Charitable Activities

Community involvement through charity and volunteer activity is a key part of our identity. To serve our customers and our shareholders, we should also serve the communities in which we work.

When CNP participates in a community project, managers will advise that the event is company-sponsored. If so, employee time and company resources may be contributed. We encourage you to volunteer and be active in your own community. However, respect the line between private citizenship and your employment with CNP.

Remember these key points:

• Pursue charitable activities on your own time, using your own resources, unless it is a company-sponsored event or you have management approval.
• In any public forum, be clear that you do not speak on behalf of CenterPoint Energy unless you were specifically requested by management to do so.

Political Activities

We comply with all laws regulating CNP’s participation in political affairs, including contributing to political parties, committees, or individual candidates. We encourage you to participate actively in the political life of your own community.

Company Political Activity
The rules governing lobbying are complex, highly regulated, and vary state by state. Only authorized employees or lobbyists may engage in lobbying on behalf of CenterPoint Energy. Because the definition of lobbying can be very broad, seek guidance from the General Counsel if you have any questions before you interact with a public official on behalf of our company.

QUESTION: Do all government agencies have the same rules concerning meals and entertainment?
ANSWER: No. Regulations differ among federal, state, and local government agencies. Before offering any gift – including meals or offers of transportation, make sure you know the regulations that apply.

QUESTION: If no cash is involved, can we contribute goods or services to a political party or candidate?
ANSWER: No. The contribution of any goods or services, such as free use of office space, transportation, clerical support, or stationery for the benefit of a political party or candidate is considered to be an “in kind” contribution. It is viewed the same as cash. The General Counsel must approve all contributions – of any kind – in advance.

CenterPoint Energy maintains state and federal Political Action Committees (PACs). The General Counsel must approve in advance all political contributions on behalf of CenterPoint Energy. A PAC can legally make campaign contributions to political candidates and organizations. PAC contributions are designed to help achieve our company’s goals, support issues that are important to our industry, and are not based on party affiliation. Employees may contribute to our PACs. All contributions are voluntary.

Personal Political Expression
We encourage you to be an informed voter and to get involved in the political process. If you choose to participate, your contributions must be on a personal basis, using your own time and funds. CenterPoint Energy will not reimburse you for any political contributions that you make. Do not use work time, money, or resources to promote a political campaign or candidate. If you express your personal views about a political issue, you should not use company resources of any kind, including company stationery, e-mail services, or make reference to your title or job with CNP.

Remember these key points:

• When taking a position about a personal political belief, make it clear that you are acting and speaking for yourself and not on behalf of CNP.
• Never loan or use company property for political purposes – unless you are specifically authorized by CNP in advance to do so.

QUESTION: I have been asked to make a presentation at a trade association meeting. Is this OK?
ANSWER: Yes. If the presentation involves your work at CenterPoint Energy, you must have management approval and review of the contents of your presentation in advance. Contact with the Media

Contact with the Media

We receive questions every day from external contacts about our business. This includes questions from the general public, shareholders, the media, and the investment community. Our goal is to communicate accurately and consistently, and in compliance with securities laws regarding fair disclosure of information about public companies.

The Corporate Communications Department decides whether and when requests for interviews should be honored. They ensure that we are consistent in how we respond to critical issues and that we do not disclose material information selectively. Only those who are trained in media relations should represent CenterPoint Energy to the public. If you receive a media inquiry, either verbal or written, from someone outside our company, always direct the question to the Corporate Communications Department.

Remember these key points:

• Assume that all discussions with a member of the media or press are “on the record.”
• Don’t try to answer a media question yourself, even if you think that you know the answer.

QUESTION: My boss is running for a seat on city council. He made it clear that he expects us to help him pass out brochures and offered to give us extra time off if we agree. Is this right?
ANSWER: As long as he received permission from the CEO, your boss is free to run for local political office. However, he cannot use his position with CenterPoint Energy to influence employees to vote for him by offering them extra time off or any other kind of benefit. In addition, he should not misuse his authority to coerce you to help with his campaign.