Senior Finance Code of Conduct
Last amended July 25, 2024
Puget Energy, Inc., Puget Sound Energy, Inc. and related subsidiaries (the “Company”) have a Code of Conduct (the “Code”) that applies to all employees and Board of Directors. The following “covered officers and finance directors” of the Company hold important and elevated roles in corporate governance and are uniquely capable and empowered to ensure that all stakeholders' interests are appropriately balanced, protected, and preserved:
- Chief Executive Officer
- Chief Financial Officer
- Controller & Principal Accounting Officer
- Corporate Treasurer
- Director of Financial Planning & Analysis
- Director of Tax
As a complement to the Code, the Senior Finance Code of Conduct (the “Finance Code”) provides specific principles designed to uphold the highest level of ethics and integrity for covered officers.
Principles Governing Professional and Ethical Conduct
Reporting of Violations
Treatment and Consequences of Violations
Waivers of the Finance Code
No Rights Created
Principles Governing Professional and Ethical Conduct
It is the expectation of the Company that its covered officers will adhere to, advocate for, and promote the following principles governing professional and ethical conduct:
- Act with honesty and integrity, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
- Provide full, fair, accurate, timely and understandable disclosures in reports and documents that the Company files with, or submits to, the Securities and Exchange Commission (“SEC”), and in other public communications made by the Company
- Comply with laws of federal, state and local governments applicable to the Company, and the rules and regulations of other appropriate private and public regulatory agencies having jurisdiction over the Company
- Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing subordination to any outside interest
- Not coerce, manipulate, mislead or unduly influence any auditor engaged in the performance of an internal or independent audit or investigation of the Company’s system of internal controls, financial statements or accounting books and records
- Provide oversight to appropriate internal controls
Reporting of Violations
If anyone becomes aware of any suspected or known violations of the Finance Code or who has concerns involving the Company or a covered officer, they should report such suspected violations promptly either to the Chief Ethics & Compliance Officer, anonymous Help-line at 1-866-236-4PSE (4773), or the web-based portal (pse.alertline.com).
Once a violation is received through these channels, the Chief Ethics and Compliance Officer with assistance as needed with the Ethics Program Manager will coordinate with the appropriate departments to review and determine whether reporting the violation to the CEO and/or Audit Committee is necessary.
As outlined in the Code, retaliation against any employee reporting in good faith an actual or suspected violation of the Finance Code or the law will not be tolerated.
Treatment and Consequences of Violations
The Audit Committee of the Board of Directors shall have the power to monitor, investigate, make determinations, and recommend action with respect to violations of this Finance Code. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence to the Finance Code, and may result in disciplinary action, up to and including dismissal. Violations of this Finance Code may also constitute violations of law and may result in criminal penalties and civil liabilities for the offending covered officer and the Company.
Waivers of the Finance Code
Any waiver (including an implicit waiver) of the Finance Code that constitutes a material departure from these provisions, as well as any amendments to the Finance Code (other than technical administrative or other non-substantive amendments), shall be publicly disclosed on a timely basis, as required by applicable rules and regulations of the SEC.
No Rights Created
This Finance Code is a statement of certain fundamental principles, policies and procedures that govern the Company's covered officers in the conduct of the Company's business. It is not intended to and does not create any rights in any employee, customer, supplier, competitor, shareholder or any other person or entity.