Otis Supplier Code of Conduct

SAFETY | ETHICS | QUALITY
everyone, everywhere, every day
At Otis, our Absolutes - Safety, Ethics, and Quality - define how we think, how we makedecisions, and how we take action.
Our suppliers are critical to our success. To provide superior Otis products and services ina responsible manner, we require you, our suppliers, and everyone you work with, toshare our commitment to meeting these Absolutes. In many cases your contract withOtis may require your compliance with even more stringent or specific requirements.

SAFETY
Nothing is more important than safety – the safety of Otis personnel, our suppliers, ourcustomers, and the public who ride our products. Safety is at the heart of everything
Otis does, and we expect the same commitment to safety by our suppliers. We expectthat our suppliers will:• Assure a safe and healthy work environment for your employees, including
reasonable work hours and conditions, as well as your business invitees.
• Comply with or exceed all applicable environmental, health and safety rules,
including those regarding, chemicals, persistent organic pollutants,
hazardous waste, noise, and preservation of soil, water, and air. Train
employees on the same.
• Conduct your end-to-end operations in an environmentally friendly manner:
minimize waste, emissions, materials of concern, and consumption of energy,
water and raw materials in your sourcing, manufacture, packaging, andtransportation processes. If you must use chemicals or other materials thatpose a hazard to the environment, ensure that they are handled, stored,managed, and disposed of in a safe manner.
• You are encouraged to track, document, and publicly report yourgreenhouse gas emissions and develop an associated reduction plan.
• When you are occupying or using land, keep in mind principles of sustainable
development and management, preservation of the environment, respect
the rights of those who have claims to the land, and consider your impact tothe community.
• Provide products and services with safety as a key guiding principle.
• Comply, and ensure your shipping and packaging suppliers comply, with all
requirements of Standards to Secure and Facilitate Global Trade (SAFE)
Framework security programs of the destination country. For instance, theCustoms-Trade Partnership Against Terrorism initiative of the United States
Department of Homeland Security (C-TPAT), Authorized Economic Operator(AEO), or similar programs.
At Otis, we are determined to comply with regulatory and customer requirements
regarding the prohibition and restriction of substances and materials, including
hazardous substances and conflict minerals. Therefore, you must ensure that all
products and services you provide to Otis comply with applicable regulations. In
particular, you will:• Declare to Otis substances of concern contained in the goods you supply tous.Otis Supplier Code of Conduct

SAFETY | ETHICS | QUALITY
everyone, everywhere, every day••Implement policy and procedural processes regarding conflict minerals andexercise due diligence to investigate the source of these minerals and, in atimely manner, address any findings of concern.
Respond in a timely manner to Otis’ requests for evidence of yourcompliance with these requirements.

ETHICS
Millions of people trust Otis because they know that we do business the right way: theethical, lawful, and honest way. We expect our suppliers to operate with the samecommitment to integrity. In addition to respecting all applicable laws and regulations,
you must:• Respect the fundamental rights and freedoms of all persons who touch yourbusiness operations, treat all persons fairly with dignity and respect, and abideby all fair labor practices. Provide all employees, contractors, temporary
workers, business partners, jobseekers, and potential business partners with equal
opportunity without discrimination and free of discriminatory selection criteria. For
instance, no discrimination based on:o race, ethnicity, color;
o religion;o sex, sexual orientation, sex stereotyping, pregnancy (which includes
pregnancy, childbirth, and medical conditions related to pregnancy,
childbirth, or breastfeeding), gender, gender identity, gender expression,national origin;o age;o mental or physical disability, medical condition, geneticinformation;o culture, ancestry, national origin, language, citizenship status;
o socio-economic, marital, military or veteran status;o any other protected status.
• Respect employee rights to freely associate and bargain collectively as
they exist under applicable laws in the countries where you operate.
• Comply with all rules and applicable regulations prohibiting humantrafficking, child labor and forced labor, with regard to your employees,
contractors and all other persons in your supply chain. Ensure:o All work is performed voluntarily.
o No forced labor by means of violence, threats, or illegal restrictions onpersonal freedom.
o Employers and agents may not hold or otherwise destroy, conceal, or
confiscate identity or immigration documents, such as government-issuedidentification, passports, or work permits unless required by law. In thiscase, at no time should workers be denied access to their documents.
o No worker is pressured or required to perform tasks that will endanger thepersonal safety of themselves or others.
o No child labor or presence of situations where children are subjected toslavery or similar practices or engaged in hazardous work.
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Respect of the UN Convention n° 138 on the Rights of the Child and theILO Convention n° 182 on the Worst Forms of Child Labour. Note: UNConvention n° 138 defines a child as person under the age of 18, but
applicable national laws always prevail.
o No use of other prohibited forms of labor including trafficking ofpersons, bonded labor, recruiting for labor or services by means offraud, trickery, threat, or by taking advantage of another person’sdifficulties or vulnerabilities including anything that would cause theperson to believe their safety or the safety of a person known to themwould be threatened if they failed to provide or offer to provide thelabor or service.
o Workers shall not be required to pay employers’ agents recruitment
fees or other related fees for their employment.
o Workers’ rights to rest and vacation are respected.
Ensure goods and services are not mined, produced, or manufactured
wholly or in part with prohibited forms of labor.
Ensure that employees can perform their work in an environment free fromphysical, psychological, or verbal harassment or intimidation, or any other formof abusive conduct. No unnecessary interference by security forces.
Pay all workers a living wage and benefits which meets or exceeds theapplicable minimum wage and provide equal pay for equal work. Do notunnecessarily withhold wages; any withholding must be permitted andauthorized under applicable law.
Ensure that work hours are reasonable and do not exceed the maximum work
hours established by law.
o••••Respect anti-corruption, fair competition, and antitrust rules• Only compete on the basis of the merits of your products and services.
• Never engage in anti-competitive or unfair conduct, whether on behalf of Otis,
yourself, or others.
o Never rig bids, fix prices, share competitively sensitive information,
allocate customers or markets.
o Never engage in other unfair market practices.
o Never make misrepresentations regarding Otis’ products or services,
your products or services, or the products or services of others.
• Refrain from payments, services, gifts, entertainment, or other items to create
advantages which are intended to influence the way in which an Otis
employee or anybody else goes about their duties.
• Do not give gifts or entertainment to Otis employees.
• Never pay a bribe or make a corrupt payment in any amount, to anyone,
anywhere, for any reason whatsoever, whether on Otis’ behalf, your behalf, oron behalf of others.
• Treat all employees and business partners fairly with transparent decisions madebased only on merit and other factors related to legitimate business interests,
and without regard to race, religion, color, age, gender, gender identity orexpression, sexual orientation, national origin, marital status, veteran status, ordisability.
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Otis Supplier Code of Conduct

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everyone, everywhere, every day•

Avoid and report all conflicts of interest and any situations which could givethe appearance or perception of a conflict of interest in your dealings with oron behalf of Otis.

Protect information and respect IP and other rights• Respect the legitimate proprietary rights and intellectual property (IP) rights ofOtis and others.
• Take proper care to protect sensitive information, including confidential,proprietary, and personal information. Collect this information only whennecessary and legally allowable.
• Protect all information we provide to you and information that you
generate or develop in support of our programs from unauthorizedaccess, destruction, use, modification, or disclosure.
• Never use material, non-publicly disclosed information obtained during yourbusiness relationship with Otis as the basis for trading or enabling others totrade in the stock or securities of Otis or any other company.
Maintain accurate records• Promptly and accurately record all transactions and expenses related to Otis
in your books and records.

QUALITY
Everything Otis does needs to meet the very definition of outstanding quality. We rely
on our suppliers to have the same commitment and focus to quality. You must:• Have quality assurance processes to detect, to notify Otis, and to correct
defects in a timely manner to ensure delivery of products and services thatmeet all contractual, legal, and regulatory requirements.
• Properly complete all inspection and testing requirements performed
by appropriately authorized and qualified individuals.
• Complete required certifications accurately.
• Cooperate with our reasonable requests for information and support when weare investigating a potential or confirmed quality issue related to your products
or services.

HANDLING MISCONDUCT
If you suspect or become aware of misconduct related to Otis business, you must
promptly notify Otis. The easiest way is to send an email to Otis Global Ethics &Compliance at ethics@otis.com. For information on other reporting channels, including
anonymous reporting, please visit www.otis.com/reportingchannels.
You must facilitate the timely discovery, investigation, and reporting of actual orsuspected misconduct and implement appropriate corrective actions.
We also expect you to offer your employees and your business partners adequate
reporting channels, including anonymous reporting methods and support a speak up
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SAFETY | ETHICS | QUALITY
everyone, everywhere, every day
culture where legal or ethical concerns are raised without fear of retaliation. You
cannot take any adverse action against anyone who reports conduct that theyreasonably believe to be illegal or in violation of this Code or in violation of The Otis
Absolutes.

COMMUNICATING AND ENSURING COMPLIANCE TO REQUIREMENTS
We expect you to promote a commitment to ethical business practices anda commitment to the expectations in this Code. This includes:• Providing training to your employees on compliance requirements
and the expectations in this Code.
• Conducting reasonable due diligence to ensure compliance.
• Ensuring timely reporting of both actual and suspected violations.
You will permit Otis and its representatives to assess your compliance with theexpectations in this Code. This includes on-site inspection of facilities and review of
associated books, records, and other documentation. Upon request, you must provide
Otis with additional information and certifications evidencing compliance.
If your contract with Otis permits you to assign, delegate, or subcontract yourobligations or to procure products or services from others that will be incorporated inproducts or services acquired by Otis, you must flow down the principles in this Code tothese business partners. We will hold you responsible for ensuring compliance by yourbusiness partners and you must ensure that Otis has the right to also assess yourbusiness partners’ compliance with the expectations in this Code in performing work for
Otis including our right for on-site inspection of facilities and review of associatedbooks, records, and other documentation.
In the event of wrongdoing, you will cooperate with Otis for a full and fair
investigation. You will ensure that your business partners also fully cooperate if suchinvestigation involves their performance. You and your business partners must correct
any non-conformances identified during assessments.
This Code applies to all parties who provide materials, products, or services to Otis,
including but not limited to direct and indirect suppliers, distributors, licensees, andsubcontractors. Your acceptance of a purchase order and/or your supply of goods orservices constitutes your acceptance of the terms set forth in this Code.
Otis does not assume any duty to monitor or ensure compliance with this Code, andyou agree that you are solely responsible for full compliance by your directors, officers,
employees, representatives, and business partners. While Otis routinely seeks to partnerwith our suppliers to improve compliance with the principles set forth herein, we may
at any time choose to terminate our relationship with any supplier that fails to meet
our expectations under this Code.

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Otis Supplier Code of Conduct

SAFETY | ETHICS | QUALITY
everyone, everywhere, every day

QUESTIONS ?
For questions or concerns about this Code, you can contact your Otis Supply
Chain representative or Otis Global Ethics & Compliance at ethics@otis.com.

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