FERC Standards of Conduct Training - CenterPoint Energy

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2. THE NO CONDUIT RULE Since EGT and/or MRT employees are prohibited from directly disclosing information to an MFE, they are also prohibited from using someone else to pass that same information along to MFEs. • No TFE of EGT or MRT may use a third party to pass on prohibited information to an MFE of an Affiliate, whether intentionally or accidentally o doing so would make the third party a conduit • No other employee may pass prohibited information on to an MFE of an Affiliate, whether intentionally or accidentally o doing so would make the employee a conduit 22 For Internal Use Only
What Information Cannot Be Shared with MFEs? EGT and MRT employees are prohibited from sharing directly or through a conduit the following types of information: • Non-public transmission function information (previously defined) • Non-public customer information (definition to follow) 23 For Internal Use Only
Page 1 and 2: FERC Standards of Conduct Training
Page 3 and 4: Culture of Compliance Enable Midstr
Page 7 and 8: Employee Classifications The FERC S
Page 9 and 10: What is a Transmission Function Emp
Page 11 and 12: The following activities DO NOT con
Page 13 and 14: No Conduit Employees No Conduit Emp
Page 15 and 16: Examples of Non-Public Transmission
Page 17 and 18: FIVE GENERAL REQUIREMENTS OF THE ST
Page 19 and 20: • For example, an MFE cannot have
Page 21: Hypothetical 2: Charlotte recently
Page 25 and 26: What is Non-Public Customer Informa
Page 27 and 28: Hypothetical 5: A Risk Control empl
Page 29 and 30: What are the Procedures When Meetin
Page 31 and 32: 3. NON-DISCRIMINATION REQUIREMENTS
Page 33 and 34: 4. TRANSPARENCY The transparency pr
Page 35 and 36: Contemporaneous Disclosure Further,
Page 37 and 38: Can Customers Voluntarily Consent t
Page 39 and 40: Posting of Certain Affiliate Inform
Page 41 and 42: Transferring Employees The transfer
Page 43 and 44: Posting and Logging of Tariff Waive
Page 45 and 46: Chief Compliance Officer (FERC) EGT
Page 49 and 50: Standards of Conduct Concerns Helpl
Page 51 and 52: How Do I Comply? It is each employe
Page 53 and 54: Congratulations! You have completed

FERC Standards of Conduct Training - CenterPoint Energy

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