FERC Standards of Conduct Training - CenterPoint Energy

More documents

Recommendations

Info

Hypothetical 4: Assume that you are an MFE. Several weeks ago, you were emailing with an EGT employee on how close the Rockets came to forcing a game seven against the Thunder. Weeks later, you receive an email from the same colleague with an unrelated subject header. Without thinking, you open the email and after reading the first few sentences, you see that it is not about the Thunder and believe that the email may contain non-public transmission function information. 1. What should you do? Forward the email to the Chief Compliance Officer (FERC) or his designee and notify your manager of the issue. 2. But isn’t the prohibition on interstate pipeline employees? Yes, but as an affiliated MFE, you must be cognizant of the rules. All employees are responsible for ensuring compliance with the Standards of Conduct. 3. What could you have done to prevent this situation? MFEs should consider subject lines of emails. When in doubt, do not open the email; send a newly composed, separate email to the sender and confirm that the email was sent intentionally and contains no Non-Public Transmission Function Information. 26 For Internal Use Only
Hypothetical 5: A Risk Control employee, Peter, currently is assigned to support EER. While visiting friends at EGT’s System Control, he inadvertently overhears a conversation about unscheduled repairs. When Peter returns to work, he attends a regular marketing meeting. An issue is being debated and he remembers the discussion he overheard about the unscheduled repairs. 1. Can Peter share the information with his co-workers, who are MFEs, so they can make an informed decision? No. Sharing Non-Public Transmission Function Information such as unscheduled repairs constitutes a prohibited disclosure. 2. Can Peter use this information for the commercial benefit of EER? No. It is Peter’s duty not to use the Non-Public Transmission Function Information that he overheard for the commercial benefit of EER. 27 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 and 22: Hypothetical 2: Charlotte recently
Page 23 and 24: What Information Cannot Be Shared w
Page 25: What is Non-Public Customer Informa
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

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?