Our conduct on the job has a major impact on PG&E’s ability to achieve its vision of being the leading utility in the United States. If you need more specific information about this code of conduct, ask your supervisor or human resources representative, or call the Compliance and Ethics Helpline at 1-888-231-2310.

Fitness for Duty

You’re expected to be mentally and physically fit for work, reporting to work fit for duty and remaining fit while on duty. Tell your supervisor if you’re taking prescription drugs or over-the-counter medications that could affect your ability to work safely or efficiently. You may not be under the influence of alcohol or illegal drugs while on duty.

Use of Alcohol, Illegal Drugs, or Medication

PG&E is committed to a workplace that is free from the influence of alcohol and illegal drugs.

As the general rule, you may not consume alcohol while on duty, including lunches and overtime meals, or on company property. Officers and the next level of management below officer may authorize, in advance, the consumption of alcohol for special occasions or for certain business meetings, as long as such use is limited and does not violate other legal requirements, such as those of the Nuclear Regulatory Commission or the Department of Transportation.

You may not operate a PG&E-owned, leased, or rented vehicle after consuming alcohol. You may not transport alcohol in a PG&E-owned, leased, or rented vehicle, unless you have the prior consent of an officer or the next level of management below officer.

Do not use, possess, sell, purchase, provide, or be under the influence of illegal drugs while on duty or on company property. You also must comply with your specific organization’s alcohol and drug policies.

Harassment and Discrimination

Conduct yourself in a professional manner and treat others with respect, fairness, and dignity. PG&E does not tolerate harassment or discrimination, including behavior, comments, jokes, slurs, e-mail messages, pictures, or other conduct that contributes to an intimidating or offensive environment. You must comply with applicable federal, state, and local statutes prohibiting discrimination or harassment based on race, color, religion, age, sex, pregnancy, disability, national origin, ancestry, medical condition, veteran status, marital status, sexual orientation, gender identity, or any other non-job-related factor.

Officers and other supervisors are expected to be familiar with PG&E’s standards on harassment and discrimination and with relevant federal, state, and local laws. Supervisors who fail to take action, or who engage in harassment, not only expose PG&E to liability, they also expose themselves to personal liability. Employees also can be held personally liable for engaging in harassment.

PG&E has the same expectations for its contractors, consultants, and suppliers when they engage in PG&E-related work. Those expectations are described in PG&E’s Contractor, Consultant, and Supplier Code of Conduct.

Safety and Health

PG&E aims to have an injury and illness-free work environment for the benefit of employees, customers, and the general public. Building safety into everything we do is a core behavior at PG&E. To this end, perform your work in a way that will protect yourself, co-workers, and the public. Comply with all safety and health rules and procedures at all times. Ensure that your work environment is safe by identifying and controlling hazards or unsafe situations, helping and encouraging others to work safely, and placing safety first. Immediately report unsafe conditions that you cannot correct to your supervisor, or call the Safety Helpline at 1-415-973-8700 (internal number 223-8700).

If necessary, safety compliance concerns can be reported by calling the Compliance and Ethics Helpline at 1-888-231-2310.

Community Activities

For more than a century, PG&E has supported the communities it serves by creating community partnerships, making charitable contributions, and volunteering at community events. To make these community partnerships successful, PG&E works closely with community residents and local organizations to identify needs and develop programs to deliver targeted contributions. If you are interested in being a positive force in PG&E’s communities, please contact the Civic Partnership and Community Initiatives Department for more information.

The endorsements section of this handbook applies when you’re engaged in community activities.

Corporate Assets

Each of us is responsible for the proper acquisition (including compliance with delegations of authority and bid and award procedures), use, maintenance, and disposal of corporate assets (e.g., materials, equipment, tools, real property, information, funds, etc.) and services.

• Acquire assets in compliance with procurement policies and procedures, (including delegations of authority and bid and award procedures) avoiding any real or apparent conflict of interest.
  
  
• Use corporate assets only for legal and ethical activities.
  
  
• Protect assets from damage, waste, loss, misuse, or theft.
  
  
• Dispose of assets only with appropriate written approval. PG&E’s goal is to obtain fair market value for all assets that no longer are needed, unless they are donated with appropriate approval. PG&E may have a legal responsibility to report a donation to a charitable entity or a political organization, so you will need to request approval in advance.
  
  
• Don’t destroy or take intangible assets, including information about PG&E or others that you obtain in the course of your job. This responsibility extends to such information when you’re no longer employed by PG&E.
  
  
• Follow procedures in Interactions in the Corporate Family: An Overview of Affiliate Rules, or contact the Law Department if you intend to share or transfer assets between or among PG&E’s lines of business.

Corporate assets such as computers, telephones and cell phones, fax machines, copy machines, conference rooms, and vehicles are intended primarily for PG&E business. PG&E allows limited personal use of these and similar assets as long as such use is occasional, is not for outside employment, doesn’t result in excessive costs, doesn’t interfere with your work responsibilities, and is in compliance with laws, regulations, and any business line or local restrictions. Personal use of a vehicle must be incidental to business use. If you would like to allow a charitable entity or political organization to use any such corporate asset, PG&E may need to report the use as a donation. You will need to request approval in advance. Please talk to your supervisor before making arrangements.

Other corporate assets, including such things as construction equipment, tools, and similar assets, may be used only for PG&E business and are not available for personal use. Exceptions are permitted in emergency situations or with officer approval.

Employee Privacy

PG&E retains the right to monitor its assets and work environments in compliance with applicable federal, state, and local law. It monitors to promote safety, prevent criminal activity, investigate alleged misconduct and security violations, manage information systems, or for other business reasons.

Even though limited personal use of company assets is permitted, you should have no expectation of privacy when you use PG&E computer, voicemail, or other systems to create, access, transmit, or store information. Such information is accessible to PG&E even if it is password-protected or deleted by the user.

Business Expenses

Use PG&E funds for business expenses only, whether paying by credit card, cash, or other method. Use good judgment to keep business expenses (for example, meal expenses) reasonable. You’re expected to comply with PG&E’s requirements for incurring and reporting business expenses. Report all expenses promptly and accurately via the travel and expense system.

Corporate Name, Logo, and Colors

PG&E Corporation legally owns the trademarks that incorporate “PG&E” and the holding company and utility corporate names. You may use the corporate names and logos, the PG&E logo, and PG&E colors in presentations to public audiences in compliance with the Corporate Identity Guidelines issued by the PG&E Corporation Communications Department.

Watch for the use of the PG&E graphic icon, the corporate name, logo, or colors by those not authorized to represent PG&E, such as contractors. Also, energy affiliate companies must include disclaimers of specific wording and size when using the icon, corporate name, or logo. If you have any questions, please call the PG&E Corporation Communications Department at 1-800-743-6397.

Endorsements

PG&E does not endorse products or services, nor the firms or individuals who supply them. Favoritism must not be implied by testimonials or endorsements of PG&E’s use of any materials, supplies, equipment, or service, or by the use of its name in advertising, publicity, or catalogues. If you have questions about endorsements, please call the Law Department or the Compliance and Ethics Helpline at 1-888-231-2310.

Implied or express endorsements of political candidates, ballot measures, community organizations, or other entities must be approved in advance by the Governmental Relations Department.

If you want to endorse an event, product, or service, or to provide a testimonial, you should not use your job title or affiliation without approval from your supervisor and the Communications Department.

News Media Inquiries

Immediately refer any news media inquiries to your News or Communications Department. Refer inquiries from national publications or news services to PG&E’s Communications Department. (Utility News Department, 1-415-973-5930; PG&E Corporation Communications Department, 1-800-743-6397.)

Investor Inquiries

Refer portfolio manager and financial analyst inquiries to the Investor Relations Department at 1-415-267-7080. Refer individual shareholders and beneficial owners with questions about shareholder accounts and other administrative matters to the Corporate Secretary's Office at 1-415-267-7070.

Regulatory or Legal Inquiries

Refer inquiries from federal, state, or local governmental officials to the Governmental Relations Department. Refer inquiries about legal issues or subpoenas to the Law Department. Refer any requests for information from law enforcement agencies to your local security contact or the Corporate Security Department.

Publishing Articles

If you author an article or other publication and plan to identify yourself as an employee of PG&E, you should get approval from your supervisor and the Communications Department prior to publication.

Proprietary Information

You may have access to proprietary non-public information on the job. Never use this information for personal gain or advantage, and never share this information without appropriate approval. If you leave employment with PG&E, it would be unethical and could be illegal to reveal non-public information that you obtained in the course of your employment with PG&E.

Three common types of confidential proprietary information are customer information, employee information, and competitor information.

• Customer information includes any information about a specific customer, including such things as name, address, phone numbers, contacts, and energy usage. Never disclose any information about a customer without the customer’s written approval unless legally required to do so (for example, under a court-issued subpoena). If you receive a request for customer information, follow your organization’s procedures for handling it.
  
  
• Employee information includes information about a specific employee, including such things as name, address, social security number, phone numbers, benefits, and performance evaluations. Never disclose such information to another employee or a third party without appropriate approval. Forward requests for employee information and references to your human resources representative.
  
  
• Competitor information is collected by PG&E from a variety of legitimate sources. PG&E uses such information to evaluate the merits of its own products, services, and marketing methods, and to develop strategic plans. Any competitor information obtained accidentally or unethically must be kept confidential and immediately reviewed with the Law Department to determine the appropriate course of action. It’s against the law and PG&E’s policy to gather competitor information by trespassing, burglary, wiretapping, theft, or other illegal activity.

There are restrictions on the flow of non-public information between PG&E’s lines of business, although non-public information may be shared freely with the holding company. For more information on this subject, review the Affiliate Rules section of this handbook and the compliance booklet, Interactions in the Corporate Family: An Overview of Affiliate Rules.

Please exercise caution when using or handling proprietary information. If you have questions, contact the Law Department.

Corporate Records and Disclosures

Accurate records and disclosures are critical to PG&E’s meeting its legal, financial, regulatory, and management obligations. Never misstate facts or omit material information. Ensure that all corporate records, disclosures, and communications are full, fair, accurate, timely, and understandable. Never hide, alter, falsify, or disguise the true nature of any transaction.

Document Retention

Many areas of PG&E have policies or regulatory requirements to retain certain documents for specific periods of time. There may be additional retention requirements for any documents you possess that relate to a topic of investigation or litigation. Also, as a condition of forming the holding company, the California Public Utilities Commission requires employees to retain certain correspondence and documents involving communications with the utility.

If you need assistance with the document retention requirements that may apply to you, ask your supervisor or contact the Law Department.