1. Gifts from Vendors

2. Gifts from Vendors: Case Summary 2 Juanita works in the marketing department and has met most of the vendors that work with her business. About a year ago, Juanita was playing in her tennis league and ended up playing against one of her Tyco vendors. During conversations at the match she expressed that she is an avid sports fan and has always enjoyed participating in and attending sporting events. Since then, the vendor has sent Juanita tickets to multiple sporting events. Juanita has attended many of the events herself, and shared the tickets with others, including co-workers.

3. Gifts from Vendors: Discussion Starters What would you do if you were Juanita? Are Juanita’s actions appropriate? What are the potential issues with and consequences of her decision to accept the tickets? Would the circumstances be different if: – the vendor sent Juanita one set of tickets to a local tennis tournament over the past 12 months? – Instead of tickets, the vendor sent Juanita a book to give her ideas for an upcoming marketing campaign? – the vendor invited Juanita to attend a sporting event with him so they could discuss his ideas for a new marketing campaign? 3

4. Gifts from Vendors: Guidelines In all cases, the acceptance of gifts, meals, or entertainment must comply with applicable industry codes and local law. All gifts valued at less than $125 USD are not required to be reported unless otherwise specified by your business. Any gift estimated at more than $125 USD must be reported at www.TycoComplianceForms.com and the employee’s direct manager. Submitted Forms will be routed to Human Resources for review and approval. www.TycoComplianceForms.com Any employee that is considering giving a gift exceeding $125 USD must obtain pre-approval at www.TycoComplianceForms.com.www.TycoComplianceForms.com Employees may not give cash or its equivalent to any present or potential customer, vendor, supplier, contractor or partner of Tyco. 4

5. Gifts from Vendors: Lessons Learned 5 The practice of providing gifts and business entertainment is commonplace. These often provide an important avenue for creating goodwill and establishing trust in business relationships. Gifts may include material goods, services, discounts, non- business related meals or entertainment, personal travel or lodging, or any other non-commercial benefit for an individual or organization. Whenever you are in doubt, discuss the gift or business entertainment offering with your boss or appropriate Human Resources specialist.

6. Raising a Concern It is important to help preserve our Vital Values and our reputation. If you see an action that makes you uncomfortable, or if you feel is inappropriate, there are many avenues that you can use to escalate a concern. They are: Supervisors Human Resources Representatives Law Department The Office of the Ombudsman or the ConcernLINE Vital Tyco Concerns website* (www.vitaltycoconcerns.com)www.vitaltycoconcerns.com *NOTE: Employees in France, Belgium, Germany, and Spain should only report financial-related concerns when reporting issues through the ConcernLINE or Vital Tyco Concerns website.