The general purpose of this Policy is
of this Policy, Social Media includes, without limitation, the following tools
and applications, which are described in greater detail in the appendix to this
In this Policy, Social Media is referenced in two contexts:
Internal Social Media tools are provided to PHI employees and
contractors so that they may share their thoughts and collaborate online with
colleagues at work. PHI encourages its employees and contractors to use
Internal Social Media tools constructively to communicate more effectively with
PHI colleagues, educate themselves about PHI’s utilities and businesses, and to
share knowledge with others in PHI. PHI expects use of all Internal Social
Media channels to be carried out in a constructive and respectful manner.
While External Social Media tools, such as Facebook, LinkedIn and
Twitter, may be accessible through a PHI Information System, PHI neither
controls nor endorses the content or subject matter posted through such tools.
PHI reserves the right to monitor, block or deny access to, in whole or in
part, any Internal Social Media or External Social Media tool without notice
and for any reason.
This Policy covers two uses of Social Media:
Personal use of Social Media by a Covered Person (also referred to in this
Policy as "Covered Social Media Activities")
NOTE: Covered Social Media Activities specifically include Social Media
accessed by a Covered Person outside of work or through personal equipment, if
the use of Social Media involves or references a PHI Interest.
PHI-Sponsored Social Media, which is essentially any
Social Media that is officially endorsed by PHI to be posted or disseminated. A
more complete description of PHI- Sponsored Social Media is found in the
appendix to this Policy.
A PHI Interest is any reference to:
Any violation of this Policy or an
Applicable Regulation is subject to disciplinary action, up to and including
In this Policy, terms that are
capitalized have specific meanings that are defined in this Policy, including
included as an appendix to this Policy. Sometimes the
definition of a capitalized term is not included with the first use of that
Notwithstanding anything to the contrary herein, this Policy will
not be construed or applied in a way that interferes with an employee's right
to engage in Protected Activity under the National Labor Relations Act
("NLRA") or other applicable laws.
Employees should raise any concerns to their supervisor, manager, Human
Resources Business Partner or the PHI Ethics Officer in accordance with PHI’s Policy for Reporting Illegal or Unethical Behavior.
1. Do Not Disclose Unauthorized Information
as specifically authorized by (1) a Vice President (or higher level executive)
who directly or indirectly supervises a Covered Person, (2) the Vice President, Corporate Governance and (3) the Vice President, Corporate Communications, a Covered Person
may not disclose any of the following information using either Internal Social
Media or External Social Media tools:
The authorization requirement set forth above does not apply to:
2. Always Comply with Applicable Regulations
Every Covered Person who engages in Covered Social Media
Activities is personally responsible for compliance with:
NOTE: These requirements do not apply to PHI-Sponsored Social Media
4. Be Truthful, Accurate and Respectful
Trade Commission guidelines mandate that individuals disclose their affiliation
with PHI any time they promote PHI’s products or services in any way, including
by providing an online recommendation.
example, if you post to a web site that seeks to elicit customer feedback of
PHI, you must disclose that you are a PHI employee.
5. Unless Authorized, You May Not Respond to Inquiries from
News Media, Including Those Made Through Social Media
It is PHI’s corporate policy that all inquiries from news media
must be referred to PHI’s Media Relations staff for response. In addition to traditional
news media sources, this corporate policy will be viewed broadly to encompass
Social Media services operating in a non-traditional news gathering way, such
as, among others, Blogs, Wikis and persons utilizing Social Media tools (i.e.,
Facebook and Twitter) to disseminate information in a manner similar to a
traditional news source.
For example, assume that a Covered Person is contacted by a known
consumer rights advocate and blogger seeking comment on a recent regulatory
filing. While this is not a request from a traditional news media source, the
Covered Person should treat this as a media inquiry given that the blogger is
gathering information in a manner similar to a traditional news outlet.
If there is any doubt as to whether a particular source or party
would be considered to be news media under this Policy, please contact the Vice President, Regional Communications in PHI’s Corporate
This rule does not apply to persons authorized to use
PHI-Sponsored Social Media.
6. When in Doubt, Ask First and Post Later
Each Covered Person is always personally and legally responsible
for his or her own use of Social Media and can be held liable for the
consequences of that use. If there is any doubt at any time about whether to post
or publish something via Social Media, or questions about this Policy, contact
the Office of the Corporate Secretary at (202) 872-3487, before posting or
Notwithstanding anything to the contrary herein, this Policy will
not be construed or applied in a way that interferes with an employee's rights
under the NLRA or other applicable laws, including an employee's right to
engage in Protected Activity under Section 7 of the NLRA.
Anyone who refers to a PHI Interest in an External Social Media
post must disclose his or her association with PHI by including the following
"I am [an employee of] [a contractor of] [manager/executive
of] PHI [or specific Utility Subsidiary, if applicable]. The statements or
opinions expressed on [name External Social Media tool] are my own and do not
necessarily represent those of PHI or any of its subsidiaries."
For example, the Required Disclaimer could be included as part of
a Covered Person’s Twitter, LinkedIn or Facebook profile. The Required
Disclaimer is not required if (1) the post is part of the Covered Person’s
official job responsibilities, (2) the Covered Person is authorized to speak on
behalf of PHI (as determined under PHI’s Fair Disclosure (Regulation FD) Policy) and (3) the Covered Person is authorized to use
PHI-Sponsored Social Media (as defined in this Policy) on behalf of PHI. See
Part II.D. of this Policy for additional information and rules regarding
PHI-Sponsored Social Media.
Personal posts using an External Social Media tool must be
generated from a personal email account, and not using a PHI email address. For
example, Covered Persons may not use a PHI email address with a personal
Facebook or LinkedIn profile. However, a Covered Person may reference
PHI (or any affiliate) as his or her employer and/or its web site address on
External Social Media tools. Exceptions to this requirement may be made only by
a Covered Person’s supervisor with approval by the Vice President, Corporate Communications (or his
or her designee).
Job recommendations or professional references regarding PHI
employees or former PHI employees conducted through any External Social Media
tool must comply with all
policies of the Human Resources Department.
From time to time, PHI may provide Internal Social Media tools to
assist employees and contractors in performing their job duties, to encourage
communication among PHI personnel and to foster efficient and effective
Covered Persons must follow good judgment in using Internal Social
Media tools. Where permitted, all third-party or user-generated content,
including links, photos, documents, videos, etc. must be business-appropriate.
No Covered Person should have any expectation of privacy regarding
Internal Social Media postings. PHI reserves the right to remove or delete any
content that is deemed to be irrelevant, inappropriate, harassing, vulgar,
discriminatory, offensive, malicious, threatening, intimidating, obscene,
intentionally defamatory or to violate any Applicable Regulation. Any use of
Internal Social Media tools that interferes with their stated purposes is
Covered Persons must review communications to ensure that they are
not inappropriately sharing market information, nonpublic transmission system
information or other nonpublic utility information.
for persons who have been specifically authorized by the Vice President, Corporate Communications (or his or her designee) or
another PHI executive, no Covered Person is authorized to use any External
Social Media tool in connection with his or her PHI job responsibilities or commitments.
Any use of external PHI-Sponsored Social Media must clearly
disclose that it is sponsored by PHI. For example, this can be accomplished by
including a statement that "this page is sponsored by PHI" and/or a
consistent identifying icon or logo (such as the PHI or subsidiary logo).
PHI-Sponsored Social Media (whether internal or external) must include legal
terms setting forth the conditions for use, e.g., "Terms of
Use," "Terms and Conditions," "House Rules." These
legal terms will be provided by PHI Legal Services. There may be certain social media platforms for which
such terms are not required. No PHI-Sponsored Social Media (whether internal or
external) may launch without receiving such terms from PHI Legal Services or
receiving such legal counsel’s approval for launch without such terms.
Information on PHI-Sponsored Social Media will be preserved in
accordance with PHI’s Retention and Maintenance of Records Policy. PHI’s General Counsel should be contacted with any
questions regarding the preservation or retention of any such content. Certain
external parties, including regulators, parties to utility regulatory
proceedings, and individuals or companies in litigation with PHI, may be
entitled to review or receive copies of PHI-Sponsored Social Media.
access information for any PHI-Sponsored Social Media tools must be kept secure
and confidential. For example:
The Policy is effective as of September 1, 2014.
Note: Certain PHI employees are employed pursuant to a collective
bargaining agreement or employment contract (labor agreement). If for such
employees, in any particular instance, the labor agreement differs from the
Policy, the labor agreement governs. If, in any particular instance, a business
practice exists and is not covered in the labor agreement, management may
Social Media Activity means any Covered Person using Social Media:
Social Media Activity does not include any activity that is properly conducted
through PHI-Sponsored Social Media in accordance with this Policy.
the purposes of this policy, an information system is any telecommunications
and/or computer related equipment or interconnected system or subsystems of
equipment used in the acquisition, storage, manipulation, management, movement,
deletion, control, display, switching, interchange, transmission, or reception
of voice and/or data, and includes software, firmware, and hardware. This
definition is intentionally broad and includes any device or service connected
to a PHI-owned asset or Intranet. Examples include, but are not limited to,
personal computers (laptops and desktops), PDAs (e.g., Blackberries™, iPads,
Android devices and Palm Pilots™), USB drives, MP3 players (i.e., iPod™),
mobile phones, voicemail and websites.
discussed in PHI’s Fair Disclosure (Regulation FD) Policy, information is
material where there is a substantial likelihood that the information, if
known, would be viewed by a reasonable investor either as having significantly
altered the total mix of information available or would be important in making
a decision to buy, sell or hold PHI’s securities.
is considered to be “non-public” until it has been widely disclosed and a
sufficient period of time has elapsed for the information to be effectively
disseminated to shareholders. As a
general rule, information will be considered non-public until the third
business day after disclosing such information in an SEC filing or by other
appropriate means of public disclosure.
any written or electronic information that relates to an identified or identifiable
person (Individual). In practice, this means any information that can
reasonably be used to identify a living person, including factual information
about such person, such as name, address, telephone number, social security
number, e-mail address or information relating to the health condition
(physical or mental) of an Individual, as well as information about his/her
opinions or beliefs. Under certain local laws and regulations, even if such
information is encoded (i.e. converted to a format that makes it impossible to
identify an Individual without access to the “key” that allows the information
to be re-associated with the Individual), subject to other de-identification
techniques or is publicly available, it may be treated as Personal Information.
Social Media is Social Media officially endorsed by PHI to be posted or
disseminated only by persons specifically designated, approved and overseen by
the Vice President Corporate Communications (or his or her designee). Examples
include PHI’s and its utility subsidiaries’ Facebook pages, Twitter feeds,
YouTube channels and LinkedIn accounts.
Social Media is designed to positively impact PHI’s reputation and its
relationships with customers and other key stakeholders; thus, it is critical
that PHI-Sponsored Social Media be fully aligned with the strategies, branding,
processes and practices established by Corporate Communications.
in any medium, which:
Examples, without limitation, include confidential
information pertaining to: customers or prospective customers, pricing,
marketing, financial plans or projections, business plans or strategies, legal
and regulatory matters, investment and securities, mergers and acquisitions,
products and product development, budgets, computer software and management
information systems, designs and drawings, research and development,
engineering, inventions, improvements, discoveries, innovations and ideas,
personnel, employees, contractors, management and training programs.
There may also be circumstances where other parties’
confidential information may be included in this term. Such circumstances include, for example,
pre-acquisition exchange of information, confidential information exchanged
solely for the purposes of and in the context of litigation, administrative or
regulatory proceedings, and contracts including confidentiality provisions
B. Any formula, pattern, device or
compilation of information maintained in secrecy which is used in business, and
which gives that business an opportunity to obtain an advantage over
competitors who do not know about it or use it. The nature of PHI’s business
operations may also constitute Proprietary/Confidential Information and Trade
Means an employee's right to engage in protected
concerted activity under Section 7 of the NLRA and/or an employee's right to
bring any whistleblower, qui tam, or similar claim or proceeding under
or described in, among other laws, rules and/or regulations:
Sensitive Information is information regarding PHI that may itself not be material, but which PHI desires not
to disclose to the public. Examples of Sensitive Information include,
Media encompasses, but is not limited, to the following areas:
are self-contained software that are typically served via a website or mobile
device. Applications may be used to deliver information or content, increase
user interaction, or provide a service. Common examples of applications are
widgets, advergames, and device-specific software like iPhone, Android or
podcast is a series of digital media files (either audio or video) that are
released episodically and downloaded through web syndication. The mode of
delivery is what differentiates podcasts from other ways of accessing media
files over the Internet. The classification of a podcast refers to audio files
that are shared online and meet the following three criteria: first, that it is
episodic; second, that it is downloadable; and third, that it is
program-driven, mainly with a host and/or theme. Popular delivery standards
include RSS, Atom and OPML. Popular listening platforms include iTunes, Juice,
Blog Talk Radio, SoundCloud and Winamp.
blog (a contraction of the term "web log") is a type of website,
usually maintained by an individual, with regular entries of commentary,
descriptions of events, or other material such as images or video. Entries are
commonly displayed in reverse chronological order. Popular blog platforms
include Blogger, Wordpress, Typepad and Livejournal.
sharing websites allow individuals to upload digital images or photos to the
Internet via an image host. The image host will then store the digital images
on its server and display them to its visitors, typically along with a variety
of sharing tools and code options. Visitors may use these options to display
the digital images on different websites in addition to the website operated by
the image host. In some instances, users may be allowed to download original
copies of the digital images to their own computers. Popular video sharing
platforms include Flickr, Instagram, Pinterest, Photobucket, TinyPic, Picasa
are a form of blog that allows users to send brief text updates or micromedia
such as images or video and publish them. These messages can be submitted by a
variety of means, including text messaging, instant messaging, email, digital
audio or the web. Microblogs differ from traditional blogs in that entries are
typically smaller in actual size and aggregate file size. Popular microblog
platforms include Twitter, Tumblr, Yammer and Plurk.
sharing websites allow individuals to upload slide decks to the Internet via a
document host. The document host will then store the slide decks on its server
and display them to its visitors, typically along with a variety of sharing
tools and code options. Visitors may use these options to display the slide
decks on different websites in addition to the website operated by the image
host. In some instances, users may be allowed to download original copies of
the documents to their own computers. Popular video sharing platforms include
Slideshare, Authorstream, Slideserve and Slideboom.
bookmaking sites allow users to share, organize, search, and manage links to
web resources. Unlike file sharing, the resources themselves aren't shared,
just bookmarks that reference them. Descriptions may be added to these
bookmarks in the form of metadata, so that other users may understand the
content of the resource without first needing to visit the link. Such descriptions may be free text comments,
votes in favor of or against its quality, or any other collaborative tagging
device. Popular social bookmarking sites
include Digg, Delicious and Reddit.
networks focus on building online communities of people who share interests
and/or activities, or who are interested in exploring the interests and
activities of others. Most social networks provide a variety of ways for users
to interact, such as user profiles, image and video sharing, interest-based
groups, public discussion threads, private messaging, and instant messaging
services. Popular social networks include Facebook, LinkedIn, MySpace, Google+,
Bebo and Orkut (now part of Google).
forums are similar to social networks, but with less robust personal networking
options. The focus of a user forum, which is also sometimes referred to as a
discussion or message board, is a threaded conversation platform in which
members discuss issues according to pre-defined topics. Each discussion has
opportunity for response from other members of the forum and is normally
maintained in reverse chronological order, with the most recent comment being
displayed at the top of the thread. In many cases, members may also create user
profiles and send each other private messages, similar to a social network;
however the focus of a user forum remains strongly centered on threaded
Sharing websites allow individuals to upload video clips to the Internet via a
video host. The video host will then store the video on its server and display
the video to its visitors, typically along with a variety of sharing tools and
code options. Visitors may use these options to display the video on different
websites in addition to the website operated by the video host. In some
instances, users may be allowed to download original copies of the video files
to their own computers. Popular video sharing platforms include YouTube,
Metacafe, DailyMotion and Blip TV.
virtual world is a computer-based simulated environment intended for its users
to inhabit and interact via avatars. These avatars are usually depicted as
textual, two-dimensional, or three-dimensional graphical representations. Some,
but not all, virtual worlds allow for multiple users. The computer accesses a
computer-simulated world and presents perceptual stimuli to the user, who in
turn can manipulate elements of the modeled world. Such modeled worlds may
appear similar to the real world or instead depict fantasy worlds. Example
rules are gravity, topography, locomotion, real-time actions, and
communication. Communication between users may range from text, graphical
icons, visual gesture, and sound. Popular virtual worlds include Second Life,
Minecraft, The Sims 3, IMVU, FarmVille, Kaneva, and There.com.
Wikis are websites that allow users to
create web pages that are collaboratively edited using a common web browser.
Wikis are often used to create collaborative websites, to power community
websites, for personal note taking, in corporate intranets, and in knowledge
management systems. Popular wikis include Wikipedia, WikiWikiWeb, WikiHow and