14
an employee field guide August 2014

an employee field guide - Electric Reliability Council of ... Field Guide_August 2014.pdf · This section reviews ... devoted to their communities and charitable causes. ... We encourage

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August 2014

Table of ContentsOur work environment 1 Work schedule What if I canrsquot get to the office What if my computer or phone isnrsquot working Personal appearance Your badge goes with every outfit Children and pets Workplace relationships Celebration and community involvement Suggesting improvements

Responding to outside communications and questions 4

Safety on the job 4 Ensuring a safe workplace Smoking alcohol and drug use Driving on company business Carrying firearms and other weapons

Time away from work 7 Holidays TIme away with pay Unpaid leave

Behavior we do not tolerate mdash and what to do about it 9

Your question not answered 12 People you can call for help

Our work environment

ERCOT aspires to create a work environment that encourages you to focus on the work you are here to do and fosters a collaborative and creative atmosphere that makes ERCOT a productive place to spend your time This section reviews some of the common day-to-day questions you might have about how we work in this environment

Work ScheduleNormal office hours for most employees are Monday through Friday 8 am to 5 pm Because of the type of work ERCOT does we may schedule various types of work at different hours of the day and night and at times more than five days a week In some areas jobs are always staffed 24

hours a day seven days a week

Managers determine the regularly scheduled work week for the employees in their groups so any questions about work schedule should be discussed with your manager We rely on you to be here mdash and your work is important mdash so being late or absent too much can be grounds for discipline or termination

If a flexible scheduling or telecommuting arrangement fits with your job duties and personal effectiveness we urge you to discuss these

arrangements with your manager Since getting the work done in your area is your managerrsquos responsibility they have the discretion to decide the details of such arrangements ERCOT has a formal program for managing flex-telecommute arrangements and your manager can work through the requirements with you if you are interested

What if I canrsquot get to the office If bad weather or other extraordinary circumstances keep you from getting to the office we ask that you do whatever work you are able from home ERCOT provides web access to email and remote access to other systems and we encourage you to use them when you cannot make it to the office

Sometimes managers in particular areas will identify ldquocritical employeesrdquo who are needed to deliver essential ERCOT services Once a designation is made critical employees may be asked to stay near the office in hotels paid for by ERCOT or otherwise work shifts different from those originally scheduled

1

If you want to find out if bad weather is affecting the office schedule call ERCOT at (512) 275-7500 If there is any information on office closures you will hear it there

What if my computer or phone isnrsquot workingThe ERCOT Help Desk is the one-stop shop for addressing problems with the equipment and technology you need to get your job done Call them at x6800 or email at HelpDeskercotcom and they will initiate the process to get you back in business

Personal appearanceIn general ERCOT has a ldquocasual dressrdquo policy but in day-to-day practice we have a ldquodress to be effectiverdquo policy Managers are expected to ensure employee dress and appearance is appropriate to meet the business needs of the department Standards for appropriate dress may vary among groups within the company If you observe dress that troubles you bring it to the attention of your manager for discussion If you are concerned about whether what you are wearing is OK it never hurts to look around and consider what the folks around you are doing and use your best judgment

Your badge goes with every outfitNo matter how formally or informally you dress you must wear your identification badge while on ERCOT property The badge must remain visible at all times Visitors must wear a visitorrsquos badge which they can obtain at the security desk If you forget your badge you must obtain a temporary badge from security All lost badges must be reported immediately You should let security know if you see anyone on the premises without an employee contractor or visitor badge Strong security is part of our duty as the electric system operator It is not only good practice but federal and state reliability standards demand it

Children and petsPlease avoid bringing your children or pets to the office during working hours Cute as they may be kids can be distracting pets may stir up allergies or other problems for co-workers and both may cause safety issues in the workplace In cases of illness please remember that when you or your child is ill bringing the illness to work is unfair to your colleagues Reasonable exceptions may be made (eg service dogs for the sight-impaired) please talk to your manager if you have special circumstances

Workplace relationshipsWe do not want to be involved in employeesrsquo romantic lives but if you have ever worked in an office you know that relationships among co-workers can complicate the workplace

2

This is not a style point proper identification and the access to sensitive areas that goes with having a badge are central to ERCOT maintaining physical and cyber-security

NAMEYOUR NAME

3

ERCOT has chosen to draw this line a person who has a supervisory relationship with another person (whether employee or contractor) should not also have a romantic relationship with that person Donrsquot date your boss or a person who works for you and we wonrsquot have to talk about this any more If you do we have a problem to discuss

Celebration and community involvementWe enjoy celebrating our accomplishments and milestones and many people at ERCOT are devoted to their communities and charitable causes The way we celebrate and encourage involvement must also recognize that ERCOT is a non-profit corporation funded by Texas electricity customers who expect us to use their money wisely We are in the public service business and must be aware that ERCOT mdash as a company mdash is legally prohibited from lobbying engaging in political activities or otherwise appearing to favor particular political positions

So when we celebrate our achievements and get involved in the community together we need to be sensitive to our role in the community and work within the following guidelines

bull If you are planning a celebration for a colleague (like a birthday or baby shower) or you want to recognize performance by celebrating using company funds budgeted for that purpose please clear it with your manager Depending on the size of the celebration the expenditure may need review and approval from executive management

bull Plug into ERCOTrsquos Community Involvement Committee or Employee Activity Committee These employee-run groups organize events and serve as champions for numerous community organizations and charitable causes Their work is supported by the company and is a great way to meet people who share a commitment to improving the workplace and the broader community

bull If you would like company support for any civic or charitable cause please send the request to the Community Involvement Committee (and please send with enough lead time that the request can be adequately considered)

bull It is fine to let colleagues know you support a cause but we do not support an environment where co-workers feel pressured to contribute (or are actively solicited at the office where the focus ought to be on work) You may post requests for support on the bulletin board designated for that purpose or offer your co-workers the chance to buy items your kids are selling to raise money but please always be respectful of your co-workersrsquo choices to participate or not

Suggesting improvementsWe know that no one has a monopoly on ideas for improving the work environment We welcome your suggestions and hope you will discuss them with your manager as ideas arise If you would prefer to submit your ideas anonymously there are suggestions boxes located in several locations at all our facilities

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Table of ContentsOur work environment 1 Work schedule What if I canrsquot get to the office What if my computer or phone isnrsquot working Personal appearance Your badge goes with every outfit Children and pets Workplace relationships Celebration and community involvement Suggesting improvements

Responding to outside communications and questions 4

Safety on the job 4 Ensuring a safe workplace Smoking alcohol and drug use Driving on company business Carrying firearms and other weapons

Time away from work 7 Holidays TIme away with pay Unpaid leave

Behavior we do not tolerate mdash and what to do about it 9

Your question not answered 12 People you can call for help

Our work environment

ERCOT aspires to create a work environment that encourages you to focus on the work you are here to do and fosters a collaborative and creative atmosphere that makes ERCOT a productive place to spend your time This section reviews some of the common day-to-day questions you might have about how we work in this environment

Work ScheduleNormal office hours for most employees are Monday through Friday 8 am to 5 pm Because of the type of work ERCOT does we may schedule various types of work at different hours of the day and night and at times more than five days a week In some areas jobs are always staffed 24

hours a day seven days a week

Managers determine the regularly scheduled work week for the employees in their groups so any questions about work schedule should be discussed with your manager We rely on you to be here mdash and your work is important mdash so being late or absent too much can be grounds for discipline or termination

If a flexible scheduling or telecommuting arrangement fits with your job duties and personal effectiveness we urge you to discuss these

arrangements with your manager Since getting the work done in your area is your managerrsquos responsibility they have the discretion to decide the details of such arrangements ERCOT has a formal program for managing flex-telecommute arrangements and your manager can work through the requirements with you if you are interested

What if I canrsquot get to the office If bad weather or other extraordinary circumstances keep you from getting to the office we ask that you do whatever work you are able from home ERCOT provides web access to email and remote access to other systems and we encourage you to use them when you cannot make it to the office

Sometimes managers in particular areas will identify ldquocritical employeesrdquo who are needed to deliver essential ERCOT services Once a designation is made critical employees may be asked to stay near the office in hotels paid for by ERCOT or otherwise work shifts different from those originally scheduled

1

If you want to find out if bad weather is affecting the office schedule call ERCOT at (512) 275-7500 If there is any information on office closures you will hear it there

What if my computer or phone isnrsquot workingThe ERCOT Help Desk is the one-stop shop for addressing problems with the equipment and technology you need to get your job done Call them at x6800 or email at HelpDeskercotcom and they will initiate the process to get you back in business

Personal appearanceIn general ERCOT has a ldquocasual dressrdquo policy but in day-to-day practice we have a ldquodress to be effectiverdquo policy Managers are expected to ensure employee dress and appearance is appropriate to meet the business needs of the department Standards for appropriate dress may vary among groups within the company If you observe dress that troubles you bring it to the attention of your manager for discussion If you are concerned about whether what you are wearing is OK it never hurts to look around and consider what the folks around you are doing and use your best judgment

Your badge goes with every outfitNo matter how formally or informally you dress you must wear your identification badge while on ERCOT property The badge must remain visible at all times Visitors must wear a visitorrsquos badge which they can obtain at the security desk If you forget your badge you must obtain a temporary badge from security All lost badges must be reported immediately You should let security know if you see anyone on the premises without an employee contractor or visitor badge Strong security is part of our duty as the electric system operator It is not only good practice but federal and state reliability standards demand it

Children and petsPlease avoid bringing your children or pets to the office during working hours Cute as they may be kids can be distracting pets may stir up allergies or other problems for co-workers and both may cause safety issues in the workplace In cases of illness please remember that when you or your child is ill bringing the illness to work is unfair to your colleagues Reasonable exceptions may be made (eg service dogs for the sight-impaired) please talk to your manager if you have special circumstances

Workplace relationshipsWe do not want to be involved in employeesrsquo romantic lives but if you have ever worked in an office you know that relationships among co-workers can complicate the workplace

2

This is not a style point proper identification and the access to sensitive areas that goes with having a badge are central to ERCOT maintaining physical and cyber-security

NAMEYOUR NAME

3

ERCOT has chosen to draw this line a person who has a supervisory relationship with another person (whether employee or contractor) should not also have a romantic relationship with that person Donrsquot date your boss or a person who works for you and we wonrsquot have to talk about this any more If you do we have a problem to discuss

Celebration and community involvementWe enjoy celebrating our accomplishments and milestones and many people at ERCOT are devoted to their communities and charitable causes The way we celebrate and encourage involvement must also recognize that ERCOT is a non-profit corporation funded by Texas electricity customers who expect us to use their money wisely We are in the public service business and must be aware that ERCOT mdash as a company mdash is legally prohibited from lobbying engaging in political activities or otherwise appearing to favor particular political positions

So when we celebrate our achievements and get involved in the community together we need to be sensitive to our role in the community and work within the following guidelines

bull If you are planning a celebration for a colleague (like a birthday or baby shower) or you want to recognize performance by celebrating using company funds budgeted for that purpose please clear it with your manager Depending on the size of the celebration the expenditure may need review and approval from executive management

bull Plug into ERCOTrsquos Community Involvement Committee or Employee Activity Committee These employee-run groups organize events and serve as champions for numerous community organizations and charitable causes Their work is supported by the company and is a great way to meet people who share a commitment to improving the workplace and the broader community

bull If you would like company support for any civic or charitable cause please send the request to the Community Involvement Committee (and please send with enough lead time that the request can be adequately considered)

bull It is fine to let colleagues know you support a cause but we do not support an environment where co-workers feel pressured to contribute (or are actively solicited at the office where the focus ought to be on work) You may post requests for support on the bulletin board designated for that purpose or offer your co-workers the chance to buy items your kids are selling to raise money but please always be respectful of your co-workersrsquo choices to participate or not

Suggesting improvementsWe know that no one has a monopoly on ideas for improving the work environment We welcome your suggestions and hope you will discuss them with your manager as ideas arise If you would prefer to submit your ideas anonymously there are suggestions boxes located in several locations at all our facilities

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Our work environment

ERCOT aspires to create a work environment that encourages you to focus on the work you are here to do and fosters a collaborative and creative atmosphere that makes ERCOT a productive place to spend your time This section reviews some of the common day-to-day questions you might have about how we work in this environment

Work ScheduleNormal office hours for most employees are Monday through Friday 8 am to 5 pm Because of the type of work ERCOT does we may schedule various types of work at different hours of the day and night and at times more than five days a week In some areas jobs are always staffed 24

hours a day seven days a week

Managers determine the regularly scheduled work week for the employees in their groups so any questions about work schedule should be discussed with your manager We rely on you to be here mdash and your work is important mdash so being late or absent too much can be grounds for discipline or termination

If a flexible scheduling or telecommuting arrangement fits with your job duties and personal effectiveness we urge you to discuss these

arrangements with your manager Since getting the work done in your area is your managerrsquos responsibility they have the discretion to decide the details of such arrangements ERCOT has a formal program for managing flex-telecommute arrangements and your manager can work through the requirements with you if you are interested

What if I canrsquot get to the office If bad weather or other extraordinary circumstances keep you from getting to the office we ask that you do whatever work you are able from home ERCOT provides web access to email and remote access to other systems and we encourage you to use them when you cannot make it to the office

Sometimes managers in particular areas will identify ldquocritical employeesrdquo who are needed to deliver essential ERCOT services Once a designation is made critical employees may be asked to stay near the office in hotels paid for by ERCOT or otherwise work shifts different from those originally scheduled

1

If you want to find out if bad weather is affecting the office schedule call ERCOT at (512) 275-7500 If there is any information on office closures you will hear it there

What if my computer or phone isnrsquot workingThe ERCOT Help Desk is the one-stop shop for addressing problems with the equipment and technology you need to get your job done Call them at x6800 or email at HelpDeskercotcom and they will initiate the process to get you back in business

Personal appearanceIn general ERCOT has a ldquocasual dressrdquo policy but in day-to-day practice we have a ldquodress to be effectiverdquo policy Managers are expected to ensure employee dress and appearance is appropriate to meet the business needs of the department Standards for appropriate dress may vary among groups within the company If you observe dress that troubles you bring it to the attention of your manager for discussion If you are concerned about whether what you are wearing is OK it never hurts to look around and consider what the folks around you are doing and use your best judgment

Your badge goes with every outfitNo matter how formally or informally you dress you must wear your identification badge while on ERCOT property The badge must remain visible at all times Visitors must wear a visitorrsquos badge which they can obtain at the security desk If you forget your badge you must obtain a temporary badge from security All lost badges must be reported immediately You should let security know if you see anyone on the premises without an employee contractor or visitor badge Strong security is part of our duty as the electric system operator It is not only good practice but federal and state reliability standards demand it

Children and petsPlease avoid bringing your children or pets to the office during working hours Cute as they may be kids can be distracting pets may stir up allergies or other problems for co-workers and both may cause safety issues in the workplace In cases of illness please remember that when you or your child is ill bringing the illness to work is unfair to your colleagues Reasonable exceptions may be made (eg service dogs for the sight-impaired) please talk to your manager if you have special circumstances

Workplace relationshipsWe do not want to be involved in employeesrsquo romantic lives but if you have ever worked in an office you know that relationships among co-workers can complicate the workplace

2

This is not a style point proper identification and the access to sensitive areas that goes with having a badge are central to ERCOT maintaining physical and cyber-security

NAMEYOUR NAME

3

ERCOT has chosen to draw this line a person who has a supervisory relationship with another person (whether employee or contractor) should not also have a romantic relationship with that person Donrsquot date your boss or a person who works for you and we wonrsquot have to talk about this any more If you do we have a problem to discuss

Celebration and community involvementWe enjoy celebrating our accomplishments and milestones and many people at ERCOT are devoted to their communities and charitable causes The way we celebrate and encourage involvement must also recognize that ERCOT is a non-profit corporation funded by Texas electricity customers who expect us to use their money wisely We are in the public service business and must be aware that ERCOT mdash as a company mdash is legally prohibited from lobbying engaging in political activities or otherwise appearing to favor particular political positions

So when we celebrate our achievements and get involved in the community together we need to be sensitive to our role in the community and work within the following guidelines

bull If you are planning a celebration for a colleague (like a birthday or baby shower) or you want to recognize performance by celebrating using company funds budgeted for that purpose please clear it with your manager Depending on the size of the celebration the expenditure may need review and approval from executive management

bull Plug into ERCOTrsquos Community Involvement Committee or Employee Activity Committee These employee-run groups organize events and serve as champions for numerous community organizations and charitable causes Their work is supported by the company and is a great way to meet people who share a commitment to improving the workplace and the broader community

bull If you would like company support for any civic or charitable cause please send the request to the Community Involvement Committee (and please send with enough lead time that the request can be adequately considered)

bull It is fine to let colleagues know you support a cause but we do not support an environment where co-workers feel pressured to contribute (or are actively solicited at the office where the focus ought to be on work) You may post requests for support on the bulletin board designated for that purpose or offer your co-workers the chance to buy items your kids are selling to raise money but please always be respectful of your co-workersrsquo choices to participate or not

Suggesting improvementsWe know that no one has a monopoly on ideas for improving the work environment We welcome your suggestions and hope you will discuss them with your manager as ideas arise If you would prefer to submit your ideas anonymously there are suggestions boxes located in several locations at all our facilities

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

What if my computer or phone isnrsquot workingThe ERCOT Help Desk is the one-stop shop for addressing problems with the equipment and technology you need to get your job done Call them at x6800 or email at HelpDeskercotcom and they will initiate the process to get you back in business

Personal appearanceIn general ERCOT has a ldquocasual dressrdquo policy but in day-to-day practice we have a ldquodress to be effectiverdquo policy Managers are expected to ensure employee dress and appearance is appropriate to meet the business needs of the department Standards for appropriate dress may vary among groups within the company If you observe dress that troubles you bring it to the attention of your manager for discussion If you are concerned about whether what you are wearing is OK it never hurts to look around and consider what the folks around you are doing and use your best judgment

Your badge goes with every outfitNo matter how formally or informally you dress you must wear your identification badge while on ERCOT property The badge must remain visible at all times Visitors must wear a visitorrsquos badge which they can obtain at the security desk If you forget your badge you must obtain a temporary badge from security All lost badges must be reported immediately You should let security know if you see anyone on the premises without an employee contractor or visitor badge Strong security is part of our duty as the electric system operator It is not only good practice but federal and state reliability standards demand it

Children and petsPlease avoid bringing your children or pets to the office during working hours Cute as they may be kids can be distracting pets may stir up allergies or other problems for co-workers and both may cause safety issues in the workplace In cases of illness please remember that when you or your child is ill bringing the illness to work is unfair to your colleagues Reasonable exceptions may be made (eg service dogs for the sight-impaired) please talk to your manager if you have special circumstances

Workplace relationshipsWe do not want to be involved in employeesrsquo romantic lives but if you have ever worked in an office you know that relationships among co-workers can complicate the workplace

2

This is not a style point proper identification and the access to sensitive areas that goes with having a badge are central to ERCOT maintaining physical and cyber-security

NAMEYOUR NAME

3

ERCOT has chosen to draw this line a person who has a supervisory relationship with another person (whether employee or contractor) should not also have a romantic relationship with that person Donrsquot date your boss or a person who works for you and we wonrsquot have to talk about this any more If you do we have a problem to discuss

Celebration and community involvementWe enjoy celebrating our accomplishments and milestones and many people at ERCOT are devoted to their communities and charitable causes The way we celebrate and encourage involvement must also recognize that ERCOT is a non-profit corporation funded by Texas electricity customers who expect us to use their money wisely We are in the public service business and must be aware that ERCOT mdash as a company mdash is legally prohibited from lobbying engaging in political activities or otherwise appearing to favor particular political positions

So when we celebrate our achievements and get involved in the community together we need to be sensitive to our role in the community and work within the following guidelines

bull If you are planning a celebration for a colleague (like a birthday or baby shower) or you want to recognize performance by celebrating using company funds budgeted for that purpose please clear it with your manager Depending on the size of the celebration the expenditure may need review and approval from executive management

bull Plug into ERCOTrsquos Community Involvement Committee or Employee Activity Committee These employee-run groups organize events and serve as champions for numerous community organizations and charitable causes Their work is supported by the company and is a great way to meet people who share a commitment to improving the workplace and the broader community

bull If you would like company support for any civic or charitable cause please send the request to the Community Involvement Committee (and please send with enough lead time that the request can be adequately considered)

bull It is fine to let colleagues know you support a cause but we do not support an environment where co-workers feel pressured to contribute (or are actively solicited at the office where the focus ought to be on work) You may post requests for support on the bulletin board designated for that purpose or offer your co-workers the chance to buy items your kids are selling to raise money but please always be respectful of your co-workersrsquo choices to participate or not

Suggesting improvementsWe know that no one has a monopoly on ideas for improving the work environment We welcome your suggestions and hope you will discuss them with your manager as ideas arise If you would prefer to submit your ideas anonymously there are suggestions boxes located in several locations at all our facilities

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

3

ERCOT has chosen to draw this line a person who has a supervisory relationship with another person (whether employee or contractor) should not also have a romantic relationship with that person Donrsquot date your boss or a person who works for you and we wonrsquot have to talk about this any more If you do we have a problem to discuss

Celebration and community involvementWe enjoy celebrating our accomplishments and milestones and many people at ERCOT are devoted to their communities and charitable causes The way we celebrate and encourage involvement must also recognize that ERCOT is a non-profit corporation funded by Texas electricity customers who expect us to use their money wisely We are in the public service business and must be aware that ERCOT mdash as a company mdash is legally prohibited from lobbying engaging in political activities or otherwise appearing to favor particular political positions

So when we celebrate our achievements and get involved in the community together we need to be sensitive to our role in the community and work within the following guidelines

bull If you are planning a celebration for a colleague (like a birthday or baby shower) or you want to recognize performance by celebrating using company funds budgeted for that purpose please clear it with your manager Depending on the size of the celebration the expenditure may need review and approval from executive management

bull Plug into ERCOTrsquos Community Involvement Committee or Employee Activity Committee These employee-run groups organize events and serve as champions for numerous community organizations and charitable causes Their work is supported by the company and is a great way to meet people who share a commitment to improving the workplace and the broader community

bull If you would like company support for any civic or charitable cause please send the request to the Community Involvement Committee (and please send with enough lead time that the request can be adequately considered)

bull It is fine to let colleagues know you support a cause but we do not support an environment where co-workers feel pressured to contribute (or are actively solicited at the office where the focus ought to be on work) You may post requests for support on the bulletin board designated for that purpose or offer your co-workers the chance to buy items your kids are selling to raise money but please always be respectful of your co-workersrsquo choices to participate or not

Suggesting improvementsWe know that no one has a monopoly on ideas for improving the work environment We welcome your suggestions and hope you will discuss them with your manager as ideas arise If you would prefer to submit your ideas anonymously there are suggestions boxes located in several locations at all our facilities

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Ensuring a safe workplaceMaintaining a safe working environment requires awareness and cooperation from everyone in the workplace While keeping yourself and your colleagues safe is a responsibility we all share we ask that you cooperate in some simple ways

bull Every employee should be familiar with and have a copy of the ldquoEmergency ndash Crisis Proceduresrdquo booklet It includes numbers for ERCOT emergency contacts evacuation procedures and guidance for how to handle other emergencies If you donrsquot have the booklet ask your manager to get a copy for you

bull If your job involves following specific safety rules we consider it part of your job to follow them Safety ldquoshortcutsrdquo lead to unwanted injuries or damage to critical equipment If someone encourages you to take such shortcuts they are asking you to violate company policy

Responding to outside communications and questionsOn a daily basis ERCOT works with participants in our market with government agencies with the media and with consultants professors and electricity consumers who are interested in our work In short ERCOT people should expect to live and work in a fishbowl

If it is not in the normal course of your job to receive questions from any of these folks (or you usually talk to market participants but not to legislators or regulators but not member of the Board of Directors or you get the picture) please refer the question or request to the Corporate Communications group They will either handle the inquiry refer it to the person best suited to handle it or help you prepare a response

Also please alert Corporate Communications if you are aware of developments in your area of expertise that may

attract the attention of the media or government officials At ERCOT transparency of information is very important to us and to our stakeholders and we prefer a ldquono surprisesrdquo approach to developments affecting stakeholders

Safety on the job

4

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

bull You are responsible for reporting accidents or injuries to your manager ERCOT provides workerrsquos compensation coverage for employees and we are also committed to repairing conditions that lead to safety problems Employees are the front line and we need you to help yourself and others by reporting problems when you see them If your manager is not available when the report needs to be made call your HR Business Partner to identify the problem For more details on these company policies please review CS 513 Safety and Workers Compensation Corporate Standard

bull We do not tolerate workplace violence or intimidation If you feel you have experienced or been threatened with either please report it promptly to your manager to security officers or to your HR Business Partner Management has established mechanisms to deal with threats or intimidation while protecting the identity of those who report it

Use of fitness facilitiesWe encourage employees to maintain active and healthy lifestyles We regularly promote wellness activities and events and have provided access to fitness facilities including workout rooms a walking track and a sport court However your participation in these activities and use of these facilities are entirely voluntary and you assume all risk of injury Once again employees are the front line Please report any unsafe conditions you notice in our fitness facilities to your manager or the HelpDesk

Smoking alcohol and drug useWe encourage employees to maintain healthy life habits on the job and everywhere else Consistent with that priority ERCOT maintains a smoke-free and vapor-free work environment If you must smoke use e-cigarettes or other ldquovapingrdquo devices there are areas at each of our facilities designated for smoking All work areas (including restrooms break areas and building entrances) are non-smoking non-vaping areas

Keeping the electric grid and markets working effectively is a job that must be done sober While on ERCOT premises and during working hours all business conducted on ERCOTrsquos behalf should be done without using alcohol or illegal drugs An employee under the influence of alcohol or drugs must never drive an ERCOT vehicle (including cars rented for business) or operate ERCOT equipment ERCOT reserves the right to test any employee for drug andor alcohol use at any time Refusal to cooperate with testing will lead to employment termination For more details on these company policies please review CS 511 Drug Testing and Alcohol Usage Corporate Standard

Employees scheduled to be on-call are expected to be sober and fit for duty upon reporting to work Sometimes an employee who is not scheduled to be on-call may be called in If an employee not on-call is called in and the employee called is under the influence they must tell the supervisor on duty and the employee will not be required to report to work

Responding to outside communications and questions

5

If you see workplace conditions that could pose safety threats please notify the Help Desk at x6800 so they will get the proper attention

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

If you feel you have developed a problem with drugs or alcohol we encourage you to seek assistance either through the Employee Assistance Program (EAP) sponsored by the company or through other programs you believe will assist you We want to see you healthy and able to meet your professional and personal goals

Driving on company businessWhether you are driving an ERCOT-owned vehicle or your own when you are on the road on behalf of ERCOT we require that you practice safety precautions that we hope you will practice on your own time too

You must follow these safety precautions in any vehicle while on company business but if you are driving an ERCOT-owned vehicle or ERCOT subsidized commuter vehicle we have some additional requirements

bull Do not provide rides for hitchhikers or other unauthorized passengersbull Do not use the vehicle while carrying a firearmbull Do not use the vehicle for personal errandsbull The driver is responsible for cleaning up ERCOT-owned vehicles after trips and returning the

vehicle with a full tank of gas

If you have an accident or injury while driving on company business please report it to the police your manager and the ERCOT Treasurer For more details on these company policies please review CS 514 Driving on Company Business Corporate Standard

Carrying firearms and other weaponsFor safety reasons ERCOT prohibits carrying firearms in our facilities We require that if you carry a firearm in your car you leave it secured in your car out of public view and do not bring it into work spaces If you believe someone is violating this policy please promptly notify the security officers at 1ercotphysicalsecurityercotcom or your HR Business Partner

Weapons that are illegal to possess in Texas may not be brought on ERCOT premises whether on your person or in your car If you are interested you can find the list of these weapons in the Texas Penal Code Section 4605 For further details please review CS 515 Firearm and Weapon Corporate Standard

6

bull Wear seat belts no matter where you are riding in the vehicle

bull Be familiar with defensive driving techniques and practice them throughout your trip

bull Do not use your mobile phone device while operating the vehicle If you have an emergency use the hands-free feature if possible If you need to make or take a call or check an email or text please pull over to a safe location

bull Never drive while under the influence of alcohol illegal drugs sleep deprivation or any medication or condition that diminishes your capacity to drive safely

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Time away from workHolidaysERCOT company holidays are as followsbull New Yearrsquos Day (observed the first weekday in January)bull Memorial Daybull Independence Daybull Labor Daybull Thanksgiving Daybull The day after Thanksgivingbull Christmas Day andbull One additional day in December (the date will vary year to year)

Time away with payIn addition to paid holidays ERCOT offers employees several types of paid days away from work vacation time sick leave paid time off (PTO) bereavement leave and civic and military leave

Vacation is part of the ERCOT benefits package and the amount of vacation time available varies with your position and your years of experience and service to ERCOT If you donrsquot use vacation time in a year it accrues up to a maximum of 30 days (240 work hours) During the benefits enrollment period each year you may also purchase additional vacation hours subject to limitations (on the purchase and use of the time) that are described in materials you will receive during open enrollment Please work with your manager when you have vacation or PTO requests

Management wants you to enjoy your time at the beach and all but itrsquos also not all about you ERCOT needs you fresh and at your best when you are back on duty Creative minds need to be refreshed regularly to work their best

Sick Leave is available for times when you cannot work due to illness or when you need to attend to medical or dental appointments (or take those for whom you are the caregiver) If you take more than three consecutive days of sick leave you need to bring a doctorrsquos note to work to verify your illness ERCOT does not permit sick leave to be tacked on to vacation or PTO time to extend vacations Sick leave that is not used may be accrued subject to limits that you can explore in detail with your manager or HR Business Partner

7

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

PTO is four days (32 hours) each calendar year for full-time employees PTO or ldquofloating holidaysrdquo can be used for any purpose but cannot be carried forward from year to year You can make an annual election to forgo sick leave accruals in exchange for six additional days of PTO Non-elective and elective PTO days will be prorated in the year you are hired

Bereavement Leave is available if you need to attend a funeral or make funeral arrangements for a member of your family or household you may have up to five days of bereavement leave We want to accommodate reasonable travel time and encourage time with family and friends As with any time off we ask that you coordinate such absences with your manager

Civic and Military Leave provides time off for fulfilling civic responsibilities like jury duty or voting if they cannot be managed without missing time at work Military leave is provided in accordance with the requirements of the Uniformed Services Employment and Reemployment Rights Act (USERRA) to any employee who is a member of the uniformed services of the United States (as defined in USERRA) If you need to call on these types of leave please discuss the circumstances with your manager

Unpaid leaveUnder certain circumstances ERCOT will make available approved periods of unpaid leave This includes job-protected leave when you are eligible under the federal Family and Medical Leave Act (FMLA) or the USERRA for military leave

ERCOT also will work with employees to establish defined periods of up to 30 days of unpaid leave when an employee seeks additional leave after using up vacation PTO sick leave or other available paid leave

All unpaid leave is subject to specific requirements to ensure ERCOT is complying with your legal rights and to ensure there is a clear understanding of expectations between the company and the employee taking leave

8

ERCOT management encourages employees to use the PTO and vacation time that are part of the terms of working here and to use leave rather than come to the office when you are ill

If you are considering any form of unpaid leave please begin discussing it with your manager well in advance of the date you hope to begin the leave if possible

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Behavior we do not tolerate mdash and what to do about it

In all ERCOT workplaces we encourage tolerance curiosity and creative thinking

But there are some things we do not tolerate ndash and you should not tolerate them either as an ERCOT employee

These include A hostile work environmentThat means a workplace in which behavior unreasonably interferes with the employeersquos work performance or creates an intimidating hostile or offensive working environment We do not accept intimidation or harassment by our employees or directed at our employees by anyone including independent contractors consultants vendors or market participants It is important for all of us to remember that people have differing perceptions of what is offensive and we must be sensitive to these differences in our dealings with colleagues

DiscriminationNegative treatment directed at any individual based on race color religion gender national origin citizenship ancestry age physical or mental disability medical condition creed veteran status marital status sexual orientation genetic information or other protected categories is strictly prohibited at ERCOT

Sexual harassmentThis includes unwelcome sexual advances requests for sexual favors and other verbal visual or physical conduct of a sexual nature particularly when submission to such conduct is made either explicitly or implicitly a basis for any decision regarding a personrsquos employment Sexual harassment may encompass a range of behaviors including but not limited to the following unwelcome conduct

bull Touching such as hugging kissing pinching or pattingbull Physical and verbal sexual advances or repeated demands for datesbull Off-color jokes emails or pictures vulgar comments offensive language and teasing

Fraudulent activityERCOT is funded by the electric consumers of Texas and we have a duty to use our resources carefully Perhaps just as important ERCOTrsquos reputation for integrity is essential to fulfilling our mission Whether it is theft of company property misappropriation of funds or inappropriate dealings with vendors or market participants ERCOT must be vigilant against fraudulent activity that robs the ratepayers and the company of our most critical tangible and intangible assets 9

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Disclosure of confidential informationWe are entrusted with large quantities of extremely sensitive information mdash sensitive both from the perspective of grid security and commercial competitiveness Section 1 of the ERCOT Protocols provides very specific rules for what information ERCOT must maintain as confidential as well as information that must remain transparent to keep the market running equitably Disclosure of confidential information can do real damage and all ERCOT employees are responsible for knowing what is confidential and what is not For more details please review CS 519 Confidentiality Corporate Standard

Conflicts of interestYou will be asked to annually affirm that you do not have impermissible conflicts of interest that would call your judgment into question ERCOT must remain impartial in addressing market issues in which millions of dollars are at stake When that impartiality is questioned it hurts the entire enterprise If you fail to disclose conflicts or do not abide by restrictions necessary to address such conflicts disciplinary action will follow The conflicts that pose problems are described in CS 518 Conflict of Interest Corporate Standard and referenced in the Ethics Agreement we ask you to review and sign annually If you have questions about conflicts please talk to your manager or your HR Business Partner

NepotismWe make every effort to hire the best people for every job A hiring decision that involves a relative of a current employee creates its own kind of conflict of interest and we are all advised to avoid it ERCOT has specific standards for when exceptions can be made and you are encouraged to discuss those standards with your manager or your HR Business Partner if the issue arises

Antitrust violationsIn the stakeholder process industry participants work cooperatively to improve the functioning of the ERCOT market Those discussions are very productive but they must be undertaken carefully so as not to violate federal and state antitrust laws When you represent ERCOT in a stakeholder forum you should ensure that you and Market Participants do not discuss the following

bull Market Participant pricing information especially margin (profit) and internal cost information and Market Participantsrsquo expectations as to current or future prices or internal costs

bull A Market Participantrsquos marketing strategiesbull Competitors dividing up customers or geographical areasbull Excluding competitors from operating in the ERCOT Region or bull Boycotting or refusing to deal with competitors vendors or suppliers

Unauthorized use of ERCOT equipment and systemsThe security rules ERCOT enforces mdash eg changing passwords using badges restricting downloads mdash are all part of protecting the electric grid Whether the threat is physical or virtual protecting grid security is central to ERCOTrsquos mission We have to take violations of our policies about using ERCOT equipment and systems very seriously and you should have no expectation of privacy when you use ERCOT systems (or when you use your personal devices to access ERCOT systems)

10

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Retaliation for reporting intolerable activitiesERCOT will not tolerate retaliation or discrimination of any kind by or on behalf of ERCOT and its employees against any employee making a good faith complaint of or assisting in the investigation of any alleged violation of laws rules or regulations ERCOTrsquos Code of Conduct and Ethics Agreement or an internal policy or standard regarding accounting standards or disclosures internal controls or matters related to the internal or external audit of ERCOTrsquos financial statements

If you are subject to or observe any of these intolerable behaviors or actions ERCOT encourages you to report it immediately More details about your reporting options can be found in CS 537 Complaint Reporting Corporate Standard but the first place to report these problems is to your manager everyone in management shares the responsibility of maintaining a welcoming work environment and preventing actions that damage ERCOTrsquos assets or reputation

If you feel uncomfortable speaking to your manager mdash or you believe your manager is involved in causing perpetuating or covering up the problem mdash ERCOT has established procedures for confidential reporting and investigation of your concerns Personnel in the Legal Internal Audit and Human Resources departments will maintain your confidentiality when you report violations of ERCOT policy They can assist you in bringing your concern to the attention of people in the company who can solve the problem

ERCOT maintains an anonymous ethics reporting tool operated by an independent company called EthicsPoint for those who may not feel comfortable discussing their complaints in person with anyone Calls to EthicsPoint are not traced and callers can choose to remain anonymous Information from such calls and from online reports is forwarded to ERCOT staff members who are not involved in the matter reported All reports are investigated to the extent possible using the reported information A response to the report is available online to the person filing the report

ERCOT has a ldquoFraud Prevention amp Whistleblowerrdquo policy that requires the General Counsel to investigate documented complaints and report them to the leadership of the ERCOT Board of Directors Retaliation against legitimate whistleblowers is a violation of company policy

Since ERCOT makes a strong point of asking everyone to avoid the intolerable behaviors and reporting them when they occur we also provide reminders and training to help everyone remember whatrsquos on the bad list That is why we ask everyone once a year to review and reaffirm they understand ERCOTrsquos ldquoCode of Conductrdquo and ethics standards ERCOT takes this stuff seriously and we need you to take it seriously too

11

EthicsPoint is available by phone or via the EthicsPoint website seven days a week 365 days a year You may call the EthicsPoint toll-free phone number 1-866-384-4277 or visit wwwethicspointcom to make a confidential report

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship

Your question not answeredThis Field Guide does not try to answer all the questions you might have about working at ERCOT Some questions require a personal conversation

We hope the first option for those conversations will be with your manager Some topics are more easily addressed by a specialist though so we encourage you to contact the following people about the listed topics (and maybe include your manager on the call if they donrsquot know the answer either) ERCOT has a lot of talented people focused on making the work experience here positive and they are here to help

Topic Contact person

Debbie McDonough512-248-6682debbiemcdonoughercotcom

Dawn Herms512-248-6358dawnhermsercotcom

Robbie Searcy512-225-7213robbiesearcyercotcom

Bill Magness512-225-7076billmagnessercotcom

Michelle Myers512-248-6953michellemyersercotcom

Health and other employee benefits

Payroll and retirement savings plan

Outside communications and questions

Confidential information

EthicsPoint Reporting Questions

In case you got the wrong idea a note from LegalThe purpose of this Field Guide is to answer common employee questions and concerns The contents of this Guide may change at any time Your employment at ERCOT is at-will meaning you or ERCOT may terminate the relationship at any time with or without cause or notice While this Guide endeavors to be helpful it is not a contract and doesnrsquot change the at-will employment relationship