Because CenterPoint Energy supplies natural energy to both wholesale and retail customers, our operations are highly regulated by both state and federal regulatory commissions. We take care to ensure the safety and reliability of our nation’s energy supply. This is part of our public service obligation. Your supervisor can provide more detailed information about these regulations and how they apply to your work.

FERC

CenterPoint Energy’s interstate transportation of natural gas is subject to regulation by the Federal Energy Regulatory Commission (FERC). CenterPoint Energy Gas Transmission Company (CEGT) and CenterPoint Energy Mississippi River Transmission (MRT) are subject to FERC control in all aspects of their business.

A primary focus of the FERC’s regulation of interstate pipelines concerns the relationships between CEGT and MRT and their Marketing Affiliates. Marketing Affiliates include the CenterPoint Energy Services. (CES) entities. We must be very careful that the parts of our company that operate interstate natural gas pipelines do not show favoritism to our Marketing Affiliate operations. We cannot use our status as an interstate pipeline to give other parts of our energy business advantages that other organizations do not enjoy.

There are separate FERC Standards of Conduct that prevent any person, regardless of the company by which he or she is employed, from serving as a conduit of non-public information about CEGT or MRT or their customers to an employee of one of our Marketing Affiliates. CEGT and MRT must function independently from the Marketing Affiliates.

Remember these key points:

• There are separate FERC Standards of Conduct that control our business. We must comply carefully with these standards as well as this Code.
• CenterPoint Energy employees, regardless of business unit, should not disclose general, non-public interstate pipeline transmission or customer information to Marketing Affiliate employees. Should this occur, that information must be made public, via an Internet posting, simultaneously to other non-affiliated parties.
• CEGT and MRT must not provide a Marketing Affiliate with any preferential treatment.
• When in doubt about what information can be shared among business units, be sure to get advice from your manager or the Legal Department.

QUESTION: A friend of mine works for the Public Utility Commission of Texas (PUCT). She does not do any work involving CNP. Can I buy her lunch?
ANSWER: You should not buy her lunch. You are free to have lunch with your friend, but if you pay for it, this could be misinterpreted as an attempt by a CenterPoint Energy employee to influence a public official whose agency regulates our industry.

Public Utility Commission of Texas

The Public Utility Commission of Texas (PUCT) regulates transactions between an electric utility and other entities operating in the Texas wholesale and retail electric markets. Because Texas has opened parts of those markets to competition, the PUCT has adopted a Code of Conduct that governs how utilities should interact with their unregulated affiliates and other entities.

CenterPoint Energy Houston Electric has adopted a specific code of conduct that follows the PUCT’s requirements. This code describes how its employees should interact with power generation companies, retail electric providers, and end-use customers in the competitive electric markets of Texas.

A utility should not use its regulated status to subsidize the activities of any of its affiliates. As a result, CenterPoint Energy Houston Electric must pay its fair share of costs of joint operations with all other parts of CNP, and it should realize its fair share of any savings that may be gained through joint operations or by being part of CenterPoint Energy.

You should not provide information regarding our electric system operations, transmission maintenance and outages, transmission and distribution expansion plans or upgrades, or any other information that could provide an unfair competitive advantage to unregulated affiliates or other entities operating in the competitive Texas electric markets. CenterPoint Energy Houston Electric may provide information about its system operations, outages, or plans provided that it releases this information simultaneously to all competitive electric market participants – for example by postings on the Internet.

CenterPoint Energy Houston reads end-use customers’ electricity meters. It has a significant amount of customer data. If you have access to customer data, you may not share this information with anyone unless the customer authorizes release of this information. We may provide aggregated customer data provided that no specific customer’s information is revealed and provided that aggregated data made available to all market entities at the same time, such as by posting on the Internet.

Remember these key points:

• Protect information that is proprietary, private to an end-use customer, market sensitive, or which could give someone else an unfair competitive advantage.
• Do not disclose end-use customer data unless you are authorized by the customer to do so or required by law to disclose this information to government authorities.
• Do not show a preference for any competitive market entity, for example by recommending that an end-use customer get retail electric service from a specific retail electric provider.

QUESTION: I work for CenterPoint Energy Houston Electric. As part of my job, I frequently talk with employees who work for other CNP business units. They ask questions about our electric and gas systems and our customers. Is it wrong to answer their questions? 
ANSWER: State and Federal Affiliate Rules and/or Standards of Conduct may prohibit sharing information related to our customers and the electric and gas systems. Before providing any customer or system specific information, check with your manager or the Legal Department.