Code of Ethics for Senior Financial Officers
This Code of Ethics applies to the Senior Financial Officers (Chief Executive Officer, Chief Financial Officer and Controller) of Eversource, The Connecticut Light and Power Company, Public Service Company of New Hampshire and Western Massachusetts Electric Company.
At Eversource (the “Company”), we comply with both the letter and spirit of the law and take very seriously our commitment and obligation to the people our business touches.
Demonstrating care and respect for others, doing the right thing in all cases, acting openly and honestly — this is all at the heart of a work environment that’s welcoming, supportive and productive for all of us. It is also reflected outside our offices and facilities as we serve the public. The purpose of this Code of Ethics for Senior Financial Officers (the “Code”) is to reinforce the Eversource Standards of Business Conduct, which currently applies to all Employees of Eversource, including the Senior Financial Officers.
This Code is further intended to promote the highest ethical conduct, and the compliance with all law and regulations, particularly as they relate to the maintenance of the Company’s financial records and the preparation of statements filed with the Securities and Exchange Commission (the “SEC”).
1. Senior Financial Officers are expected to comply with both the letter and spirit of laws and regulations governing our business. In conducting Company business with federal, state and local government officials or government and regulatory agencies, Senior Financial Officers shall exercise good judgment and the utmost integrity at all times. This includes:
- providing responsive and forthright disclosure of information pursuant to regulatory proceedings and reporting requirements;
- ensuring that all responses to inquiries from government agencies are timely, accurate and complete; and
- representing yourself and the Company with honesty and integrity when called to testify before government agencies.
In addition, Senior Financial Officers are responsible for maintaining internal controls and procedures to assure that financial information is correct, complete, accurate and properly recorded.
Senior Financial Officers shall review every periodic report for accuracy and completeness prior to its filing with the SEC and its release to the public, with a view to promoting full, fair, accurate, timely and understandable disclosure in reports filed with the SEC and other public communications.
Senior Financial Officers shall promptly report to their immediate supervisor, and where appropriate to the internal auditor, General Counsel, Audit Committee, Board of Trustees or Independent Auditor, any concerns regarding the accuracy and completeness of any periodic reports or material weaknesses in the Company’s disclosure or internal controls or any violations of this Code.
Senior Financial Officers shall be held accountable for adherence to this Code.
2. The position as a Senior Financial Officer in the Company may never be used to improperly benefit oneself, family or friends. Specific activities that may be considered conflicts of interest include, but are not limited to:
- directly or indirectly acquiring or retaining a significant financial interest in an organization that is Eversource's customer, vendor, or competitor, or that seeks to do business with the Company;
- serving, without proper safeguards, as an officer or director of, or working or rendering services for, a customer, vendor, competitor or other organization that seeks to do business with the Company;
- requesting or accepting gifts, gratuities or invitations if they are, or could reasonably be perceived to be, intended to influence a business decision or create a feeling of obligation;
- accepting loans on behalf of yourself or family members from any individual or organization which the Company does business with, or that seeks to do business with the Company, unless the loan is from a financial institution at normal rates prevailing at the time of the loan;
- offering anything of more than nominal value, including Company property or equipment, loans, contributions or unpaid services to a representative of another company, member of the public, or governmental official or agency, without prior authorization from a Company officer;
- offering or receiving, directly or indirectly, any payment in the nature of a bribe or kickback; or
- making illegal political contributions on behalf of the Company.
3. Waivers and Amendments to this Code of Ethics for Senior Financial Officers may only be approved by the Board of Trustees. Any such Waivers and Amendments shall promptly be disclosed pursuant to law.
4. Senior Financial Officers are responsible for obeying all laws with respect to insider trading until material non-public information about the Company, or any other company, is publicly released and enough time has passed for the stock market to evaluate it, Eversource's policy requires you to:
- refrain from disclosing such information to anyone who does not have a clear need-to-know;
- abstain from buying, selling or trading securities or from making buy or sell recommendations to anyone while in possession of such information;
- refrain from engaging in on-line “chat room” discussions concerning such information; and
- refrain from taking any other action that would result in personal gain for you or others from such information.
Exceptions from and changes to Code of Ethics since inception: