ITT Industries Corporate Code of Conduct: Basic Principles

At ITT Industries, we are committed to always doing the right thing. That is why we have an ethics and compliance program and why we publish this Code. The Code is specifically designed to be part of an effective program to prevent and detect violations of law as set forth in the Organizational Sentencing Guidelines of the U.S. Sentencing Commission. Before you review specific principles, you should have a general sense of ITT Industries’ basic principles reflected in this Code. These principles are:
1) We will always be truthful.
2) We will strictly adhere to the letter and spirit of all laws.
3) We will provide high-quality products and services.
4) We will be a good corporate citizen. We will obey the laws and conform to locally accepted standards of good corporate citizenship in each country in which we do business.
5) We will promote and sustain a work environment that fosters mutual respect, openness and individual integrity.
6) We will be fair in all aspects of our business.

When faced with a business decision that seems to have ethical overtones, here are several questions you should ask yourself to determine if your actions are proper:
1) Am I adhering to the spirit, as well as the letter, of any law or ITT Industries policy that may be involved?
2) Would I want my actions reported on the front page of a newspaper?
3) What would my family, friends or neighbors think of my actions?
4) Will there be any direct or indirect negative consequences for ITT Industries?
5) Are my actions consistent with the overall values set forth in this Code and the ITT Industries Corporate Policy Manual?

This Code is not just for our employees. All consultants, sales agents and representatives must be informed about the ITT Industries Code of Corporate Conduct. In some cases, U.S. or other countries’ laws may impose on our business associates, including consultants, sales agents and representatives, an obligation to obey and to help us obey certain laws. Also, where the actions of our consultants, agents or representatives may be attributable to us, we must insist that they conduct themselves in accordance with this Code in carrying out those actions, and help us comply with applicable laws.
If you remain uncertain about what to do, stop and ask for help. Refer to the relevant section of this Code. Speak with your supervisor or, if you prefer, communicate with any of the other points of contact indicated in this Code.
If you have any doubt, ask for help.