Corporate Ethics & Compliance Program
Code of Ethics for Senior Financial Officers
The Chief Executive Officer, Chief Financial Officer, Chief Accounting Officer, and Vice President Finance and Treasurer (together the "Senior Financial Officers") of Puget Energy, Inc. and Puget Sound Energy, Inc. (together the "Company") hold important and elevated roles in corporate governance in that they are uniquely capable and empowered to ensure that all stakeholders' interests are appropriately balanced, protected, and preserved. This Code of Ethics for Senior Financial Officers ("Code of Ethics") provides specific principles these officers are expected to follow and promote.
Principles Governing Professional and
Ethical Conduct
Financial Reporting and Disclosure
Reporting of Violations
Treatment and Consequences of
Violations
Waivers of the Code
Principles Governing Professional and Ethical Conduct
It is the policy of the Company that its Senior Financial Officers will adhere to, advocate for, and promote the following principles governing professional and ethical conduct:
- Honesty and integrity, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the Securities and Exchange Commission ("SEC") and in other public communications made by the Company;
Compliance with laws of federal, state and local governments applicable to the Company, and the rules and regulations of other appropriate private and public regulatory agencies having jurisdiction over the Company; - The prompt internal reporting of violations of the Company's Corporate Ethics and Compliance Code ("Code") to an appropriate person or persons identified in the Code; and
- Accountability for adherence to the Code.
This Code of Ethics supplements the Company's Corporate Ethics and Compliance Code. The Senior Financial Officers are expected to abide by the Code of Ethics, the Code, and all other applicable Company policies and guidelines. All Senior Financial Officers of the Company annually shall certify in writing their compliance with the Code of Ethics.
Financial Reporting and Disclosure Senior Financial Officers shall seek to promote fair, accurate, timely, and understandable disclosure in the reports and documents the Company files with or submits to the SEC. The Company seeks to provide disclosure to the investment community that is not only in conformity with applicable rules of the SEC, but that also fairly presents to the investors the financial condition and results of operations of the Company. Senior Financial Officers shall seek to promote ethical behavior by other Company officers and employees involved in financial reporting.
Reporting of Violations Any employee of the Company who becomes aware of any suspected or known violations of the Code of Ethics or who has concerns regarding questionable accounting or auditing matters involving the Company or a Senior Financial Officer should report such suspected violations promptly either to the General Counsel, Chair of the Audit Committee of the Board of Directors, or the Company's toll-free help line. To assist in the response to or investigation of the alleged violation, the report should contain as much specific information as possible to allow for proper assessment of the nature, extent, and urgency of the alleged violation. Callers to the toll-free help line have the option of remaining anonymous.
Additionally, matters involving allegations of wrongdoing relating to accounting and auditing issues will be reported to the General Counsel and the Chair of the Audit Committee, with notice to the Corporate Ethics and Compliance Officer. An investigation will then be conducted under the direction of the General Counsel and the Chair of the Audit Committee
Treatment and Consequences of Violations
The Audit Committee, or appropriate persons designated by the Audit Committee, shall have the power to monitor, investigate, make determinations, and recommend action to the Board of Directors with respect to violations of this Code of Ethics. Any violation of this Code of Ethics may result in disciplinary action including, but not limited to, the following:
- Disciplinary action (up to and including suspension or termination of employment);
- Pursuit of any and all remedies available to the Company for any damages or harm resulting to the Company from a violation, including injunctive relief; and
- Referral of matters to appropriate legal or regulatory authorities for investigation and prosecution.
Waivers of the Code
Only the Company's Audit Committee of the Board of Directors is authorized to provide waivers to this Code of Ethics in appropriate circumstances with advice, if requested, from the Corporate Ethics and Compliance Committee. The Audit Committee will not grant waivers except under extraordinary circumstances. Any waivers that are granted shall be publicly disclosed on a timely basis. In addition, any changes to this Code of Ethics shall be publicly disclosed on a timely basis.
The undersigned have read the foregoing and certify their
compliance with this Code of Ethics.
Don Gaines
Vice President
Finance & Treasurer
Jim Eldredge
Corporate Secretary &
Chief Accounting Officer
Bert Valdman
Senior Vice President
Finance & Chief Financial Officer
January 6, 2004