ETHICS AND COMPLIANCE OVERSIGHT

Integrity is as foundational to our business as safety. All our leaders and employees play a critical role in creating an environment where our business practices are consistent with our values - helping individuals do the right thing and treating our coworkers, customers and communities with respect. An ethics and compliance Key Performance Indicator (KPI) component for all non-bargaining, non-physical employees in our annual incentive compensation program drives employee accountability and reinforces the importance of a strong culture of ethics and integrity. The Office of Ethics & Compliance (OEC) oversees compliance, assurance, training and communications across the organization.

COMPLIANCE PROGRAM OVERVIEW

We are focused on embedding a culture of uncompromising integrity and ethical behavior throughout the company. Key efforts include:

Centralizing compliance assurance activities within a single organization under the leadership of the Chief Ethics and Compliance Officer.
Building strong compliance processes, policies and controls.
Strengthening the channels for concern reporting and further maturing our processes to address concerns.
Seeking continuous improvement by monitoring, benchmarking and incorporating an independent assessment of our program.
Increasing transparency and accountability around FirstEnergy's political and public policy engagement.

Please visit our Proxy Statement to read more about the key steps we have completed to create a leading ethics and compliance program.

Centralized Compliance Approach

Graphic showing Prevention Detection and Correction

THE POWER OF INTEGRITY

FirstEnergy's Code of Conduct, The Power of Integrity, lays the foundation for what we expect from all employees, regardless of their role. It reflects our collective commitment to keep integrity at the forefront of everything we do – a pledge underscored by our refreshed mission statement and core values.

The Power of Integrity applies to all FirstEnergy employees, officers and directors, regardless of role, seniority or tenure at the company. Anyone whose actions are found to be inconsistent with the expectations in The Power of Integrity will be held accountable and may be subject to disciplinary action.

Our employees are all responsible for understanding and following The Power of Integrity. By adhering to the expectations in this Code, always acting with integrity and speaking up when something doesn't seem right, we are paving the way for a strong future for FirstEnergy.

EMPLOYEE TRAINING AND COMMUNICATIONS

As we develop and mature, we continue to implement more robust, best-practice approaches to training and communications on ethics and compliance issues. Following communications and training opportunities, we request feedback from employees on how to improve, which could result in changes and improvements to the program. This approach helps ensure consistent understanding and implementation of expectations.

The Office of Ethics & Compliance leads training on processes, policies and controls we have in place, such as the Code of Conduct, gifts and entertainment requirements, conflicts of interest and reporting concerns.

Key Communication Channels:

Ethical Perceptions Survey
Quarterly Newsletters
Video Blog (VLOG)
Micro-learning Videos
Leader Discussion Guides and Responses
Office of Ethics & Compliance SharePoint
- Leader Resource Center Page
- Concerns Management Report and Anonymized Concerns Page
FirstEnergy Live Events
Meeting Messages
Employee Touchpoints
Bi-annual Concerns Management Report
Board Meetings and Executive Council Meetings

Key Training Modules:

Code of Conduct (The Power of Integrity)
Political and Public Policy Engagement and Political and Public Engagement Practice
Concerns Management for Leaders
Speak-Up (Concerns Management) training for Employees
Gifts and Business Courtesies

Based on employee feedback, the training modules for both Code of Conduct (The Power of Integrity) and Concerns Management for Leaders saw a number of content updates. The enhanced modules included more examples to provide greater clarity, helping ensure positive learning and compliance outcomes.

The Ethical Perceptions Survey

FirstEnergy conducts an Ethical Perceptions Survey to better understand employee perceptions of ethics and compliance (E&C) issues and culture. The survey measures employees’ perceptions aligned to the following eight pillars of ethical culture:

Awareness of the E&C Program and Resources
Perceptions of the Function
Observing and Reporting Misconduct
Pressure
Organizational Justice
Manager Perceptions
Perceptions of Leadership
Perceptions of Peers and Environment

ETHICS AND COMPLIANCE CONCERN REPORTING

Our employees share a responsibility to foster and contribute to a culture that places compliance, ethics and integrity at the forefront of everything we do. That responsibility requires that employees act with integrity and voice opinions and concerns whenever a situation does not conform to expectations in The Power of Integrity, or violates laws, rules or regulations. Employees with information about an actual or suspected violation have an obligation to bring that concern to the company's attention.

We strive to make it as easy as possible for employees to ask a question or report a concern. The following channels are available and identified in The Power of Integrity: the employee's own supervisor, another supervisor (of any level), Office of Ethics and Compliance, Human Resources, Legal, Internal Audit, Corporate Security, Executive Council and the Board of Directors.

In addition, we maintain anonymous reporting channels that are visible and widely available to employees. Employees who wish to report anonymously can do so by contacting our Employee Concerns Helpline or by going to our EthicsPoint website.

The Employee Concerns Line and EthicsPoint website are managed by an independent third-party organization that helps personnel communicate sensitive, and sometimes confidential, information to the company. The organization is staffed by professionals who are trained to protect anonymity and handle concerns discretely and confidentially.

For additional details on our confidential concern management process, as well as our investigation and resolution process, please see our Code of Conduct.