• Reporting Unethical Behavior

  • It is the policy of Pepco Holdings, Inc., and its affiliates (collectively, "PHI" or the "Company") to have multiple effective means for (i) providing advice to employees and others working at or on behalf of the Company about acceptable business practices and (ii) reporting possible violations of corporate and other business policies and illegal or questionable conduct. It also is the Company's policy to remedy violations of Corporate and Area Business Policies promptly and respond appropriately to illegal, unethical or questionable conduct.

    Advice/Reports/Complaints:  

    The PHI Ethics Officer: 

    The General Counsel of PHI also is PHI's Ethics Officer. One of the Ethics Officer's roles is to ensure that allegations of unethical conduct are appropriately investigated. A second role is to help individuals to think through ethical questions, including potential conflicts of interest, to help them make sound, informed decisions. Responsibility for actions taken or not taken when faced with an ethical question remains with the individual who has the question.

    Any PHI employee or other person working at or on behalf of PHI can reach PHI's Ethics Officer by mail (701 Ninth Street, N.W., Room 1007, Washington, D.C. 20068), facsimile (202-872-3586), or by email to Ethicsofficer@pepco.com. Messages also can be left on the Corporate Ethics Hotline: 1-888-683-0041 or 202-872-3376. While it is difficult to conduct a thorough investigation based on limited information or to respond directly to an anonymous concern, anonymous messages also may be left at the Corporate Ethics Hotline.

    Additional whistleblower process for employee complaints including confidential anonymous complaints regarding accounting, Internal Accounting Controls or Auditing Matters:

    Complaints from Company employees or other persons working at or on behalf of PHI regarding accounting, internal accounting controls or auditing matters may be submitted in writing to the Director, Internal Audit, Pepco Holdings, Inc., 701 Ninth Street, N.W., Room 8220, Washington, D.C. 20068 or may be made by telephone to 202 872-3341. If for any reason the person making the report does not wish to submit the complaint to the Director, Internal Audit, it may be addressed to the Chairman of the Audit Committee using the procedures set forth in Section N, "Communications with Directors," of the Company's Corporate Governance Guidelines, or it can be made by telephone to the Company's Ethics Officer Hotline at 1 888-683-0041 or 202-872-3376, or submitted in writing to the Ethics Officer at 701 Ninth Street, N.W., Room 1007, Washington, D.C. 20068.

    The Chain-of-Command: 

    The normal chain-of-command-supervisors, managers, and the people to whom they report-are the primary means for getting advice about acceptable business practices and for reporting possible violations of Corporate or Area Business Policies or illegal or other questionable conduct. Allegations, complaints or concerns regarding sexual harassment or harassment may also be referred to the Vice President, People Strategy & Human Resources. Allegations, complaints or concerns regarding business practices, possible violations of Corporate or Area Business Policies or illegal or other questionable conduct of a member of senior management should be reported directly to the General Counsel. If such behavior involves the General Counsel, such report shall be made to the Director, Internal Audit.

    No Retaliation:

    There will be no retaliation against a person for making a report alleging ethical violations. Any person who engages in such retaliation, directly or indirectly, or encourages others to do so, may be subject to discipline, up to and including discharge.

    All reports will be reviewed thoroughly, and, where warranted, corrective action will be taken promptly. Anyone making a report or otherwise involved in an investigation is expected to provide all relevant information requested from such person in the course of any investigation.