Recent Amendments To The Ingersoll Rand Code of Conduct

On February 2, 2011, the board of directors of Ingersoll-Rand plc approved an amendment to the “Inside Information and Investment in Securities” section of the Code of Conduct clarifying that no employee or director can engage in activity designed to profit from or hedge against decreases in the value of Ingersoll Rand stock at a time when such person has material inside information about the company and also prohibiting the company’s directors and executive officers at all times from (i) engaging in any activity that is designed to profit from or hedge against decreases in the value of Ingersoll Rand stock, or (ii) holding company securities in a margin account or pledging company securities as collateral for a loan (unless the director or executive officer can cover the margin call in cash). The amendment also strongly discouraged all employees from engaging in any of these activities even when not in possession of material inside information.