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This Code of Ethics applies to the Senior Financial Officers (Chief Executive
Officer, Chief Financial Officer and Controller) of Northeast Utilities,
The Connecticut Light and Power Company, Public Service Company of New Hampshire
and Western Massachusetts Electric Company. At the Northeast Utilities System
(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 Northeast Utilities
Standards of Business Conduct, which currently applies to all Employees
of the Northeast Utilities System, 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”).
- 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.
- 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 NU’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.
- 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.
- 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, NU’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.
Effective: July 15, 2003
Exceptions from and changes to Code of Ethics since inception
None.
Last updated as of 1/13/04
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Standards of Business Conduct