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 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 and Compliance (OEC) oversees organization-wide compliance, assurance, training and communications.
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.
Pleaes see our Investor FactBook to read more about the key steps we've completed to create a leading ethics and compliance program.
Centralized Compliance Approach
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
We are implementing more robust, best-practice approaches to training and communicating with employees on ethics and compliance issues. Our renewed approaches will help ensure consistent understanding and implementation of expectations.
The Office of Ethics and 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:
- Video Blog (VLOG).
- Leader Discussion Guides and Responses.
- Town Halls.
- Meeting Messages.
- Micro-learning Videos.
- Employee Touchpoints.
- Board Meetings and Executive Council Meetings.
- Code of Conduct (The Power of Integrity).
- Political and Public Policy Engagement
and Political and Public Engagement Practice.
- Concern Management for Leaders.
- Concern Management for Employees.
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.