Corporate Governance - Business Policies
PHI Policy on Reporting Illegal or 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 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.
Any PHI employee or other person working at PHI can reach PHI’s Ethics Officer by mail, facsimile, or by e‑mail. 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 a 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 regarding accounting, internal accounting controls or auditing matters may be submitted in writing to the Vice President and General Auditor, Internal Audit, Pepco Holdings, Inc., 701 Ninth Street, N.W., Room 8220, Washington, D.C. 20068 or may be made by telephone to 202‑872-3524. If for any reason the employee does not wish to submit the complaint to the Vice President and General Auditor, 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, which may be found on the Company's Internet Web site at www.pepcoholdings.com, or it can be telephoned to the Company's Ethics Officer Hotline at 1-888-683-0041 or 202-872-3376.
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.
