Compliance and Ethics

Driving Compliance, Ethical Conduct and Process Improvement

In early 2010, PG&E revised and reissued its Employee Code of Conduct, which emphasizes the company’s values, describes our standards of conduct and addresses key regulatory and compliance requirements. The company took a number of steps to ensure every active employee knew about the revised code, including a process for management employees to certify that they had read, understood and would comply with the code. Union-represented employees received face-to-face briefings from supervisors.

Just as we are committed to ethical business conduct and compliance with applicable laws, regulations and policies, we expect the same commitment from our vendors and Boards of Directors. In December 2010, the Boards of Directors reaffirmed their Code of Business Conduct and Ethics for Directors. In early 2011 we reissued our Contractor, Consultant and Supplier Code of Conduct to all of our suppliers.

We continue to focus on tools and strategies to enable employees to meet compliance commitments. A network of Compliance Champions leads efforts in their organizations to identify compliance requirements, establish appropriate controls to help ensure compliance and monitor those controls to ensure they are both efficient and effective. Building on this network, we expect to develop a compliance scorecard that will enable each organization to identify areas on which to focus attention.

We are also building an Enterprise Compliance Tracking System to help PG&E manage the thousands of compliance requirements applicable to the company. The system allows PG&E to maintain an inventory of requirements and controls and to assign compliance tasks to the employees responsible for completing them.

We are also working on improving how policies and procedures are written and communicated to employees. We are building a central library and offering training on how to write clear process documents. The goal is to help employees perform their work safely, correctly, efficiently and in compliance with laws, regulations and internal company requirements, while minimizing the opportunity for human error.

Training and Employee Helpline

In 2010, more than 99 percent of employees completed our annual compliance and ethics training. The training is typically conducted in small groups to stimulate discussion and share experiences. The facilitated training sessions are supported by a video that portrays various compliance or ethical dilemmas employees may face. Our Compliance and Ethics department develops a new training video each year to address current issues and to respond to employees’ suggestions. Our 2010 training addressed diversity and inclusion, compliance procedures and controls and doing the right thing.

We also encourage employees to ask questions and raise concerns with their supervisors or through other means. For example, PG&E’s Compliance and Ethics Helpline is available to employees, contractors and customers 24 hours a day. Calls are confidential and callers may remain anonymous.

The Helpline handled 707 concerns in 2010, a 14 percent increase over 2009. Of the 707 calls, the number of employees seeking advice in 2010 was 69 percent higher than in 2009. These increases may be due to increased employee awareness about our Employee Code of Conduct as a result of the significant outreach we conducted when it was reissued.

We are continuing our practice of posting on the company’s internal website confirmed instances of employee misconduct and the resulting discipline. This supports a culture where appropriate conduct is expected and reinforces the fact that PG&E takes misconduct seriously and addresses it.