CenterPoint Energy’s core values provide the foundation for our business practices and standards. We work consistently to develop and enhance a culture based on our values and policies:
- Ethics and Compliance Code
- Code of Ethics for our Chief Executive Officer and Senior Financial Officers
- Ethics and Compliance Code of Conduct for Consultants, Contractors, Suppliers and Vendors
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 the Policy section of our intranet site.
We 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.

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 with responsibility for the company’s Ethics and Compliance program, including initiatives related to anti-bribery and anti-corruption. She is supported in these efforts by our Senior Vice President, Deputy General Counsel and Chief Ethics and Compliance Officer and the other members of the Ethics and Compliance Department.
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.
Training and Engagement
Our officers and employees complete annual ethics and compliance training, which includes anti-corruption and anti-trust topics, among other subjects, and acknowledge their responsibility to comply with the Ethics and Compliance Code. All active employees received Ethics and Compliance training in 2023.
We conduct periodic culture surveys in support of our ethical and compliant culture. The Ethics and Compliance department holds in-person roundtable sessions to hear directly from employees and share ethics and compliance information. The feedback from these sessions helps to drive continuous and risk-based development of the Ethics and Compliance program.
Audits and Risk Assessments
CenterPoint Energy regularly engages outside experts to perform an external assessment of its Ethics and Compliance department and program. Our metrics are benchmarked against Department of Justice guidelines, as well as with other utilities and industries, to help us to remain vigilant on trends and best practices. We participate in various organizations and events as part of our efforts to keep our program current.
The Ethics and Compliance department reviews third parties and organizations for reputational and compliance risks to identify those that have been placed on government watch lists or have a public history of compliance issues and otherwise. In cases where verified 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 Enterprise Risk Management department conducts regular corporate, business unit and project risk assessments.

Safety
We Provide a Safe and Healthy Work Environment

Integrity
We Act with Integrity and Lead by Example

Accountability
We Protect Company Assets and Preserve Resources

Initiative
We Honor Our Community and Make a Difference

Respect
We Value Everyone

Anti-Bribery and Anti-Corruption
Our Ethics and Compliance Code addresses our expectations of employees about anti-bribery and anti-corruption risks, which are covered in our required annual training.
Our Ethics and Compliance Code of Conduct for Consultants, Contractors, Suppliers and Vendors addresses expectations of our vendors about these risks, and our Vendor Risk Management Program includes a review of bribery and corruption risks presented by our suppliers. 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.
We have 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.
CenterPoint Energy does not allow, offer, give or accept gifts or entertainment where such exchange could potentially create a conflict of interest.
Reporting or Raising Concerns
Employees are encouraged to speak up and talk with their supervisors about perceived ethical issues or suspected or known violations of the law or policies. Concerns about business ethics and compliance and grievances may be raised to a direct supervisor or manager, confidentially or anonymously through the Ethics and Compliance Concerns Helpline, the Ethics and Compliance Department or any other member of management.
Employees, customers, contractors and vendors can reach the Helpline at 888-888-3155 or online at https://centerpointenergy.com/ethics, 24-hours-a-day, seven-days-a-week.
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. We refer to reports of potential Ethics and Compliance Code violations or other misconduct as “concerns” and those who report them as “concernees.” Other organizations may refer to them as whistleblowers and their reporting mechanisms as an ethics helpline.
The Ethics and Compliance Department reviews and determines how to best address each concern including, where appropriate, starting an impartial, fair and thorough investigation, or coordinating with other subject-matter experts for handling. If an investigation reveals a violation of our standards, it will be addressed accordingly.
CenterPoint Energy does not tolerate any form of retaliation or negative reaction for raising good faith concerns about violations of our Ethics and Compliance Code or any applicable laws or regulations. After an investigation concludes, Ethics and Compliance personnel follow up with the reporter to verify that no retaliation has occurred.
All concerns are tracked and processed through a system that provides us with a comprehensive analysis of reports. The Audit Committee of the Board of Directors receives quarterly reports from the Chief Ethics and Compliance Officer about concerns and investigations.