• Contacts with Regulatory Agencies and Other Governmental Officials

  • It is the policy of Pepco Holdings, Inc. and its affiliates (collectively, "PHI" or the "Company") to comply with applicable laws and rules set forth by the state and federal and other governmental agencies that regulate the Company, including the provisions of the Foreign Corrupt Practices Act of 1977, as amended (the "FCPA"). Any questions as to rules, interpretations of rules and applicability should be directed to the PHI , except that any questions as to the FCPA should be directed to the Office of the.

    Contacts with Regulatory Agencies

    Because the Company operates in four local jurisdictions and the wholesale power and transmission marketplace, certain of its operations are subject to regulation by three State Public Utility Commissions, the District of Columbia Public Service Commission, and the Federal Energy Regulatory Commission. At any point in time the Company is involved in numerous regulatory activities involving these regulatory bodies. Contacts with these bodies that may seem inconsequential by themselves may have a bearing on other matters in the same or other jurisdictions, or may be the subject of prior communications or precedents of which the employee or other person working by or on behalf of the Company is unaware. Accordingly, it is essential that the Company's interactions with utility regulatory agencies which have authority over the Company's regulated operations be coordinated. Therefore as a general process, no employee or other person working at or on behalf of the Company should contact such a utility regulatory agency unless that contact is discussed with and approved in advance by the PHI Executive Vice President and General Counsel or his or her designee. If an employee or other person working at the Company is contacted by such a regulatory agency, that person should inform the PHI Executive Vice President and General Counsel or his or her designee of the contact to coordinate the Company's response. Where contacts will be of a frequent or routine nature, an appropriate coordination mechanism should be worked out in lieu of contacts regarding each individual interaction with the agency.

    Where in the judgment of a business unit head, discussion and approval of a regulatory contact in advance is not possible due to time constraints, he or she may authorize the contact and provide appropriate information for coordination purposes after the fact.

    Furthermore, it is the policy of the Company that PHI and its directors, officers, employees and others working at or on behalf of the Company must always abide by all applicable laws, rules and regulations, including the FCPA, in its contacts with foreign officials and members of regulatory agencies in other countries. More detailed information regarding this policy may be found in "Public Officials and Campaign Contributions and Activities".

    All of the Company's business units will invariably have numerous contacts with various state and federal regulatory authorities. Care should be taken to ensure appropriate coordination with other business units which may be affected.