CenterPoint Energy’s core values of Safety, Integrity, Accountability, Initiative and Respect provide the foundation for our business practices and standards. We work consistently to develop and enhance a culture based on our values through our Ethics and Compliance policies, workforce and supplier diversity programs, environmental and energy conservation initiatives, and our community relations activities.
Ethics & Values
Our reputation, our relationships and our future depend on a commitment to ethics, values and compliance.
- Our Ethics and Compliance Code forms the foundation for who we are and how we conduct business. It serves as a roadmap that incorporates our values into the decisions we make every day. The Code provides an overview of the laws, regulations and policies applicable to all directors, officers and employees.
- CenterPoint Energy’s Code of Ethics for our Chief Executive Officer and Senior Financial Officers obligates our Chief Executive Officer, Chief Financial Officer, Chief Accounting Officer, Treasurer and Assistant Controller to address actual or apparent conflicts of interest between personal and professional relationships in an ethical manner.
- Our Ethics and Compliance Code of Conduct for Consultants, Contractors, Suppliers and Vendors describes expectations for our suppliers to embody CenterPoint Energy’s values by promoting and maintaining a safe environment free from discrimination; complying with all applicable labor, employment and human rights laws; and upholding a zero-tolerance policy for workplace violence, among other things.
Ethics & Compliance Training
By investing in and empowering our greatest assets – our employees, living our values and maintaining the highest ethical standards, we help ensure our company’s future success.
Annually, our officers and employees complete Ethics and Compliance training, which includes anti-corruption and anti-trust policies and procedures, among other subjects.
All active full- and part-time employees received Ethics and Compliance training in 2022.
Each year, all employees are required to complete an ethics refresher training and acknowledge their responsibility to comply with CenterPoint Energy’s Ethics and Compliance policies. All new employees are required to complete ethics and compliance training within their first 30 calendar days of employment. Our Board members receive in-person Ethics and Compliance training annually.
CenterPoint Energy’s Ethics and Compliance Code provides that all directors, officers and employees should avoid actual conflicts of interest, as well as the appearance of a conflict of interest. According to our Corporate Governance Guidelines, Governance, Environmental and Sustainability Committee Charter, and Related-Party Transaction Approval Policy, the Board has delegated to the Governance, Environmental and Sustainability Committee the responsibility for reviewing and resolving any issues with respect to related-party transactions and conflicts of interest involving executive officers, directors of the company or other related individuals under the applicable disclosure rules of the U.S. Securities and Exchange Commission.
Governance and Oversight
The Audit Committee of the Board of Directors is responsible for assisting the Board in fulfilling its oversight responsibility for compliance with legal and regulatory requirements and our systems of disclosure and internal controls.
Our Executive Vice President and General Counsel is the highest-level executive who maintains responsibility for the company’s Ethics and Compliance program, including the company’s initiatives related to anti-bribery and anti-corruption. She is supported by our Senior Vice President, Deputy General Counsel and Chief Ethics and Compliance Officer and the other members of the Ethics and Compliance Department, including both legal counsel and other compliance professionals.
Per our Corporate Governance Guidelines, Governance, Environmental and Sustainability Committee Charter, and Related-Party Transaction Approval Policy, the Board has delegated to the Governance, Environmental and Sustainability Committee the responsibility for reviewing and resolving any issues with respect to related-party transactions and conflicts of interest involving executive officers, directors of the company or other related individuals under the applicable disclosure rules of the U.S. Securities and Exchange Commission.
Audits and Risk Assessments
CenterPoint Energy regularly engages outside experts to perform an external assessment of its Ethics and Compliance Department and Program. Our Ethics and Compliance Program and Ethics and Compliance Concerns Helpline metrics are benchmarked against Department of Justice guidelines regularly, as well as with other utilities and industries, to remain vigilant on trends and best practices. We participate in various organizations and events to keep our program current.
CenterPoint Energy conducts periodic culture surveys in support of its ethical and compliant culture. In addition, the Ethics and Compliance department conducts in-person roundtable sessions that allow us to interact directly with employees from across CenterPoint Energy’s footprint. The sessions provide an opportunity to hear directly from, and stay in touch with the pulse of, employees and to share information on a variety of ethics and compliance topics. The feedback we receive from these sessions drives continuous and risk-based development of the Ethics and Compliance program.
As part of our third-party risk management structure, CenterPoint Energy regularly screens suppliers and other third parties for reputational and compliance risks. The Ethics and Compliance department reviews third parties and organizations to identify those that have been placed on government watch lists, those that have a public history of compliance issues, and those that have received adverse media coverage. In cases where issues are found, CenterPoint Energy considers engagement of the third party and takes action as necessary, which may include termination of the relationship with the third party.
Our Enterprise Risk Management function assists leaders in making risk-based decisions and links key corporate risks with long-term strategic objectives. The department conducts regular corporate, business unit and project risk assessments.
We Provide a Safe and Healthy Work Environment
We remain focused on safety. We strive to instill a culture of safety excellence at all levels of our company. We will perform our duties safely or we won’t do them.
We Act with Integrity and Lead by Example
We do what is right for our customers, our communities, our shareholders, our business partners and each other. Without fail, we follow our values, our rules and policies, and the law.
We Protect Company Assets and Preserve Resources
We are straightforward in our actions and truthful in our relationships. When we say we will do something, we follow through and keep our commitments. We accept personal responsibility for our decisions. We are all accountable for making sure our own conduct reflects and supports our values-based culture.
We Honor Our Community and Make a Difference
We are not afraid to take bold and innovative action. We make hard decisions and tackle tough choices. We speak up. We use our resources and assets wisely.
We Value Everyone
We show respect to everyone. How we treat our fellow employees and customers is just as important as the results that we achieve. We are considerate and show appreciation for diverse thinking. Every individual with whom we work deserves our best efforts. We are responsible to our stakeholders and work to earn their trust every day.
Ethics and Compliance
CenterPoint Energy expects every employee to act with personal and professional integrity, follow all applicable laws and regulations, and adhere to any additional policies and procedures that may apply to an employee’s role. Detailed policies and procedures on topics throughout the Ethics and Compliance Code are available to all employees through CenterPoint Energy’s Policy Center on our intranet site.
We promote diversity, equity and inclusion and strive to maintain a culture where all employees are free from discrimination. We respect our employees by following all labor, employment, and human rights laws applicable to our business.
Our Ethics and Compliance Code provides an overview of the laws, regulations and policies applicable to all directors, officers and employees.
Anti-Bribery and Anti-Corruption
Integrity is one of our core values – we strive to do what is right for our customers, our communities, our shareholders, our business partners, and each other. Our Board and Executive Committee support our values and emphasize the importance of ethics, compliance, and integrity in everything we do.
A key aspect of our focus on integrity is anti-bribery and anti-corruption. Our Ethics and Compliance Code addresses our expectations of employees about these risks, and we cover them each year in our required training.
Similarly, our Ethics and Compliance Code of Conduct for Consultants, Contractors, Suppliers and Vendors addresses our expectations of our vendors about these risks, and our Vendor Risk Management Program includes a review of bribery and corruption risks presented by our third parties. We have further matured our third-party risk management governance structure to bring greater transparency, monitoring and controls to this area. As a component of our ongoing third-party risk management efforts, we annually distribute a letter to all vendors reminding them of our Ethics and Compliance Code and the limitations on our employees about giving and receiving gifts.
In response to recent reports of bribery issues in the utility industry, we conducted anti-bribery training sessions, including case studies, and provided leadership with toolkit resources. Leaders used the materials for discussions with employees to drive awareness of these risks and promote individual and corporate integrity. Additionally, our Independent Chair of the Board recorded a video for all employees about the importance of ethics and compliance in general and about this risk in particular.
In addition to the targeted training and awareness efforts, as detailed in our Ethics and Compliance Code, CenterPoint Energy does not allow offer, give or accept gifts or entertainment where such exchange could potentially create a conflict of interest. Certain employees receive an annual survey about conflicts of interest wherein we ask direct questions about any potentially improper payments or political contributions, outside business interests and relationships, or other actions taken that may be improper or illegal.
Reporting or Raising Concerns
Ethics and Compliance Concerns Helpline 888-888-3155
Employees are encouraged to talk with their supervisors openly about business ethics and compliance concerns and grievances, and confidential and anonymous resources are also available via the Ethics and Compliance Concerns Helpline. Employees, customers, contractors and vendors can reach the Helpline at 888-888-3155 or online at https://centerpointenergy.com/ethics.
For individuals who share their identity when raising a concern, we take steps to maintain confidentiality of the concernee’s identity and the information shared. We do not disclose their identity unless necessary in the course of an investigation of their concern.