Standards Of Business Conduct - Consolidated Edison

Transcription

Standards ofBusinessConduct

Table of ContentsA Message from Tim Cawley. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3The Company and Our Shareholders Matter . . . . . . . . . . . . . . 23Our Mission, Priorities, and Values. . . . . . . . . . . . . . . . . . . . . . . . . . . 4We Honor Supply Chain Obligations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Introduction to Our Standards of Business Conduct*. . . . . . . 6A Model for Ethical Decision-Making . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8We Protect Our Assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24We Are Careful When Working with OtherCon Edison Companies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25We Protect Our Reputation in Our Communications . . . . . . . . . . . . . . . 26Speaking Up Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9We Safeguard Confidential Information. . . . . . . . . . . . . . . . . . . . . . . . . . . 27We Do Not Tolerate Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11We Manage Financial Records with Honesty. . . . . . . . . . . . . . . . . . . . . . 29We Get Help and Answers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10We Provide Anonymous and Confidential Reporting . . . . . . . . . . . . . . . 11We Conduct Fair and Objective Investigations. . . . . . . . . . . . . . . . . . . . 11We Create and Maintain Accurate Records . . . . . . . . . . . . . . . . . . . . . . . 28We Engage in Trading Activities Ethically . . . . . . . . . . . . . . . . . . . . . . . . . 30Our Communities Matter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31Our Employees Matter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12We Are Committed to Our Sustainability Efforts . . . . . . . . . . . . . . . . . . . 32We Maintain a Secure and Safe Workplace . . . . . . . . . . . . . . . . . . . . . . . 14We Conduct our Business Free From Corruption . . . . . . . . . . . . . . . . . . 34We Strive for Excellence in Safety. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13We Value Diversity and Respect. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15We Provide Service in Our Communities. . . . . . . . . . . . . . . . . . . . . . . . . . 33We Compete Fairly . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35We Protect Confidential Personal and Private Information. . . . . . . . . . 16We Comply with Trade Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36Our Customers and Business Partners Matter . . . . . . . . . . . . 18Everything Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37We Avoid Conflicts of Interest. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19We Are Held Accountable for Our Actions . . . . . . . . . . . . . . . . . . . . . . . . 38We Follow Our Guidelines for Gifts, Hospitality,and Entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Amendments to Our Standards and Policies . . . . . . . . . . . . . . . . . . . . . . 39We Conduct Our Business with Integrity . . . . . . . . . . . . . . . . . . . . . . . . . 19We Get Help and Answers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38Guidelines for a Waiver of Our Standards of Business Conduct. . . . . 39Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39*These standards are not a contract of employment and do not create new or additional responsibilities or legal rights.2STANDARDS OF BUSINESS CONDUCT

A Message fromTim CawleyDear Colleagues,While the energy industry continues to change as we transitionto a clean energy future, our commitment to doing businessthe right way never wavers. By doing so, we realize our threepriorities: focus on safety for our employees and the public weserve, operational excellence, and the customer experience.Our Standards of Business Conduct is our guide for doingbusiness in a way that demonstrates integrity and our corporatevalues. The future of our company depends on all of uscommitting to uphold our standards.If you have questions, need advice, or wish to report anintegrity-related concern, contact the Ethics Helpline at1-855-FOR-ETHX (1-855-367-3849). You may choose toremain anonymous.Tim CawleyChairman, President, andChief Executive Officer,Consolidated Edison Inc.Familiarize yourself with these standards and incorporate themas you do your work. We owe it to ourselves, each other, andthe communities we serve.Tim CawleyChairman, President, and Chief Executive Officer,Consolidated Edison, Inc.ETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)3

Our Mission, Priorities, and ValuesOur MissionOur Three PrioritiesThe mission of Consolidated Edison, Inc.and its subsidiaries (Con Edison) is to:Three priorities drive everything we do:Provide energy servicesto our customers safely,reliably, efficiently, and in anenvironmentally sound manner.SafetyWe are committed to eliminating accidentsand injuries. We work as a team to protect thesafety of the public and each one of us.—Provide a workplace thatallows employees to realizetheir full potential.—Provide a fair returnto our investors.—Improve the quality of lifein the communities we serve.4STANDARDS OF BUSINESS CONDUCTOperational ExcellenceWe stand behind our work and lookfor new ways to excel at our jobs.We talk openly about ethical choices,follow all laws, rules, and regulations,adapt to change, and invest in our skills.Customer ExperienceWe strive to see the customer’s point of view,make customer priorities our own, and elevatethe experience of doing business with us.

Our Corporate ValuesOur corporate values are at the heart of ourStandards of Business Conduct. Our individualcommitment to support and uphold them in everyaspect of our work is the foundation of our cultureof integrity.Service: We will provide the best possible energyservice. We will never forget that what we do, andthe way we do it, vitally affects the millions of peoplewho depend on our service.Honesty: We will conduct our business withhonesty and integrity, and communicate openly.Concern: We will show concern for the welfare ofour customers, our fellow employees, and the menand women who invest their savings in our company.We will protect the environment in which we live.We will make the safety of our employees and thepublic a top priority.Courtesy: We will be courteous to our customers, to each other, and to all those whose liveswe touch.Excellence: We will strive for excellence in allthat we do. We will never be satisfied with lessthan the highest standards of performance.Teamwork: We will work together in harmonyas a team, combining our best thinking and effortsto make Con Edison the finest energy servicescompany in the nation.ETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)5

Introduction to Our Standardsof Business Conduct

Why We Have Standards ofBusiness ConductOur Standards of Business Conduct (standards)explain the behaviors expected of us while workingfor Con Edison and reinforce our corporate valuesguiding us to do business the right way.Based on the laws, regulations, and companypolicies we need to know and follow, our standardsserve as a framework for ethical decision-makingand direct us to the appropriate resources when weneed help or more information.The Plan:Con EdisonA secure and safe work environmStriving for ExcellenceThroughout these standards,we reference “Con Edison,” definedas Consolidated Edison, Inc. and itssubsidiaries, which includes:Our loyalty to Con Edison means we always do what’sfromviolenceconductright and act with integrity.Eachof us isandrequiredto: that isalso means a workplace freedangerous or disruptive to anyon Apply these standardsin ourorjobseveryCEI.dayinsideouside Demonstrate our values in all that we doEmployees and officers of anyCon Edison subsidiaryOfficers of Con EdisonMembers of the Con Edison Boardof Directors and members of the boardsof each of its subsidiaries—Every one of us has the responsibility to followour standards and apply them to our daily work.What’s Covered in Our StandardsOur standards are the foundation of our commitmentto integrity and are a framework for making effectiveethical decisions. They are not intended to coverevery situation or dilemma we may encounter. Therewill be times when we need to seek further guidancefrom a Help and Answers Resource. Be fair and honest at all times with those wework and interact with Maintain the trust of our stakeholders Treat everyone with respect and courtesy Ask questions and seek advice when we arenot sure how to proceed in specific situations Speak up if we have concerns about ethicalmisconduct or violations of the standards, ourpolicies, procedures, or the lawREMEMBER: We always act in accordance withall applicable laws, regulations, and stock exchangelisting requirements everywhere our company doesbusiness. When working outside the United States,we are also expected to adhere to the laws of thecountry in which we are operating, as well as complywith all company policies governing businessactivities abroad.ETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)7

Leading by ExampleOur culture of integrity starts at the top. Those whosupervise, manage, or are in positions of leadershipare expected to: Model our standards and lead by example Help others understand how to apply thestandards in their daily work Make it clear that it is never okay to compromiseethical standards to accomplish business goals Recognize and encourage the ethical conductof team members Raise concerns of unethical, noncompliant, orillegal conduct to the Ethics Helpline Create a culture where others feel safe raisingconcerns and questions without fear of retaliationA Model for Ethical Decision-MakingWhen deciding how to proceed in situations where the proper course of action is not clear,we must ask ourselves:Is it the right thing to do?Will it reflect positivelyupon Con Edison?Is it consistent with ourstandards, the law, and ourpolicies and procedures?Would my manager orteammates agree with the actionor decision?Would I want to read about myactions on Twitter, Facebook, orother media channel?If the answer to any of these questions is “No” or “Not sure,”seek guidance from a Help and Answers Resource before taking action.8STANDARDS OF BUSINESS CONDUCT

Speaking Up Matters

We Get Helpand AnswersA secure and safe work environmalso means a workplace freefrom violence and conduct that isdangerousto anyonWhen calling during businesshours, orwedisruptivemay chooseinside oforaousideCEI.andto speak with a representativelocal EthicsCompliance office to answer questions, get advice,discuss concerns, and report possible violations.We all have a responsibility to speak up. Seekingguidance when we are in doubt or when we needto raise a concern about conduct that may not bein compliance with our standards is not alwayseasy, but it is always the right thing to do.Additionally, no matter when we call, we maychoose to speak with a representative from outsideCon Edison who will document the question orconcern, and share it with the appropriate Ethicsand Compliance office for a response.At Con Edison, we can always speak with ourdirect supervisor, manager, or any of theseadditional resources:All contacts are confidential to the extent possible.When we call or submit reports through the onlineform we may remain anonymous.HELP AND ANSWERS RESOURCES: A Values in Action (VIA) Advisor at ConEdison of New York, Con Edison Clean EnergyBusinesses, or Con Edison Transmission A Business Ethics Council member at Orange& RocklandREMEMBER: If we ever have concerns regardingfinancial reporting or accounting issues, we mayalso contact the Office of the General Auditor at212-460-3296. A manager with whom we feel comfortable A Human Resources Professional Office of Diversity & Inclusion at 212-460-1065Find additional information on the Help andAnswers Resources. Con Edison of New York Office of theOmbudsman at 212-206-0949 Con Edison of New York Corporate Security at212-460-2444 or Orange & Rockland CorporateSecurity at 845-577-3130 An employee of Business Ethics & Complianceor a local Ethics and Compliance office Ethics Helpline at:– 1-855-FOR-ETHX (1-855-367-3849)– FORETHX@conEd.com– Online FormThe Ethics Helpline is available 24 hours a day,seven days a week, and is staffed by experiencedprofessionals.10STANDARDS OF BUSINESS CONDUCT

We Do Not TolerateRetaliationWe should feel comfortable seeking advice andreporting concerns of misconduct. Con Edisonstrictly prohibits retaliation, threats, or harassmenttoward any employee for making a report in goodfaith, or participating in an investigation. Anyonewho intentionally makes a false report or engagesin an act of retaliation may be subject to disciplinaryaction, up to and including termination.to thoroughly investigate a concern or follow upon issues. Therefore, to assist us in investigatingconcerns, we encourage callers to identifythemselves whenever possible.We Conduct Fair andObjective InvestigationsThe Plan:Con Edison carefully reviews allegations ofmisconduct, including violationsthesestandards,A secureofandsafework environmcompany policies, procedures,orapplicablelaws orfreealso means a workplaceregulations. When concerns are raised, Con Edisonfrom violence and conduct that ishandles them promptly, thoroughly, discreetly, anddangerous or disruptive to anyonprofessionally.inside or ouside CEI.All reports are treated confidentially, to the fullestextent possible, consistent with the need to conductan appropriate investigation and to comply withapplicable legal requirements.Raising a concern in good faith includesproviding the relevant information in aforthright and truthful manner. We do not raiseconcerns knowing the information we areproviding is false or manufactured.We Provide Anonymousand ConfidentialReportingThe Ethics Helpline is an additional resourcewhere we can raise concerns anonymously andconfidentially. In many situations, investigationscan be conducted without knowing the identity ofthe individual making the report. However, in somecircumstances, anonymity may make it difficultWe are each expected to cooperate fully andaccurately in investigations. Our cooperation isessential to fostering the openness and transparencythat helps to improve Con Edison processes andresolve concerns of suspected misconduct.Employees who fail to cooperate, or who obstructinvestigations, will be subject to disciplinary action.REMEMBER: If we are approached by a lawenforcement officer or government official forinformation about Con Edison in a nonemergencysituation, or if we receive a subpoena or other legaldocument relating to the company, we immediatelyrefer the officer or official to the Office of theSecretary, Law department, or Corporate Securityprior to responding or releasing information. We mayalso contact the Ethics Helpline directly for guidanceand assistance.ETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)11

Our Employees Matter

We Strive forExcellence in SafetyThe Plan:Protecting the health and safety ofall employees and the public is anintegral part of our work. We identifyand review the risks before everyjob, follow all applicable safetyprocedures and instructions, wearthe right protection, and considersafety in everything we do.Each of us is responsible for planning and creating asafe environment for all employees, our families, andthe public, in all aspects of our work. We must knowand comply with all applicable health, environmental,and safety laws and regulations and companypolicies, and incorporate them into all of ourdecisions. Our vendors and other business partnersare expected to demonstrate the same commitment.An inclusive work environment, where we shareour perspectives and listen to each other, alsohelps keep us safer. An inclusive work environmentsupports our efforts to communicate openly, learnfrom each other, and look out for those around us.PUTTING THE PLAN TO WORK means we: Encourage free and open communicationabout environmental, health, and safetyconcerns, and seek guidance when needed Do not harass, intimidate, or retaliate againstanyone who reports an environmental, health,or safety concernIf hazardous substances or materials arereleased, spilled, or handled improperly,immediately report the incident to the ConEdison of New York EH&S Control Desk at212-580-8383 or Orange & Rockland EH&SSpill Reporting at 844-406-3471. Trained andqualified individuals will address the incident.In these situations we: Report honestly Disclose all information Make required notifications withinCon Edison or to appropriate governmentagencies Do not intimidate, harass, or retaliateagainst those who report incidentsFind related policies and additional resources. Report safety concerns to a supervisor, theEnvironment, Health and Safety (EH&S)manager, or a local EH&S representativeETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)13

The Plan:We Maintain a Secureand Safe WorkplaceA secure and safe work environmealso means a workplace freefrom violence and conduct that isdangerous or disruptive to anyoneinside or ouside CEI.The Plan:A secure and safe work environmentalso means a workplace free fromviolence and conduct dangerousor disruptive to anyone inside oroutside Con Edison.Con Edison does not tolerate any form ofviolence, including threats, acts of violence,or intimidation. If someone is in immediatedanger call 911 and then Con Edison of NewYork Corporate Security at 212-460-2444 orOrange & Rockland Corporate Security at845-577-3130.PUTTING THE PLAN TO WORK means we: Never bring weapons or ammunition of anytype to any Con Edison property or theworkplace unless we receive prior writtenapproval for an exception from a vice presidentor senior officer, and notify Corporate Security Never use illegal drugs, abuse alcohol, ormisuse prescription or over-the-countermedication as that may compromise ourcapabilities Do not smoke in Con Edison buildings,company vehicles, or other prohibited locations Report known or suspected violence orthreats to Con Edison of New York CorporateSecurity at 212-460-2444 or Orange &Rockland Corporate Security at 845-577-313014REMEMBER: We report all arrests, indictments,misdemeanor or felony convictions, or other officialactions taken against us, whether work-related ornot, as soon as possible, and no longer than threecalendar days after the event. The report can bemade to our supervisor, manager, or the EthicsHelpline.Find related policies and additional resources.STANDARDS OF BUSINESS CONDUCT

We Value Diversityand RespectThe Plan:Each of us is responsible forfostering an environment thatvalues our differences andencourages teamwork. Wepromote a diverse and inclusiveenvironment free from harassmentor discrimination.We treat everyone with respect, dignity, andconsideration. The power of our diversity is madestronger through inclusion. An inclusive workplaceinvites each of us to voice our ideas, share ourperspectives, listen to each other, and empowersus all to reach our full potential.PUTTING THE PLAN TO WORK means we: Value diversity and foster an inclusive culture Do not engage in or tolerate harassment ordiscriminatory behaviorsEach of us is responsible for making fairbusiness decisions based on the needs ofthe business or an individual’s qualifications,ability, contributions, and demonstrated pastperformance. We do not make employmentrelated decisions based on an individual’s: Race Pregnancy Color Geneticinformation Religion Treat each other with respect and consideration Creed Maintain positive professional and personalrelationships National origin Never threaten, intimidate, or bully others Sex Age Marital status Sexualorientation Gender identity Disability Citizenship Veteran status Other legallyprotectedcharacteristicsETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)15

We Protect ConfidentialPersonal and PrivateInformationThe Plan:Our fellow employees, customers,and others trust us to protect theirThePlan:Harassment is any action (whether or notpersonal and private information.sexually related) with the purpose or effectA secure and safe work environmentIn maintaining their confidence,of creating an intimidating, offensive, orwe are committed to securing thealsoformeansa workplacefreedemeaning environmentanotherperson,privacy, confidentiality, identity,and is prohibited at ConHarassmentfromEdison.violenceand conduct that isand integrity of this information.may include making:dangerous or disruptive to anyone Offensive jokes orinsideinsultsor ouside CEI. Unwelcome sexual advances, requestsfor sexual favors, or repeated, unwelcomesexual suggestions Unwanted physical contact Inappropriate comments about another’sappearanceHarassment may also include distributing ordisplaying offensive or inappropriate materialthrough email, social media, or other means.We preserve the trust and confidence of ourcustomers, fellow employees, business partners,vendors, retirees, shareholders, and others byprotecting their information. When we collect, use,or store personal and private information, we takespecial care and follow all policies and proceduresto protect it from loss, theft, destruction, andunauthorized disclosure.REMEMBER: If we observe or experiencediscriminatory or harassing behavior, we shouldreport the situation to the Office of Diversity &Inclusion or a Help and Answers Resource. Wedo not tolerate retaliation against anyone whomakes a report in good faith.Find related policies and additional resources.16STANDARDS OF BUSINESS CONDUCT

PUTTING THE PLAN TO WORK means we: Identify and protect personal and privateinformation Collect only the information we needThe Plan: Only access information if we haveA secureandneedsafe work environmentauthorization and a validbusinessalso means a workplace free Maintain privacy by not disclosing personalfromviolence andand private informationto individualsor conduct that isor disruptiveorganizations unlessdangerousproperly authorizedby the to anyoneowner of the information,a supervisor,asinsideor ouside orCEI.required or permitted by law Secure personal and private information whentransmitting it and use all reasonable measuresto protect it from loss, theft, and unauthorizeddisclosure Properly store, secure, transmit, share, print,and label all company data (paper, electronic, orother material) in accordance with our policies Report suspected unauthorized or inappropriatedisclosure of personal and private informationimmediately to the Ethics Helpline or a Helpand Answers ResourceREMEMBER: The privacy and security of personallyidentifiable information (PII) is a priority. Employeesshould use the utmost care in handling, maintaining,and storing PII and only give access to authorizedindividuals. For questions about PII or to reportan actual or suspected disclosure, contact the PIIIncident Response Team at 212-780-6999 or emaildl - PII Incident Response Team.Find related policies and additional resources.Personally identifiable information (PII) isinformation, either by itself or in combinationwith other information that identifies a person,such as: Social Security numbers or any part of theSocial Security number, such as the lastfour digits Government issued identificationincluding driver’s license and nondriveridentification card numbers, such asNYCID or passports Personal financial account numbers,credit/debit card numbers, securitycodes, and passwords Usernames and email addresses withpasswords or security questions andanswers Any information related to a person’shealth, medical or physical condition(including drug and alcohol test results),or biometric and genetic informationETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)17

Our Customers and BusinessPartners Matter

We Conduct OurBusiness with IntegrityThe Plan:We provide quality service in allwe do. This means we conductall our dealings with or affectingcustomers, vendors, and otherstakeholders in a fair, ethical, andlawful manner.PUTTING THE PLAN TO WORK means we: Never take advantage of others throughmanipulation, concealment, abuse ofconfidential information, misrepresentation ofmaterial facts, or other unfair dealing practices Refrain from conduct that unfairly promotespersonal interest or Con Edison’s interestsat the expense of our customers or otherstakeholders Follow procedures and deliver and meet allrequired specifications Deliver our services safely and with qualityWe Avoid Conflictsof InterestThe Plan:Each of us acts in the best interestof Con Edison and avoids conflictsof interest. When we make businessdecisions, they are based onsound business reasoning and notinfluenced by personal interest.We avoid conflicts of interest, or even theappearance of conflicts, to maintain our objectivityand show our commitment to Con Edison’s corporatevalues, and not to any outside interests. If ourpersonal or other outside interests or relationshipscould pose a conflict with our responsibilities toCon Edison, we remove ourselves from participatingin company decisions relating to that interest orrelationship.ETHICS HELPLINE 1-855-FOR-ETHX (1-855-367-3849)19

PUTTING THE PLAN TO WORK means we:The Plan: Use good judgment in our outside activities toA secure and safe work environmentavoid conflicts of interestalso means a workplace free Make fair decisions and prevent situationsfromviolenceandorconduct that iswhere our personal oroutsideinterestsdangerousor disruptiverelationships could interferewith ourability to to anyonemake decisions objectivelyinside or ouside CEI. Do not have a second job or engage in anoutside business activity that competes withCon Edison’s businesses Do not use company time or other companyresources for outside interests Understand that actual or potential conflicts ofinterest also involve members of our familiesor households Disclose actual or potential conflicts of interestby completing a Certificate of Disclosure andupdating it whenever our circumstances changeREMEMBER: If we need guidance or are unsurewhether to disclose a particular situation, we shouldcontact the Ethics Helpline. Business Ethics &Compliance will review all disclosures submittedand will assist in resolving potential conflicts.A conflict of interest occurs when our outsideor personal interest conflicts, or appearsto conflict, with our responsibilities to ConEdison. Conflicts of interest also apply tomembers of our families or households.Conflicts can occur when we take action,have interests, or make decisions that couldmake it difficult for us to perform our workobjectively and effectively. Conflicts can alsoarise when we (or members of our familiesor households) receive improper personalbenefits as a result of our position withCon Edison.A “family member” can be related by blood,marriage, or adoption, and includes: Spouse or domestic partner Children, stepchildren, and grandchildren Grandparents, parents, and stepparentsFind related policies and additional resources. Siblings and stepsiblings Aunts, uncles, nieces, nephews, andfirst cousins In-laws (parents, brothers, sisters, sons,and daughters)A “member of household” is anyone who liveswith us other than rent-paying tenantsor employees who are not family members.20STANDARDS OF BUSINESS CONDUCT

We Follow OurGuidelines for Gifts,Hospitality, andEntertainmentThe Plan:We use good judgment andexercise the highest standards ofintegrity when handling situationsthat involve gifts, hospitality, andentertainment in relation to our work.We do not offer or accept gratuities or gifts,other than nominal promotional items. Whendeciding whether to offer or accept hospitality orentertainment from an existing or potential customer,vendor, or other business partner, we follow thebelow guidance.PUTTING THE PLAN TO WORK means we:Sometimes we entertain or socialize withcustomers, vendors, or other business partnersto advance Con Edison’s legitimate businessinterests. When deciding whether to offer oraccept hospitality or entertainment, we mustput Con Edison’s interests first. The activitymust meet the following criteria: Has a legitimate business purpose Is not lavish, expensive, or frequent Meets normal industry practices Does not put the employee or thecompany in a position to be compromised Does not conflict with our businessconduct standards or the other party’sstandards Never accept cash, tips, or cash equivalents,including gift cards Has been approved under applicablepolicies Never solicit gifts, hospitality, or

Edison of New York, Con Edison Clean Energy Businesses, or Con Edison Transmission A Business Ethics Council member at Orange & Rockland A manager with whom we feel comfortable A Human Resources Professional Office of Diversity & Inclusion at 212-460-1065 Con Edison of New York Office of the Ombudsman at 212-206-0949