Governance, Ethics & Risk Management
We hold ourselves to the highest standards of ethical conduct. That means doing what is right for our business, for the environment and for society. Several standards and policies guide our action. The Trane Technologies Code of Conduct applies to all employees throughout the world and confirms our commitment to ethical behavior and compliance with laws wherever we work. We also have a Global Human Rights Policy and an Environment, Health & Safety Policy. The company believes that the fundamental values set forth in these policies should serve as our global minimum business standards across our value chain.
While some of our standards and rules reinforce legal imperatives in places where we operate, each one reflects our commitment to fairness, honesty, and ethical business practices. Read more about our approach to governance, ethics and compliance in our 2020 Annual Report and on our website.
Code of Conduct
Our Code of Conduct embodies the standards we expect our employees to uphold both internally and externally. The Code covers dozens of topics, including labor relations, human rights, diversity, equal employment opportunity, affirmative action and harassment. It reinforces our values and describes how we interact with our customers, suppliers, colleagues, and government and regulatory bodies. The essence of our Code is simple:
- We act lawfully and ethically
- We ask if we have a question about the Code or an ethics issue
- We speak up to report concerns about unethical conduct
Signed by our Chairman and CEO, the Code applies to every employee, regardless of role or location, and to our Board of Directors (when they are acting in connection with their Trane Technologies-related duties). We also expect that all entities doing business with us practice the highest legal, moral and ethical standards as outlined in our Business Partner Code of Conduct. Read more about our approach to supply chain transparency and performance.
Our Code of Conduct and associated Anti-Bribery and Corruption Policy hold all our employees to the highest standards of integrity and legal compliance everywhere we do business. Our Code prohibits all company employees from giving and offering anything of value in exchange for business advantage. This includes a complete ban on facilitation payments to secure routine government functions, even though such payments are permissible under the Foreign Corrupt Practices Act.
Our business partners and service providers undergo due diligence reviews based on risk ratings. We use a third-party vendor to conduct compliance screenings from thousands of global public record databases. These screenings help identify any potential business partners who are not upholding our high standards for ethics.
Upholding Our Code
The Audit Committee of our Board of Directors annually reviews our compliance program, including compliance with the Foreign Corrupt Practices Act. Our Global Business Integrity Council and region-level councils set, approve, and operationalize compliance practices. Read more about our Corporate Governance Guidelines and board committees.
All salaried employees complete an annual Code of Conduct training program, including an attestation of their compliance. For 2020, salaried employees completed training on anti-corruption, conflicts of interest, fraud and financial crimes, IT security awareness and sexual harassment prevention.
Employees who have legal or ethical concerns have several ways to report an issue. They may contact the Ethics HelpLine, raise an issue with their manager, the Human Resources, Legal departments, the Ethics and Compliance Group, or the Internal Audit and SOX Compliance group. We take violations of our Code of Conduct seriously by investigating all reports to the Ethics HelpLine and taking remedial action to ensure compliance. Retaliatory actions are not tolerated.
Cybersecurity is a top priority for our company. We use industry best practices and tools, such as encryption and multiple layers of access control and authentication, to protect our customer and company data.
Our Cybersecurity strategy is overseen by the Audit Committee of our Board of Directors and directed by our Chief Information Officer. Our cybersecurity strategy, programs and policies are designed to protect the company’s most important information and technology assets from an ever-evolving landscape of threats.
All salaried employees complete an annual cybersecurity training program, where specific threats and scenarios are highlighted, based on our analysis of current risks to the organization.