Corporate Governance - Business Policies

PHI Policy on Reporting Illegal or Unethical Behavior

IIt 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 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 and respond appropriately to illegal or questionable conduct.

Advice/Reports/Complaints
The PHI Ethics Officer:  The General Counsel of PHI also is PHI’s Ethics Officer, and as such has several roles.  One is to ensure that allegations of unethical conduct are appropriately investigated.  A second role is to help employees think through ethical questions to help them make sound, informed decisions.  Responsibility for actions taken or not taken when faced with an ethical question remains with the employee or other person working at the Company. 

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 Business Policies and 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.

Support Services:  Many PHI Corporate Services groups have specialized expertise that they provide to one or more of PHI’s businesses.  Managers of these groups can be reached by mail, telephone, facsimile, or e-mail if advice is needed about one of these specialized functions, or if a possible violation of corporate or departmental business policies or illegal or other questionable conduct involves one of these areas.

Investigations:  There will be no retaliation against a person who makes a report merely for having done so.  Any person who engages in such retaliation, directly or indirectly, or encourages others to do so, may be disciplined, up to and including discharge.

All reports will be investigated 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.

If Employees Need Help: As in most situations, good judgment and common sense should guide employees’ decisions about how to interpret and apply these business policies.  If employees need help interpreting these policies or if they observe potential violations of these policies, they should contact their supervisor or the Ethics Officer.