Corporate Policy Manual

Carrier’s success depends upon ensuring that the actions of its directors, officers, employees and representatives all over the world are in full compliance with the letter and spirit of all applicable laws and regulations as well as Carrier’s Code of Ethics (the “Code”). The purpose of the Carrier’s Corporate Policy Manual (“CPM”) is to establish critical policies and procedures designed to help ensure such compliance. This policy sets forth the applicability, governance and procedures for issuance and revision of all policies contained in the CPM. This policy also defines frequently used terms.

CPM 1: Governance & Definitions

At Carrier, we are committed to protecting what matters – our people, our stakeholders and the environment. We will create a world where every person is safe and comfortable by designing, sourcing, producing, marketing and delivering our products and services in a secure, environmentally conscious and socially responsible manner.

CPM 2: Environment, Health and Safety Policy

Carrier will establish and maintain proactive product integrity programs to ensure the quality and safety of the products and services it provides. These programs, designed to prevent product and process defects, will assure that Carrier customers receive products and services that meet or exceed all stated requirements.

CPM 3: Product Integrity

Carrier is committed to the highest standards of ethics and compliance. This commitment is reflected in our Code of Ethics (“Code”), which goes beyond what is required by the law and reflects our core values. The Code is the foundation for everything we do, driving us to act in a manner consistent with the highest standards of business ethics. In so doing, we promote both our products and values everywhere we do business, giving us a competitive advantage in the market place.

Carrier expects full compliance with our Code and all applicable laws and regulations, in all places, all of the time. Our commitment is manifest by this Policy, the Corporate Policy Manual, and our Financial Manual, which set forth our rules for governance in certain key compliance areas. We will proactively identify our legal and regulatory risks and requirements, create programs to comply with such requirements, develop systems and controls to better ensure compliance, use technology to manage and promote our programs, and educate people to ensure they know and understand what is expected of them, and how to behave in a manner consistent with all laws and our Code. Then, in a systematic manner, we will self-assess, audit, and verify compliance, while also driving continuous improvement.

CPM 4: Global Ethics & Compliance Program

Each employee of Carrier, no matter what position he or she holds, is responsible to ensure Carrier's compliance with applicable antitrust laws (known in some countries as competition laws). These laws are designed to promote competition and protect consumers from unfair business arrangements and practices. Violations of antitrust laws can result in severe penalties and significant damage to the company’s reputation, including large fines and the loss of important contract, patent and license rights for Carrier as well as fines and jail sentences for individual employees. In addition to government suits, private parties can sue, and damage awards can be massive, as can the legal fees incurred to defend the suits.

CPM 5: Antitrust Compliance Program

An absolute priority at Carrier is to provide a safe working environment for all of our employees and other stakeholders who work at or visit our facilities throughout the world.  This policy and its supporting materials will help ensure Carrier remains faithful to this commitment. 

CPM 6: Physical & Electronic Secuirty

Carrier shall compete for business and pursue other business objectives solely on the merits. No corrupt payment, in any amount or form, shall be authorized, offered, promised, or made by or on behalf of Carrier to anyone, anywhere, for any purpose. Carrier’s Books and Records shall accurately record all company assets, liabilities, and transactions. No deliberately false or misleading entry shall be made in company Books and Records, and no alternate set of Books and Records or unrecorded fund or asset shall be established. Carrier shall prevent its assets from being used for money laundering or terrorist financing. This absolute prohibition against corrupt payments, non-transparent books and records, and money laundering or terrorist financing will be broadly construed and strictly enforced.

CPM 8: Anti-Corruption

CPSW 8G: Anti-Money Laundering

Carrier is subject to a diverse and complex set of international trade laws and regulations governing the international movement of our products, technical data, software and services.

International trade laws include export controls, economic sanctions and embargoes, import controls, and U.S. antiboycott requirements that are used by national governments and supranational bodies throughout the world to safeguard national security, prevent proliferation of weapons of mass destruction, support foreign policy objectives, protect economic security interests, and ensure health, safety and other standards.

Carrier’s global scale means that international trade requirements touch virtually every aspect of our business activities. Beyond the significant civil and criminal penalties, failure to meet our obligations can harm governments’ national security or foreign policy interests, disrupt business initiatives, delay fulfillment of customer commitments, and damage Carrier’s reputation. Carrier is committed to conducting business in full compliance with all international trade laws and regulations.

CPM 9: International Trade Compliance

Carrier invests significant resources annually to develop new products and services, develop cutting edge technologies and manufacturing processes, develop and market its brands, and maintain competitively sensitive information and data in confidence. All of these critical assets include Carrier Intellectual Property which is entitled to a number of legal protections including Patents, Trade Secrets, Copyrights, Trademarks/Service Marks, and Proprietary Information, all of which Carrier invests in significantly to enhance competitiveness across its business portfolio. This Policy and referenced Procedures describe how Carrier protects its Intellectual Property and what is expected of its employees.

CPM 10: Intellectual Property & Data Protection

Carrier may donate funds, property, products, and services to reputable philanthropic organizations when provided openly and transparently for Philanthropic Purposes in approved focus areas. Donations that are unrelated to bona-fide Philanthropic Purposes, or that are offered or given in a concealed manner or to corruptly influence, are categorically prohibited because they are contrary to Carrier’s core values, misappropriate company resources, and expose Carrier to significant liability under anti-corruption and related laws.

CPM 11: Philanthropic Donations

Carrier shall compete for business and pursue other business objectives solely on the merits. No corrupt payment, in any amount or form, shall be authorized, offered, promised, or made by or on behalf of Carrier to anyone, anywhere, for any purpose. Carrier’s Books and Records shall accurately record all company assets, liabilities, and transactions. No deliberately false or misleading entry shall be made in company Books and Records, and no alternate set of Books and Records or unrecorded fund or asset shall be established. Carrier shall prevent its assets from being used for money laundering or terrorist financing. This absolute prohibition against corrupt payments, non-transparent books and records, and money laundering or terrorist financing will be broadly construed and strictly enforced.

CPM 12: Government Relations

CPSW 12A: Government Relations Procedures & Requirements 

CPSW 12B: Climate Change

The securities and exchange laws of the United States, U.S. states, and other jurisdictions are designed to promote informed decision-making by the investing public by requiring full and fair disclosure of information about securities and the companies that issue them. These laws also support transparent and efficient securities markets and public confidence in them by prohibiting certain deceptive and manipulative practices such as deliberately misleading, fraudulent, or selective disclosures, insider trading, and other misuses of material non-public information. As an ethical company and an issuer of securities, Carrier is fully committed to these goals. Carrier, its directors, officers, and employees shall therefore comply at all times with the letter and spirit of applicable securities and exchange laws as well as this policy and associated procedures and guidelines.

CPM 13: Investor Relations and Securities Law Compliance

CPM 13A: Safeguarding and Preventing Misuse of Material Non-Public Information

CPSW 13B: Preventing Insider & Other Prohibited Securities Trade Practices

CPSW 13C: Investor Relations & Preventing Selective Disclosures

CPSW 13D: Ensuring Compliant Disclosure and Reporting to Investors

Carrier will retain records and data as needed to satisfy business needs and applicable laws and regulations. Carrier will maintain a database of current and historical records of certain corporate governance data as required to support Carrier’s compliance with applicable laws and its policies and procedures.

CPM 14: Records Retention and Corporate Governance Data

Carrier will identify, understand, and appropriately manage the risks of its businesses.

CPM 16: Enterprise Risk Management

This Carrier Engineering Policy documents provides clarification and instruction on a variety of key activities that enable engineering to deliver safe, reliable, and competitive products.

CPM 17: Engineering

The purpose of this policy is to ensure compliance with all applicable laws related to financial reporting, disclosure and controls and maintenance of the Carrier Finance Manual which documents Carrier’s accounting and financial policies.

CPM 18: Finance

This policy will serve as overarching guidance to the development of policies and practices focused on Carrier’s greatest asset, its employees.

CPM 19: Human Resources

HR-2: Non-Retaliation Policy - English

HR-2: Non-Retaliation Policy - German

The purpose of this Policy is to ensure that Carrier enters into Commercial and U.S. Government sales contracts on terms and conditions with which it can comply and which appropriately mitigate legal and commercial risk.

CPM 20: Commercial and U.S Government Contracts

This procurement policy (the “Policy”) intends to ensure that the goods and services Carrier procures are the product of transparent, objective, and cost-effective decision making and risk management governed by the principles articulated below.

CPM 21: Procurement

This procurement policy (the “Policy”) intends to ensure that the goods and services Carrier procures are the product of transparent, objective, and cost-effective decision making and risk management governed by the principles articulated below.

CPM 24: Data Privacy

This Carrier Product and Software Security Assurance Policy documents and provides clarification and instruction on a variety of key practices and activities that enable Product and Service development teams to deliver safe, reliable, and competitive Products and Services in a secure manner.

CPM 25: Product and Software Security Assurance

The purpose of this policy is ensure manufacturing and logistics activities across Carrier adhere to certain established protocols and procedures which enable us to timely and efficiently deliver safe, high-quality products and services to our customers.

CPM 26: Manufacturing & Logistics

CarrierFlight manages transportation of company directors, executives, and business guests via general aviation aircraft, whether owned or contracted by Carrier. Operation and use of such aircraft shall comply at all times with applicable laws and regulations, this Policy, and associated procedures and guidelines.

CPM 27: CarrierFlight Operations

Respect for human rights is foundational to Carrier’s values and The Carrier Way. We respect and protect human rights and labor standards consistent with the UN Guiding Principles on Business and Human Rights (2011), the Universal Declaration of Human Rights (1948) and the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work. 

CPM 28: Human Rights