For nearly 100 years, ITW has remained financially sound and performed well because of our proven business strategies of 80/20, innovation and global growth. But there are other qualities that have made us a great company—the personal principles and integrity of ITW’s people. We believe strongly in equal opportunity and the health, safety and financial security of our employees, and we hold high standards for the conduct of every person in our organization.

ITW Code of Ethics

ITW has an established Code of Ethics for our Chief Executive Officer and key financial and accounting personnel that helps ensure our financial accountability and inspires trust in our employees, shareholders and customers. The Code of Ethics is based on six key principles: honest and ethical dealing; full, fair and accurate disclosures; legal compliance; prompt internal reporting; accountability; and consequences for violations of the Code of Ethics.

Governance/Board of Directors

ITW is governed by its Board of Directors, all of whom are independent except for the Chairman & Chief Executive Officer. The Board adheres to our Corporate Governance Guidelines, a comprehensive, transparent set of guiding principles and standards regarding board and committee structure, responsibilities, independence standards, board processes and CEO succession planning. To be considered independent, a director of the company must meet all of the guideline’s Categorical Standards for Director Independence. In addition, a director who is a member of the company’s Audit Committee must meet additional criteria to be considered independent for the purposes of membership on the Audit Committee.

Business conduct

As a global, decentralized company, with over 800 businesses, we face the challenge of complex local, national and international laws. Nonetheless, ITW is firmly committed to complying with all applicable laws, including employment laws, rules and regulations. We expect our business units to follow our Statement of Principles of Conduct—internal standards and principles of behavior that apply to all ITW operations, divisions and subsidiaries, regardless of where they are located. The document is disseminated in multiple languages to our employees around the globe, and our employees are encouraged to take action when a potential violation is observed.

Employee fairness

The statement includes an extensive section on employment, which details ITW’s strict prohibition against unlawful harassment, unfair or discriminatory conditions for employment and child labor. ITW also recognizes minimum wage and the right to bargain collectively, and we require adherence to any national employment standards where our companies do business. Although ITW is highly decentralized, our Statement of Principles of Conduct is a truly global, uniform policy that ensures we run our company according to the highest ethical standards.

Employee health and safety

Our Statement of Principles of Conduct also details the requirements that all of our businesses must follow regarding employee health and safety. General Managers at each of our businesses are held accountable for compliance with environmental regulations applicable to their facility. The statement is supplemented by the policies, tools and programs provided by our corporate Environment, Health, Safety and Sustainability (EHSS) Department. The EHSS Department maintains an intranet site that provides the business units with guidance and information on compliance and best practices for safety.

In 2009, we had three U.S. Occupational Health and Safety Administration (OSHA) STAR-certified facilities, one OSHA Merit facility, and two OSHA Safety & Health Achievement Recognition Program (SHARP) facilities. (Out of 120,000 eligible establishments, there are only 1,500 OSHA STAR sites in the U.S.)

ITW also tracks accident frequency data for selected businesses. In 2009, these business units had an average incident rate of 3.15 and a DART (Days Away from work and Restricted/Job Transfer) rate of 1.95. The most recently published (2007) Bureau of Labor Statistics rate for all manufacturing companies showed an average incident rate of 5.0 and an average DART rate of 2.7.

Connect|Well

To further support the well being of our employees, ITW launched a Corporate Wellness Committee in 2009 to help employees take charge of their health. ITW now offers Connect|Well, which includes life-saving, confidential biometric health screenings, access to live registered nurses and other personalized health programs. The Connect|Well program is free, available at over 300 locations throughout North America and includes incentives such as credits toward our employees’ health premiums.