Corporate Compliance and Business Conduct

Conducting our business in an honest and ethical manner is one of our corporate values. It is the right thing to do and a foundation of our success. As a result, Xcel Energy has a solid reputation for good corporate governance. Our company’s rigorous Corporate Compliance and Business Conduct (CCBC) program exists to identify and manage risks and improve the awareness of an ethical business culture; it is a cornerstone of how we do business.

Compliance and Business Conduct Governance

The Audit Committee of our board of directors is the governing authority for compliance and business conduct matters. As such, it is knowledgeable about the content, processes and operation of the program, and exercises reasonable oversight with respect to implementation and effectiveness. While the Audit Committee has overall CCBC program oversight, the Governance, Compensation & Nominating (GCN) Committee has oversight responsibilities for corporate policies. The GCN reviews proposed content changes for designated corporate policies, including the Code of Conduct, and recommends board approval as appropriate. Our chief ethics and compliance officer has overall responsibility for our CCBC program and reports directly to the CEO. The CCBC Council is made up of executives from key business areas. It monitors the effectiveness of specific compliance programs and business conduct issues.

Code of Conduct

Our employees make decisions every day that impact other employees, customers, the community, shareholders, business partners and government decision makers. The Code of Conduct provides employees with the knowledge they need to make sound business decisions that meet or exceed our ethical and legal standards. For example, we abide by anti-corruption laws, including the Foreign Corrupt Practices Act, which is a topic in our Code of Conduct.

Communications and Training

Regular, consistent communication to employees about company values, the Code of Conduct, other policies and training requirements is a high priority at Xcel Energy. We use a variety of techniques to reach employees who have regular computer access and those who do not.

Code of Conduct training is one component of our annual CCBC training plan. Code of Conduct training is required within 30 days of being hired and annually thereafter. Courses are identified for the annual training plan based on policies, regulations, key issues and our three-year rotating training cycle. The goal is 100 percent training completion by due dates. Employees are responsible for knowing and following not only our Code of Conduct, but all corporate policies and applicable laws and regulations.

Investigations and Resolving Conflicts

We encourage employees to discuss issues with their leaders. Numerous other reporting options also are available, including Xcel Energy’s new enterprise investigations system, EthicsPoint. The system will be used by all areas that have responsibility for tracking, monitoring and reporting activities related to investigations for allegations of wrongdoing. EthicsPoint provides an enhanced web tool for reporting allegations, the ability for employees to ask questions about company policies, and improved data analytics for identifying patterns and trends. Anonymous reports are accepted. Every issue reported is investigated, and as necessary, appropriate responsive action is taken. Actions can range from communicating key messages to discipline to termination. The company strictly prohibits any retaliation against an employee who, in good faith, reports a violation or suspected violation of the Code of Conduct or company policy.

Performance and Trends

Employees are invited annually to respond to five specific statements regarding the effectiveness of our CCBC program. Favorable results have been reported for the last eight years. These results demonstrate that a culture of compliance and ethics is embraced at Xcel Energy.

2014 Corporate Compliance and Business Conduct Employee Survey Results
I know what is expected of me 100%
I believe I would be protected from retaliation 94%
My manager would never ask me to do something unethical 98%
I am familiar with the company’s vision, mission and values 100%
Company leaders use our vision, mission and values to guide the company 90%

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