Honeywell’s Integrity and Compliance program implements a number of key controls to reduce compliance risks.  These controls include the following key features:

• Mandatory training for all employees on Honeywell’s Code of Business Conduct.
• Formal company-wide procedures requiring training on health, safety, environmental stewardship and sustainability, non-discrimination and other employee workplace concerns, anti-corruption, trade controls, and business integrity.
• Robust integration processes to ensure that newly acquired companies understand and comply with Honeywell policies and procedures.
• Legal and compliance reviews of proposed transactions that take into account applicable legal restrictions, including health, safety, environmental stewardship, anti-corruption, trade controls and business integrity.
• Dedicated compliance resources, both at the corporate level and at the various business and regional levels.
• Automated order management systems and other IT tools at key sites to help ensure that no unauthorized orders are accepted or shipments made to sanctioned countries or sanctioned persons.
• Enhanced forensic audit capabilities that specifically address corruption risks.
• Robust internal reviews/audits of government contract sites.