Code of Business Ethics and Conduct · PDF fileIf you have a concern or wish to report a...

Code of Business Ethics and Conduct

Portland General Electric

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Cover Images, clockwise from top:

PGE has more than 26,000 miles of distribution line to watch over.

The Lundquist family volunteers at Fort Stevens State Park for a SOLVE beach cleanup.

PGE’s Advisory Committee on Diversity and Inclusion advises management on diversity related issues.

Opposite:

PGE President and CEO Jim Piro has more than 41 years’ experience in the utility business.

There are slight formatting differences between the print and online versions of this document, however the content of both versions is identical.

A message from Jim Piro

Please don’t allow anyone or anything to ever compromise your commitment to integrity. If you see something that doesn’t seem to meet the high bar we have set for ourselves, speak up. We welcome and support employees who have questions or seek guidance on particular issues or want to report a concern or violation. Be assured no employee raising a concern or asking a question in good faith will be subject to discipline for speaking up. In addition, we do not tolerate retaliation in any form against an employee for reporting a concern or suspected violation, or for participating in an investigation.

The Code of Business Ethics and Conduct is one of the most important documents you will receive while with PGE. I ask that you read it in its entirety, and make a personal commitment to understand and uphold it. No code can address every situation, and we don’t try to do so here. There may be situations when you have a question or concern about what is proper conduct for you or someone else. That’s when you should raise the issue with your manager or contact a member of our Ethics & Compliance team at (503) 464-7091.

Thank you for your dedication to these principles and to making PGE a great place to work.

Sincerely,

President and CEO Portland General Electric

Dear employees, officers, and board members:

We aspire to power our customers’ potential as the region’s trusted energy partner. Our success in achieving that goal depends on our ability to earn and retain the trust of co-workers, customers, regula-tors, investors, and communities. This requires that we act with the highest levels of honesty, integrity, and compliance — making the right decisions and taking the right actions every time.

It’s not always easy to know what’s right in a particular situation. Our Code of Business Ethics and Conduct provides guidance for what’s expected of us as we conduct the company’s business and is intended to help us do things the right way. The Code is aligned with our Core Principles, which describe what is important to our company and what our customers expect from us. These principles are: Safety & Health, Continuous Improvement, Ethical Business Practices, Diversity & Inclusion, Community Investment, and Environmental Stewardship. The Code also reflects our Guiding Behaviors, which employees use when making day-to-day decisions. These principles and values are foundational for PGE and are essen-tial for us to achieve the level of excellence to which we aspire.

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Introduction

Purpose

Who the Code covers

Affirming commitment to the Code

Waivers

Our core responsibilities

Follow the Guiding Behaviors

Make the right decisions

Report concerns or violations

Management responsibilities

Our commitments to our co-workers

We promote a safe, secure, and healthy workplace

We do not retaliate

We do not discriminate

We do not engage in harassment

We treat each other fairly

Table of Contents

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If you have a concern or wish to report a violation, you may contact any of the following: Your manager or supervisor; EthicsPoint Hotline, 866-384-4277, or www.EthicsPoint.com; Ethics & Compliance, 503-464-7091;

Human Resources, 503-464-7250; or the corporate compliance officer, 503-464-8860.

5If you have a concern or wish to report a violation, you may contact any of the following: Your manager or supervisor; EthicsPoint Hotline, 866-384-4277, or www.EthicsPoint.com; Ethics & Compliance, 503-464-7091;


Our commitments to our customers

We deal fairly with others

We protect our customers’ information

We properly offer and accept business entertainment and gifts

We avoid conflicts of interest

We don’t use our connections with PGE for personal gain

Our commitments to the community

We communicate honestly and accurately

We protect the environment

We only engage in lawful political activities

We comply with laws and regulations

We gather information about other businesses lawfully and ethically

Our commitments to investors

We do not engage in insider trading

We report personal investigations

We protect PGE’s assets

We protect confidential information

We comply with laws protecting intellectual property

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If you have a concern or wish to report a violation, you may contact any of the following: Your manager or supervisor; EthicsPoint Hotline, 866-384-4277, or EthicsPoint.com; Ethics & Compliance, 503-464-7091;


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Clockwise from top left:

PGE linemen take a break for a photo during work on the PGE-owned portion of the 500kV intertie.

Bob Millican, facilities management supervisor, helped oversee the renovation of Rose City.

This team received a Project of the Year award for the Move Service Automation project.

Introduction

www.EthicsPoint.com



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Purpose

Our Code of Business Ethics and Conduct (Code) expresses the fundamental principles, policies, and practices that we must use when conducting PGE’s business. It acts as a guide for helping each of us make the right decisions and take the right actions every day. The Code is central to our efforts to sustain an ethical culture at PGE, and ensure we are complying with our business, regulatory, and legal obligations.

The Code is not intended to address every situation that may come up. We should also look to PGE’s Core Principles, Guiding Behaviors, other corporate policies, or individual department policies and practices for guidance. We can also use the questions in the

“Make the right decision” section of this Code, or contact any of the resources listed at the bottom of these pages. In the end, we must use our best ethical judgment and commitment to integrity to make the right thing happen.

Who the Code covers

The Code, which has been approved by PGE’s Board of Directors, applies to every board member, officer, and employee of PGE and its subsidiaries.

Affirming commitment to the Code

We must all read, understand, and comply with the Code, other company policies, and the law. Affirming our commitment to the Code is a condition of employment and means we agree to behave in accordance with it. If we violate the Code, we may be subject to discipline, up to and including termination.

Waivers

An individual may request a waiver of a specific policy requirement by submitting a Policy Waiver Request Form (found on PGE’s intranet). The individual’s manager, functional officer, and the officer who sponsors the policy must approve the request. Waivers for board members, officers, and the controller may be granted only by the audit committee of the board of directors and must be disclosed promptly to share-holders as required. It is important to understand that policy waivers will be granted only in extremely limited situations.

www.EthicsPoint.com



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Our Core Resonsibilities

Follow the Guiding Behaviors

The Guiding Behaviors are values and perspectives we use to approach everyday deci-sions and guide our behavior in the workplace. By consistently modeling these values, we build a strong ethical culture at PGE. If we violate any of the Guiding Behaviors, we may be subject to discipline, up to and including termination.

• Be Accountable — We accept responsibility for all aspects of our work. We honor commitments; “own up” to results, decisions, and actions; and chal-lenge ourselves and others to continuously improve. We take initiative, always asking “what more can I do?”

• Dignify People — We respect and value others, and appreciate each person’s unique contributions. We recognize that our co-workers and customers are indi-viduals, with their own needs and goals, and we treat them the way they would like to be treated. We listen to diverse voices, because if we don’t, we’ll miss new ideas and won’t grow and change.

• Make the Right Thing Happen — We constantly look for ways to do our jobs better, always striving for continuous improvement. We aren’t afraid to ask why we do something a certain way, and we welcome ideas for how to be more effi-cient, serve customers better, or be more cost-effective. We can influence others by staying positive, addressing problems head on, and encouraging innovation, flexibility, and creativity.

• Positive Attitude — We believe success is achievable, and we bring that attitude to our individual work and to our work as a team. We don’t allow obstacles to stop us; instead, we see them as opportunities to find solutions we haven’t tried before.

• Team Behavior — We know we can make tremendous progress when we work together to confront a problem or achieve a common goal. We value the in-sights, skills, and knowledge each individual brings to the team, and we encour-age them to share what they know so we can all learn. In the end, putting the needs of the team first benefits everyone.

• Earn Trust — We keep our promises and commitments, are honest and straight- forward, and deal with issues fairly and consistently. Through these behaviors we earn the trust of our co-workers and customers.

www.EthicsPoint.com



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Make the right decisions

Our Code can’t address every issue that may arise. When we’re confronted with a difficult situation, and don’t know what to do, we can use the follow-ing questions to help us make the right decision:

• Would my action be legal?

• Would my action be consistent with the Code, PGE’s Core Principles, the Guiding Behaviors, and other PGE policies?

• Am I being fair and honest?

• How might others (including customers) be affected by the choice I make?

• Would I be unwilling or embarrassed to tell others about my actions?

• Would I feel comfortable if my actions were reported in the news?

If we’re still unsure, we can discuss the issue with our manager or supervisor, or any of the other contacts listed at the bottom of these pages.

GUIDING BEHAVIORS

Q I have witnessed my manager treat-ing employees in a very undignifying manner on several occasions. She often criticizes employees in public, rudely interrupts them, rolls her eyes and makes faces, and generally treats them as if they are not competent. It’s very uncomfort-able and seems like a poor management practice. I’ve encouraged my co-workers who are targets of her attacks to speak up for themselves, but they never do. I don’t feel comfortable approaching my manager, because I don’t want to be her next target. What should I do?

A All employees must exemplify our Guiding Behaviors, regardless of title. Those who don’t, need to be held ac-countable. If you don’t feel comfortable providing feedback, report the incident(s) to one of the resources listed at the bot-tom of these pages. We want a respectful, professional work environment for all employees.

Tucannon River Wind Farm, located near Dayton, Wash., came online in December 2014.

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Report concerns or violations

We report any concern or suspected violation of this Code; the Guiding Behaviors; PGE policies; and all laws, rules, and regulations applicable to our work. As long as any of us makes a report in good faith, we will not be subject to discipline for making such a report. Raising a concern in good faith means speaking up about a situation we believe to be true even if it is later deter-mined that no wrongdoing occurred. If we make a report in bad faith, know-ing the information is false or manufactured, we may be subject to discipline, up to and including termination.

We can raise issues by contacting any of the resources listed at the bottom of these pages. Anyone who reports a concern can be assured their identity will be kept confidential to the extent reasonably possible and where consistent with legal requirements. Completely anonymous reports may be made to the EthicsPoint Hotline. If we make an anonymous report through EthicsPoint, we get a unique code that enables us to access our case online. It’s very important that we check our case periodically, because the investigator may have ques-tions or need additional information in order to investigate the concern.

PGE has designated individuals who will promptly look into all reported con-cerns or suspected violations, so we should never conduct our own investiga-tions. Investigations may involve complex issues, and acting on our own may compromise the integrity of an investigation and adversely affect both us and PGE.

We must be truthful and cooperate fully with any investigation. PGE will not tolerate retaliation in any form against an employee for reporting a concern or suspected violation of the Code, or for participating in an investigation. If we or someone we know is experiencing retaliation, we should contact any of the resources listed at the bottom of these pages.

“PGE will not tolerate retaliation in any form against an employee for reporting a concern or suspected violation of the Code, or for participating in an investigation.”

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Management responsibilities

In addition to understanding and promoting the Code, PGE’s officers and managers must foster a workplace that promotes ethical and compliant behavior. Here are some ways for managers to do that:

• Set a positive example by modeling ethical behavior.

• Create an environment where employees feel comfortable raising questions or concerns, and they know you’ll listen and respond appropriately.

• Ensure that employees understand the importance of participating in ethics and compliance training programs.

• Provide feedback to employees about their ethical or compliant behavior.

• Make sure employees who report concerns or suspected violations are aware of PGE’s policy against retaliation.

• Do not retaliate against an employee for reporting a concern or suspected violation, or for participating in an investigation.

Top: Gordon Chan is manager of Enterprise Operations.

Bottom: Chad Croft is plant manager at a PGE hydro facility.

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Our commitments to our co-workers

We promote a safe, secure, and healthy workplace

SAFETY IS ONE OF OUR CORE VALUESWe are committed to providing a safe and healthy place of business. In support of that goal, we:

• Perform our duties in accordance with all safety and health laws, regulations, and PGE policies;

• Read and follow the safety manuals and other materials that apply to our job;

• Create and maintain a safe work environment;

• Immediately notify our supervisor of any hazardous condition in the workplace; and

• Report any work-related near miss, accident or injury.

For more information, see our Safety and Health policy and the PGE Safety Manual.

SAFETY AND HEALTH

Q Chad, a storeroom employee, saw a co-worker get debris in his eye while doing some cleanup work in the store-room. The job called for wearing safety glasses, but Chad’s co-worker was not wearing any. It turns out the co-worker was fine, and there was no personal injury. Since he wasn’t hurt, is this some-thing Chad should report?

A Yes, all occupational incidents must be reported so PGE can determine what happened, how it happened, why it hap-pened, and what’s necessary to prevent similar occurrences in the future.

Q Sally works downtown and wonders what the big deal is about letting some-one in through a card access door. If she recognizes the person as an employee, why can’t she be polite and hold the door open?

A The purpose of limiting access is to ensure the safety of our employees and protection of company assets. Even if you recognize someone as an employee, you can never be certain of their current employment status. Simply apologize for the inconvenience, and tell them they will need to use their own badge for access. If they don’t have a badge, direct them to the security desk to obtain temporary access. At other company locations, check first with the person the visitor is request-ing to see. If it’s an employee, obtain appropriate authorization from the employee’s manager.

www.EthicsPoint.com

http://sharepoint/eandc/policies/safety_health_policy.pdf

http://sharepoint/HR/Safety/myPGE/Our-Company/Initiatives/Safety/Policies-Practices/safety_manual.pdf



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WE MAINTAIN AN ALCOHOL- AND DRUG-FREE WORKPLACEIn order to perform our jobs as safely as possible, we never work while under the influence of illegal drugs, alcohol, or any other substance that impairs job perfor-mance. These affect our judgment and motor skills and put us, our co-workers, cus-tomers, and others at risk. While on company premises, or conducting PGE business, we cannot use, sell, or purchase; attempt to use, sell, or purchase; or be under the influence of alcohol, any illegal drug, or any legal drug used in an illegal manner. We are also prohibited from misusing prescription drugs or over-the-counter medications. Marijuana is treated as an illegal drug under our Drug and Alcohol policy.

For more information, see our Drug and Alcohol policy.

WE DO NOT TOLERATE VIOLENCE IN ANY FORMWe cannot act or behave in any way that intimidates, threatens, or causes harm to persons or property, or is violent. If we become aware of a threat, violence, intimida-tion, or harm to others, or harm to PGE property, we must report it. If there is a threat of imminent harm, we contact Corporate Security immediately. Otherwise, we may contact one of the resources listed at the bottom of these pages.

We cannot possess weapons (other than pocketknives with a blade of four inches or less) or materials, substances, or explosives that may be used to harm persons or prop-erty when engaged in PGE business. This also applies to employees with licenses to carry a concealed handgun. Security employees are exempt from this prohibition.

For more information, see our Workplace Violence Prevention policy.

We do not retaliate

We will not tolerate retaliation in any form against an employee for reporting a concern or suspected violation of the Code, or for participating in an investigation. If we or someone we know is experiencing retaliation, we should contact any of the resources listed at the bottom of these pages.

We do not discriminate

PGE is an equal employment opportunity employer. This means we do not discriminate in recruitment, hiring, termination, promotion, salary treatment, or any other condi-tion of employment on the basis of race, color, sex, religion, national or ethnic origin, age, disability, marital status, veteran status, sexual orientation or gender identity, or genetic information. We abide by all laws prohibiting discrimination in the workplace.

We do not engage in harassment

We believe the workplace should be free from harassment. Harassment includes any behavior that is intended to or does create an intimidating, hostile, or offensive work environment, or interferes with an individual’s work performance. It can take many

www.EthicsPoint.com

http://sharepoint/Eandc/Policies/drug_alcohol_policy.pdf

http://sharepoint/Eandc/Policies/workplace_violence_prevention_policy.pdf



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forms, including verbal remarks, physical advances, or visual displays, and can come from co-workers, suppliers, contractors, or customers.

“We believe the workplace should be free from harassment.”

Harassing conduct can be nonsexual or sexual. Nonsexual forms of harassment include, but are not limited to: using derogatory nicknames or slurs, negative stereotyping, behaving in a threatening or intimidating way, and verbal or physical conduct that degrades or shows hostility or hatred toward an individual or members of a group. It can also include displaying or circulating written or graph-ic material that ridicules or shows hostility to an individual or group. Forms of sexual harassment include, but are not limited to: verbal harassment, such as unwelcome comments, jokes or slurs of a sexual nature; physical harassment, such as unnecessary or offensive touching or blocking movement; and visual harassment, such as offen-sive posters, cards, cartoons, graffiti, drawings, or gestures.

We treat each other fairly

At PGE, we do not play favorites. This means we do not treat a person or group better or worse than other employees based on our personal preferenc-es. Instead, we make decisions about how we treat people objectively, based on strengths, perfor-mance, and accomplishments.

Two forms of favoritism we specifically avoid are:

• Nepotism — Showing favoritism to a rela-tive, domestic partner, or spouse based on the relationship. These individuals won’t be treated differently from other applicants for employment. However, PGE will look more closely at situations where we might be in-

HARASSMENT

Q One of my co-workers told an inappropriate joke to me and some team-mates. I found it offensive, but I don’t know if I should approach my co-worker with my concern. Everyone else laughed, so maybe it’s just my problem. What should I do?

A We each have a responsibility to ensure PGE is a great place to work for all employees. Offensive behavior like this is not acceptable, and if you feel comfortable doing so, let your co-worker know how you feel. If you aren’t comfort-able addressing the issue directly, contact one of the resources listed at the bottom of these pages.

Q A co-worker regularly touches my shoulder when we talk, and it makes me uncomfortable. She’s probably just being friendly, and I don’t want to get her in trouble, but I wish she would stop. What should I do?

A If you are comfortable speaking to your co-worker directly, let her know how her behavior makes you feel, and ask that she stop. If you aren’t comfortable ad-dressing the issue directly, contact one of the resources listed at the bottom of these pages.

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volved in a workplace decision involving a relative, domestic partner, or spouse. We may not enter into or stay in a position where we exercise supervisory, appointment, promotional, or grievance authority over a relative, spouse, or domestic partner, or if the position otherwise creates a conflict of interest.

• Cronyism — Showing favoritism toward a friend or associate from either inside or outside of PGE.

This doesn’t mean that our friends and family can’t work for PGE. It just means that they can’t be offered positions based on personal relationships rather than qualifications. These situations can be complicated, so when in doubt, call Ethics & Compliance.

We deal fairly with others

We are committed to providing outstanding service. This means we treat every-one in a fair, ethical, and lawful manner. We do not take advantage of anyone through manipulation, concealment, abuse of privileged information, misrep-resentation of material facts, or any other unfair-dealing practice. We do not take actions that unfairly promote our own or PGE’s interests at the expense of our customers.

We protect our customers’ information

Our customers expect us to keep their information confidential, and we take this obligation very seriously. We will not release personally identifiable infor-mation to third parties without the customer’s consent unless permitted or required by law, rule, regulation, or company policy, or we believe such action is necessary to:

• Protect and defend our rights or property;

• Protect against misuse or unauthorized use of our website; or

• Protect the safety or property of our customers or the public.

For more information, see our Release of Confidential Information policy, and additional information titled Privacy Policy and Security at PortlandGeneral.com/privacy_policy.

Our commitments to our customers

www.EthicsPoint.com

http://sharepoint/Eandc/Policies/release_confidential_information_policy.pdf

https://www.portlandgeneral.com/privacy-policy

https://www.portlandgeneral.com/privacy-policy



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We properly offer and accept business entertainment and gifts Building business relationships is important and valuable. Exchanging gifts and busi-ness entertainment can create goodwill or provide an opportunity to increase industry or product knowledge. It can also create a conflict of interest. We need to be fair, im-partial, and objective, so we must never accept gifts, entertainment, or personal favors that could affect or be perceived to affect our business judgment or decisions. We must never ask for gifts, entertainment, or any other business courtesies from a business contact. Finally, we cannot give or receive a bribe, gratuity, or kickback in any form. These rules apply to us, our families, and members of our household.

“We must never accept gifts, entertainment, or personal favors that could affect or be perceived to affect our business judgment or decisions.”

When we use the terms business entertainment and gifts, we mean the following:

• Business entertainment — Business entertainment is any meal, sporting event, cultural event, or comparable activity that we attend with a business contact; or conferences or other business functions where a business contact pays the fees, travel, or accommodations. Business entertainment is acceptable if it is unsolicited, for a legitimate business purpose, not excessive in value, appropri-ate in nature, and given or accepted without an express or implied obligation.

• Gifts — Gifts can be anything of value, including such items as tickets to a sporting event, wine, a coffee mug, a service, etc. Gifts may be accepted as long as they are consistent with accepted business practices and the law, and public disclosure wouldn’t negatively affect PGE or the people involved. We cannot accept cash or a cash equivalent in any amount, unless it is a mer-chant-specific gift card or gift certificate (e.g., Target, Starbucks) with a value of $25 or less. A cash equivalent is something that can be spent like currency or readily exchanged for goods or services. Cash equivalents include, but are not limited to, checks, loans, savings bonds, non-merchant specific gift cards or gift certificates, and prepaid debit or credit cards.

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BUSINESS ENTERTAINMENT AND GIFTS

Q After a thorough selection process, Sarah and her team have chosen a vendor for their project. The selection process was conducted fairly and objectively, and the vendor was notified they were awarded the contract. The next day, Sarah and each team member receive a thank you card from the vendor that includes two tick-ets to an upcoming performance of the Oregon Symphony. The tickets have a face value of $80. What should Sarah do?

A Because the contract was awarded before the gift was received, and the val-ue of the gift for each employee is $160, Sarah and each team member can accept the gift without preapproval. However, in situations like this, when a gift is given in such close proximity to the awarding of the contract, it’s also important to consid-er how others might perceive the gift. If in doubt about what to do, consult with Ethics & Compliance.

Q A vendor just gave Ted a $50 gift card to use at a local restaurant. Can Ted accept it?

A No. Ted can only accept a gift card in the amount of $25 or less. Gift cards must also be merchant specific.

Employees gather to celebrate the 40th anniversary of the Beaver Plant coming online.

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BUSINESS ENTERTAINMENT AND GIFTS

Q A vendor Ann works with just fin-ished an important project on time and under budget. Ann wants to express her appreciation with a gift. What is appropriate?

A When we give gifts, we set the tone for how we conduct business. Just as we want others to respect our standards, we want to be mindful of theirs. Ann should ask the vendor first about their policy on gifts, because she might discover they are not allowed to accept them. It’s better to find out ahead of time to avoid any awkward refusals. If gifts are allowed, Ann should adhere to the vendor’s policy or she should consider following the same guidelines we use for ourselves.

While it may seem rude, we can politely refuse a gift or business entertainment. We should thank the giver for his/her generosity but explain that PGE policy doesn’t allow us to accept the gift or business entertainment.

We should not provide a gift or business entertain-ment that violates another company’s policy. It’s also important to remember that what is accept-able in the commercial business environment may be unacceptable or illegal in dealings with the gov-ernment. As a result, we cannot provide anything of value to government officials or employees, or members of their families, in connection with PGE business without obtaining prior written approval from the corporate compliance officer. Finally, if we provide business entertainment, our expenses should be prudent and approved by management as part of the business expense approval process.

While we are allowed to accept certain business entertainment and/or gifts, there are times when we have to report them, or get approval before accepting them. The chart on the following page lists the reporting and approval requirements.

Across the company, employees have been working to improve our meeting culture.

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If you have a concern or wish to report a violation, you may contact any of the following: Your manager or supervisor; EthicsPoint Hotline, 866-384-4277, or www.EthicsPoint.com; Ethics & Compliance, 503-464-7091;


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BUSINESS ENTERTAINMENT REPORTING AND APPROVAL

Business Entertainment with an estimated value of more than $500

Preapproval is required by:

• Your functional officer AND the corporate compliance officer or Ethics & Compliance manager.

• The chairman of the board for the CEO.

• The corporate compliance officer for board members.

Complete a Business Entertainment & Gift Report form located on the PGE intranet.

Business Entertainment with an estimated value between $200 and $500

Reporting is required.


Business entertainment with an estimated value of less than $200

No reporting or approval is necessary.*

GIFTS REPORTING AND APPROVAL

Gifts with an estimated value of $200 or more

Preapproval is required by:

• Your functional officer AND the corporate compliance officer or Ethics & Compliance manager.

• The corporate compliance officer for board members.

The CEO will report receipt of gifts valued between $200 and $500 to the corporate compliance officer. The chairman of the board must approve gifts for the CEO if the gift is more than $500.


Gifts with an estimated value of less than $200

No reporting or approval is necessary*

Merchant-specific gift cards with a value of $25 or less

No reporting or approval is necessary.*

NOTE: We cannot accept non-merchant-specific gift cards of any value, or merchant-specific gift cards valued at more than $25.

* If you receive Business Entertainment and/or Gifts less than $200, but with a cumulative value of more than $500, from a single business contact in a 12-month period, you must complete a Business Entertainment & Gift Report form located on the PGE intranet.

https://sharepoint/myPGE/Forms/Compliance/003901803.pdf






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We avoid conflicts of interest

To best serve our customers, we must keep in mind that our primary loyalty is to PGE’s guiding prin-ciples and values, not to outside interests. This means we should avoid any activity, relationship, or situation that creates an actual or potential conflict of interest. A conflict of interest occurs when our personal interests, relationships, or activities inter-fere with our ability to work objectively and effec-tively. When performing our jobs, the best rule of thumb is to always put PGE’s interests before our own interests. We should be aware of influences that could affect or appear to affect our loyalty to PGE and avoid them whenever possible.

For more information, see our Conflict of Interest policy.

We don’t use our connections with PGE for personal gain

While performing work for PGE, we are responsi-ble for putting the company’s interests ahead of our own. This means we should never take advan-tage of business and investment opportunities for ourselves (or for the benefit of friends and family) that we discover through our work at PGE, unless we get advance written approval from the corpo-rate compliance officer. Also, we may not compete with PGE while we are employees.

We can engage in business and investment op-portunities discovered through independent and personal research. If we’re not sure whether a po-tential investment might be an issue, we ask the corporate compliance officer before investing.

PERSONAL GAIN

Q While doing my job for PGE, I some-times meet customers who need work done for them. Since I have a side busi-ness that can serve their needs, can I offer my services?

A No. That would be using your posi-tion at PGE for improper personal gain. It also could confuse people as to whether you are acting on behalf of PGE or as a private contractor or consultant.

Prior to starting work, a team gathers to discuss how to complete the job safely.

www.EthicsPoint.com

http://sharepoint/Eandc/Policies/conflict_of_interest_policy.pdf



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CONFLICT OF INTEREST

Q Jared, a general line foreman, is a part-owner in an outside business that is seeking to do business with PGE. What does Jared need to do to ensure management knows and to find out if this is okay?

A Jared needs to complete a Conflict of Interest disclosure form, which can be found on PGE’s intranet. This form documents potential or actual conflicts of interest and provides the information needed to address them.

Q James would like to hire his reIative for some contract work at PGE. It’s a legit-imate project that needs to be done, and his relative is trained to do this type of work. Is it okay for him to hire her?

A Although the work is legitimate, this situation creates the appearance of a conflict. While that doesn’t mean his relative can’t work for PGE, James should discuss the situation with Ethics & Compliance first, so the situation can be indepen- dently reviewed prior to committing to a contract. This will help protect James, his relative and PGE if the relationship ever comes into question.

Top: As PGE’s corporate pilot, Brian Sonnier flies the PGE helicopter approximately 20,000 miles a year.

Bottom: The Specialized Billing team is responsible for billing customers who choose special pricing options, have street-lights and traffic signals, or who generate their own power.

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Our commitments to the community

We communicate honestly and accurately

We provide honest, accurate, and timely information to our customers, employees, shareholders, and the community. They depend on us to be a reliable source of information. In order to meet this standard, we ensure all communi-cations reflect our values of dignifying people and earning trust.

INQUIRIES AND PRESENTATIONSIt’s important that our messages are accurate and consistent. We don’t speak on behalf of PGE with outside groups or organizations about PGE business unless we are authorized to do so. If we get a request for information about PGE, we refer the request to Corporate Communications. If the request is for financial information only, we refer it to the director of Investor Relations. Finally, if we are asked to give a presentation to an outside group as a rep-resentative of PGE, we must get preapproval from our manager or supervi-sor and notify Corporate Communications. Our manager or supervisor and Corporate Communications must also review and approve the presentation materials.

SOCIAL MEDIAPGE recognizes the growing importance of participating in social media and encourages responsible use of these resources. We need to be aware of how our online postings can affect us and PGE, and we should follow the guidelines below whenever we use social media:

• We don’t speak, comment, or post on behalf of PGE on blogs or social media without first receiving permission from Corporate Communications.

• Any personal use of social media during business hours must follow PGE’s policy on acceptable use of the internet/intranet.

• We don’t share material, nonpublic information, or nonpublic information about PGE’s transmission function.

• If posting about PGE products/services, we clearly disclose our relationship to the company and state that we are not representing the views of PGE or our co-workers.

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• If we identify ourselves as a PGE employee in a posting that isn’t sponsored or autho-rized by PGE, we must include a disclaimer stating the views expressed are ours and do not reflect the views of PGE or our co-workers.

• If we are interviewed by or give a statement to an outside entity about our personal be-liefs, we should not wear PGE apparel or display PGE-branded items.

PGE recognizes we have the right to speak as indi-viduals to express our personal opinions or beliefs.

NOTHING IN THIS DOCUMENT OR THE COMMUNICATIONS POLICY IS DESIGNED TO INTERFERE WITH, RESTRAIN, OR PREVENT ANY COMMUNICATIONS BY EMPLOYEES REGARDING WAGES, HOURS, OR OTHER TERMS AND CONDITIONS OF EMPLOYMENT. WE HAVE THE RIGHT TO ENGAGE IN OR REFRAIN FROM SUCH ACTIVITIES.

For more information, see our Communications Policy.

We protect the environment

Environmental stewardship is one of our Core Principles. We help reduce impacts from our oper-ations by making sure we understand and comply with all applicable environmental laws and regu-lations. As part of our compliance obligations, we report any release of pollutants and hazardous substances, even if accidental, to our supervisor or manager immediately.

Top: The Floating Surface Collector on the Clackamas River is expected to boost the survival rate of fish traveling downstream.

Bottom: Sara Boyd pauses for a selfie during a SOLVE beach cleanup on the Willamette River.

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We only engage in lawful political activities

We comply with all laws and regulations governing corporate political activi-ties, including political contributions. (Political contributions include monetary donations to political parties or candidates, lobbying of legislators or public officials, use of employees or company assets in political activities, and any other political activities.) These laws are complex, so we contact Public Policy if we have any questions. We also get written approval from the vice president of Public Policy before making any political contributions or engaging in any fundraising or campaigning on PGE’s behalf.

We comply with laws and regulations

Our business is governed by many state and federal laws, rules, and regulations — too numerous to list in our Code — and we are committed to fully complying with the letter and spirit of all of them. For example, we must be mindful of antitrust laws that prohibit agreements among competitors on matters such as prices, terms of sale, and allocations of markets or custom-ers. These agreements do not have to be formal, written documents. Courts can decide that an agreement exists based on “loose talk,” informal discussions, or the exchange of information between competitors that could result in some form of illegal cooperation. If we become aware of any such situations, we should report them immediately, even if we’re unsure whether a violation has occurred.

There are many resources available to help us understand our responsibilities and do the right thing. These resources include policies, procedures, and em-ployee training. We take the initiative to identify the compliance obligations affecting our work, and if we have questions, we ask our manager. When asked to complete compliance-related training, we do it promptly and make sure that we understand the content.

“When asked to complete compliance-related training, we do it promptly and make sure that we understand the content.”

We gather information about other businesses lawfully and ethically

We may gather information about other businesses, including our customers and competitors, as long as it’s done legally and ethically. We must never attempt to acquire trade secrets or other proprietary information through unlawful or unethical means such as theft, spying, or bribery.

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Clockwise, from top left:

In April, PGE volunteers Spring Into Action.

Edwin Coleman is a specialist in Field Tech Support.

PGE employees tour the Beaver Plant located in Clatskanie.

Carolyn Brenner is a customer service representative.

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We do not engage in insider trading

Many of us have access to company information not available to the general public that could be material to an investor’s decision to buy, sell, or hold securities (stock, bonds, or notes) of PGE or other companies. Examples of nonpublic information include:

• Unannounced dividends, earnings, or financial results

• Projections of future earnings or losses

• Major organizational changes

• Unannounced regulatory, court, or legislative actions

• Major purchases or new contracts

• Mergers, acquisitions, joint ventures

• Practical knowledge about the transmission network

We are not allowed to buy or sell PGE securities (or securities of another com-pany) while having knowledge of material, nonpublic information such as the examples listed above. This is known as insider trading, and it’s illegal. It’s also unlawful to pass such information on to others. For example, if we learn that PGE is going to change its dividend amount, we cannot trade PGE stock or share that information with others until the news is publicly announced. These same restrictions apply to our family members, others living in our household, and friends. Additional trading restrictions and reporting requirements may apply to officers and board members.

We should always play it safe with regard to insider trading. If we aren’t sure whether we possess information that could affect our ability to legally trade securities, then we should ask the corporate compliance officer for guidance.

For more information, see our Insider Trading policy.

INSIDER TRADING

Q My family and friends often ask me about PGE and whether they should buy stock. Usually, I tell them what I know about our business and suggest they buy stock. Is this a problem?

A It could be. If a relative or friend buys or sells stock based on nonpublic information that you give him or her, both of you could be liable for violation of securities laws. If the information you divulge is public already, then you’re fine. Information is considered public if it has been disclosed in a broadly disseminated news release or a filing with the Securities and Exchange Commission. If ever in doubt, check first with the corporate compliance officer.

Our commitments to investors

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USE OF COMPANY ASSETS

Q Would it be okay for Julie to take discarded equipment, such as scrap cable, old file cabinets or office supplies for personal use or resale?

A No. Even items that appear to be discarded remain company property and may not be taken for personal use in most cases. Employees who identify furniture, surplus or scrap material, equipment and assets that are no longer used by the company must follow procedures outlined in our Material Disposal and Sales Request policy. Surplus or used supplies can also be sent to our Simply Reuse Center at World Trade Center for redistribution to other departments or for charitable contribu-tions. There are occasions when some material can be taken for personal use, but only if it’s a cost benefit for PGE and prior approval from management is obtained.

We report personal investigations

While working at PGE, it’s possible we may be in-vestigated by governmental agencies for activities unrelated to our jobs. If the investigation or its outcome could affect the company’s reputation or our co-workers, or cause us to lose certification necessary to perform our jobs, we should inform Human Resources.

We protect PGE’s assets

We are entrusted with company assets and infor-mation on a daily basis and are responsible for protecting them and using them appropriately. Generally, company assets should only be used for conducting company business. Examples of assets include: records, documents, equipment, vehicles, employees’ work time, computers, and communi-cation devices.

“We are entrusted with company assets and information on a daily basis and are responsible for protecting them and using them appropriately.”

COMPANY RECORDSTo maintain stakeholder trust and PGE’s financial and reputational integrity, we are all responsible for maintaining company books, records, accounts, financial statements, and other business records ac-curately and in reasonable detail. Business records include such things as expense reports, time sheets, medical forms, and logs. Company records need to be accurate, complete and appropriately reflect all transactions. If we know of any instance where company records have been falsified, we should report it promptly to Ethics & Compliance.

Additionally, there are some laws and regulations that require us to take certain actions in the event of an unauthorized release of employee or custom-er information. For this reason, we must immedi-ately report any such unauthorized release to our manager.

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DOCUMENT AND RECORD RETENTIONWe protect and maintain company records in a way that preserves the integ-rity of our information. We follow our Records Management policy to ensure that we comply with applicable laws and regulatory requirements related to retaining and destroying documents. Under no circumstances may we destroy company records or decide to maintain records outside the company’s premises or designated storage facilities.

If we learn of a subpoena, pending litigation, or government investigation, we must immediately notify our general counsel or his/her designee and pre-serve all relevant records until the Legal Department tells us how to proceed. Records include paper documents, electronic documents, emails, and voice mail messages. If we suspect company records are being improperly altered or destroyed, we must report it immediately to the general counsel or his/her designee.

For more information, see our Records Management policy.

USE OF COMPANY ASSETSWe each have a duty to use company assets efficiently for business purposes and to protect them from misuse, waste, damage, abuse, theft, and loss. When we leave PGE, we must return all company property in our possession.

“We each have a duty to use company assets efficiently for business purposes and to protect them from misuse, waste, damage, abuse, theft, and loss.”

Human Resources employees sort files to make sure documents are saved appropriately.

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While certain personal tasks are reasonable, like calling or emailing home to check on a sick child or making an occasional copy for personal use, we must avoid excessive personal use of company as-sets. We should never use company assets for out-side business activities, and we need to notify our management immediately about any lost, dam-aged, or stolen assets.

We protect confidential information

As part of our work, we may deal with sensitive information that needs to be protected. Our Release of Confidential Information policy defines confidential information and states the company’s expectations for how we will handle such informa-tion. Examples of confidential information include:

• Pricing information

• Customer records

• Business and marketing plans

• Research and development projects

• Security information

• Nonpublic financial information

• Computer programs

• Employee information

We may not use any confidential information for our personal benefit or to benefit others inside or outside PGE. In fact, our obligation to protect confidential information follows us even after we leave the company.

For more information, see our Release of Confidential Information policy.

MAINTAINING ACCURATE RECORDS

Q George, an hourly employee, has worked five hours of overtime this week. His supervisor asked him to leave an hour early every day next week, instead of reporting the overtime hours. What should George do?

A The supervisor is asking George to falsify his time sheets, which would be a violation of this Code, so George should not comply. He should record the actual hours he worked this week and not adjust his schedule next week. He should also re-port the supervisor’s improper request to his supervisor’s manager or to one of the resources listed at the bottom of these pages. We are all responsible for main-taining company records, including time sheets, accurately.

Jardon Jaramillo chats with another attendee at the PGE-sponsored Diversity Summit.

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We comply with laws protecting intellectual property

We recognize and respect the individual intellectual property rights of PGE and others. When using the name, trademarks, logos, or printed materials of PGE or another company, we must do so properly and in accordance with applicable law.

Trademarks: PGE’s logos and the name Portland General Electric Company are examples of company trademarks. We must always use our trademarks prop-erly and advise our supervisor, manager, or the Legal Department of infringe-ment by others.

Contact Corporate Communications to learn more about proper use of our company logo.

Copyright compliance: Books, articles, drawings, computer software, and other such materials may be covered by copyright laws. To avoid violating those laws, we only make copies of copyrighted materials when we have been granted permission by the copyright holder or where the law permits. PGE licenses the use of much of its computer software from outside companies. In most cases, this software is protected by copyright, and we are not allowed to make, ac-quire, or use unauthorized copies.

PGE’s intellectual property: In our work, some of us may develop or create in-tellectual property such as new designs, inventions, systems, or processes. PGE owns this intellectual property and has the right to patent any new, inventive, and useful product or idea we produce within the course and scope of our employment.

All managers, supervisors, and authorized PGE representatives are expected to document any instance where an employee creates intellectual property in the course and scope of employment. For more information about intellectual property rights, we should contact the Legal Department.

This Code is a statement of fundamental principles and key policies and procedures that govern how we conduct the company’s business. It does not cover every law, rule, regulation, and PGE standard and policy that applies to our business. Each of us has an obligation to

familiarize ourselves with all of the requirements related to our job. Our commitment to a culture that values integrity and doing the right thing is what makes PGE such a special place to work. It is foundational to our company and will enable us to sustain the

business and help both PGE and the communities we serve to thrive.

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Portland General Electric

Code of Business Conduct and Ethics, Effective January 2016

Clockwise from top left:

Rosa Sambrano is a journeyman meterman.

PGE delivers electricity to downtown Portland through an underground wiring system.

PGE’s System Control Center keeps the pulse on our transmission, distribution, and generation.

Code of Business Ethics and Conduct · PDF fileIf you have a concern or wish to report a...

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