Policy to Combat Slavery and Human Trafficking

 
Eaton Corporation plc is committed to ensuring that its suppliers do not use slave labor or engage in human trafficking.  Eaton’s Code of Ethics establishes respect for human rights as a fundamental Eaton principle, and one that both Eaton employees and suppliers are expected to honor.  Eaton’s Ethics Guide specifically prohibits Eaton suppliers from using forced labor of any kind.
 
Eaton suppliers are required to adhere to Eaton’s Supplier Code of Conduct (the “Supplier Code”), which can be found at:
 
 
Eaton requires its suppliers to certify compliance with the Supplier Code.
 
Under the terms of the Supplier Code, Eaton is permitted to audit its suppliers’ compliance with the Supplier Code, and in cases in which serious risks are presented, this audit may be immediate and unannounced.  Eaton monitors its supply chains for compliance with the Supplier Code; however, such monitoring is typically not focused solely on human trafficking or slavery.  And while Eaton regularly audits its suppliers for a variety of reasons, typically those audits are not performed solely to determine compliance with the prohibition against slave labor or human trafficking.  Eaton generally does not engage third parties to evaluate compliance with human trafficking or slave labor laws.  However, Eaton promptly and thoroughly investigates any claims or indications that a supplier is engaging in human trafficking or slave labor, or is otherwise not complying with Eaton’s Code of Ethics or Supplier Code.   Any such claim made through our Ethics Office would be reported to the Audit Committee of Eaton’s Board of Directors, along with the resolution of the claim and/or the findings of the investigation.   Supply Chain management and other Eaton executives receive training on Eaton’s Code of Ethics and Supplier Code, although specific training on eradicating slave labor or human trafficking is not generally provided.
 
Eaton will not continue to purchase goods or services from any supplier that is found to be engaging in human trafficking or using slave labor.