Vermont Gas’ Code of Ethics and Conduct is about doing the right thing – acting with integrity, treating each other with respect, and following the law. Together, we share a commitment to high standards of integrity which help us provide outstanding services to customers, hire great people, and conduct business with the knowledge that it matters to those we impact. In living up to this commitment, we expect each and every one of our employees, directors, and officers to conduct themselves with the highest degree of performance, professionalism and ethical conduct when performing their duties and responsibilities with VGS.
Conduct Business with Honesty and Integrity
At its core, ethics is about conducting business with uncompromising integrity and professionalism. We put this into practice by:
- Telling the truth – being honest, candid and forthright.
- Communicating clearly, respectfully, and professionally in business,
- Treating customers, suppliers, distributors, and others fairly,
- Acting as a responsible corporate citizen and managing the impact of our business on the world around us, and
- Keeping accurate financial and other books and records.
Know the Code
We expect all VGS employees, directors and officers to know the code, follow both it’s spirit and it’s letter, lead by example, and speak up when they see something that is falling short of our commitment to integrity. Each of us has a personal responsibility to incorporate these principles into our work, and encourage others to do the same. Complementary to the Code of Ethics, we have detailed and comprehensive policies on numerous related subjects including employee conduct, harassment, anti-discrimination, and confidentiality.
Exercise Good Judgment
You won’t find the answer to every question here, so when faced with a situation that is not covered, consider your action in light of the following questions:
- Is it ethical and legal?
- Is it consistent with VGS values?
- Does it comply with our Code of Ethics or other company policy?
- Would you feel okay about it if it was reported in the media or communicated to management? Your peers? Your family?
- Does it protect VGS short-term and long-term interests?
- Would you look anyone in the eye and say you did the right thing?
If you can answer “yes” to all of these questions, then the decision to move forward is probably appropriate. If you’re not sure, consult with your Supervisor or Human Resources.
Value Safety and the Environment
We all are responsible for creating and promoting a healthy and safe working environment. We are proud of our extensive safety policies, which provide guidance and expectations for safe behaviors. It is the responsibility of every employee to know and follow all safety practices related to their work, as well as use daily awareness and common sense to create a safe environment for themselves and their co-workers.
VGS has a strong commitment to corporate citizenship and we strive to conduct business in an environmentally aware and responsible manner. To this end, it is our policy to comply with all environmental laws and regulations. As a business and as individuals, we must be responsible stewards of the environment.
Follow the Law
As a regulated energy company, Vermont Gas’s business and activities are subject to a diverse and complex set of laws, regulations and rules enforced by federal, state and local authorities. Each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. If you are uncertain about any applicable laws, rules or regulations, consult with your Supervisor or Human Resources.
Avoid Conflicts of Interest
All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict. When faced with a potential conflict of interest, ask yourself:
- Would this activity create, or be perceived as creating, an incentive for me to benefit myself, my friends or my family, or an associated business at the expense of VGS?
- Would this harm my reputation, negatively impact my ability to do my job at VGS, or potentially harm VGS?
- Would this activity embarrass VGS or me if it showed up in the news or a blog.
Conflicts of interest can show up in many places, and transparency is key to ensuring relationships do not create these types of conflict. Here are a few areas in which to be particularly vigilant: sales and supplier relationships, personal investments, outside employment, advisory roles, board seats, starting your own business, business opportunities found through work, friend and relatives or co-worker relationships or use of VGS resources. If you think an activity or relationship that presents a conflict may exist, you must disclose it to your Supervisor or Human Resources.
Refuse Inappropriate Gifts, Gratuities and Entertainment
VGS employees must not offer, solicit or accept gifts, gratuities, entertainment or other substantial favors of more than token value to or from any outside concern that seeks to do business with, competes with, or seeks to influence VGS and its affiliates. Generally speaking, accepting something valued at more than $100 would be considered more than token value. It is not unethical to accept meals and refreshments that are business-related, reasonable and not likely to influence your performance of VGS business.
Be Responsible with Money and Assets
An important value of VGS is to spend resources wisely. When you submit an expense for reimbursement, hire a vendor, drive a vehicle or use resources on VGS’s behalf, make sure that the cost and use are reasonable and directly related to VGS business. You should never interfere in any way with the auditing of VGS’s financial records or falsify any record or account, including time reports, expense accounts and any other VGS records.
We have the tools and equipment we need to do our jobs and serve our customers effectively, and we are expected to be responsible and not wasteful. When you use VGS computer or communications resources to access Internet services or to send communications, you are acting as a representative of VGS. Furthermore, VGS funds, equipment and other assets are not to be requisitioned for personal gain, and no employee may compete with VGS directly or indirectly.
Protect Confidential and Proprietary Information
VGS employees might have access to confidential or proprietary information about Vermont Gas or its customers. VGS employees must maintain such information in the strictest of confidence unless disclosure is authorized by a Supervisor or is legally mandated. Always remember that we are asking our customers to trust us with their personal information. Each of us has a responsibility to protect personal and other confidential data from unauthorized access, loss, misuse, or unauthorized disclosure.
Treat Others with Respect
The experiences, skills, and insights from a variety of personal backgrounds enrich our workplace, improve our employees’ effectiveness and satisfaction, and ultimately contribute to the success of VGS. VGS is an equal opportunity employer and believes every employee is entitled to fair treatment, courtesy, and respect. We do not tolerate illegal employment discrimination or unlawful workplace harassment. VGS strives to create an environment where employees can communicate openly and raise issues as they occur. We are each individually responsible to foster and support an open and honest work environment.
Accountability of the Code
We expect all of our employees, officers and board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment and civil or criminal penalties. Moreover, while the Code is specifically written for VGS employees and board members, we expect VGS contractors, consultants and others who may be temporarily assigned to perform work or services for VGS to follow the Code in connection with their work with us, and misconduct can result in the termination of their relationship with VGS.
Speak up if you see or suspect activity that violates our Code. It may seem easier to say nothing or to look the other way, but taking no action can have serious consequences. Report any known or suspected violations of the law, this Code, VGS policy, or other misconduct to your Supervisor, Human Resources, or the Chair of the Board of Directors’ Audit Committee.
If you want to remain anonymous, you can make a report of a suspected violation or concern through the Ethics and Compliance Hotline at 844-240-0005.
Anyone who reports a violation will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reporting truthfully and in good faith. VGS will investigate all reports promptly and as confidentially as possible. Vermont Gas prohibits retaliation against any worker who reports or participates in an investigation of a possible violation of our Code made in good faith by employees. Directors, officers and employees are expected to cooperate in internal investigations of misconduct.
The VGS Board of Directors, through the VGS Audit Board Committee, will oversee the administration of this Code. Human Resources at VGS is responsible to promptly investigate all reports, review the code annually with employees, and present annual reviews to the Audit Board Committee.