The Otis
Absolutes

Made to move you© 2020 OTIS ELEVATOR.

THE OTIS ABSOLUTES

What’s in this guideIntroduction

INTRODUCTION												LIVING OUR ABSOLUTES					03YOU ARE OTIS –The building blocks of being our best 				

04You make all the difference						

07Looking for direction? This is your compass				09

Our helpful checklist for making ethical decisions 			

10

PEOPLE, WORKPLACE AND ENVIRONMENT

11

Safety is always first11

Quality is the foundation of everything we do			

13

We are many voices: equal opportunity				14

We are better together: fostering a respectful workplace		

15

Protecting our environment 					

17Protecting human rights 						19Contributing to communities 					

20CUSTOMERS, SUPPLIERS AND MARKETPLACE 		21

Doing business globally 						22Fierce but fair competition 						

23Bribery, corruption, and choosing business partners wisely 		25

Conflicts of interest

27

Navigating public policy and political activity 			29

ASSETS, PROPERTY AND REPUTATION			

31

Protecting and respecting intellectual property (IP)			

31

Insider trading and how to avoid it 					

33Maintaining accurate records 					

34Getting personal, and serious, about personal information 		

35

Social media, possibilities and perils 				

37Dear Otis Colleagues,
We work in a fast-paced businessenvironment where decision-making
happens quickly and frequently. Some
decisions are harder than others, andsome present real ethical dilemmas. In
every case, we should all do the rightthing: protect human health and safety,
conduct business with integrity, andhonor our agreements.
At Otis, the way we work anddo business is summed up in our
unwavering commitment to ourThree Absolutes: Safety, Ethics,
and Quality. These core values
establish standards of conduct andethical principles that guide eachof us – regardless of geographic
boundaries, titles, functions orcultures – in our day-to-day decisions.

There is nothing more sacrosanct thanour Absolutes. That’s why our leadersmodel them and every one of ouremployees embraces them – it is whatgives you the honor of wearing theOtis logo.
As a member of the Otis team, it is yourresponsibility to speak up if you havequestions and take action if you suspect
wrongdoing. I can assure you: you will
never get in trouble for speaking up toprotect our Absolutes.
When we apply these principles to ourdaily work, we create an environmentthat allows us to pursue our vision giving people freedom to connect andthrive in a taller, faster, smarter world.

Judy Marks

President & CEO, Otis

YOUR RESOURCES						39Information and support						41Fine print and waiver						43													
2

LIVING OUR ABSOLUTES

Living our
Absolutes

THE BUILDINGBLOCKS OF BEING
OUR BEST
Welcome! If our culture reflects
who we are, then our Three Absolutes
define how we think, how we makedecisions, and how we take action,
every single day.

We give people
freedom to connect
and thrive in a taller,
faster, smarter world.
Safety, ethics, and quality are
absolutely core to us and what we do.
They’re the DNA of the Otis family.
They’re what drive us, and the world
around us, to new heights. And theseThree Absolutes are key to conquering
our challenges, communicating clearly,
and constantly staying one step ahead.
Because while we are many voices, we
all share a common pursuit to be ourabsolute best. It’s simply who we are.

4

LIVING OUR ABSOLUTES

Everyone,
Everywhere,
Every day

SafetyEthics

Quality

We may be in the businessof making a taller, fasterand smarter world, but wenever take shortcuts to getthere. That’s why safety isat the heart of everything
we do. So, whether it’s ourpeople building, installingor servicing our technology,
or the public riding on it,
we must always put

Our reputation is
priceless. Millions ofpeople, from customers
and shareholders, toemployees and passengers,
trust us because they
expect, and know, that we
do business the right way– the ethical, lawful andhonest way. Everything wedo and make runs on that

We want Otis to be the best.
Period. And we all havea role to play. Simply put,
we stand for outstanding
quality – from engineering,
manufacturing, installationand service, to selling,
marketing, and reportingon financials. That requires
everyone to work together,with the same commitment
and focus across the entire

safety first.

“Everything 		depends
on movingpeople safely.”spirit of integrity.

organization.

“Doing business“We deliver 		the right way –quality results
it’s who we are.” in everything
we do.”

6

LIVING OUR ABSOLUTESYOU MAKE ALL THE DIFFERENCE
It takes courage to live up to our high values. But speaking up when things don’t lookquite right, or when we believe we can do better, is simply how we work.
Everyone at Otis has a voice and is encouraged to use it. Listen to each otherand share your opinions. Are we in line with our Three Absolutes? Are we missing
opportunities? Is this really the right thing to do?
Asking a question or raising a concern might look easy, but it’s not always that
simple. That’s why good listeners abound at Otis. Your supervisors, your HR and legal
colleagues, your Ethics & Compliance Officers are all ready to help.
When in doubt, reach out. If you raise a concern, we’ll get to the bottom of it
thoroughly and fairly.
We have a consistent process to understand what happened, and why. When needed,
we correct the situation (which sometimes requires discipline) to prevent it fromhappening again.
IT’S EVERYONE’SRESPONSIBILITY TO:

IF YOU’RE A SUPERVISOR OR
MANAGER, MAKE SURE YOU:

Step up, help out, and set an
example – every time.

Create a positive, inspirational,
productive place to work.

Know the Otis Absolutes andput them into action.

Encourage everyone to comeforward with ideas, improvements,
and concerns.

Always go above and beyond.

Respond promptly and respectfully
to all reports.

i

You will never get
into trouble, ever,for speaking up if
something seems
unsafe, unethical orjust doesn’t seem right.

Want more info? Check out our Non-retaliation Policy.

8

LIVING OUR ABSOLUTESLOOKING FOR DIRECTION?
THIS IS YOUR COMPASSOUR HELPFUL CHECKLIST FOR
MAKING ETHICAL DECISIONS

Think of this guide as your blueprint for making Otis a safeand ethical place to do your highest quality work. It’s aliving document with clear guiding principles and it’s meant to
be internalized.

Elisha Otis built our company on integrity, and that’s been a common passion of
everyone who’s worn our logo since we first put brakes on elevators, way backin 1853. But leading with integrity takes focus. So, whenever you’re faced with an
ethical choice you should always ask yourself two fundamental questions before
you act:

You should know, down to your core, that we’re all
empowered, and responsible, for creating the workplace,products, and company that reflect our very best, even when
we’re faced with difficult situations.
Here you will find key responsibilities that we embrace as ateam, as well as resources for when you have concerns orface difficult decisions. Where helpful, we also offer policy
references and examples of similar situations.

1: Can I…?
Is this legal? Compliant? In linewith laws and policies?

2: Should I…?
Does whatever you’re about to domatch up with our Three Absolutes
and reputation? (Imagine if it goes
viral on the internet.)

If you answer ‘no,’ or even if you’re
not 100 percent sure about youranswers to these self check-ins,
take a moment and reflect:  
• What are your duties to 			everyone affected bythis decision?
• What happens if you goahead with this choice?
• What are the potential 			alternatives?

It’s absolutely okay to ask questions when you are unsure. You should. That’s partof your job. Talk to your supervisor, your HR or legal colleagues or your Ethics &Compliance Officer – that’s what they’re there for!

i For additional guidance, our Policy Manual and Financial Manual is the place to go.
10PEOPLE, WORKPLACE AND ENVIRONMENT

People, workplaceand environment
SAFETY IS ALWAYS FIRST
Otis safely moves the equivalent of the entire world’s population…every threedays. Think about all those millions of Otis colleagues, customers, suppliers andpassengers who trust us with their lives.
Why? Because safety always takes precedence over schedule and costs – and wenever apologize for that. In fact, it’s a point of immense pride for us and it’s why wealways put safety first.
Whether on the ground floor or 75 stories in the sky, anyone who steps into ouroffices and elevators, onto our jobsites and escalators, should feel confident andsecure, every time.
We call our fundamental work-safety principles the Cardinal Rules. They are built
into everything we do – from fall protection in the hoistway to controlling elevator
movement during service and electrical safety procedures on the jobsite.
Cardinal? Because they should never be broken: we want Otis workers and field
professionals to return home safely at the end of every day. We want you, andeveryone who interacts with Otis, to be safe.

i

For more information about safety, see our programs on Environment Health and Safety,
Product and Services Safety, Fatality and Serious Injury/Incident Investigation Reporting,
Substance, Drug, Alcohol Abuse Policies.

Following the safety rules comes down to a few key choices you make daily:
Observe all laws, standards andsafety guidelines that govern
your work.

Be comfortable giving andreceiving feedback on how we
can all be safer.

Spot and control risks, reportconcerns and near misses, so all
can be fixed.

Respect our security andemergency procedures soeverything and everyone isprotected.

Keep your workplace tidy
– inside and out – free fromhazards and injuries.

Abide by alcohol and drug
restrictions at work.

If you can’t follow the Cardinal Rules, stop immediately and contact yoursupervisor. Safety comes before anything else! You’ll never, ever get in trouble
for putting safety first.

Q: How does our zero-tolerance
drug policy affect my use ofprescription drugs?
A: If you are on prescribed medicine
that could affect your work
performance, you should mention it
to your supervisor or Human

Resources. In certain cases, prescription
drugs might impair judgment orawareness in a way that leads to unsafe
working conditions. By discussing
this, you can be sure you are properly
evaluated and observed, for the sakeof everyone’s safety

about your safety or that of others? Contact a supervisor, the Safety department, Humani Worried
Resources or the Legal department, an Ethics & Compliance Officer, or the Otis Hotline.

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PEOPLE, WORKPLACE AND ENVIRONMENTQUALITY IS THE FOUNDATION OF
EVERYTHING WE DO

WE ARE MANY VOICES:EQUAL OPPORTUNITY

The work we all do at Otis has a real, significant, and measurable impact on
people’s lives. Day and night, around the globe, our passengers and customers trust
our unbending commitment to quality to get them safely where they’re going.

The more openly we think, the better problem-solvers we become. That’s why werely on as many different points of view as possible to move the world forward. Our
Otis family includes over 68,500 distinct voices and each one is heard.

But making, installing and upkeeping the world’s best elevators and escalators is only
one way we’re obsessed with quality. This deep-held promise can be felt throughout
all of Otis – we all strive to deliver flawlessly on our daily commitments.

We do not discriminate, whether on the basis of race, religion, nationality, gender,
age, ability, veteran status, marital status, citizenship, creed, sexual orientation or any
other bias. Why? Because it’s the right thing to do – and the right way to do business.

“Every one of us owns quality.”

We also make sure all our hiring and promoting is based fairly on skill andperformance. And as champions of diversity and inclusion, we make accommodations
for employees or job candidates who are alter-abled and observe all applicable laborand employment laws.

TO BE THE MOST TRUSTED PROVIDER IN THE INDUSTRIES WESERVE, WE:
Take full responsibility for the workmanship and service we provide.
Act passionately to eliminate quality issues at their source.
Respond quickly to resolve any problems and satisfy our customers.
Never sacrifice quality under any circumstance.

i

For more information, see our policy on Quality.

i

For more information, see our Managing Workforce Diversity Policy and Equal
Employment/Affirmative Action Policy.

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PEOPLE, WORKPLACE AND ENVIRONMENTWE ARE BETTER TOGETHER: FOSTERINGA RESPECTFUL WORKPLACE
What creates a great workplace? What makes you think this is so Otis? For morethan 165 years we’ve pioneered a safe, ethical (there are those Absolutes again!),trusting environment where we can each freely express our thoughts and ideas, ask
questions and make helpful suggestions – a place where we can all do our best work.

“You can walk into an Otis facility anywhere in theworld, and there’s something about it that feels
familiar. There’s a feeling that this is Otis.”
The cornerstone of all of this? Respect. And that’s where you come in. By addressing
situations that exclude or disrespect others, you put our Absolutes into action andfollow the law by:
Trusting and respecting each other, and taking action so that no one ever feels
threatened or intimidated.
Proactively discouraging any intimidating behavior and standing up to bullying
and harassment.
Reporting all forms of incivility and threats, whether or not you’re the target,
while promoting personal safety and empathy for others.
Speaking up and encouraging others to do the same. Express your ideas!
Offer your opinions! Ask questions, and listen openly to the ideas of others.

i

If you see or suspectharassment, contact
a supervisor, Human
Resources, an Ethics& Compliance
Officer, or the Otis
Hotline as soon as
possible.

For more information, see our Harassment-Free Workplace Policy.

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PEOPLE, WORKPLACE AND ENVIRONMENTPROTECTING OURENVIRONMENTWith great reach comes great responsibility. Otis
works in almost every country and territory in
the world, so we take our global duty towards theplanet seriously by setting ambitious sustainability
and conservation goals.

You have a part to play, too. We canall be catalysts of positive change tothe environment by:
Continually seeking opportunities
to conserve energy, water, andmaterials.
Working to design andmanufacture products that meetand exceed environmental andsustainability codes and goals.
Creating energy-efficient
escalators, elevators and systems
without compromising safety andquality.
Limiting pollutants to the lowest
possible levels across operations.
Expecting suppliers to use
sustainable practices.
Staying current on permits,
incidents, and waste disposal.

you have concerns about ani Ifenvironmental
issue, contact a supervisor,

Environmental Health & Safety (EH&S)
professional, Ethics & Compliance Officer,or the Otis Hotline.

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PEOPLE, WORKPLACE AND ENVIRONMENTPROTECTINGHUMAN RIGHTSCONTRIBUTING TOCOMMUNITIESCreating a world where people connect and thrive starts with basic human rights
and quality of life for people around the world.

Everything we do at Otis, from our lift cables to our volunteer efforts, makes
modern life better. That’s a vision we take into our communities, too, drawing
strength and inspiration from the places we work and live – because when ourcommunities are stronger, we’re all stronger.

With safety, ethics and quality as our North Star, Otis respects and protects humanrights everywhere we do business by:
Ensuring safe and healthy working conditions for our employees andbusiness partners.
Never using forced or child labor, ever.
Only working with suppliers who share our same standards.
When good citizenship calls, we answer – and engage with others to promote betterworking conditions for all.

To that end, we absolutely support participation in vibrant charitable opportunities
and social improvement efforts. Become active in your communities and show
support by celebrating the roles your coworkers take as volunteers, mentors, anddonors, and get involved yourself by engaging in causes that have been researched.
But remember, kindly refuse anything offered in return for charitable contributions (asyou’ll learn about in the sections to come).

Q: I’m going to volunteer at acharity fundraiser this weekend.
Is it okay if I represent myself as
an Otis employee because I know
the company has been a longtime
supporter of this charity?

i

See our Supplier Code of Conduct, Human Trafficking Policy, Conflict Minerals Policy for more.

i

A: You should go and be proud of
Otis’ commitment to the organization.
But discuss it ahead of time withyour supervisor to understand if Otis
wants an official representative at theevent too.

For more information, see our Charitable and Philanthropic Donations Policy.

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CUSTOMERS, SUPPLIERS AND MARKETPLACE

Customers,
suppliers andmarketplace

DOING BUSINESS GLOBALLY
We have passengers, customers, and partners in just about every corner of theworld, which means we must stay aware of (and compliant with) all relevant rules thatguide global business.
This means closely following not only International Trade Compliance (ITC) rules – like
import and export laws, international sanctions, embargoes, and boycotts, but also
rules that thwart money laundering and terrorist financing.
The only smart way to quickly and safely move goods around the world (and to be
paid correctly) is to follow the rules. Not doing so could cost us our work licenses, ourreputation, and hefty fines. That’s why we:
Find out first if trade between countries is restricted or subject to controls,
boycotts or embargoes.
Keep a close eye on our physical and digital technology to avoid unauthorizedaccess, transfer or release (never letting it fall into the wrong hands).
Double-check that all government authorizations are handled correctly.
Screen transactions and parties for sanctions, end-use and end-user.
Classify all exported and imported goods and value them correctly.
Conduct business only with reputable and legitimate customers and takereasonable steps to prevent and detect suspicious payments.
When in doubt, just think about how we do business in general: the ethicalway – quality and safety for the right price – or not at all.

i

For more information, see our ITC policies.

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CUSTOMERS, SUPPLIERS AND MARKETPLACEFIERCE BUT FAIRCOMPETITION
When we win, we win fairly. Remember, everything we do and make, runs on that spiritof integrity. We’re constantly pushing ourselves to do better, for our customers and for
ourselves.
But providing quality and safety for the right price isn’t always as easy to pull off
as it sounds. Competitive intelligence should come through public sources andsmart thinking.
Fierce but fair competition means:

Dealing fairly with every customer, supplier, competitor and coworker,
every day.
Seeking competitive advantages through innovative problem solving, neverthrough arrangements with competitors about price, discounts, sales terms,
bids, or things like “I won’t sell to your customer or area if you don’t sell
to mine.”Staying alert when competitors are present – especially at industry
associations and working groups (always check-in with legal before
attending, too), and avoid making inaccurate or disparaging comments about
competitors.
Never taking advantage of anyone through manipulation or by abusing
confidential or proprietary information.
Doing otherwise could be against laws that protect free and fair competition (also known
as antitrust or competition rules).

more information, see our Antitrust Compliance Policy. If you suspect something of concern,
i For
walk away from the situation and immediately contact your legal colleagues.

Q: Before Otis, I worked for acompetitor. Just recently, I saw aformer colleague, and we’re still
friends. He’s preparing a bid for a new
infrastructure project and asked if Otis
was planning to bid. I told my friendthat I couldn’t talk about that.
Was that the right answer?

A: Yes, absolutely. There should be no
discussion about bids with competitors– even if you are friends. You shouldreport this conversation to your legal
department immediately.

24

CUSTOMERS, SUPPLIERS AND MARKETPLACE

BRIBERY, CORRUPTION AND CHOOSING
BUSINESS PARTNERS WISELY...you will never
get in trouble forstanding behind
our Absolutes,
even if you losethe deal.

No matter who they are, how big or small, and how much influence they have, you mustnever be persuaded by partners, businesses or anyone else to engage in bribery
or corruption.
What happens if a customer offers to close a deal, but expects to get something personalin return? What if a government official promises to get things taken care of quickly, but
expects a favor in return?
Giving and/or taking bribes is not only unethical and illegal, but it can also result in safetyor quality requirements being bypassed (compromising all Three Absolutes at once).
As we’ve mentioned, you will never get in trouble for standing behind our Absolutes, even
if you lose the deal. In fact, by preventing bribery and corruption, you not only protect
Otis and yourself, you also promote an open market and lessen corruption’s destructive
influence – all while standing out as honorable and transparent.

Some things to keep in mind when you are working with others:
Never improperly influence the decision of a customer or anyone else bygiving something of value – pride yourself on winning on merit.
Keep business gifts and entertainment modest, occasional and in line withcustomary business practice (and get pre-approval before giving or receiving
gifts of any kind when needed).
Retain accurate and complete records and formalize business relationships
in writing.
Only work with likeminded partners who share our commitment to all our Absolutes
and check this in advance.
Comply with all laws, rules and regulations.
Report any suspicions of bribery or other corruption quickly.

i

If you suspect something of concern, contact the legal team, your Ethics & Compliance
Officer, or call the Otis Hotline.

i

For more information, see our Anti-Corruption Policies (gifts, sponsoring third party travel,
donations, intermediaries), Supplier Code of Conduct, Conflicts of Interest Policy.

26

CUSTOMERS, SUPPLIERS AND MARKETPLACECONFLICTS OF
INTEREST
Everyone has personal and professional lives. That’s just life. But sometimes they
can intersect while working at Otis. Think about activities outside work, relationships
at work, and personal financial interests in Otis suppliers or customers – these cancreate conflicting interests.
There are a lot of ways your different lives can cross paths (from mistakenly using
corporate property to competing with the company) which can be a lot to think
about. So, how can you tell if you’re headed for a conflict of interest?

Can you (or someone close to you) benefit from what you at Otis
have agreed to do, say, or provide?

Follow these tips to be aware of conflicting interests:
Stay honest and loyal by not seeking or using for personal gain any opportunities,
resources, property, or information that belongs to the company.
Pay close attention when personal and financial connections of you (or of people
close to you) may influence your work.
Be transparent and recognize that intentions might be personally motivatedrather than in Otis’ interest.
Be careful not to let your personal obligations affect your professional duties.
Stay alert to conflicts and priorities when people in your personal life connect
with your professional life.
Speak up as soon as possible, even when in doubt, so that we can help you solve
the situation quickly.

Could it lead to you acting, now or later, outside the best interestof Otis?
The slightest ‘yes’ to any of the above may indicate a conflict of interest between
your personal and professional lives. Even apparent conflicts can be an issue because
they may lead others to think we’re acting improperly or that personal interests are in
conflict with our commitment to safety, ethics and quality.
Conflicts of interest must always be dealt with quickly and appropriately so that
there’s no perceived bias or unethical behavior. That’s why it is important to speak
up ahead of time, as soon as you see potential conflicts on the horizon. Only then can
we take the steps necessary to resolve the situation.

Q: My sister owns a great generalcontractor firm. A contract with Otis
would really make a huge difference
for her business. Am I allowed torecommend her?

A: Great question! It’s always best
to ask. We always look for the best
partners for Otis and that could be
your sister’s firm. To make sure that all
business decisions are ethical, speak
to your Ethics & Compliance Officer –they’ll help to guide you through theprocess quickly.

actual and potential conflicts should be disclosed to your Ethics & Compliance Officer as sooni All
as humanly possible. Our Conflicts of Interest Policy goes into further depth on this issue.

28

CUSTOMERS, SUPPLIERS AND MARKETPLACENAVIGATING PUBLIC POLICYAND POLITICAL ACTIVITY
As a company, we sometimes work closely withgovernments or regulatory agencies.
Otis may have an interest in political or regulatory outcomes,
and when we do, we work to advocate for our company orindustry. But whenever we participate in these processes, we
do so responsibly and lawfully.
We encourage and support your civic engagement, as well,while you:
Keep your actions legal and above reproach – and makeit clear when you’re expressing your personal views vs.
views of the company.
Tell your Ethics & Compliance Officer if you run for apolitical position.
Don’t make any political contributions on behalf of Otis
or use company funds.
Stay attuned to lobbying rules, public disclosure, andreporting requirements.

i

For more information, see our Government Relations andLobbyist Policies.

30

ASSETS, PROPERTY AND REPUTATION

Assets,property andreputation
PROTECTING
AND RESPECTINGINTELLECTUAL
PROPERTY (IP) AND
OTHER COMPANYASSETS

Through more than 165 years of innovation and hard work we put in every day, we
have created a robust portfolio of tangible and intellectual property: from assets andcopyrighted material to patents, software, know-how, and trade secrets.
That’s why we should all be guided by the same principle: use our assets only for
legitimate business purposes. In other words, we should protect Otis assets and ensure
their efficient use. It’s crucial you protect these assets by:
Staying on constant lookout for
waste, carelessness and theft, andreporting any suspected misuse or
risk that involves Otis assets.
Keeping Otis’ Intellectual Property(IP) and other proprietary information
safe and secure.
Telling us if you’ve invented
something (congrats, by the way!) so
we can start the patent process.

Disclosing proprietary information –even with coworkers – only if theyneed to know the information, andto third parties only if we protect our
information through a solid contract.
Understanding contractual or
regulatory requirements so that third
parties receiving our proprietary
information promise to protect it.
Nailing-down IP ownership andlicense rights on paper and throughregistration – before collaboratingwith others.

And just as Otis cares for its own property and assets (intellectual or otherwise),
we respect the legitimate intellectual property rights of others by:
Not soliciting, accepting, or using
assets or IP of others without lawful
approval.
Always licensing the work of others
that we use.

Double-checking that we’ve given
credit where credit is due.
Reporting counterfeit products andother intellectual property crimes assoon as possible.

i See our policies on Proprietary Information Protection and Software License for more information.
32

ASSETS, PROPERTY AND REPUTATIONINSIDER TRADING AND
HOW TO AVOID IT

MAINTAINING ACCURATE
RECORDS

Being an independent, publicly traded company is an honor for us. But this honor
comes with important responsibilities. When you work at Otis, you may come acrossinformation that is not known outside the company but if known could influence thestock market.

Whether it’s an annual report, a purchase order, a timesheet, an expense orsafety report, you’ll find quality recordkeeping habits behind all our smart businessdecisions. Shareholders also rely on accurate and transparent records to guide theirinvestments.

Trading stock on the basis of such important inside information is not only dishonest,
it’s also illegal. To stay out of the dangerous waters of dubious trading, make sure you:Complete and accurate books and records are an essential part of an honest, ethicalbusiness. They make our business more efficient and productive. They also protect us
against reputational damage and penalties.

Never trade stock when you haveimportant inside information.
Keep secret things secret, and neverpass inside Otis information on toothers (not even your friends andfamily) who could use it to boost
their financial portfolio. That, too, isdishonest, and a crime.

Wait at least two trading days
before trading stock once “inside”
information, like expected earnings,
new products or developments, hasbeen made fully public.

To always be your best:

Always ask for legal advice if you’rein doubt. Penalties can be severe:fines and even prison.

Record transactions and eventsaccurately and in a timely manner.

Protect non-public and personal
information you have.

Align budget proposals and economic
evaluations fairly and clearly.

Advise customers of errors andpromptly apply credits and refunds.

Never engage in inaccurate,
deceptive, or secret bookkeeping.

Retain and dispose of records
correctly, and keep all legal
records safe.

Any suspected record tampering? Mention it immediately to a supervisor, Ethics &Compliance Officer, legal Department, or the Otis Hotline.

i

For more information, see our policy on Securities Trading.

iMore information can be found in our Financial Manual, as well as our policy on
Retaining Records.

34

ASSETS, PROPERTY AND REPUTATIONGETTING PERSONAL, AND
SERIOUS, ABOUT PERSONALINFORMATION
Because we’re in the business of connecting people, we know each other well andoften share information and material: contact details, photos, data in your HR file,building access rights, and much more.
But increasingly across the globe, there are limits to what types of information you arelegally allowed to share (and gather) about others. Personal information, whether it
relates to you or a customer, supplier, another employee or any other individual,
even passengers, is confidential.
You know what else is confidential? Any non-public information that might be of use tocompetitors, or harmful to Otis or its customers, if it’s disclosed.
That’s why we protect everyone’s privacy, just as we protect our own, by:Collecting, using and keeping personal data only when necessary and legallyallowable.
Keeping personal information safe, and following our data security
procedures closely.
Never sharing others’ personal data, inside or outside Otis, without proper
permission and clearance.
Reporting weak spots in data security and data breaches quickly.
If you suspect unusual data activity or something that could put our data security proceduresin danger, contact your Ethics & Compliance Officer or Otis data privacy officer, legal
colleagues, or the Otis Hotline or privacy@otis.com.
more detailed procedures? See our policy on Personal Information and our Employee Privacy
i NeedNotice.

Q: My supervisor asked me to workwith a service provider to create ateam directory listing the employees
on my project with each employee’s
name, work telephone number,email address, home telephone
number, and photograph tofacilitate communication, teamwork,and sharing of contact informationin case of a crisis. Should I create

and provide that list to the service
provider?
A: Not before completing Otis’
Privacy Impact Assessment. All of theinformation requested is personal,
which means that you should follow
Otis’ standard work policy to confirm
that collection and sharing areappropriate.

36

ASSETS, PROPERTY AND REPUTATIONSOCIAL MEDIA, POSSIBILITIESAND PERILS
Social media is a great way for you to connect with those we’re working for
and with, whether sharing information, perspectives, or just inspirational
food-for-thought.
But as you know, information spreads quickly and unpredictably online and on social
media, so be careful, responsible, and sensitive any time you post.
In this age of lightning-fast digital communication, every Otis voice is guided by:
Being open and honest about our Otis identities when expressing opinions.
(Think: is this sensitive, non-public or confidential?) (Is it your opinion or Otis’?).
Considering what you’re sharing, and how it could be perceived. (Is theinternet really the best place for what I’m about to post?)
Deferring to those who are specifically authorized to speak for Otis.
Using your good judgment in refraining from disparaging or offensive remarks.
Always channeling our Absolutes when you’re using social media.

Q: We just released a cool video
explaining a breakthrough inconnected elevator technology.
Can I tweet a link to the video,
or should I just leave that to oursocial media team?

i

For more information, see our Social Media Policy.

A: As long as you’re certain it was
officially cleared for public release,
you can tweet about it, too (andabout being an Otis employee). We
absolutely encourage you to sharecompelling company content with yoursocial network when it’s been cleared
and approved.

38

YOUR RESOURCESYour resources

Would you ever use an elevator or
escalator that doesn’t work properly?
Of course not. That’s why our passion
for safety, ethics and quality is morethan an ideal; it’s a roadmap to achieve
success in all areas of our business.
Becoming one of the world’s mostrespected and top-performing
companies means delivering on-time,safe and defect-free technology andservices, every day, in every market.
We’re committed to sending all of ouremployees and field professionals homesafely every day. And always doing it theright way, the ethical way, the Otis way.

40

YOUR RESOURCESINFORMATION
AND SUPPORTWe provide a number of great
resources for you and encourage
you to always get in touch and seek
guidance on issues or questions
you might have.

“The fact of thematter is: if you see
something, speak up.
You will never be introuble for saying:‘This does notseem right’.”If you have a reason to believe
something’s wrong, or that the Otis
Absolutes are not being upheld, oreven if you just need some clarity about
the Absolutes, just say so. You should;
truthfully coming forward protects ourAbsolutes, but it also protects you. We
do not accept retaliation for coming
forward – because speaking up is rightfor our business. Again, it’s simply
who we are.

Help is just a phone call or emailaway and there are many ways to getconnected. Use the one that is most
comfortable for you.
At your business: Talk to a supervisor of
any level, the HR or legal department oran Ethics & Compliance Officer.
Anonymous: If you feel more
comfortable keeping your name toyourself and speaking anonymously,that is perfectly okay. And you caneven do it in your own language andat any time (available 24 hours/day
and 7 days/week).
A phone call to the Otis Hotline
An online form on the Otis Web-line
Post a letter to Global Ethics& Compliance at the global
headquarters.

i

Need to know more?
See www.otis.com/reportingchannels

42

Otis is the world’s leading
manufacturer and maintainer of
elevators, escalators and moving
walkways.
Founded more than 165 years ago
by the inventor of the safety elevator,
Otis offers products and services
through its companies in more than
200 countries and territories, andmaintains approximately 2 million
elevators and escalators worldwide.
Every day, Otis moves more than 2billion people through the world’s
urban landscapes.
For more information, visit www.
otis.com or follow Otis on LinkedIn,
YouTube and as @OtisElevatorCo on
Twitter, Facebook and Instagram.

Waiver of all or part of this document or otherpolicies issued to implement it will be granted only
in exceptional circumstances and only after approvalby the Vice President, Global Ethics & Compliance.
Any waivers for directors and executive officers must
be approved by both the Vice President, Global
Ethics & Compliance and the Board of Directors ora Board committee, and will be promptly disclosed
when required by law, regulation, or Otis policy.

OTIS WORLDWIDE CORPORATION
1 CARRIER PLACEFARMINGTON CT 06032
UNITED STATESOTIS.COM