Employee Conduct Standards

Working Safely
PG&E strives to have an injury- and illness-free work environment for the benefit of employees, customers, and the public.

At PG&E, working safely and in compliance with safety and health rules and procedures, including PG&E's Rules to Live By, is a condition of employment. Ensure that the work environment is safe by identifying and controlling unsafe conditions and occupational and public safety hazards. When operating a vehicle on PG&E business, make sure you have a valid driver's license, comply with the state vehicle code, and operate the vehicle safely at all times. Help and encourage others to work safely, and always place safety first.

Immediately report to your supervisor all occupational injuries and illnesses, injuries to non-employees, damage to property resulting from PG&E business activities, and any unsafe conditions that you cannot safely correct. You also can contact the 24-hour Safety, Health and Claims Helpline at 415-973-8700.

• Q. I was injured at work but I don’t want to report it because it will negatively affect our department's safety goal. What should I do?
• A. Report it. Each of us is responsible for reporting workplace injuries. The department’s desire to achieve the safety goal should not preclude any employee from reporting a workplace injury, and supervisors must never encourage employees to cover up a safety incident.

Fitness for Duty
You are expected to be mentally and physically fit for work, to report to work fit for duty, and to remain fit while on duty. While on duty, you may not be under the influence of alcohol or any drugs that impair your ability to perform your work safely and efficiently. Never use, possess, sell, offer to sell, transfer, provide, share, or purchase illegal drugs while on duty or on PG&E property—or be in possession or under the influence of medication prescribed for someone other than you.

You must comply with your specific organization's alcohol and drug standards and any other fitness-for-duty regulations that apply to your job, such as those required by the Nuclear Regulatory Commission and the Department of Transportation.

Tell your supervisor if you're taking prescription drugs or over-the-counter medications that you reasonably believe could affect your ability to work safely or efficiently.

• Q. I'm taking prescription medication that could inhibit my ability to work, but I don't want to tell my supervisor because I don't want to reveal my medical condition. Do I have to tell my supervisor what kind of medication I'm taking and why I'm taking it?
• A. No, you are not required to tell your supervisor the type of medication you are taking or why you are taking it. However, you must inform your supervisor about the effects of a medication that you and your treating physician (who understands your work activities) believe could affect your work performance. You and your supervisor can then determine if you're able to do your work safely and efficiently.

Attendance Reporting
If you are unable to report to work for any reason, you must contact your supervisor prior to the start of your work period. Also, check with your supervisor to see if your department has additional call-in requirements.

Use of Alcohol
Never report to work under the influence of alcohol. You may not consume alcohol while on duty, including lunches and overtime meals, or on company property. Exception: officers and directors 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, even if consumption is permitted under the exception described above. You may not transport alcohol in a PG&E-owned, leased, or rented vehicle unless you have the prior consent of an officer or a director.

Consuming alcohol while on duty, except as allowed in the exception described above, will result in termination.

• Q. When I attend work-related conferences, there are times when I have dinner with other conference attendees after the conference has ended for the day. May I consume alcohol at dinner?
• A. You are permitted to consume alcohol if the business portion of the conference is over, you are no longer performing work duties, and you will not be driving a company or rented vehicle. Don't consume alcohol to the extent that you would negatively affect the company's reputation or image. Also, if you are driving a personal vehicle after consuming alcohol, it is your responsibility to make sure that you’re fit to operate a vehicle safely and in compliance with the law.

Harassment and Discrimination
At PG&E we are committed to maintaining a work environment that respects individual differences. 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, photographs, or other conduct that contributes to an intimidating or offensive environment. Harassment and discrimination also can occur in the form of bullying, initiation activities, or workplace hazing, which can be humiliating, degrading, or cause emotional or physical harm. No forms of harassment or discrimination are tolerated, regardless of the employee's willingness to participate, and such conduct can result in termination.

You must comply with applicable federal, state, and local statutes prohibiting conduct that could reasonably be construed as sexual in nature¹, or discrimination or harassment based on race, color, religion, age, sex, pregnancy, physical or mental disability, national origin, ancestry, medical condition, veteran status, marital status, sexual orientation, gender identity, genetic information, or any other non-job-related factor. This applies to all employment practices, including advancement, disciplinary decisions, benefits, training, and general workplace conduct.

Further, 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, engage in harassment, or permit harassment to occur not only expose PG&E to liability, they also expose themselves to personal liability. Employees 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.

• Q. I am new to the company and work with several employees who have worked for the company for more than 25 years. The longer-term employees refer to the younger employees as "kids" or the "youth group". While I respect all of my co-workers, I am offended by their comments. Are their comments considered age discrimination? If so, what should I do?
• A. Age discrimination under the law applies to people 40 years or older. While the comments would not be considered age discrimination under the law (because they are directed at employees under the age of 40), they are disrespectful and violate the company’s anti-discrimination standard. If you feel comfortable, you can respectfully inform your co-workers that you’re offended by their comments and ask them to stop. If you don’t feel comfortable addressing your co-workers directly, you should discuss the issue with your supervisor or your Human Resources representative. You also may call the HR Helpline at 415-973-HELP or call the Compliance and Ethics Helpline at 888-231-2310 to report the inappropriate behavior.

Workplace Violence
PG&E is committed to maintaining a safe and secure workplace and working environment. Acts or threats of physical violence, intimidation, harassment or coercion, stalking, sabotage, and similar activities are not tolerated. Employees who engage in act or threats of violence will be terminated.

Weapons in the Workplace
You may not bring, carry, store, or use any type of weapon on PG&E-owned, leased, or rented property; in a PG&E-owned, leased, or rented vehicle; in a personal vehicle while on PG&E business; or at a job site, whether on or off duty, unless you're explicitly authorized and have a legitimate business reason to do so. A "weapon" is a firearm, ammunition, explosive, or any other device or object that can be construed as a weapon by the Corporate Security Department. Weapons do not include tools that are used for legitimate business purposes.

Gambling in the Workplace
Gambling while at work is prohibited at all times, including during breaks. For purposes of this standard, "gambling" is defined as playing a game for money or property or betting on an uncertain outcome. Prohibited gambling activities include, but are not limited to:

• Games (e.g., cards, dice, and dominoes) played for money or property
• Sports pools such as the Super Bowl, all-star games, the World Series, or the NCAA basketball tournament
• Internet gambling

In addition, using company resources, such as computer software to track wagers or copying machines to copy wagers, is not permitted.

Company Assets
Each of us is responsible for the proper acquisition, use, maintenance, and disposal of company assets (e.g., materials, equipment, tools, real property, information, and funds) and services. Theft, carelessness, and waste have a negative impact on PG&E's success. Protect the company's assets and ensure their efficient use.

• Acquire assets in compliance with procurement standards and procedures (including delegations of authority), avoiding any real or apparent conflict of interest.
• Use company assets only for legal and ethical activities.
• Protect assets, including information, from damage, unauthorized modification or disclosure, waste, loss, misuse, or theft.
• Dispose of assets only with appropriate written approval. Any donation of an asset to a charitable entity or political organization must reported.
• Follow affiliate rules procedures if you intend to share or transfer assets between or among PG&E's affiliates or subsidiaries, including between the corporation and the utility. For more information, see the Affiliate Rules Intranet site or contact the Law Department.
• Don't misuse or take intangible assets, including nonpublic information about PG&E or others that you obtain in the course of your job. This responsibility continues even when you're no longer employed by PG&E.
• Don't install, rearrange, remove, or tamper with company metering or service equipment without proper approval and authorization.
• Don't divert or steal energy.
• Don't co-mingle company funds with personal funds.
• Don't take or misuse company property, funds, or service.
• Don't charge a customer for work normally provided at no cost by the company.

Company assets such as computers, telephones and cell phones, fax machines, copy machines, conference rooms, and vehicles are intended for PG&E business. PG&E allows limited personal use of these and similar assets as long as such use conforms to the following requirements:

• It is occasional.
• It is incidental to business use.
• It is not for outside employment.
• It does not result in excessive costs.
• It does not interfere with your work responsibilities.
• It is in compliance with laws, regulations, company guidance documents and any business restrictions.

Other company assets, including construction equipment, tools, and similar assets, may be used only for PG&E business. Exceptions are permitted in emergency situations or with officer approval.

If you're unsure about what is appropriate use of a company asset, ask your supervisor or call the Compliance and Ethics Helpline at 888-231-2310.

If you would like to allow a charitable entity or political organization to use a company asset—for example, a conference room for a meeting—PG&E may need to report the use as a donation. You need to request approval in advance. Please talk to your supervisor before making arrangements.

• Q. My daughter is selling cookie dough for her school fundraiser. Am I allowed to bring the flyer and order sheet to work so my co-workers can purchase the cookie dough?
• A. With permission from local management, you may put a flyer and order sheet in the break room or area and distribute the cookie dough during your break or meal period. You're responsible for ensuring that your activities do not interfere with your work or cause a disruption in the workplace.

Company Assets and System Security
You are responsible for ensuring the security of PG&E by complying with the company's information security standards. Make sure you:

• Don't share passwords or other access credentials with any other person or group and don't use another person's password.
• Use only approved, authorized, and properly licensed software on PG&E computer systems.
• Connect only PG&E-owned computers and equipment to PG&E networks.
• Don't attempt to circumvent or attack security controls on a computer system or network.
• Don't access or download pornographic, gaming, file sharing, or other inappropriate files or websites.
• Don't store inappropriate or pirated content on your company equipment.

Accessing pornographic material using company computers, phones, BlackBerry devices, or other company device will result in termination.

Immediately report any suspected or actual breach of PG&E computer system or network security to Information Security's 24-hour emergency hotline at 415-973-2477 and assist in the investigation as needed.

Publishing Articles
If you author an article or other published material about your employment activities at PG&E or a service that PG&E provides and you plan to identify yourself as a PG&E employee, get approval from your supervisor and Corporate Affairs before publication.

Social Media
Social media outlets (e.g., Facebook and Twitter) are used by many to share insights, opinions, and information. Unless you are an officially designated company spokesperson, you are not authorized to speak on behalf of PG&E through social media channels, regardless of whether you're using a company or personal device.

In the course of your own personal use of these outlets, if you choose to post information related to PG&E, you are personally accountable for what you post online. Remember, once information is posted to the Internet, it is there for good. Be sure to:

• Be open and honest about who you are and your role with the company.
• Always include a disclaimer stating that the views you publish are your own and don’t necessarily reflect those of PG&E (unless you are authorized to speak on behalf of the company).
• Be truthful and accurate; don’t speculate; and if you make a mistake, correct it quickly.
• Be respectful.
• Disagree agreeably and be professional.
• Protect confidential information and respect copyright and fair use laws.

Please be aware that social media tools can introduce malware (e.g., viruses, Trojans, or key loggers) to your computer, and many social media sites have the right to change your privacy settings and often exercise that right.

For more information, contact the Corporate Affairs Department.

• Q. Can I state on a social networking site that I work for PG&E?
• A. Yes. However, assuming that you are not an authorized company representative, you may not comment about or endorse any of PG&E's products or services unless you clearly disclose that you're not authorized to speak on the company’s behalf and the opinions are your own. Also, you must not engage in communication that could negatively affect PG&E's reputation or image or exceed the limited personal use requirements discussed in the Corporate Assets section of this Code.

Employee Privacy
PG&E retains the right to monitor its assets and work environments in compliance with applicable federal, state, and local law. The company 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 a PG&E work space, computer, voicemail, or system to create, access, transmit, or store information. Such information is accessible to PG&E even if it is password-protected, deleted by the user, or in a locked area.

Confidential Information
You may have access to confidential information on the job. Maintain the confidentiality of information entrusted to you by PG&E and our customers, except when disclosure is properly authorized or legally mandated. Never use this information for personal gain or advantage, and never share this information without appropriate approval. This obligation continues even after you are no longer employed by PG&E. Revealing nonpublic information that you obtained in the course of your employment with PG&E is a violation of this Code of Conduct and may be illegal.

Confidential information includes all proprietary nonpublic information that might be useful to competitors or harmful to PG&E or our customers if disclosed. There are four types of confidential proprietary nonpublic information:

• Customer information includes any information about a specific customer, including such things as name, address, Social Security number, phone numbers, contact names, and billing data such as balance owed or energy usage. Never disclose any information about a customer to a third party without the customer's written approval unless legally required to do so (for example, under a court-issued subpoena). Also, never change, update, or manipulate your own utility account or the account of a family member, friend, or co-worker. 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, home address, Social Security number, personal phone numbers, benefits, and performance evaluations. Never disclose such information to another employee, stockholder, 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, accessing unprotected networks, or other illegal activity.
• Supplier information includes pricing and contract information. Never disclose supplier information to a third party without appropriate approval and a legitimate business reason. You also must comply with any non-disclosure agreement or the confidentiality provisions of an applicable supplier/vendor agreement.

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

• Q. I have access to confidential information as a part of my regular job duties. I understand that I can't share confidential information with people outside of the company or outside of my department. However, can I share this information with a co-worker inside my department who does not have access to the same information?
• A. You may share the information with your co-worker only if he or she has a business need to know. Before sharing confidential information with an employee who does not normally have access to such information, discuss it with your supervisor.

Company Records and Disclosures
Accurate records and disclosures are critical to PG&E meeting its legal, financial, regulatory, and management obligations. Never misstate facts or omit material information. Ensure that all company records, disclosures, and communications are full, fair, accurate, timely, and understandable. Never hide, alter, falsify, or disguise the true nature of any transaction nor forge endorsements, approvals, or authorizing signatures for any payment.

If you know that a record or disclosure is false or misleading, don't enter, process, or approve it. Report the matter to your supervisor or other appropriate person. Examples of company records and disclosures include:

• Financial reports
• Expense reports
• Performance metrics reports
• Reports to government agencies or other public communications
• Workers' compensation or other benefit-related information such as dependent eligibility
• Time cards, including supporting materials to substantiate requests for time off
• Inspection reports
• Meter-reading data for the purposes of customer billing

Records Retention
Many areas of PG&E have internal, regulatory, or legal requirements to retain certain records for prescribed periods of time. Consistently retain each record for the appropriate period, and then promptly and properly dispose of it at the end of its prescribed retention period.

There may be additional retention requirements for records 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 communication between the holding company and the utility. Emails between the holding company and the utility are retained automatically. Hard copy documents must be retained by either the receiver or the sender.

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

Business Expenses
Use PG&E funds for business expenses only, whether paying by credit card, cash, or another 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. Employees may not:

• Make unauthorized or personal purchases on company credit cards, through purchase orders, or by other means.
• Incur unreasonable expenses on behalf of the company.

• Q. I am traveling on a business trip with my spouse. When we go out to dinner, can I put my spouse's meal on my corporate credit card?
• A. No. Company credit cards may be used for employee business expenses only. An exception exists in the rare event that your spouse's participation in the business event is necessary and/or appropriate and is pre-approved by an officer through a pre-trip authorization (PTA).

Corporate Name, Logo, and Colors
PG&E Corporation 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 standards issued by Corporate Affairs. For additional guidance, see the Smart and Simple Everyday website.

Watch for the use of the PG&E graphic icon or 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 contact Corporate Affairs.

Endorsements
Subject to exceptions approved by Corporate Affairs, PG&E does not endorse products or services or the firms or individuals who supply them, and 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, articles, or catalogs. If you have questions about endorsements, please call the Law Department or the Compliance and Ethics Helpline.

Implied or express endorsements of, or opposition to, political candidates, ballot measures, community organizations, or other entities on behalf of PG&E must be approved in advance by Corporate Affairs. Please contact Corporate Affairs for more information.

If you want to provide a testimonial or endorse an event, product, or service, do not use your job title or affiliation without approval from your supervisor and Corporate Affairs.

Community Activities
PG&E is committed to supporting the communities we serve in various ways, such as encouraging our employees to volunteer and providing shareholder-funded financial contributions to community organizations.

PG&E does not support organizations that, in their by-laws, policies, or practices, discriminate on the basis of race, color, religion, age, sex, national origin, ancestry, physical or mental disability, medical condition, veteran status, marital status, pregnancy, sexual orientation, gender identity, genetic information, or any basis prohibited by applicable law.

Using your job title or affiliation, or wearing the PG&E logo while participating in a community activity, may constitute implied or express support. If you're unsure if this is appropriate, please check with your supervisor or Corporate Affairs before participating.

News Media Inquiries
Immediately refer any media inquiries to Media Relations and Nuclear Communications at 415-973-5930. This team is available 24 hours a day, seven days a week to act as the direct representative and liaison for the company to the news media.

If the media asks to speak with a PG&E subject matter expert, Media Relations and Nuclear Communications coordinates on behalf of PG&E. Under no circumstances are contractors permitted to represent themselves to the media as speaking on behalf of PG&E unless they are expressly authorized by Corporate Affairs.

In the case of an emergency, reporters arriving on the scene will try to gather information from any available source. If forced by the situation to respond to reporters, do not attempt to improvise an answer, do not speculate, and do not downplay the seriousness of the situation. Direct all reporter inquiries to company media relations personnel and, if they are not on the scene, then to the 24-hour media line (415-973-5930). Let them know that your priorities are to focus on safety for our customers and on completing the work.

Employment Inquiries
You may not provide an employment reference for a former employee on behalf of the company; however, the Payroll Service Center (415-973-3767) will confirm the time period that a former employee worked for the company and positions held. If you wish, you may provide a personal reference for the former employee, provided you do not use company resources to do so.

¹Examples of conduct that is sexual in nature include: invitations for sexual contact or graphic commentary about an individual’s body; any conduct involving sexually suggestive or obscene objects, pictures, websites, cartoons, posters, clothing, notes, letters, e-mails, or electronic media such as texting, instant messaging or blogging; sexual gestures; leering; inappropriate touching; assault; or impeding or blocking movement.

Look to the Code Connection to find additional guidance on sections of this Code of Conduct. If you have questions, contact your supervisor or Human Resources representative, or call the Compliance and Ethics Helpline at 888-231-2310.