UTC faces a wide range of business and compliance risks, including those associated with corruption. Through UTC’s Enterprise Risk Management program, a continuous process conducted by all operating units across the corporation, we identify, assess and mitigate risks that may affect achievement of our performance objectives. Senior management is responsible for the implementation of mitigation plans, including those related to prevention of corruption. All allegations of corruption are promptly and thoroughly investigated, and, if verified, reported to senior management for disciplinary and corrective action and, where appropriate, to the Audit Committee of UTC’s Board of Directors.
UTC’s commitment to anti-corruption includes the following:
- Corrupt Payments: UTC conducts all of its business solely on the merits. We will not bribe anyone to obtain or retain business or secure any other advantage, nor allow anyone to do so for our benefit, in any market — public or private — anywhere. As a general rule, employees cannot seek or accept any payments from anyone doing business with or seeking to do business with UTC.
- Books and Records: A fundamental requirement of our UTC operating system is the maintenance of fully accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and no UTC employee must ever make a deliberately false or misleading entry – no matter how small or immaterial – in our books and records. UTC maintains a robust audit program to ensure that all of our businesses are upholding these non-negotiable requirements.
- Third-Party Intermediaries: Our third-party intermediaries are subject to similar rules and will be selected after a robust due diligence process aimed at confirming their good business practices. Once on board, they will be trained and monitored. Intermediaries engaged in advocacy and sales on our behalf have limited term contracts (not to exceed four years), which cannot be renewed without a refreshed assessment.
- Training: Every UTC employee receives annual ethics and compliance training from their supervisor. More than 100,000 employees are provided with computers and given access to our Ethics & Compliance Education Center, where online training is also available. New employees complete nearly 20 ethics and compliance certifications and training courses in their first two years (with about half to be completed within 90 days); two of these modules specifically address corruption risk. Beyond the first two years, employees will continue to receive annual anti-corruption training if they hold a position that presents a higher level of corruption risk.
- Reporting and Investigations: In managing risk, UTC is conservative and data-driven. We apply our ACE operating system for continuous improvement and risk reduction.
In standing by our principles and complying with our Code of Ethics and company policies, we fight corruption and support the global development of fair markets. Our success relies on abiding by our core principles – regardless of what might be seen as customary or acceptable in a given market.