I agree
I have read and agree to the processing of my personal information as described in sections 4 and 5 below.
This Data Protection & Privacy Notice (the “Notice”) applies to personal data submitted to the EthicsPoint system.
The data protection and privacy laws in some countries require that prior notice be given to a person who intends to submit a report through the EthicsPoint system containing personal data. The notice must set out how any submitted personal data will be used, processed, and retained and the person submitting a report must be asked for their consent to these terms of use and processing before they can submit a report.
This Notice applies to the personal data of the reporter or requester and of any other identifiable persons included in the report or in any supporting information submitted to the system.
You are asked to read and accept the terms of use and processing set out in this Notice. If you do not wish to accept these terms, we are unable to accept a report from you through the EthicsPoint system. We suggest that you make your report directly to your supervisor or manager or to a representative of Human Resources, the Law Department, or the Ethics and Compliance Office, depending on the nature of your report.
1. General
The EthicsPoint system, operated by NAVEX on Eaton’s behalf, is a web and phone-based intake system provided by Eaton to its employees, vendors, suppliers and business partners and those of its subsidiaries (“Reporters”) for reporting suspected or known violations of laws or regulations, Eaton’s Code of Ethics, or company policies.
You may contact Eaton with any questions relating to this Notice or EthicsPoint as follows:
Ethics and Compliance Office
1000 Eaton Boulevard – 4N
Cleveland, Ohio 44122
or
Ethics@eaton.com
To proceed further, you must read this Notice in its entirety and confirm your consent to its terms. If you do consent, check the I AGREE box. You will then be able to submit a report or question using EthicsPoint. If you do not provide your consent, you will not be able to submit a report or question through EthicsPoint.
You can withdraw your consent at any time by contacting ethics@eaton.com where your consent is the legal basis upon which we are permitted to process your personal data.
2. Use of EthicsPoint
Use of EthicsPoint is entirely voluntary. You are encouraged to report suspected or known violations or other concerns directly to your supervisor or manager, or to a representative of Human Resources, the Law Department, or the Ethics and Compliance Office, depending on the nature of your report. If you feel that you are unable to do so, you may use EthicsPoint to make your report.
3. Country Reporting Restrictions
The laws of certain countries may limit the types of matters that may be reported through EthicsPoint and may prohibit anonymous reports. When submitting a report, you will be asked to indicate the country in which the suspected issue or violation occurred. Please review the country-specific notice provided when you select the country for any reporting restrictions based on local law.
4. What personal data and information is collected and processed?
EthicsPoint captures the following personal data and information that you provide when you make a report: (i) your name and contact details (unless you report anonymously) and whether you are employed by Eaton; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e., description of role, functions and contact details); and (iii) a description of the issue or circumstances of the incident prompting the report.
5. How will personal data and information be processed after your report is submitted and who may access personal data and information?
The personal data and information you provide will be stored in a database which is located on servers hosted and operated by NAVEX in the United States. NAVEX has entered into contractual commitments with Eaton to secure the information you provide in accordance with applicable law. NAVEX is committed to maintaining stringent data protection and privacy and security practices, including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement.
For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed, and used by the relevant personnel of Eaton, including Human Resources, Finance, Internal Audit, the Law Department, the Ethics and Compliance Office, management, external advisors (e.g., legal advisors) or, in limited circumstances, by technical staff at NAVEX. Those individuals may be located in the United States or elsewhere.
Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data may be located in the United States or in another country that may not provide the level of data protection available in the European Union.
Your report and the personal data you provide will be kept as long as necessary to process your report and investigate it and, if applicable, as long as necessary to take appropriate follow-up actions including corrective actions or disciplinary sanctions or to meet our legal or financial requirements.
6. Accessing information concerning the report
Subject to applicable local laws and restrictions, you can request access to a copy of your personal data that is included in a report or otherwise stored in EthicsPoint. When considering requests for access to personal data submitted in relation to EthicsPoint, Eaton will consider the status of the requestor, the current stage of the investigation, the nature of the information held as well as Eaton’s Data Protection and Privacy policy and local legal requirements and restrictions.
In addition, you may request that your personal data be: (i) corrected, if it is inaccurate or incomplete; (ii) processed differently; or (iii) deleted. Deletion of personal data can only take place where it is no longer required for a legitimate business purpose and/or it is no longer required under Eaton’s record retention policy or by law to retain it.
To make a request to access to your personal data or for its correction or deletion, please contact the Ethics and Compliance Office at ethics@eaton.com.