Corporate Governance - Business Policies
Public Officials and Campaign Contributions and Activities
It is the policy of Pepco Holdings, Inc. and its affiliates (collectively, “PHI” or the “Company”) to maintain professional and productive relationships with public officials and to comply with all federal, state and local laws, rules, regulations and orders governing those relationships.
To keep government and regulatory officials informed about Company business, we maintain relationships with government employees and representatives including elected and appointed public officials (collectively, "public officials"). Employees and other persons representing the Company who are responsible for contact with state, federal and other levels of government must be totally familiar with, and abide by, any applicable specific standards adopted by the jurisdiction or any governmental body therein.
Similarly, employees and other persons who work for the Company who are not responsible for contacts with state, federal and other levels of government, but may from time to time come into contact with public officials, should always keep in mind the importance of maintaining professional and productive relationships with these officials and the importance of complying with all applicable federal, state and local laws, rules, and regulations.
Lobbying
PHI employees considered lobbyists (as defined by local, state and federal government rules and regulations), and other persons under contract to lobby on behalf of PHI, are expected to understand and follow applicable governmental laws, rules and regulations. These persons also are expected to be properly registered as lobbyists and to file all required reports. Generally, responding to requests for information from public officials, testifying before government agencies at the request of a registered lobbyist, and submitting comments on proposed legislation or regulations are not considered lobbying and do not require registration. However, specific requirements of lobbying registration laws are quite complex. Before interacting with government officials, advice should be sought from Government Affairs and Public Policy to ensure employees do not inadvertently trigger a registration requirement.
Because maintaining good relationships with elected officials and government agencies requires that PHI present timely, accurate, and consistent information to elected officials and government agencies, employees and others working at PHI should not initiate contact with elected officials or government agencies on matters relating to the Company nor represent Company policies or positions on public issues without the prior notification and approval of either Government Affairs and Public Policy, the Legal Services Group, or Regulatory Affairs (depending on which official or agency is to be contacted). Where in the judgment of a business unit head such prior notification and approval is not possible due to time constraints, he or she may approve action without such prior justification and approval, and provide appropriate information for coordination purposes after the fact.
This policy does not apply to contacts with government officials for purposes other than lobbying or related action, such as sales of goods and services, which in the business head’s judgment do not require such coordination.
Occasionally, employees or others working at PHI may be asked to contact elected or governmental officials on behalf of the Company. Employee participation in these "grassroots" efforts is important to the ongoing success of PHI.
Relationships
All employees and other persons working at PHI are expected to conduct relationships with public officials honestly and ethically. The information we supply to government officials, whether in formal filings or in conversations, must be accurate and complete to the best of the knowledge of the person providing such information. Activities designed to influence the legislative process, or to influence official action of public officials, must be in compliance with applicable laws, rules and regulations governing lobbying and political contributions.
Campaign Contributions and Activities
Federal law restricts the circumstances under which PHI can make corporate campaign contributions to local, state, and federal political campaigns. Under no circumstances shall any such corporate contributions be made without the express approval of Government Affairs and Public Policy. Employees should contact the Senior Vice President of Government Affairs and Public Policy if they have questions about these restrictions, including whether and how they apply to a particular situation. PHI is committed to the representative form of government. As part of this commitment, the Company from time to time provides information and shares its political viewpoint with its employees, customers and the general public. The Company also supports personal involvement of employees on their own time in the political process and respects the fact that the decision whether and how to participate is a personal one that only the employee can make.
