Center for the Study of Ethics in the Professions at IIT

Eaton Corporation's commitment to the highest degree of integrity and honesty in the conduct of its business affairs is stated in the following letter. This letters, and prior versions of it, have been distributed periodically to Eaton employees since 1976.

Eaton Corporation
Eaton Center
Cleveland, OH 44114-2584
September 1, 1996

Dear Fellow Employee:

Eaton has always had a well-deserved reputation for honesty and integrity - a reputation which we have all helped build and maintain. My purpose in writing is to reaffirm Eaton's commitment to the highest standards of ethical behavior. I particularly want to emphasize that our standards remain constant even as Eaton experiences new international growth and evolution into a truly global company.

If you're concerned about any particular situation involving ethics, please don't hesitate to contact your supervisor or another member of management.

Here are the broad concepts that we regard as fundamental principles of ethical business behavior.

Obeying the Law-We respect and obey the laws of the cities, states and countries where we operate.

Competition-We respect the rights of competitors, customers and suppliers. The only competitive advantages we seek are those gained through superior research, engineering, manufacturing and marketing. We do not engage in unfair or illegal trade practices.

Conflicts of Interest-We expect Eaton employees to avoid any association which might conflict with their loyalty to the company or compromise their judgment. Under this guideline, it would be a conflict of interest for an Eaton employee to work simultaneously for a competitor, supplier or a customer.

Government Contracts-Eaton's customers include national, state and local governments. We take care to comply with the special laws, rules and regulations which govern these contracts.

Payments to Government Personnel-We do not make illegal payments to government officials of any country. In the case of U.S. federal government employees, we must comply with the stringent rules on business gratuities that they are permitted to accept.

Kickbacks and Gratuities-We do not offer or accept kickbacks or bribes, or gifts of substantial value.

Political Contributions-Our policy prohibits company contributions to political candidates or parties even where such contributions are lawful. We encourage individual employees to be involved in the political process and make personal contributions as they see fit.

It is important that the policies and principles set forth in this letter be understood and followed on a consistent basis by each of us. Our reputation for integrity is an important corporate asset. The principles as outlined are designed to help us protect that asset. Anyone violating these principles will face appropriate disciplinary action. Your commitment to ethical behavior is essential if Eaton is to maintain the highest degree of honesty and integrity in its business activities.