Ethics and Compliance Program

1. A Company-wide ethics awareness and education program is designed, established and maintained to ensure that all employees have an awareness of:
   • PGESCo fundamental canons of ethics, values and standards of conduct
   • Legal requirements that are relevant to their work at a level of detail appropriate to their job functions.
2. All employees participate in an ethics awareness training event at least once a year.
3. A record of employee participation in Ethics and Compliance training is maintained for tracking and reporting purposes.
4. Contractors’ personnel, agents, consultants and others acting for the Company must also be made aware of the Company’s expectations for ethical behavior and that they must abide by the PGESCo standards of conduct when they are acting for, or on behalf of the Company.

PGESCo Code of Conduct booklet and the Anti-corruption Compliance guidelines are accessible to all employees, members of the Board of Directors and other interested stakeholders on PGESCo’s internal and external websites.

1. PGESCo encourages employees to raise questions or concerns with management.
2. The PGESCo Ethics Helpline is provided as a confidential means of communication separate from line management available to employees.
3. Retaliation against employees who come forward to raise concerns will not be tolerated. Threats or acts of retribution against any employee for proper use of any Company reporting mechanism is cause for appropriate discipline, up to and including termination.

PGESCo Compliance Committee is formed to develop and implement the company wide ethics awareness and education program, to develop and implement PGESCo Ethics Helpline for employees questions and concerns, to investigate and report any complaints regarding ethics, and to assist the General Manager in the periodic review of the effectiveness of existing policies and procedures.