way to behave responsibility to comply with A . Speak Up and Ask for Help A . Fraud of business ethics and practices . and sets the framework for our policies and regulations that affect B . Non-Retaliation and Confidentiality B . Financial Accounting, Record keeping and Reporting commitment to building and sustain- our business, as well as the re- C . Buying and Selling Stock Insider Trading To set us apart from our ing an Ethical work environment . sources available to you to raise Promoting a Positive Workplace and competitors, we need to maintain any concerns you have.

3 Respecting Others .. 8 Protecting and Managing Company our Ethical culture and remain Together with business-specific A . Valuing Diversity and Promoting Inclusion Property, Information and Records .. 22 committed to our core values of policies and local laws and regula- With every one of us embracing our B . Preventing Harassment A . Physical Assets and Communication Systems Integrity, Teamwork, Excellence and tions, the Guide is designed to help shared commitment to our values C . Our Responsibilities to Our Communities B . Proprietary Information and Intellectual Property Accountability . Every Tyco employee you understand what is expected and the Guide , we are making C.

4 Records Management must live these values every day . of you and to help you make good Tyco a stronger, more successful Protecting Our Employees and the D . Data Privacy decisions, especially in situations company a company we can all Environment: Zero Harm .. 10 where the right course of action be proud to be part of . A . Commitment to a Safe Workplace Communications with Media, isn't always clear . B . Respecting the Environment Investors and the Public .. 24 Thank you for playing a vital C . Product Quality and Product Safety A . Communications with the Media role in our success . B . Communications with the Investment Community Conflicts of Interest.

5 12 C . Social Media and Communications with the Public A . Outside Employment B . Family and Personal Relationships Political Activities and C . Financial Interests Charitable Contributions .. 26. Gifts and Business Entertainment .. 14 Conclusion .. 28 George Oliver, CEO. A . Giving and Accepting Gifts Tyco B . Business Entertainment Speak Up Resources .. 28. C . Providing Gifts and Entertainment to Government Officials 2 Tyco Guide to Ethical Conduct Tyco Guide to Ethical Conduct 3. Our Commitment to Ethics at Tyco At Tyco, we are committed to doing the right Our role begins but doesn't end with A. Application of the Tyco The Tyco Guide to Ethical Conduct thing in all aspects of our business.

6 This requires understanding Tyco's Vital Values and Guide to Ethical Conduct applies to all employees, part- that all of us, every day, exhibit an unwavering Guide to Ethical Conduct . We are At Tyco, we are all governed by a time employees, contractors, dedication to the highest Ethical standards. obligated to act . If an issue raises a core set of Vital Values Integrity, executives and our board of We work diligently across our organization to question in your mind, you have a Excellence, Teamwork and directors . The information within reinforce the fundamental premise that every responsibility to Speak Up.

7 Reports Accountability . All of us, regardless the Guide supplements any corpo- employee carries a share of the responsibility of suspected misconduct are confi- of where we Conduct business, are rate, business or regional policies for the Conduct and success of our company. dential, and Tyco will not tolerate expected to incorporate these values related to the content discussed retaliation against anyone for into our daily work activities and within the Guide . The Guide offers reporting suspected misconduct abide by the principles outlined in general guidelines only and is subject or providing information as part of the Guide .

8 To local law . It is not intended to be Tyco's Values responding to their needs . We are Our Guide to Ethical Conduct , an investigation . all inclusive . Tyco's culture is built on a founda- dedicated to diversity, fair treatment, together with our business-specific As a global company incorporated tion of four key values . These values mutual respect and trust . We are policies, defines what is expected The truth is that everyone share- in Switzerland, publicly traded on As an employee of Tyco, you will shape employees' behavior toward committed to producing our products of each of us in our locations around holders, customers, suppliers, regu- the New York Stock Exchange be asked to sign a commitment customers and toward one another.

9 And serving our customers with zero the world . In everything we do, we lators, employees, and community (NYSE:TYC), and with businesses statement that you have read and Together, they drive our company harm to people and the environment . must strive to act with honesty, fair- partners watches what we say and operating in over 60 countries, there understand the Tyco Guide to Ethical forward . The values are: ness and integrity, and to obey the do . Our message about the impor- are international laws, regulations Conduct , and that you will act in full Teamwork laws and regulations wherever we tance of ethics, integrity and compli- and global standards that apply to all compliance with the Guide .

10 Integrity We foster an environment that operate . Regardless of our position ance must be perfectly clear, and our of us . In addition to these internation- We demand of ourselves and each encourages innovation and creativ- within the company, we share equal actions must conform to our mes- al laws and standards, we are com- other the highest standards of ity, and delivers results through accountability for: sage . With each of us embracing the mitted to following the local laws of individual and corporate integrity . collaboration . We practice leader- commitment to Conduct business each country where we do business.