ETHICS & COMPLIANCE

Integrity is the cornerstone of the way we do business at Textron. Our adherence to a high standard of ethical behavior is not only the right thing to do but has earned us the trust and respect of our customers, shareholders, employees and the communities where we live and work.

All Textron employees—regardless of position or title—are accountable for safeguarding and furthering the high ethical standards associated with our company in the global marketplace. Adherence to our policies and the laws and regulations of each country within which we conduct business is expected. Our values of integrity, respect, trust and the pursuit of excellence are the foundation of our culture of responsible and ethical behavior.

For more than 30 years, Textron’s Ethics and Compliance Program has provided a roadmap and resources for our employees and has continued to evolve in response to changes in our business and the legal environment in which we operate. The Program requires each of our business units to assess ethics and compliance risks annually and, based upon changes in the business, the operating environment and other factors, prepare annual risk-based Ethics and Compliance Action Plans which include action steps for risk mitigation. A variety of rigorous processes, including ongoing monitoring, audits to detect violations, self-assessments by each Textron business unit, live and computer-based compliance training and other performance checks, ensure we are on the right course. Where appropriate, we incorporate lessons learned from these performance checks into our Ethics and Compliance Action Plans and use them to improve our Program.

BUSINESS CONDUCT GUIDELINES

Textron’s Business Conduct Guidelines set a strict standard for business conduct in areas including conflicts of interest, protection of assets, equal opportunity, diversity, environmental protection, health, safety, personal data protection, gifts and entertainment and anti-corruption. Our Business Conduct Guidelines apply to our Board of Directors and every Textron employee and have been translated into multiple languages and dialects for use by Textron’s global workforce. They define our values and our code of conduct and point the way for all of us.

ETHICS & COMPLIANCE OVERSIGHT

Oversight of Textron’s Ethics and Compliance Program resides at the highest levels of the organization. The Textron Steering Committee on Corporate Ethics and Compliance Programs is responsible for oversight and review of the Program as well as its implementation and effectiveness. The Committee meets quarterly, and its members include Textron’s Chairman and Chief Executive Officer, Executive Vice President and Chief Financial Officer, and Executive Vice President, Human Resources. The Committee is chaired by the Executive Vice President, General Counsel and Chief Compliance Officer of Textron Inc., who also reports to the Audit Committee of the Board of Directors on legal, ethics and compliance matters at each Audit Committee meeting.

GLOBAL ANTI-CORRUPTION COMPLIANCE POLICY Textron’s Global Anti-Corruption Compliance Policy applies to our Board of Directors and every Textron employee. It provides detailed standards and processes related to interaction with government officials and onboarding and monitoring of third-party business partners. The Policy prohibits improper payments to government officials and commercial bribery, and it strictly restricts facilitating payments to extremely limited situations where they are necessary to ensure the safety, health or well-being of Textron employees or their family members. The Policy provides detailed approval processes that govern gifts, entertainment, hospitality, and travel expenses for government officials, as well as non-U.S. charitable donations and non-U.S. political contributions. It also requires periodic training, certification, and background checks for employees in high-risk positions.

With respect to third parties, the Global Anti-Corruption Compliance Policy establishes a risk-based due diligence process for the review, approval and appointment of sales agents, representatives, dealers, distributors, consultants, customs brokers, freight forwarders, lobbyists, joint venture partners, offset providers and teaming partners who will act on behalf of Textron outside the U.S. The policy also establishes requirements for the inclusion of specific compliance language in contracts with third parties, mandating specific processes for making payments and for ongoing monitoring and periodic review.

HUMAN RIGHTS

Textron is committed to respecting fundamental human rights throughout our global operations and our supply chain. For decades, our regard for human rights has been grounded in the values of our Business Conduct Guidelines. We recently reaffirmed and strengthened this dedication by creating the Textron Human Rights Commitment, a robust document that expresses our commitment to respect and protect human rights and sets forth the principles we expect our businesses and employees, as well as our customers, suppliers and other business partners, to uphold.

Key provisions of our Human Rights Commitment address the following topics: Non-Discrimination and Harassment, Work Environment and Compensation, Forced Labor, Child Labor and Human Trafficking, Health and Safety, Privacy, Freedom of Association and Collective Bargaining, Environment and Sustainability, Relationships with Suppliers and Business Partners, Ongoing Supply Chain Management, and Supplier Diversity.

To maintain a culture with respect for human rights, we provide and publicize multiple channels for employees to raise concerns regarding human rights without fear of retribution, including the Textron Ethics HelpLine. Textron strongly encourages any employee to report any potential violation of our Human Rights Commitment.

Read our full Human Rights Commitment.