Rockwell Collins - World Banksiteresources.worldbank.org/INTETHICS/Resources/Rockwell_Collins... ·...

Rockwell CollinsStandards of

Business Conduct

Welcome. Our Vision Statement, “working together

creating the most trusted source of communication and

aviation electronic solutions,” depends on each of us

maintaining the expectations outlined in our Standards of

Business Conduct and putting them into action every day.

In this way we not only uphold our ongoing commitment

to unquestioned integrity, we also create the framework

in which we build trust every day.

Keep this in a convenient place for easy reference and

review it whenever you encounter any standards of

business conduct issue. Should you have any questions

or concerns about any company policies described here,

please don’t hesitate to talk to any one of the resources

listed within.

Thank you in advance for your cooperation and

commitment. Remember, Ethics is good business and

trust is at the heart of all we do.

Clay Jones

Chairman, President & CEO

� �

Ethics is good business and

trust is at the heart of all we do.

How to use this information

Rockwell Collins’ Standards of Business Conduct is the cornerstone of our Ethics Program. This document provides you with a general overview of our policies and procedures as well as guidelines of conduct in various scenarios. It is not intended as a definitive description of every corporate policy that may apply to you.

For a detailed explanation of the additional policies and procedures that govern your actions in the workplace, talk with your supervisor and/or Human Resources. Our annual Ethics Training along with our Legal and Business Compliance Courses are another excellent source of information. Finally, Rockwell Collins online policies and procedures can be an important source of information.

Operating globally

Because we do business all around the world, on occasion our employees will find themselves subject to multinational laws and regulations they may not be familiar with. It is our expectation that every employee know, follow and respect the laws of the land in which they work. In cases where these laws and cultural customs differ from the Rockwell Collins Standards of Business Conduct, it is our expectation that employees will follow whichever requires the highest standard of ethical conduct.

How to use this information . . . . . . . . . . . . . . . . . . . . . . . . . 05

Ethics decision making process . . . . . . . . . . . . . . . . . . . . . . . . 06

Where to go for help . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 08

Ethics policy and principles . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Conflicts of interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Insider trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Gratuities and business courtesies . . . . . . . . . . . . . . . . . . . . 16

Company books, records and reports . . . . . . . . . . . . . . . . . . 18

Disclosure of material information. . . . . . . . . . . . . . . . . . . . 20

Using company resources . . . . . . . . . . . . . . . . . . . . . . . . . 22

Product integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Protecting information . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Export, import and antiboycott compliance . . . . . . . . . . . . . . 28

Antitrust and competition . . . . . . . . . . . . . . . . . . . . . . . . . 30

Doing business with the government . . . . . . . . . . . . . . . . . . 32

Recruiting government employees . . . . . . . . . . . . . . . . . . . . 34

Procurement integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Lobbying expenditures . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

Employee health and safety and the environment . . . . . . . . . . 40

Respect and concern for others . . . . . . . . . . . . . . . . . . . . . . 42

Problem reporting and resolution . . . . . . . . . . . . . . . . . . . . 44

� �

Table of contents

A good ethical decision making process includes the following elements:

MAKE YOURSELF AWARE

• Which policies are involved?• What are the possible violations?• What are the ethical implications?

ANALYZE THE SITUATION

• How might an improper response affect the Company and/or me, now or in the future?• What are the possible short-term effects?• What are the possible long-term effects?

REVIEW THE FACTS

• Is it legal?• Does it uphold my personal standards and principles?• Is it consistent with Company beliefs, policies and operating procedures?• Does it accurately project the corporate image?• How comfortable would I be explaining my actions in front of national television news cameras?• How comfortable would I be if my decision was published in the newspaper?• Would I do the same thing if a loved one, boss or friend were watching?

USE YOUR RESOURCES

• What and who should I consult with for additional information, assistance or advice?

It is not always easy to determine

the right thing to do in a particular

work situation. Sometimes because

of the complexity of the situation,

the decision is not always clear cut.

Sometimes you may face situations which,

although not a violation of law or policy, do

not seem to be the “right thing to do.” In such

cases, it is important to consider the matter

in the context of our ethical philosophy and

principles. To assist you, the decision making process

provides a consistent approach to the evaluation of an

ethical dilemma.

Ethical decision

making process

� �

Resources Leadership – Successive levels of leadership are available to discuss your ethical concerns or questions. They may refer you to another resource, but under most circumstances this should be your first point of contact.

Human Resources – Contact your local Human Resources representative to assist with employee relations matters or as a general point of contact involving employee-related concerns.

Legal Counsel – Contact the Office of the General Counsel to obtain legal advice or to assist you with intepretation of laws, regulations or Company policies that address legal compliance matters.

Rockwell Collins Ethics Line/Ombudsman Office – Contact the Ethics Line within the Ombudsman Office to answer questions, seek guidance, express concerns or report suspected violations of Rockwell Collins’ Standards of Business Conduct. Ethics Line – 1-866-224-8137

General Ethics Information – For additional information and resources, please refer to the Ethics Page, which is accessible via the RWEB home page. For e-mail correspondence:Internet/e-mail: [email protected]

RWEB (Intranet) –http://rweb.rockwellcollins.com/ent/ombudsman/ombudsman.htm

If you want help resolving

questions about our Standards of

Business Conduct as it applies to

any specific situation, you should

utilize one of the resources listed in

this document.

Where to go for help

� �

Ethics principles Doing what’s right; the guiding principles of Rockwell Collins. This includes:• Honest and ethical conduct at all times• Full, fair, accurate, timely and understandable disclosure in all public communications• 100% compliance with applicable laws, rules and regulations• Fair dealing with our customers, suppliers, competitors and employees, including properly maintaining the confidentiality of sensitive information• Protection and proper use of Company assets• The prompt internal reporting of violations of this policy to appropriate personnel• Accountability for adherence to these standards

Why is this important?

First and foremost, because our shared vision of creating the most trusted source of communication and aviation electronic solutions depends on it. Second, because it has proven to be a foundation for our success. To demonstrate anything less than complete honesty, integrity and fairness to our customers, suppliers, shareholders and each other can undermine what we are all working so hard to build.

Your role

The decisions made by Rockwell Collins employees on a daily basis not only affect the Company’s bottom line, they also affect our reputation. That’s why we expect every employee to do the right thing, for the right reason, in the right way, every time. And while it’s every employee’s personal responsibility to strive to succeed in all our business endeavors, this success must never come at the expense of our ethical standards.

To that end, it is the personal responsibility of every employee to ensure that the Company’s business is conducted in absolute compliance with applicable laws and Company policies. Should any questions or possible violations be observed, it is the responsibility of every employee to share their concern with appropriate Company management.

Ethics Policy: It is Rockwell Collins’

policy to conduct its business

honestly, ethically and in accordance

with all applicable laws. We expect all

employees to conduct themselves with

the highest standards of business conduct.

Ethics policy and principles

10 11


Rockwell Collins has an obligation to its customers, vendors and shareowners to ensure that business decisions are based on quality, price, delivery, service, experience and reputation. Further, business decisions must not be influenced by personal considerations or interests.

Employees and their immediate family members are not to use Company property, information or position for personal gain. Employees, officers and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

Your role

Seek guidance when you or a family member are involved in an activity, or have a personal interest, which could affect your objectivity in performing your duties and responsibilities at Rockwell Collins. Keep in mind that an actual conflict of interest does not need to be present to constitute a violation of this policy. Activities that create the appearance of a conflict of interest or may prohibit a corporate opportunity must be fully disclosed before actions are taken which could impact the reputation of Rockwell Collins or our employees. Seek advice from Human Resources or the Ombudsman for further guidance on how to make a disclosure.

Questions to consider

• Outside of your Rockwell Collins’ responsibilities, are you involved with a third party entity that could present a conflict of interest? • Do you work with a family member who may have direct or indirect influence on the terms and conditions of your employment?• Do you or an immediate family member own or work at an outside business which may have a competing interest with Rockwell Collins?

Policy: It is Rockwell Collins’ policy

that all employees must avoid

any conflict, or even the appearance

of a conflict, between their personal

interest and the interest of the Company.

Neither our employees, or their immediate

family members, may be involved with any

undisclosed business that competes or does

business with Rockwell Collins, and no such

person may take for themselves personally any

opportunity properly belonging to Rockwell Collins.

Conflicts of interest

1� 1�


First and foremost, insider trading is illegal and consequences of insider trading can be severe – loss of employment, substantial fines and/or imprisonment. It is also a violation of Rockwell Collins’ policy to trade Rockwell Collins stock while in possession of material nonpublic information.

Information may be considered material if:

• An investor considers it important when deciding whether to buy or sell securities/stocks• Information could be viewed as altering the “total mix” of information made publicly available

Examples of material information may include (but not limited to):

• Mergers, acquisitions and divestitures• Significant new product developments• Government investigations• Revenues or earnings information

Your role

If you have material nonpublic information about Rockwell Collins or other companies due to your role with Rockwell Collins, you are prohibited from trading in those companies’ securities/stocks, as well as from communicating such information to family, friends or any other person.


• Are there facts I have learned as part of my role as a Rockwell Collins employee which have influenced my decision to buy or sell stock?• Have I shared information with friends, family or any other person which could offer them an unfair advantage in the stock market or other public financial trading?


that employees must not benefit

from, or enable others to benefit

from, trading in securities/stocks based

on material information not available to

the general public.

Insider trading

1� 1�


To ensure the integrity of our business transactions and to comply with applicable laws, sales, purchases and other business decisions must not be influenced or appear to be influenced by gifts or gratuities. Further, the Company has a long-standing tradition of not doing anything that might cause others to potentially violate the law or the policies of their employer.

Gratuities are defined as items of value (cash, goods, services, use of property, etc.) that are given voluntarily and not in return for, or in anticipation of, a reciprocal service or courtesy.

Business Courtesies are reasonable accommodations (meals, refreshments, entertainment, transportation or lodging, etc.) that may be offered or received only in connection with marketing, product information, procurement, public relations or other business activities of the Company.

Your role

Giving Gratuities and Business Courtesies – As an employee of Rockwell Collins, you should not offer or approve an offer for a gratuity or business courtesy which could be interpreted as an attempt to gain an unfair business advantage. Providing gratuities or business courtesies directly or otherwise to Government officials needs to be handled in accordance with Company policy.

Receiving Gratuities and Business Courtesies – Employees of Rockwell Collins should not solicit any gratuity or business courtesy at any time. In addition, you should not accept a gratuity or business courtesy if doing such could create an actual or perceived influence or unfair advantage in conducting business with Rockwell Collins.

Further guidelines and approval requirements are provided in Company policy.


• Have I been singled out to receive this gratuity or is this being offered to all customers?• Could my offer of this gratuity or business courtesy be construed as an attempt to gain special favor?

Policy: It is Rockwell Collins’

policy that its employees and

representatives must conduct

business with customers (including

U.S. and Foreign Governments) and

vendors on the basis of service, quality,

performance and price without giving

or accepting anything of value that could

influence or appear to influence the outcome

of a transaction. Further, it is against the law for

employees or representatives of a U.S. corporation

to give anything of value, directly or indirectly, to an

official of another country in order to obtain or retain

business or influence an official act or decision.

Gratuities and business

courtesies

1� 1�


As a public company there can be no compromise in the proper maintenance of our books, records and reports. The information from these records becomes a building block for our public reports to shareowners and regulators as well as for prices charged to our customers. Incorrect time charging or other business entries violate the trust of our customers, shareowners, vendors and may also violate the law.

Your role

Accuracy of the Company’s books and records begins with each of us. Whether the records are time cards, expense reports, general accounting records, or purchasing or manufacturing records, each of us has a personal responsibility to ensure that every document is complete and accurate.


• Am I charging my time accurately?• Does the Company record I created accurately reflect the transaction?• Have I reported accurate information that may be used in the Company’s public reports?


that books and records must be

maintained in accordance with good

accounting practices and all applicable

laws and regulations. All time and

costs must be accurately and completely

recorded in an auditable manner. No false,

misleading or artificial entries may be made in

the books and records of the Company.

Company books,

records and reports

1� 1�


At Rockwell Collins we believe in honest and open communication. As a public company, we also understand that an important purpose of the public disclosure laws is the protection of the securities marketplace so that all investors uniformly have timely access to material information. Selective disclosure of material nonpublic information to certain investors (e.g., securities analysts and institutional investors) or failure to disclose material nonpublic information in public filings that make our public reports misleading may subject the Company and/or its employees to substantial fines or imprisonment.

Information is considered “material” when consistent with the materiality standards discussed in the Insider Trading section of this document. Further guidance on specific information required for disclosure can be found in Company policy or by contacting the Office of the General Counsel.

Your role

We expect employees to notify members of the Office of the General Counsel, the Office of the Chief Financial Officer or the Disclosure Committee of any and all potential material matters relating to our Company early in the process. Disclosure controls and procedures need to be followed to ensure material information is reported to the General Counsel, Chief Financial Officer or a member of the Disclosure Committee.


• Do I have information which may be required to be disclosed in public filings?• Have I informed the General Counsel, Chief Financial Officer or member of the Disclosure Committee of material information?• Before I disclose this material information outside the Company, have I considered whether such a disclosure would violate the rules against selective disclosure?


policy that we will provide full, fair,

accurate, timely and understandable

disclosure in public communications.

In addition, selective disclosure of

material nonpublic information to certain

investors (such as securities analysts or

institutional investors) is prohibited.

Disclosure of material

information

�0 �1


Our continued success depends on the appropriate and effective use of Company assets to benefit the organization as a whole. Improper use for nonbusiness purposes could reduce profit to our shareholders, increase prices to our customers and, ultimately, result in decreased business and fewer jobs.

Rockwell Collins defines Company assets as facilities, equipment (including computers and phones), electronic and telecommunications media as well as any proprietary information that are used for conducting business.

Your role

Treat all Company assets with respect and keep in mind that access to these resources is a privilege. Use common sense when using e-mail, telephones, faxes or other Company resources and ensure that such use is not inappropriate, excessive or interfering with your responsibilities as an employee of Rockwell Collins. Remember that all software is to be used in accordance with applicable license agreements. Use of unauthorized computer software violates Company policy and may be in violation of federal copyright statutes.


• Does the use of Company property serve the business interests of Rockwell Collins?• Am I spending excessive amounts of time sending personal e-mails or talking on the phone to friends about nonwork related subjects?• If I forward an off color joke to my co-worker, could that be considered offensive to other employees?


that Company assets are provided

for the purpose of serving the business

interests of the Company and may

not be used for any illegal purpose, to

support a personal business venture, for

political purposes or any purpose which would

cause embarrassment to Rockwell Collins.

Excessive personal use of Company property

is prohibited as well. Downloading, storing or

transmitting information which contains obscene or

explicit language or images that are offensive are also

prohibited.

Using company

resources

��


Rockwell Collins strives to be the supplier of choice and is committed to providing the best quality, delivery and service. Our reputation depends on diligent adherence to customer and contractual specifications. Any unauthorized deviation could violate the contract and adversely affect our customers’ faith in the integrity of our products.

Your role

It is imperative that all employees design, manufacture and test our products in strict accordance with all contract requirements and document any authorized deviations. Even if the product arguably exceeds contract requirements, such noncompliance must be approved and documented. Rockwell Collins accepts responsibility not only for the design or manufacturing defects in products that we make, but also for any such defects in products or components manufactured by our suppliers and resold by us. The best way to support product integrity is to consistently follow Company processes intended to assure quality, safety and reliability.


• Am I adhering to the customer and contractual requirements?• Have I sought approval and accurately documented any deviations to the contract?• Is the test or manufacturing procedure required by the contract or manufacturing instructions?


that our products and services

must be accurately represented to

our customers and meet or exceed

requirements for safety, reliability,

quality and performance throughout

their life cycle.

Productintegrity

��


Unauthorized disclosure of Company sensitive or unauthorized possession or use of someone else’s sensitive information, could compromise customer trust in Rockwell Collins and may expose the Company and the employee to legal liability.

Employees must be familiar with established policies and procedures that govern the protection of information. This may include:• Company sensitive information • Third party proprietary data• Employee personal data• Government classified information If governing laws are violated, the Company and the person or persons involved in the violation could face substantial fines and/or imprisonment.

Your role

You must take care in protecting the Company’s proprietary information which includes both technical and nontechnical information.

Additionally, using another company’s proprietary information without their permission can have serious implications for you and Rockwell Collins. Using unauthorized proprietary information of others, including that of competitors, customers, suppliers or individuals could expose the organization to legal liability. You should never share proprietary information belonging to your previous employer with any person at Rockwell Collins.

When in doubt, seek guidance and remember, your obligation to protect Rockwell Collins’ proprietary information extends not only to your period of employment, but also after your employment with Rockwell Collins ends.


• Is the information I am about to receive, someone else’s proprietary or confidential information?• Is this proprietary information that I learned from my previous job?• Have I sought the proper authorization prior to sharing Company proprietary information with non-company employees?


policy to proactively safeguard all

information that could be reasonably

considered Company Sensitive (which

includes Company Official Information

and Proprietary Information) as a means

of preserving Rockwell Collins’ integrity and

protecting our competitiveness, profitability

and security in dealing with all outside parties.

It is also Rockwell Collins’ policy to not use another

company’s proprietary information without

their permission.

Protecting information

��


In today’s global economy, providing or receiving hardware, software or technical data to and from a foreign company can be a highly complex process. Not only do you need to be aware of and comply with our country’s import/export laws, you must also act in accordance with the laws and regulations of the applicable Government that controls such technology transfers. Certain licenses or other Government approvals may be required to export or import products, services or technical data. Noncompliance of the export and import laws and regulations can result in serious fines for Rockwell Collins and may even include a loss of export privileges. Moreover, Rockwell Collins may not cooperate with, and must report to the U.S. Government, requests that are prohibited by the U.S. antiboycott laws and regulations.

Your role

Early coordination with Company experts is critical. Export and import regulations are often complex and based on the type of goods, technology or services being exported or imported and the intended destination. The identity of the customer and the intended end user (if different) is also critical.

Compliance with export controls is more than simply shipping product overseas. It may also include any visual disclosure or discussion involving technical data with any foreign persons, abroad or in the U.S., including foreign national employees, consultants, temporary employees or contract laborers.

The bottom line is to seek help and guidance before taking action which could expose you or the Company to violations of import, export or antiboycott regulations.


• Is the technical data controlled by any export or import regulations?• Do we have a license or agreement to share this technical information with a foreign person?• What are the export or import restrictions associated with this technology?


policy to abide by applicable

export and import rules and

regulations whenever and wherever

Rockwell Collins’ business is being

conducted. Sharing, selling, giving,

receiving or otherwise transferring Company

products, services or technical data to or from

a foreign person or entity must be in compliance

with export and import rules of the United States

and the foreign territory. In addition, there are

antiboycott laws and regulations which prohibit us

from assisting in the boycott of another country.

Export, import and

antiboycott compliance

��


The consequences of failing to follow antitrust and competition laws can be severe. Often this results in the violator being subject to criminal penalties, including imprisonment and/or significant fines as well as exposure to damages.

Certain types of conduct clearly violate U.S. antitrust laws and the competition laws of countries where business is being conducted. This type of conduct includes:

• Price fixing• Bid rigging• Market allocations of customers or territories• Group boycotts

Other types of conduct may or may not violate U.S. antitrust laws or the competition laws of countries where the Company does business. Employees must check with the Office of the General Counsel before engaging in such conduct, especially the following:

• Tying arrangements – requiring procurement of a Company product or service in order to be able to buy another Company product or service.• Exclusive dealing arrangements and requirements contracts.

Your role

Employees should have a general awareness of the types of business arrangements that have antitrust implications and contact the Office of the General Counsel before entering into such arrangements. Employees should promptly report potential antitrust/competition violations to the Office of the General Counsel.


• Does the proposed transaction involve prohibited conduct, such as price fixing, bid rigging, market allocations or group boycotts?• Does the proposed conduct eliminate competition or reduce the customer’s choices?• Will I be expected to share pricing or other competitive terms and conditions with competitors?


and good business to obey the

antitrust and competition laws of

every country where we do business.

Antitrust and

competition

�0 �1


Violations of applicable laws and regulations in performing under U.S. and Foreign Government contracts can lead to substantial fines and penalties, and in severe cases, suspension or debarment from receiving Government contracts. These laws prohibit conduct that might unfairly favor one contractor over another during Government procurement. Such conduct may include making employment offers or offering gratuities or business courtesies to Government procurement officials, or acquiring confidential source selection information related to the Government procurement.

Your role

All employees must exercise discretion, use sound business judgment and comply with applicable laws and regulations in dealing with Governments in all countries in which we operate. It is expected that Rockwell Collins employees will deal with Government representatives in an honest and ethical manner and avoid any circumstance that could be considered as deceitful or fraud, creating the appearance of an impropriety, or a conflict of interest.


• Do I and the members of my team understand the procurement laws and regulations that affect the Government customer or agency that we are dealing with?• Could an impartial observer characterize my interaction with my Government customer as being deceitful, creating the appearance of impropriety or creating a conflict of interest? • Is the information I am about to receive source selection information that I am not permitted to have under the procurement integrity rules?


policy and good business to obey

the laws of every country where

we do business. It is also the policy of

Rockwell Collins to deal with Government

representatives in an honest and ethical

manner and to comply with Government

procurement rules and procedures.

Doing business

with the government

��


Current and former U.S. Government employees are subject to federal laws and regulations that may limit the ability of the Company to recruit and hire certain individuals, and may limit the activities they may be able to perform for the Company. Depending on the circumstances, it may be against the law for you and that person to discuss potential employment with Rockwell Collins. Additionally, prior to engaging in employment discussions with Government officials in other countries, guidance should be sought to ensure compliance with local country laws and regulations.

Your role

Rockwell Collins employees, or anyone acting on our behalf, are prohibited from engaging in employment discussions with certain current U.S. Government employees. This means that you must not even discuss the possibility of employment with a current U.S. Government employee until they have formally notified their superior of such employment discussions.

Whether dealing with a U.S. Government employee or Government employee from another country, guidance should be obtained through the Office of the General Counsel to determine whether their employment could create a conflict of interest and/or a possible violation of law.


• Someone I have worked with on a Government program is planning to retire and I think she would make a great addition to the Rockwell Collins’ team. If I tell her I’d like her to come and work for us when she retires, will I be violating the law?• Do I understand the restrictions that apply to former Government employees who work for me?• Do I understand the rules related to discussing employment opportunities at our Company with current or former Government officials?

Policy: It Rockwell Collins’ policy

to conduct its recruiting and hiring

practices of Government employees

in accordance with laws and

regulations in which the Company

operates and not create the appearance of

an impropriety in this regard. Solicitation for

employment, employment discussions and

employment offers to current or former

Government officials (including military officers)

must be made in accordance with the laws and

regulations governing post-Government employment.

Recruiting

government employees

��


We are expected to deal fairly and honestly with customers, competitors, public agencies and subcontractors by ensuring that no data concerning customers or competitors is obtained or solicited contrary to law or regulation, and the confidentiality of procurement information is properly maintained.

For U.S. Government procurements, there is a ban on either obtaining or disclosing certain contractor bid or proposal information or Government source selection information. This includes competitive information submitted to a Government agency as part of, or in connection with, a bid or proposal to enter into a Government procurement contract. This may also include nonpublic information which has been prepared for use by the procuring agency in the evaluation of a contractor’s bid or proposal. These procurement integrity restrictions apply to everyone involved in a U.S. Government procurement and it applies until the contract is awarded.

Your role

Always exercise caution should a third party offer to provide you with bid, proposal or source selection information and pay special attention to receiving or disclosing marketing intelligence, which may include competitor’s price, cost data or program evaluation criteria.

Finally, all employees involved with any aspect of Government procurement must keep in mind that other confidentiality and nondisclosure restrictions may also apply.


• Do I and members of my team understand the rules of procurement integrity laws and regulations that affect the Government customer that we are dealing with?• Am I about to receive a competitor’s proposal information or Government source selection information that I am not legally permitted to receive?


to compete fairly and ethically in

all of its business dealings. As part of

this process, employees must strictly

comply with the laws, rules and

regulations that apply to U.S. Government

procurements. Employees are prohibited

from attempting to improperly obtain a

competitor’s bid or proposal information when

there is any reason to believe that obtaining such

information is prohibited by law or regulation.

Procurement integrity

��


The Company is limited by law regarding expenditures for lobbying activities, contributions to political parties or candidates and expenditures regarding ballot measures.

Contributions that are governed by our policy include, in addition to cash donations, any costs incurred by the Company on behalf of any political party or candidate for political office, or any ballot measure, including, e.g., postage, internal or purchased items such as graphics and printing, tickets to fund raisers and similar events, and the wages and benefits of employees for any time that they may spend during regular working hours in connection with such matters.

Your role

Employees are encouraged to participate in the political process as good citizens, but those activities must be engaged in during the employee’s own time and expense and may in no way be expressed as representing Rockwell Collins.

This does not preclude eligible employees from voluntarily participating in the Rockwell Collins Good Government Committee.


• If I expense a political fund raising event I attended, will it violate political contribution laws?• Have I contributed my own money to the Rockwell Collins Good Government Committee to help ensure our Company’s interests are being communicated to Congressmen?


policy to comply with all laws

relating to political contributions and

lobbying expenditures. Any direct or

indirect contributions to, or expenditures

incurred on behalf of, any political party or

candidate for political office, or regarding any

ballot measure, whether in the United States

or any other country, by any organizational

component of the Company are prohibited

unless approved by the Vice President, Government

Operations, after consulting with the General Counsel

and Chief Financial Officer.

Lobbying expenditures

��


The U.S. Government and many Governments of countries where we do business have established strict standards for the storage, use, treatment and disposal of a wide variety of materials and for the assurance of employee health and safety.

Failure to conduct our operations properly can have serious and damaging consequences for our employees, neighborhoods, customers, shareowners and the environment.

We are committed to not only comply with but, through continuous improvement programs, strive to exceed applicable environmental and employee health and safety standards by:

• Ensuring a safe work environment for all employees• Eliminating or minimizing the generation of hazardous and other wastes• Conserving energy, water and raw materials

Your role

You should be aware of your surrounding environment and help operate our business in a compliant and responsible manner which will protect our employees, our communities and our environment. All employees should be aware of Rockwell Collins’ environmental, health and safety policies and procedures and strictly adhere to them. Employees should report any concerns immediately to their leader or the Rockwell Collins Environmental, Safety and Health Organization.


• Is there anything I can do or suggest to make the Company’s workplace a safer environment?• Am I complying with the Company’s safety policies if I choose not to wear safety glasses?• If I only have a small amount of chemical waste, can I dispose of it in the sink without violating the strict standards for disposal of such wastes?


that all employees must comply

with all applicable environmental

and health and safety laws and

regulations.

Employee health and

safety and the environment

�0 �1


Preventing harassment, discrimination and threats is a matter of respecting each other’s rights and dignity, which is a basic value at Rockwell Collins.

Rockwell Collins’ employees and business associates are entitled to conduct their business in a work environment free of these distractions. To help ensure such an environment, we must all take any discrimination, harassment or threat seriously and promptly advise appropriate management.

Your role

As an employee, you are responsible for your actions while conducting Company business and are expected to treat co-workers, vendors, clients, customers and contractors with respect. Employees who do not uphold such conduct will be subject to disciplinary action which may include loss of employment with Rockwell Collins. Working together to support these standards of conduct will create an environment of respect and concern for others.


• Am I discriminating against our employee based upon age, race, color, religion, national origin, sex, sexual orientation, disability or veteran status?• Am I creating a hostile work environment or harassing a co-worker?• Have I witnessed conduct that appears to be unwelcome and sexual in nature?• Have I witnessed a co-worker returning from lunch with slurred speech and smelling of alcohol?

Policy: It is Rockwell Collins’ policy to

provide a work environment which

affords all employees the opportunity

to contribute to the best of their abilities.

For this reason, Rockwell Collins will not

tolerate discrimination, harassment/sexual

harassment, or physical or verbal threats.

The Company’s policy on equal employment

opportunity prohibits discrimination based on race,

color, religion, national origin, sex, sexual orientation,

age, physical or mental disability, and veteran status.

This applies to all terms and conditions of employment.

Additionally, all employees are prohibited from being

under the influence of, having possession or distribution of

controlled substances, or being intoxicated while on

Company business or on Company property.

Respect and concern

for others

��


Unethical behavior is wrong and can damage the Company. At Rockwell Collins, we believe upholding our Standards of Conduct is everyone’s responsibility. To that end, we’ve worked hard to create a culture of shared accountability, where everyone feels free to bring any ethical concerns forward.

Unfortunately, rules are sometimes broken. The Company must know about these violations so prompt and appropriate action may be taken. To help assure the Company’s Standards of Business Conduct are enforced, each employee should understand and accept their responsibility to report any violations and know they can do so without fear of retaliation. If any employee feels that he or she has been retaliated against for helping to uphold Rockwell Collins’ Standards of Business Conduct, it is the policy of the Company to take immediate action.

Reports to the Ombudsman may be made anonymously in the United States. Certain European data protection regulations discourage reporting violations anonymously and Rockwell Collins endorses this position. However these regulations permit reporting violation anonymously for our employees located in Europe under certain circumstances and Rockwell Collins will honor those requests for anonymity.

Your role

Employees are urged to seek answers or clarification if there are any doubtful or “gray” areas. We urge all employees to seek answers to questions concerning ethical behavior before it becomes a problem. Whether you speak to your supervisor, or someone in Human Resources, the Office of the General Counsel or the Ombudsman, there are multiple avenues available to you to raise your concerns or questions.


• As a leader, am I creating an environment where employees feel comfortable raising their ethical concerns?• I witnessed a violation of our Standards of Business Conduct. Who should I report it to?• I am experiencing retaliation for raising my ethical concerns to the Ombudsman, who should I report it to?


policy that if you have knowledge

of any activity that is or may be a

violation of the Company’s Standards

of Business Conduct, all employees

should promptly report such activity

to your supervisor, another member of

management, Human Resources or the

Ombudsman. Harassment of, or retaliation

against, an employee for making a disclosure to

the Ombudsman or any member of management is

prohibited by Company policy. Deliberately making a

false report is also prohibited.

Problem reporting

and resolution

��

For more information contact:Rockwell Collins400 Collins Road NECedar Rapids, Iowa 52498319.295.4085

RWEB (Intranet):

http://rweb/rockwellcollins.com/ent/ombudsman/ombudsman.htm

1��-0��-000-RC 0�/0� �0M BUS © Copyright �00�, Rockwell Collins, Inc.,All Rights Reserved, Printed in USA

Rockwell Collins - World Banksiteresources.worldbank.org/INTETHICS/Resources/Rockwell_Collins... ·...

Documents

Transcript of Rockwell Collins - World Banksiteresources.worldbank.org/INTETHICS/Resources/Rockwell_Collins... ·...