About the Ethics Help Line and the EthicsPoint system
Reporting – General
Reporting Security & Confidentiality
Tips & Best Practices

About the Ethics Help Line and the EthicsPoint system

What is the Exelon Help Line and the EthicsPoint system?

The Exelon Help Line is tool for reporting potential violations of the Exelon Code of Business Conduct (“Code”) and other issues and concerns. The Help Line can be accessed via the Internet or the telephone with the option to report anonymously. EthicsPoint is the software platform created by our partner NAVEX and used by Exelon to support the Exelon Help Line. It is a comprehensive and confidential reporting tool that allows us to effectively investigate and address workplace misconduct including, fraud, abuse, harassment and other misconduct in the workplace, while promoting an ethical culture and positive work environment.

Why do we need an Ethics Help Line system?

  • While employees are encouraged to report ethics concerns to their leadership that is not always comfortable or practical. Having multiple options for reporting increases the likelihood that concerns will be raised and properly investigated. The Ethics Help Line and web portal are available 24 hours a day, every day of the year. Both have an anonymous reporting option.
  • Publicly traded companies are required by law to provide a method for the anonymous reporting of potential accounting and auditing fraud. Like many companies, Exelon uses the EthicsPoint system to both meet and go beyond the requirements of the law. The Exelon Ethics Office uses the system to track all potential violations of the Code.
  • An effective, centralized reporting and investigation tracking system for potential misconduct is an essential element to assuring a culture of integrity and accountability.

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Reporting – General

How do I report a concern?

You may use the EthicsPoint system to access the Exelon Help Line via the Internet or the telephone, whichever is easier or more comfortable for you. Either way, you will have the option to make your report anonymously.

What type of things should I report?

Ethics issues are most easily defined as potential violations of the Exelon Code of Business Conduct (“Code”). You should report any behavior you think is inconsistent with the Code (which includes violations of the law and other Exelon policies).

If I see a potential violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

Ideally, concerns should be reported to your direct manager, or another member of your leadership team but, as noted above, that is not always comfortable or practical. Having multiple options for reporting increases the likelihood that concerns will be raised and properly investigated. The Ethics Help Line and web portal are available 24 hours a day, every day of the year. Both have an anonymous reporting option. We would rather concerns be reported anonymously than not reported at all.

It’s OK if you don’t have all the details. Provide as much information as you can. No matter how a concern is shared, Exelon takes each report seriously.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?

Absolutely. In fact, we need you to report. Employees and other stakeholders know what is going on in our company - both good and bad. Reporting concerns as soon as they arise can minimize the potential negative impact on the company and our employees and give us a chance to fix what’s broken- whether that’s someone’s behavior or an ineffective process or control.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. The reports are provided directly to Exelon Ethics Office personnel who evaluate each concern and share with the personnel necessary to investigate and address the concerns.

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Reporting Security & Confidentiality

Won’t my company computer generate a record that might identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

Exelon is also committed to NOT pursuing the identity of a reporter who chooses to be anonymous. We may, however, encourage reporters to consider identifying themselves if we think that may increase the effectiveness of the investigation or if we are have safety or security concerns.

If you feel uncomfortable making a report on your work device, you have the option of using a computer or other device outside our work environment (at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, or any other Internet portal will also remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I am still concerned the information I provide will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint and Help Line system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “As the longest serving person in my department…”.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. The interviewer does not work for Exelon and merely puts the information into the system. Reports taken over the phone have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish. If your report involves concerns specific to you or information that only you know or can verify, you may want to consider identifying yourself to assure the matter can be fully investigated.

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Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Exelon chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.

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