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Kevin J. O’Connor
Vice President,
Global Compliance

Kevin J. O’Connor was appointed Vice President, Global Compliance of United Technologies Corporation in March 2012.

Kevin joined UTC from the law firm of Bracewell & Giuliani, LLP where he served as Partner and Chair of the White Collar Practice Group since 2009. Previously, Kevin served in leadership roles in the United States Department of Justice (DOJ) including Associate Attorney General of the United States, Chief of Staff to the United States Attorney General, Associate Deputy Attorney General of the United States, and Chair of DOJ’s Intellectual Property Task Force. Kevin also served as United States Attorney for Connecticut and Senior Counsel with the U.S. Securities and Exchange Commission’s Division of Enforcement.

O’Connor is a trustee of the Federal Bar Foundation, a board member of St. Francis Hospital, and is Second Vice President of the University of Notre Dame Monogram Club.

He earned a B.A. from the University of Notre Dame and a juris doctor from the University of Connecticut School of Law.

Ethics & Business Practices

Latest News

January 19, 2011

Keynote Address at Ethics Resource Center Fellows Dinner, Remarks of Didier Michaud-Daniel, former Otis President, Washington DC – As Prepared

"We are proud of our performance culture at Otis and UTC… in addition to the other performance targets we expect from our business leaders, we require that they set and meet ethics targets and demonstrate ethical performance."


January 3, 2011

Using Program Structure to Improve Ethical Performance

A presentation to the PLI Corporate Compliance and Ethics Institute


Governance at UTC begins with our Code of Ethics, which was adopted by UTC’s Board of Directors. We aim to create value for stakeholders, build an ethical culture and achieve 100 percent compliance with laws and regulations.

Our Code of Ethics, adopted in 1990 and relaunched in 2006, goes beyond a recitation of rules and represents a framework for decision making. It identifies our values, our corporate commitments, and a process for decision-making. We operate under this single code, worldwide, with translations in 33 languages.

UTC’s ethics and compliance program includes (a) regular communications regarding ethics, (b) mandatory ethics training for all employees, (c) additional, online ethics training for salaried employees, (d) a formal process for risk management, (e) an ethics competency in personnel appraisal (which is applied to all salaried employees), (f) annual ethics objectives (which are cascaded from the CEO to others in leadership positions), (f) channels for reporting issues or raising questions (including the Ombudsman/DIALOG program), and (g) regular monitoring at multiple levels within the company. During 2010, the managers’ tool kit on risk management was expanded; a toolkit for new managers was created; the number of online training courses increased by 9, to a total of 270; and the total number of language versions for those online courses increased by 318, to a total of 1677.

Management works with a business practice organization, headed by Kevin J. O’Connor, Vice President, Global Compliance, and approximately 450 business practice officers (BPOs) worldwide. For the most part, the BPO is a part-time position for a full-time employee. The business practices organization oversees the Corporate Policy Manual, provides ethics training, investigates ethics issues, oversees compliance risk management, and assures that compliance audits are conducted. The business practices organization also works cooperatively with the functional departments, such as Finance, to assure the effective implementation of robust compliance programs. The business practices office at UTC HQ can be contacted here.

In 1986, UTC created its Ombudsman/DIALOG program, which is a worldwide, confidential communication channel that allows employees alternative means of asking questions, making suggestions, registering complaints and reporting suspected wrongdoings. Ombudsman/DIALOG is designed to facilitate clear communications, where management answers the inquiries, but where the identity of the person raising the inquiry is not revealed to management. More information regarding Ombudsman/DIALOG is available here.

UTC's Code of Ethics and other related brochures are available online in the PDF format. Click here to read the Code of Ethics. Click here to read the Code supplement brochures. You may download Adobe® Acrobat® Reader® here.