Download Rules for Regulated and Marketing Affiliates

Rules for Regulated and Marketing Affiliates
Employees need to comply with all applicable state or federal regulatory Codes of Conduct governing our
industry when doing business with NU affiliates. At NU, our regulated Wholesale Power Supply group is
considered a marketing affiliate for purposes of these rules. An employee who discloses, accesses, seeks
to access, uses or exploits in any manner restricted information in violation of the Regulatory Codes of
Conduct will be subject to disciplinary action up to and including discharge.
Guidelines for Employees of Regulated Affiliates
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Treat all customers fairly, regardless of their energy supplier, and treat all energy service
companies fairly regardless of their affiliation.
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Charge all similarly situated customers the same prices for your services, regardless of their
energy supplier.
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Keep customer-specific information confidential; release it only to the customer or the customer’s
authorized representative or energy supplier with written authorization.
•
Keep non-customer specific, non-public information (e.g., distribution company electricity
purchases, etc.) confidential unless it is also made contemporaneously and easily available to
other service providers.
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Adhere to transfer pricing and cost allocation rules.
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Do not provide sales leads for NU’s marketing affiliates, and do not use your position to direct
customers to do business with your side business or to a business in which you have a
financial interest.
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Do not share customer-specific information with our marketing affiliates, unless they are the
authorized agent of the customer.
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Do not share non-customer specific, non-public information with our marketing affiliates, unless
the information is made available to all potential competitors at the same time.
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Do not represent to anyone that our marketing affiliates will receive preferential treatment.
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Do not engage in any joint marketing activities with, or give preferential treatment to, customers
of our marketing affiliates.
Guidelines for Marketing Affiliate Employees
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Use the regulated company name (e.g., CL&P, PSNH, WMECO, NSTAR Electric, Yankee Gas
and NSTAR Gas) and explain the affiliation with the regulated company via a written disclaimer.
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Adhere to cost allocation rules.
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Do not represent to anyone that our marketing affiliates’ customers will receive preferential
treatment from the marketing business based on their relationship with the regulated company.
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Do not represent that customers of marketing affiliates will receive more reliable power than
customers of other energy suppliers.
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Do not attempt to engage in any joint marketing efforts with the regulated company.
•
Do not attempt to extract customer-specific or non-public information from regulated company
employees.
General Information
Information that is related to providing administrative and general services may be shared, as long as
marketing employees do not obtain access to restricted information. Examples include but are not limited
to payroll, benefits, personnel, auditing, general accounting, rate design, treasury services, shareholder
services, financial reporting, financial planning and analysis, corporate security, regulatory affairs,
lobbying, legal, IT and general purchasing.
NU has established separate shared areas on the Local Area Network (LAN) for regulated and marketing
information. Information generated by or on behalf of the regulated function must not be stored in or
moved to any shared area, including NU’s internal Web site (NUNet), unless it has been specifically
established for the regulated function or appropriately secured.
Restricted information must not be input into any mainframe application unless such information is
encrypted or an electronic security measure has been installed to protect the information.
NU’s computer systems are subject to periodic audits to ensure these provisions comply with the
Regulatory Codes of Conduct.
Certain Codes of Conduct restrict movement of employees between regulated and marketing affiliates,
or between transmission and marketing affiliates. For purposes of the Federal Standards of Conduct,
the Corporate Compliance Manager must be informed in order to post certain employee transfers to the
appropriate Transmission website. Additional information is provided in “Codes of Conduct Employee
Transfer Procedures.”
Contact Information
Scott Devendorf
Corporate Compliance Manager
Legal Department, Berlin BME-2
Office: 860-665-2004
[email protected]
Phyllis Lemell
Assistant General Counsel
Legal Department, Berlin BME-2
Office: 860-665-5118
[email protected]