Using the Ethics and Compliance Code
This Code is a common-sense guide that you can use to make good business decisions. The Ethics and Compliance Code applies to everyone at CenterPoint Energy, Inc. (CenterPoint Energy or CNP). Each CNP employee and Board of Directors member is expected to read, understand, and follow our Code. Only the Board of Directors may waive a provision of this Code for executive officers or directors. Waivers will be promptly disclosed according to the law.
The Ethics and Compliance Code will help you:
Resolve difficult questions about conduct on the job
Get confidential advice
Work with your fellow employees, customers, business partners, competitors, regulators, vendors, and suppliers
Bring to our attention suspected unethical or illegal behavior
We expect our suppliers, vendors, contractors, and business partners to respect our Code and to support effective compliance programs within their own organizations.
In addition to this Code, CenterPoint Energy has adopted many policies and procedures. This Code does not replace our employment policies and work rules. You are expected to know and follow the policies that apply to your work.
This Code is a living document. It cannot address every situation. It will change over time. However, this Code is not an employment contract between you and CNP. Because you are employed at will, you or CNP can terminate your employment with or without cause and with or without notice. Employees who violate this Code are subject to disciplinary action, up to and including termination of employment.
Speaking Up to Get Answers
Most of us have faced a difficult situation where the right course of action was hard to determine. Maybe the facts were complex or you did not have all the information you needed. Perhaps a good choice was just not obvious. Your persoal interests may not have been consistent with the best interests of CenterPoint Energy.
Reading this Code and understanding our expectations will help you handle most situations. The Code will not give you an answer for every situation. Sometimes, a law or policy clearly dictates the outcome. More often, a situation will require interpretation to decide a fair and reasonable course of action. If you are unsure about the right course of action, discuss the situation with your supervisor.
If that is uncomfortable or impractical for any reason, you can seek help from:
- Any member of management
- Human Resources
- Audit Services
- Legal Department
- Corporate Security
- Ethics and Compliance Department
- Concerns Helpline at 1-888-888-3155
Talking with Your Supervisor or Manager
Every supervisor and manager is expected to keep an open door and to provide timely advice on ethical concerns. We encourage you to involve your supervisor or manager. However, we understand that this may not always be comfortable, practical, or appropriate.
Talking with Human Resources
Many business conduct issues involve human resources policies and practices. Contact your Human Resources Representative if your concern involves employee relations, management practices, compensation, benefits, transfers, or promotions. Human Resources and the Corporate Compliance Officer work closely to resolve reports of unethical conduct.
Contacting CNP’s Corporate Compliance Officer
The Ethics and Compliance Department is a company-wide resource that can assist you with ethics and compliance-related issues. If you have a question, want to express a concern, or report a possible violation of law or our policies, contact the Corporate Compliance Officer by e-mail at Compliance.Officer@CenterPointEnergy. com. Often, the Ethics and Compliance Department can provide you with immediate advice. If your issue requires additional attention, they will keep you informed of progress on your question.
Making Tough Decisions
The information in this Code will help you work through difficult business issues and dilemmas.
But if the answer to a problem is not obvious, take the extra time to think through these questions:
- Have I reviewed the facts carefully?
- Have I used the resources available to me?
- What are the issues?
- Have I thought carefully about my options?
- What are the consequences of my choices?
- Will I be comfortable seeing my decision reported in the news?
If you are still not sure what to do, speak up and get the advice you need. Keep asking questions until you are certain you are doing the right thing.