• Annual Certification Process

  • It is the policy of Pepco Holdings, Inc. and its affiliates (collectively, "PHI" or the "Company") to require that certain persons working at or on behalf of the Company (i) certify annually that they have completed the online PHI Corporate Business Policies Course, (ii) certify annually that they have completed the applicable online course regarding the Sarbanes-Oxley Act (the “SOX Course”), and (iii) complete the online PHI Corporate Business Policies Certification Form, in which they must disclose (A) any conflicts of interest they may have with PHI's interests, or (B) any other matters that should be disclosed under those policies. If the person is in a supervisory position, the Annual Certification will include a representation that certain discussions with employees and others about PHI's Business Policies have taken place.

    In addition, it is the responsibility of each PHI Business, Support Services and Corporate Services Organization Head to provide a written annual certification to the Corporate Ethics Officer that those individuals employed in their Business, Support Services or Corporate Services Organization that are required to complete the annual PHI Corporate Business Policy certification requirements described above, including the SOX Course (the “Annual Certification Process”), have indeed done so. This certification by the PHI Business, Support Services and Corporate Services Organization Heads to the Corporate Ethics Officer is to be completed by March 31 of each year.