Limitations on Ombudsman/DIALOG

1. As communication intermediaries, UTC’s Ombudsmen and DIALOG Program Coordinators do not conduct investigations, and they cannot make or change any company policy or decision. If you believe the response provided by management (through Ombudsman/DIALOG) is inconsistent with requirements of law or UTC’s Code of Ethics, you can ask that Ombudsman/DIALOG refer the matter to the Business Practices organization.
2. Ombudsman/DIALOG has no capability to reply to an anonymous writer of a DIALOG, except those users of eDIALOG who create a personal identifier. Even for anonymous DIALOGs, Ombudsman/DIALOG follows its standard processes and forwards the inquiry to management for response and appropriate action.
3. The eDIALOG system is web-based, encrypted, and hosted outside of UTC. If a user of eDIALOG forgets his or her personal identifier, he or she will not be able to retrieve management’s response. If a paper DIALOG is sent anonymously, or without a return address, a direct response to the Ombudsman/DIALOG issue is not possible, nonetheless, the issue is sent to management for review and any appropriate action.
4. Ombudsman/DIALOG will not address an issue that is covered by a collective bargaining agreement or that is not permitted by applicable law. Ombudsman/DIALOG respects privacy laws. Under French law, for example, Ombudsman/DIALOG is limited to the following four categories: (a) accounting, financial, banking and auditing matters; (b) bribery and corruption matters; (c) anti-competitive matters; and (d) internal processes and controls related to (a), (b), and (c) above. For more information regarding Ombudsman/DIALOG in France, please click here.
5. If an Ombudsman/DIALOG contact alleges misconduct, management will perform an appropriate investigation. Responsive action is determined by management, and management will not act on an allegation that is not substantiated.
6. Before a DIALOG is forwarded to management, an Ombudsman or DIALOG Program Coordinator will remove information that might identify the DIALOG writer. There can be issues known only by a few people, however, such that the removal of information that can identify the author of a DIALOG inquiry, as a practical matter, can be difficult. In such cases, the better choice is to call an Ombudsman and discuss options for addressing the inquiry.
7. Ombudsman/DIALOG is available only with respect to inquiries directly connected with UTC, such as issues involving performance under UTC’s contracts or issues associated with UTC’s employees and its representatives. Ombudsman/DIALOG, for example, cannot address human resources issues at suppliers, or consumer issues.
8. UTC prohibits retaliation against any person who raises, in good faith, any concern with respect to policies or practices within the company, or for reporting anything the person reasonably believes constitutes a violation or suspected violation of UTC's Code of Ethics. However, reporting does not absolve anyone from accountability for personal involvement in wrongdoing.