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2013 ETHICS AND COMPLIANCE INVESTIGATIONS 62


Launched 57 Closed


61% – Substantiated claims 39% – Unsubstantiated claims


Enterprise risk management


PGE regularly evaluates risks that may keep us from reaching our business objectives. Ethics and compliance and internal audit are two key functions that help drive our strong commitment to risk management.


ETHICS AND COMPLIANCE Affirming who we are Our Code of Business Ethics and Conduct builds on our Core Principles and Guiding Behaviors to expand on our expectations for employees and board members.


Every two years, employees take training and affirm their commitment to the code, which covers items such as: • Fairness in the workplace • Safety and health • Conflicts of interest • Business entertainment and gifts • Compliance with laws and regulations • Protection/use of company assets • Confidential information • Company communications


In 2012, 100 percent of active employees affirmed our Code of Business Ethics and Conduct. We are currently completing employee affirmations for 2014. New employees are trained and affirm their commitment to the code when they are hired. We also have a specific Code of Ethics for Chief Executive and Senior Financial Officers.


Employees are expected to conform to additional policies, procedures and guidelines that help them work honestly, ethically and in compliance with applicable laws and regulations. They also have options for reporting ethical or compliance concerns, including an anonymous, confidential hotline.


Corporate oversight


Several committees oversee PGE’s Ethics and Compliance program: • Board of Directors Audit Committee: Oversees PGE’s compliance with legal and regulatory requirements and PGE’s Code of Business Ethics and Conduct.


• Controls Committee: Senior PGE officers report relevant activity to the Board of Directors Audit Committee once a quarter.


• Corporate Compliance Committee: Comprised of managers from across PGE, this committee assists executive leadership and the Controls Committee in overseeing PGE’s business conduct related to ethics and compliance issues.


INTERNAL AUDIT Our Internal Auditing Services function provides objective feedback that helps us improve operations and evaluate the effectiveness of our risk management, governance processes and adherence to internal policies and guidelines.


To ensure this function is independent, its director reports to the chair of the Audit Committee of the PGE Board of Directors with day-to-day reporting to the general counsel while also maintaining a direct relationship with Jim Piro, our president and CEO.


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