Company-wide Policy Educational Assistance

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Company-wide Policy Educational Assistance Notice to Readers In this document, "Honeywell" or the "Company", shall mean Honeywell International Inc., its subsidiaries and affiliates, and their respective predecessors and successors. This Policy is not intended to create contractual obligations between an employee and the Company. In the United States and certain other countries, employment with the Company is "at will", which means that either the Company or the employee may terminate the employment relationship at any time and for any reason, without notice. The Company reserves the right to modify, amend, or rescind this Policy at any time. This Policy supersedes any prior policies of Honeywell International Inc. or its predecessors, subsidiaries, and affiliates, whether written or oral, on the topics covered herein. Please do not re-distribute, by re-posting on the Company's intranet or (public) Internet sites, this Policy or the documents referenced in Section 9, entitled "Forms and Exhibits." Please refer employees to the official Web site located at http://start.law.honeywell.com/gpp/. Should the reader discover (1) any local policies that cover topics already addressed in our Company-wide policies; or (2) any of our Company's policies posted on Web sites other than the official Web site, please report the address of the Web site and send a copy of the policies to the Policy Steward via electronic mail to: policy.steward@honeywell.com. Please do not re-distribute, by re-posting on the Company's intranet or (public) Internet sites, this Policy. Please refer employees to the official Web site located at http://start.law.honeywell.com/gpp/.

TABLE OF CONTENTS Approvals...1 Related Policies...1 1.0 Purpose...1 2.0 Revision History...1 3.0 Persons Affected...1 4.0 Policy...1 5.0 Procedure...3 6.0 Roles and Responsibilities...5 7.0 Definitions...5 8.0 Standards, Laws, and Regulations...6 9.0 Forms and Exhibits...6 1999-2009 Honeywell International Inc. All Rights Reserved. i

Educational Assistance Policy Owner: SVP of Human Resources & Communications Focal Point: Cynthia Robinson http://start.law.honeywell.com/gpp/2062 Approvals Approval Date Approval Role Title Name 11-JUN-2009 Policy Owner Approval SVP of Human Resources & Communications Mark James 11-JUN-2009 Legal Approval VP and Deputy General Counsel for Human Resources Kevin Covert 11-JUN-2009 Administrative Approval Policy Administrator Ashitha Varghese Related Policies There are no related policies. 1.0 Purpose This Policy and accompanying procedures provides financial assistance to Covered Employees for certain pre-approved educational expenses that support their (i) continuing growth in current assignments, or (ii) career development plans. 2.0 Revision History Effective Date Version Description of Change Section(s) Affected 01-MAR-1987 0.1 Policy 312 established. All 01-AUG-2009 1.0 Supersedes Policy 312, Version 0.1, reflecting updates to Version 0.1 and Conversion to new format. All 3.0 Persons Affected 3.1 All Employees of Honeywell International Inc. in the United States and Puerto Rico 4.0 Policy 4.1 Eligibility 4.2 Scope 4.1.1 This Policy is generally the exclusive mechanism to reimburse Covered Employees for approved Eligible Expenses. 4.1.2 Covered Employee does not include 1) any Honeywell employee who is on an authorized leave of absence; 2) any newly hired employee who was enrolled in classes prior to their hire date; or 3) any employee covered by a collective bargaining agreement, except to the extent such collective bargaining agreement specifically adopts the provisions of this Policy. 4.1.3 Adoption of this policy is determined by the SBG HRVP. 4.2.1 This Policy does not apply to Executive Development programs (e.g., Harvard, University of Michigan, or accelerated/weekend executive programs). Page 1 of 6

4.3 Approval 4.2.2 This Policy is also not intended to apply to individual courses offered by Honeywell or individual seminars offered by external organizations, unless such courses are part of an overall degree program. 4.3.1 A Covered Employee must gain approval from his/her supervisor/manager prior to registering for any courses. 4.3.2 Request and approval must be made through the on-line Education Reimbursement site. 4.3.3 N/A 4.3.4 N/A 4.4 Approved Criteria and School Qualifications 4.4.1 This Policy requires that the Covered Employee be enrolled in a degreed program and working toward a degree i.e. Associates, Bachelors, Masters or PhD. Courses taken on a non-matriculating basis will not be eligible for reimbursement. 4.4.2 Non-business related elective and prerequisite courses necessary to fulfill the degree requirements in an authorized field of study are generally eligible for reimbursement under this Policy. 4.4.3 The criteria for approval of an educational institution will be its accreditation and the quality of its education programs. Generally, this Policy applies to schools properly accredited by an accrediting agency recognized by the U.S. Secretary of Education. 4.5 Reimbursement 4.5.1 Covered Employees who successfully achieve the necessary grade requirement for an approved course and whose performance is At Standard or Exceeds Standard in both Results and Behaviors" as per the annual HPD assessment at the time the approval request is made shall generally be eligible for reimbursement of Eligible Expenses up to an annual maximum of $5250 for undergraduate (associate and bachelors) courses and $7500 for graduate (masters and PhD) courses. Part-time employees are subject to the same requirements and are eligible for 50% of maximum annual benefit. Classes already completed by August 1, 2009 or in progress as of August 1, 2009 will be reimbursed based on the previous policy and not be subject to the new caps. Classes beginning on or after August 1, 2009 will be subject to the annual caps and all tuition reimbursement for classes taken in 2009 will count towards the caps. 4.5.2 Employees who are approved to take both undergraduate and graduate classes in one calendar year are limited to a maximum tuition reimbursement of $7500. 4.5.3 N/A 4.5.4 N/A 4.5.5 N/A 4.5.6 N/A 4.5.7 N/A 4.5.8 N/A 4.5.9 N/A 4.5.10 N/A 4.6 Eligible Expenses 4.6.1 Eligible Expenses under this Policy include: (A) Tuition (B) Registration fees (C) Required text books (D) Required lab fees (E) CLEP exam fees (College-Learning Examination Program) or DANTE (F) On-line (electronic) course fees from nationally accredited institutions, provided they meet criteria for approval. 4.6.2 To the extent a Covered Employee receives financial assistance from other non-honeywell sources (including scholarships, grants, fellowships, veteran s assistance, etc.), these non-honeywell financial resources will be applied first and Honeywell educational assistance will apply to the remainder only. 4.6.3 In no case will an employee be reimbursed for more than 100% of the Eligible Expenses incurred, when considering all sources of financial assistance received. Page 2 of 6

4.7 Taxation 4.7.1 Federal tax law provides that up to $5,250 of eligible educational assistance reimbursements may be excluded from an employee s gross income. This $5,250 annual exclusion applies to eligible expenses for both undergraduate and graduate courses. 4.7.2 Qualifying reimbursements in excess of $5,250 may also be excluded from an employee s gross income if the reimbursements are for courses related to the employee s current job. A course is considered related to an employee s current job if (1) the course maintains or improves the skills or knowledge necessary for the employee s current job, or (2) the course is required by the employer or applicable law to keep the employee s current salary, status or job and the employee had previously satisfied the minimum educational requirements for his or her current position. However, reimbursement for a course that is part of a program of study that can qualify the employee for a line of work that is different from the employee s current job is not considered job-related and is taxable to the employee. 4.7.3 Reimbursements for non-job related courses in excess of $5,250 per year must be reported by Honeywell as taxable income to the Covered Employee. These taxable reimbursements are subject to applicable income tax withholding and employment taxes (including FICA). 4.7.4 If Eligible Expense reimbursements exceed $5,250 per year, the Covered Employee s supervisor must determine whether a course is job-related. Failure to properly classify educational reimbursements as taxable income can result in the imposition of IRS penalties and fines for underpayment of tax. 4.8 Payback Provision 4.8.1 If a Covered Employee voluntarily leaves Honeywell or is discharged for cause within one-year following a reimbursement under this Policy, such Covered Employee will be required to repay 100% of the reimbursements received within the 12 month period immediately preceding the Covered Employee's last day of active employment. Reimbursements must be paid in full upon termination. 4.9 Special Situations and Exceptions 4.9.1 Covered Employees affected by internal career advancement opportunities, shift changes or military service that adversely impacts the Covered Employees ability to successfully complete a course(s) will be reimbursed their Eligible Expenses upon the submission of documentary proof of payment and a written statement from their immediate supervisor summarizing the intervening circumstances. 4.9.2 Covered Employees impacted by a reduction in force will be eligible for reimbursement under this Policy even if their coursework is not completed until after their termination date. 4.10 Impact on other Honeywell Benefit Plans 4.10.1 Reimbursements under this Policy are not considered earnings or compensation for any Honeywellsponsored benefit plan. For example, educational reimbursements are not considered pensionable pay for purposes of Honeywell s pension plans. 4.11 Interpretation, Amendment, Termination of this Policy 5.0 Procedure 4.11.1 The Corporate Compensation & Benefits is responsible for the interpretation and regulation of this Policy. The site Human Resources Director must approve, in writing, any exceptions to this Policy. 4.11.2 The Company reserves the right to modify or terminate this Policy at any time; provided, however, that any modification or termination will not affect an employee s entitlement to reimbursement for Eligible Expenses hereunder to the extent such amounts were properly reimbursable under the terms of the Policy as of the date of such modification or termination. 4.11.3 This Policy supersedes any prior educational assistance or tuition reimbursement policy maintained by the Company for or on behalf of Covered Employees. 4.11.4 This Policy is not intended to create contractual obligations. Employment with the Company is at will, which means that either the Company or the employee may terminate the employment relationship at any time and for any reason, without notice. Page 3 of 6

5.1 Eligibility 5.2 Scope 5.1.1 N/A 5.1.2 N/A 5.3 Approval 5.1.3 Access to tuition reimbursement site is not available to employees whose location has not adopted this policy. 5.2.1 Where professional development discussions result in an employee s selection for an "Executive Development program", arrangements will be made and approved by the applicable business Vice President of Human Resources and the associated expenses charged to departmental expense budgets. 5.2.2 These types of seminars and courses referenced in Section 4.2.2 should be paid for separately through departmental expense budgets and not reimbursed as educational assistance under this Policy. 5.3.1 Request and approval must be made through the on-line Education Reimbursement site (https:// my.honeywell.com/secure/tuition/index.jsp). 5.3.2 Requests for educational assistance must be reasonable and consistent with the Covered Employee s past academic record and work performance, as determined by the Covered Employee s manager and Human Resources in their sole discretion. Eligibility for educational assistance under this Policy is a privilege, not a right. Approvals will be granted based upon individual performance and other relevant criteria. 5.3.3 When disputes arise over the approval of coursework for reimbursement under this Policy, the appropriate Human Resources representative should be consulted. 5.3.4 Approvals will generally only be granted for courses that are scheduled during non-working hours that qualify for credit toward an accredited college or post-graduate degree in an authorized field of study and satisfy at least one of the following criteria: (A) Enables the Covered Employee to maintain or improve the skills necessary for his or her current job. (B) Supports the Covered Employee s career development plan, together with the strategic business objectives of the Covered Employee s business unit. (C) PhD programs must be related to the employee's technical field of work that supports Honeywell s strategic business objectives. 5.4 Approved Curricula 5.4.1 Refer to Section 5.4. 5.4.2 Refer to Section 5.4. 5.4.3 Notwithstanding anything herein to the contrary, a business Vice President of Human Resources has the authority and discretion to limit such business reimbursement to a specific educational institution based on business needs or local circumstances. 5.5 Reimbursement and Scope 5.5.1 To receive reimbursement the Covered Employee must successfully complete the course with a grade of B or better. There is no reimbursement for a course if a grade of C or below is received. 5.5.2 For any graduate or undergraduate course where grading is only a satisfactory or unsatisfactory completion (e.g., pass or fail ), Eligible Expenses will only be reimbursed in the case of satisfactory completion, No reimbursement will be made for an unsatisfactory completion. 5.5.3 To receive reimbursement the Covered Employee s performance must be At Standard or Exceed Standard in both results and behaviors as per the annual HPD assessment at the time the approval request is made. 5.5.4 Amount of reimbursement of Eligible Expenses is up to an annual maximum of $5250 for undergraduate (associate and bachelors) courses and $7500 for graduate (masters and PhD) courses. 5.5.5 Requests for reimbursement must be submitted within 60 days of course completion. Please refer to your Human Resources representative for details about how to apply for reimbursements under this Policy. 5.5.6 Reimbursement requests which meet the necessary requirements will be processed at the completion of the course. Page 4 of 6

5.5.7 All reimbursed expenses are charged back to the employee s department. 5.5.8 Reimbursement is evaluated on a course-by-course basis and courses must be approved by the Covered Employee s supervisor/manager prior to enrollment. 5.5.9 Reimbursements for both undergraduate and graduate classes in one calendar year are aggregated and limited to a maximum tuition reimbursement of $7500. 5.5.10 Reimbursements will be applied toward the annual maximum of the year the class was started. 5.6 Eligible Expenses 5.6.1 N/A 5.6.2 N/A 5.6.3 N/A 5.7 Taxation 5.7.1 N/A 5.7.2 N/A 5.7.3 N/A 5.7.4 With regard to Section 4.7.4, this determination will be made in accordance with the guidelines outlined in this policy and will be relied upon by Honeywell payroll for tax reporting and withholding purposes. 5.8 Payback Provision 5.8.1 If a Covered Employee voluntarily leaves Honeywell or is discharged for "cause" within one-year following a reimbursement under this Policy such Covered Employee will be required to repay 100% of the reimbursements received within the 12 month period immediately preceding the Covered Employee's last day of active employment. Reimbursements must be paid in full upon termination. 5.9 Special Situations and Exceptions 5.9.1 Reimbursement under these circumstances shall be made under the assumption that the Covered Employee receives a B grade or a satisfactory, as the case where a letter grade is not applicable. Grades should be submitted as per instructions on the tuition reimbursement site on the intranet. 5.9.2 N/A 5.10 Impact on other Honeywell Benefit Plans 5.10.1 N/A 5.11 Interpretation, Amendment, Termination of this Policy 5.11.1 For questions or guidance on this policy employees may contact One-Stop at 1-877-258-3699 Option 4. 5.11.2 N/A 5.11.3 N/A 5.11.4 N/A 6.0 Roles and Responsibilities 6.1 The SVP of Human Resources & Communications will ensure compliance with this Policy. 7.0 Definitions 7.1 Covered Employees Includes all regular full-time salaried employees of Honeywell; regular full-time hourly employees of Honeywell; and part-time salaried or hourly employees of Honeywell (i.e., those regularly scheduled to work 20 hours or more per week). Source: Human Resource Function. Page 5 of 6

7.2 Eligible Expenses Include tuition, registration fees, required text books, required lab fees, CLEP exam fees (College- Learning Examination Program) or DANTE, fundamental skills assessment and course fees (Reading, Writing and Mathematics), correspondence course fees from nationally accredited institutions, provided they meet criteria for approval, on-line (electronic) course fees from nationally accredited institutions, provided they meet criteria for approval. Source: Human Resource Function. 7.3 Employee of Honeywell Means an individual employed by a Honeywell Employer (i) in a salaried position that regularly requires 20 or more hours of work per week or (ii) in a regular full-time or part-time hourly position that regularly requires 20 or more hours of work per week in a category of employment or business location designated as covered by this Policy. Source: Law Function. 8.0 Standards, Laws, and Regulations 9.0 Forms and Exhibits Page 6 of 6