PROCEDURES TO IMPLEMENT FERC ORDER NO. 717 STANDARDS OF CONDUCT FOR
TRANSMISSION PROVIDERS DOMINION ENERGY TRANSMISSION, INC.; DOMINION
ENERGY COVE POINT LNG, LP; DOMINION ENERGY CAROLINA GAS TRANSMISSION,
LLC; DOMINION ENERGY QUESTAR PIPELINE,LLC; QUESTAR SOUTHERN TRAILS
PIPELINE COMPANY; DOMINION ENERGY OVERTHRUST PIPELINE, LLC; WHITE RIVER
HUB, LLC; AND VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY
VIRGINIA)1
I. Definitions (Capitalized terms in these Procedures have the following
meanings) Affiliate means an entity that controls or is controlled by or
is under common control (10 percent or more) with Dominion Energy, Inc,
including a division that operates as a functional unit. “Control” means
the direct or indirect authority, whether acting alone or in conjunction
with others, to direct or cause to direct the management policies of the
Affiliate. Chief Compliance Officer (CCO) means the employee identified on
the Internet Website who is responsible for managing compliance with the
Standards of Conduct. Dominion Energy’s Chief Compliance Officer is:
Carlos M. Brown, Senior Vice President and General Counsel 120 Tredegar
Street, Pump House 3rd Floor, Richmond, VA 23219, (804) 819-2690,
Carlos.M.Brown@dominionenergy.com. Dominion Energy means Dominion Energy,
Inc. and its Affiliates. Employee means employee, contractor, consultant
or agent of Dominion Energy. 1 Dominion Energy South Carolina, Inc. has
posted separate procedures to implement FERC Order No. 717, Standards of
Conduct for Transmission Providers on its OASIS. Date: April 29, 2019 Page
2 FERC or Commission means the Federal Energy Regulatory Commission or any
successor agency thereof. Internet Website means a location on
www.dominionenergy.com where a Dominion Energy Transmission Provider posts
certain information required by the Standards of Conduct. The Transmission
Provider may also use its proprietary Information System (e.g. Dekaflow,
QuestLine) or the OASIS or Electronic Bulletin Board (EBB) to post certain
information required by the Standards of Conduct. Intranet Website means a
location on Dominion Energy’s corporate data network that is accessible
only to Dominion Energy employees. Information on this network may be
available to all employees (e.g. telephone directory, Law Department –
Federal Regulation, Ethics program Intranet Websites, etc.) or may be
restricted to certain employees through software access controls.
Marketing Affiliate means Affiliates of Dominion Energy with Marketing
Function Employees, which includes: For Gas: Dominion Energy Field
Services, Inc., Dominion Energy Solutions, Inc., Hope Gas, Inc., The East
Ohio Gas Company, Dominion Energy Fuel Services, Inc., SCANA Energy
Marketing Inc., PSNC Energy, South Carolina Electric & Gas Company and
Virginia Power Services Energy (VPSE). For Electric: Dominion Energy
Generation Marketing, Inc., Dominion Energy Virginia, and Dominion Energy
South Carolina, Inc. Marketing Function: For Gas: means the sales for
resale in interstate commerce, or the submission of offers to sell in
interstate commerce, natural gas, subject to the following exclusions: 1)
bundled retail sales; 2) incidental purchases or sales to operate
interstate natural gas pipeline transmission facilities; 3) sales of
natural gas solely from a seller’s own production; 4) sales of natural gas
solely from a seller’s own gathering or processing facilities; or 5)
onsystem sales by an intrastate natural gas pipeline, by a Hinshaw
interstate pipeline exempt from the Natural Gas Act, by a local
distribution company, or by a local distribution company operating under
7(f) of the Natural Gas Act. For Electric: means the sales for resale in
interstate commerce, or the submission of offers to sell in interstate
commerce, of electric energy or capacity, demand response, virtual
transactions, or financial or physical transmission rights, all subject to
an exclusion for bundled retail sales, including sales of electric energy
made by providers of last resort (POLRs) acting in their POLR capacity.
Marketing Function Employee (MFE) means an employee, contractor,
consultant or agent of Dominion Energy who actively and personally engages
on a day-to-day basis in marketing functions. Date: April 29, 2019 Page 3
Procedures means these Procedures designed to Implement FERC Order No.
717, Standards of Conduct for Transmission Providers pursuant to 18 C.F.R.
Section 358.7(d). Services Company means Dominion Energy Services, Inc.
Standards of Conduct means the rules governing the relationship between
TFEs and MFEs as established by FERC in Order No. 717, Standards of
Conduct for Transmission Providers. Transmission For Gas: means natural
gas transportation, storage, exchange, backhaul, or displacement service
provided pursuant to subparts B or G of Part 284 of FERC’s regulations.
For Electric: means electric transmission, network or point-to-point
service, ancillary services or other methods of electric transmission, or
the interconnection with jurisdictional transmission facilities pursuant
to Part 35 of FERC’s regulations. Transmission Customer means any eligible
customer, shipper or designated agent that (1) can or does execute a
transmission service agreement or (2) can or does receive transmission
service, including persons with pending requests for transmission service
or information regarding transmission. Transmission Functions means the
planning, directing, organizing or carrying out of day-to-day transmission
operations, including the granting and denying of transmission service
requests. Directed at short-term real time operations, including decisions
made in advance of real time that are directed at real time operations.
Transmission Functions do not include long-range planning. Transmission
Function Employee (TFE) means an employee, contractor, consultant or agent
of a transmission provider who actively and personally engages on a
day-to-day basis in Transmission Functions. The Internet Website will
identify the job titles and job descriptions of TFEs. Examples of TFEs
include employees in the following areas: Gas Control or System Operations
Centers, System Optimization, Pipeline Operations, Transportation and
Customer Services, and Interstate Marketing. Generally, employees in the
following areas are NOT TFEs (unless they are involved in day-to-day
operations): Field, Maintenance and Construction, Engineers, Technical
Support Staff, Human Resources, Information Technology, Storage Engineers,
Pipeline Safety, Measurement, Business Development, Attorneys,
Accountants, Risk Management, Regulatory Personnel, Rate Design, Strategic
Planning, Clerical. Transmission Function Information means information
relating to Transmission Functions, as defined above, that is not Date:
April 29, 2019 Page 4 otherwise also available to the general public
without restriction, all users of E-SCRIPT or the Internet Website, as
applicable. This can include, but is not limited to, past, present and
future information about: transmission maintenance schedules, transmission
customer information, curtailments of transmission service, available
transmission capacity, including storage, transmission service requests
and request status, transmission service pricing offers, transmission
outages, expansion plans and schedules, Cove Point LNG ship schedules,
transmission line outage information and transmission loading relief
information. Transmission Provider means Dominion Energy Transmission,
Inc., Dominion Energy Cove Point, LNG, LP Dominion Energy Carolina Gas
Transmission, LLC, Dominion Energy Questar Pipeline, LLC, Questar Southern
Trails Pipeline Company, MountainWest Overthrust Pipeline, White River
Hub, LLC, Dominion Energy Virginia, and Dominion Energy South Carolina,
Inc. II. Applicability These Procedures implement the Standards of Conduct
and apply to the relationship and communications between TFEs including
employees with Transmission Function Information and MFEs. All TFEs, MFEs,
and all other employees, including senior management and supervisory
personnel, are responsible for adhering to these Procedures.2 III. General
Principles of the Standards of Conduct The general principles of the
Standards of Conduct are as follows: A. A Transmission Provider must treat
all customers on a not unduly discriminatory basis, and must not grant
undue preferences, especially to its Affiliates; B. A Transmission
Provider’s TFEs must function independently from its Affiliate MFEs; C. A
Transmission Provider must not disclose or use a conduit to disclose
non-public Transmission Function Information to its Affiliate MFEs; and D.
A Transmission Provider must provide equal access to non-public
Transmission Function Information to all its customers, except in the case
of confidential customer information or Critical Energy Infrastructure
Information (CEII). 2 There are six (6) other Codes/Standards of Conduct
that are applicable to Dominion Energy Affiliates, including the FERC Code
of Conduct (Affiliate Restrictions), the Virginia Commission Electric
Retail Access Codes of Conduct, the Virginia Commission Electric
Functional Separation Code of Conduct, the North Carolina Commission Code
of Conduct, the Ohio Commission Gas LDC Standards of Conduct, and the
South Carolina Commission Code of Conduct. These Procedures are compatible
with these other Codes/Standards, but do not address those requirements.
For further detail on these other Codes/Standards, Dominion Energy
employees may consult the Law Department’s Intranet Website. Also,
additional information relating to Dominion Energy’s general corporate
compliance program is available on the Dominion Energy Ethics Program
Intranet site. Date: April 29, 2019 Page 5 IV. General Rules &
Requirements of the Standards of Conduct The general rules and
requirements of the Standards of Conduct include the following: A.
Non-Discrimination Requirements (See Section V below) B. Independent
Functioning Rule (See Section VI below) C. No-Conduit Rule (See Section
VII below) D. Transparency Rule (See Section VIII and XI below) V.
Non-Discrimination Requirements The Transmission Provider must treat all
Transmission Customers, whether affiliated or not, on a not unduly
discriminatory basis, and must not operate its Transmission system to give
preferential benefits to its Marketing Affiliates. This requirement shall
be implemented pursuant to the following standards: A. The Transmission
Provider will strictly enforce all tariff provisions relating to the sale
or purchase of open access transmission service, if these tariff
provisions do not permit the use of discretion. B. The Transmission
Provider will apply all tariff provisions relating to the sale or purchase
of open transmission service in a fair and impartial manner that treats
all Transmission Customers in a non-discriminatory manner, if the tariff
provisions permit the use of discretion. C. The Transmission Provider may
not, through its tariff or otherwise, give undue preference to any person
in matters relating to the sale or purchase of transmission service
(included issues of price, curtailment, scheduling, priority, ancillary
services or balancing). 1. Tariff Waivers – To the extent the Transmission
Provider waives a tariff provision in favor of an Affiliate; it must be
posted on its Internet Website. The Transmission Provider must also
maintain a log of such waivers which must be retained for five years.
“Exercises of discretion” that are allowed in the Transmission Provider’s
tariff, or which have been approved by the Commission, do NOT have to be
posted or recorded in the waiver log. D. The Transmission Provider will
process all similar requests for transmission service in the same manner
and within the same period of time. VI. Independent Functioning Rule A.
GENERAL RULE: TFEs must function independently of any MFEs, which means
they shall not perform any Marketing Functions or perform any work for any
MFE, Date: April 29, 2019 Page 6 except as noted below. B. GENERAL RULE:
MFEs will not conduct Transmission Functions for the Transmission
Provider. C. Facilities: 1. If TFEs work in the same building as MFEs, the
TFE’s work space shall be physically separated and restricted to the
maximum extent practical from MFEs. Shared facilities that staff both TFEs
and MFEs are listed on the Internet Website. 2. MFEs will not have access
to the Transmission Provider’s Gas Control or System Operations Centers,
or any similar Transmission Provider facilities used for day-to-day
transmission operations or reliability functions that differs in any way
from the access available to other Transmission Customers. Access to these
facilities will be restricted by cardkey or other appropriate means on a
24- hour basis. 3. MFEs will not have access to the Transmission
Provider’s commercial function and system operations area that differs in
any way from the access available to other Transmission Customers. Access
to these facilities will be restricted by cardkey or other appropriate
means on a 24-hour basis. MFEs may have access to these areas upon
appropriate registration/sign-in and will be escorted throughout the
visit. a. CardKey Access (i) An automated “Employee Transfer/Termination
Notification” program will alert Cardkey administrators to revoke
applicable facility access from employees that have been transferred or
terminated from a TFE position. (ii) Dominion Energy’s Corporate Security
or other appropriate personnel will review cardkey access lists to ensure
their accuracy. 4. Emergency Exception In emergency circumstances
affecting system reliability, the Transmission Provider may take whatever
steps necessary to keep or restore system operation, including exchanging
non-public Transmission Function Information between TFEs and MFEs
necessary to maintain or restore operation of the transmission system or
generating units, or that may affect the dispatch of generating units.
Record of Communication – Record must be made as soon as practicable.
Please refer to Section VII.D.1 for further details. 5. Reliability
Standards Exception Date: April 29, 2019 Page 7 In order to maintain
compliance with the Reliability Standards approved by the FERC, the
Transmission Provider may exchange certain non-public Transmission
Function Information between TFEs and MFEs. Record of Communication –
Contemporaneous record must be made of the exchange. Please refer to
Section VII.D.1 for further details. VII. No Conduit Rule A. GENERAL RULE:
The Transmission Provider is prohibited from using anyone as a conduit for
the disclosure of non-public Transmission Function Information to its
MFEs. B. GENERAL RULE: Transmission Provider employees, contractors,
consultants or agents AND employees, contractors, consultants, or agents
of an Affiliate with MFEs are prohibited from disclosing non-public
Transmission Function Information to MFEs. VIII. Information Exchanges A.
Posting of Prohibited Disclosures: 1. Non-Public Transmission Information
– The Transmission Provider must immediately post non-public Transmission
Function Information on the Internet Website if the Transmission Provider
inadvertently discloses such information to an MFE. 2. Non-Public
Transmission Customer Information and CEII – The Transmission Provider
must immediately post notice on the Internet Website that the Customer
Information or CEII information has been disclosed. 3. Exceptions to
Posting: a. Customer Voluntary Consent - If a non-affiliated transmission
customer consents in writing to allow the Transmission Provider to share
its customer information with an MFE, the Transmission Provider may share
such information. The Transmission Provider will post notice on the
Internet Website (EBB) of the consent along with a statement that it “did
not provide any preferences, either operational or rate-related, in
exchange for the voluntary consent.” b. Specific Requests Relating to
Transmission Provider Service - The Transmission Provider is not required
to disclose on the Internet Website information regarding a Marketing
Affiliate’s specific request for transmission service (i.e. confirmations,
nominations, schedules with upstream producers, Date: April 29, 2019 Page
8 interconnecting pipelines), including discussions with the Marketing
Affiliate with respect to the Marketing Affiliate’s participation in
capacity expansion or new development projects. This exception does not
apply to outages or other system conditions. The Law Department- Federal
Regulation recommends that a record of the meeting or communication be
made and retained as best practice. See Section VII.D.1.b. (ii) for
further details. c. Emergencies - The Transmission Provider may share
non-public Transmission Function Information between TFEs and MFEs to
maintain or restore operation of the transmission system or generating
units. A record of any such meetings or communications under this
exception must be maintained. See Section VII.D.1.b.(i) for further
details. d. Reliability Standards Compliance – The Transmission Provider
may share non-public Transmission Function Information between TFEs and
MFEs pertaining to compliance with NERC or other Reliability Standards
approved by FERC. A record of any such meetings or communications under
this exception must be maintained. See Section VII.D.1.b.(i) for further
details. B. Communications Between TFEs and MFEs: 1. GENERAL RULE: Order
No. 717 and its regulations permit joint meetings between TFEs and MFEs as
long as non-public transmission function information is not shared and the
meetings do not relate to transmission or marketing functions. A joint
meeting includes, but is not limited to, face-to-face meetings, telephone
and conference calls. a. Permitted Meetings or Communications Requiring
Recordation between TFEs and MFEs where non-public Transmission Function
Information is shared include the following limited situations (record of
meeting or communication must be made and retained): (i) the topic of the
meeting is in response to an emergency concern that requires information
sharing in order to maintain or restore operation of the transmission
system or generating units; or (ii) the topic of the meeting is to share
non-public transmission information pertaining to compliance with FERC
approved Reliability Standards. See Section VII.D.1.b. (i) for further
details on required recordation. b. Record of Joint Meetings between TFEs
and MFEs (i) Required Recordation - For exchanges between TFEs and MFEs
that are permissible under Section VII.D.1.a, a contemporaneous record
must be made and maintained for a period of five years. The record may
consist of hand-written or typed notes, electronic records such as e-mails
and text messages, recorded telephone exchanges, and the like; however,
the Date: April 29, 2019 Page 9 record must be retrievable. In an
emergency when a contemporaneous record cannot be made, the record must be
made as soon as practicable after the fact. (ii) Recommended Recordation –
For exchanges between TFEs and MFEs that are permissible and where
non-public Transmission Function Information is not disclosed, the Law
Department recommends a contemporaneous record be made and maintained for
a period of five years as best practice.3 The record may consist of
hand-written or typed notes, electronic records such as e-mails and text
messages, recorded telephone exchanges, and the like. (iii) The Law
Department recommends that Employees follow the Joint Meeting Procedures
and Checklists which are available on the Law Department Intranet Website
as best practice for both required and recommended recordation of a
meeting or communication between TFEs and MFEs. (iv) Employees attending
the joint meeting must be reminded to comply with the restrictions on the
exchange of Transmission Function Information beyond what is allowed by
the rules and regulations of FERC. Further, the joint meeting should only
be held if the topic of the meeting is one of the topics permissible as
identified in the Joint Meeting Procedures and Checklists. If it is
unclear whether the topic is permissible, seek clearance from the Law
Department - Federal Regulation. C. Information Access “Best Practices”:
1. To implement the no-conduit requirement, the following “best practices”
procedures should be followed by the Transmission Provider to ensure
proper access to non-public transmission information: a. The Transmission
Provider should use the Internet Website to publicly disseminate to
transmission customers, including its Marketing Affiliates, information
required to be posted pursuant to the Standards of Conduct or other
Commission regulations. All postings shall comply, if applicable, with the
requirements of Part 284 of FERC’s regulations. b. Dominion Energy’s IT
department has erected and maintains appropriate password requirements,
firewalls, and other security measures for all Transmission Provider’s
information systems. The IT department should 3 The Law Department has
prepared Joint Meeting Procedures and Checklists that are recommended for
all Dominion Energy Employees to use. The Joint Meeting Procedures and
Checklists provide a list of permissible exchanges between TFEs and MFEs.
Intranet Website link to Gas Joint Meeting & Checklist and Electric Joint
Meeting & Checklist . Date: April 29, 2019 Page 10 conduct a periodic
review of passwords, firewalls, and other security measures to ensure that
the integrity of the information systems is maintained. Such measures
include: (i) Transmission Function Information that is accessible via
Dominion Energy’s Intranet Website shall be protected from access by MFEs.
The IT department will ensure that the appropriate MFEs do not have access
to Transmission Function Information on Dominion Energy’s Intranet
Website. (ii) Transmission Function Information accessible via Dominion
Energy’s computer systems shall be protected from access by MFEs. MFEs are
identified with an “M” after their name in the telephone directory and
email. TFEs are identified with a “T” after their name in the telephone
directory and e-mail. (iii) An automated program monitors employee
terminations and transfers daily and sends a notification to the CCO (or
its designee) or applicable system administrators when a qualifying event
occurs. When applicable, the CCO (or its designee) will adjust access to
all affected computer systems, physical facilities and employee e-mail
addresses to prevent inclusion on prior distribution lists. IX. Additional
Employee Responsibilities A. General: 1. All Dominion Energy employees are
individually responsible for strict compliance with Standards of Conduct
and these Procedures. Dominion Energy does not condone or tolerate
violations of the Standards of Conduct. Employees who fail to comply with
these Standards of Conducts may be subject to disciplinary actions up to,
and including, termination. In addition to the requirements set forth in
these Procedures, all employees are asked when appropriate to consider the
safeguards described below. 2. Prior to sharing Transmission Function
Information with any Dominion Energy Employee outside of the Transmission
Provider organization, employees should check to see whether the recipient
is allowed to receive the Transmission Function Information under
Standards of Conduct. If you are unsure about whether the information is
Transmission Function Information, or whether the requestor is an MFE,
consult the Company Directory, ask your supervisor or contact the Law
Department - Federal Regulation. 3. Employees should clearly mark all
e-mails, documents or other communications that contain Transmission
Function Information with the following header or another substantially
similar message: “This communication contains FERC Date: April 29, 2019
Page 11 Order 717 Transmission Function Information that must be kept
confidential. DO NOT copy or forward to any Marketing Function Employee
without express clearance from Dominion Energy’s Law Department.” 4. When
possible, Employees should protect Transmission Function Information that
is sent via an electronic method with passwords or
non-copying/nonforwarding features enabled. Employees are encouraged to
use the Code of Conduct Classification Tool within the Company’s
electronic mail application. This functionality enables users to easily
classify messages that contain sensitive content, such as Transmission
Function Information. Once the sender marks a message as sensitive and the
message is sent, the mail system validates each recipient prior to
delivery to prevent any violation. This tool is available to all Dominion
Energy Employees. Employees can find more information on this tool on the
FERC Policy and Compliance SharePoint site on Dominion Energy’s Intranet
Website. 5. All Employees also must strictly comply with the “No Conduit”
rule. The “No Conduit” rule means that although certain employees may have
access to Transmission Function Information, they may never be a “conduit”
or pass this Transmission Function Information to MFEs. In particular,
employees of Marketing Affiliates who are not considered MFEs must be
diligent not to pass any Transmission Function Information to MFEs. Also,
employees who provide a corporate service function for both the
Transmission Provider and Marketing Affiliates should not pass
Transmission Function Information to any MFE. 6. In summary, Employees
should abide by the following requirements: Know the extent of access
you have to Transmission Function Information. Never act as a “conduit”
by providing this information to an MFE. If you are uncertain about
whether the information is Transmission Function Information, or whether
the requestor is an MFE, consult the Company Directory, ask your
supervisor, or the Law Department - Federal Regulation. Make sure
Transmission Function Information received from the Transmission Provider
is clearly marked as such to prevent inadvertent sharing of information.
Err on the side of caution by playing it safe and sharing Transmission
Function Information only with employees who are clearly TFEs. B.
Marketing Function Employees: 1. MFEs must be aware of the information
restrictions and the Independent Functioning Rules that apply between TFEs
and MFEs. Generally, MFEs may not have access to Transmission Function
Information unless it is obtained via a public source (e.g., the Internet
Website). Also, MFEs must operate separately Date: April 29, 2019 Page 12
from the TFEs. 2. In practice, MFEs should abide by the following
requirements: Do not gain or attempt to gain access to Transmission
facilities, including computer systems, or Transmission Function
Information by any means. If you have access to Transmission facilities or
Transmission Function Information or if you feel you have received access
inappropriately, do not review the information and report the incident
immediately to your supervisor, or the Law Department - Federal
Regulation. If Transmission Function Information is obtained
inadvertently or otherwise in violation of the Standards of Conduct or
these Procedures, do not use the information in any capacity and report
the incident immediately to your supervisor, or the Law Department -
Federal Regulation. X. Chief Compliance Officer (CCO) Responsibilities. A.
Duties of the CCO (or its designee) include: 1. Identify and maintain a
list of employees that must receive Standards of Conduct training. Ensure
that all affected employees receive the necessary training on an annual
basis. 2. Provide guidance on the FERC Standards of Conduct to all
affected employees. 3. Monitor employee transfers between various Dominion
Energy companies and departments. Ensure that appropriate actions are
taken for employees that transfer into or out of the Transmission Provider
organization and change from TFEs to MFEs, and vice versa. Actions include
necessary postings on Internet Website and restrictions to facilities,
including any computer systems. 4. Ensure proper documentation of
Standards of Conduct issues and matters. Ensure that documentation is
retained for requisite statutory period. 5. Monitor and update
informational postings to ensure that data is current and correct,
consistent with the procedures described in Section 0 below. XI.
Informational Posting Procedures A. Information to be Posted: The
following information shall be maintained on the Internet Website by the
CCO (or its designee). The CCO will update this information within seven
business days of any change and will post the date the information was
updated. Date: April 29, 2019 Page 13 1. Names and addresses of Marketing
Affiliates. This information will be derived and kept current through
communications with the Dominion Energy Corporate Secretary’s Department.
2. Complete list of employee-staffed facilities that are shared by both
TFEs and MFEs. 3. The job titles and job descriptions of all TFEs. 4. Name
and address of potential merger partners to the Transmission Providers
that may employ or retain MFEs, within seven days after the potential
merger is announced. For purposes of the Standards of Conduct, once a
potential merger is announced the Standards of Conduct will apply as if
the entity were already acquired or merged. 5. Information on employee
transfers. The name of a TFE that transfers to a position as an MFE, or
any transfer of an MFE to a position as a TFE. The information must be
posted on the Internet Website for 90 days, and include the name of the
transferring employee, the respective title held in the Transmission
Function and Marketing Affiliate, and the effective date of the transfer.
This information will be derived and kept current by Human Resources’
information provided via automated reports. 6. Information Disclosure. The
Transmission Providers must immediately post any non-public Transmission
Function Information, non-public Transmission Customer Information or CEII
that was disclosed to MFEs. See Section VII.C above. 7. Waivers. Notice of
each waiver of a tariff provision that a Transmission Provider grants in
favor of an Affiliate, unless such waiver has been approved by the FERC.
See Section V.C.1 above. 8. Name of Chief Compliance Officer. Name and
contact information of Dominion Energy’s FERC Standards of Conduct CCO. 9.
Notice of Customer Voluntary Consent. Notice of customer voluntary consent
to allow the Transmission Provider to disclose customer information to
MFEs. See Section VII.C.3.a above. 10. These Procedures. These Procedures
will be kept current by the Law Department in conjunction with the CCO and
the Transmission Providers. XII. Training Procedures. A. Written
Procedures: Date: April 29, 2019 Page 14 1. The following employees will
receive an Intranet Website link to provide assistance and guidance on
compliance. The link will include documents related to Standards and Codes
of Conduct, helpful tools/guides and frequently asked questions. It will
also include these Procedures: Transmission Function Employees.
Marketing Function Employees. Officers, Directors, Supervisory and other
employees of the Transmission Providers who are likely to become to privy
to Transmission Function Information Officers, Directors, Supervisory
and other employees of Affiliates of Dominion Energy (include Services
Company Employees) to the extent they are likely to become privy to
Transmission Function Information. 2. All Employees of Dominion Energy
have access to these Procedures through the Internet Website or the
searchable Intranet Website. B. Training: 1. The following employees will
be trained regarding FERC Standards of Conduct annually. These employees
are required to certify (by signature or electronic certification) that
they have participated in training: Transmission Function Employees;
Marketing Function Employees; Officers, Directors, Supervisory and other
employees, contractors, or agents of the Transmission Providers who are
likely to become to privy to Transmission Function Information; and
Officers, Directors, Supervisory and other employees, contractors, or
agents of Affiliates of Dominion Energy (include Services Company
Employees) to the extent they are likely to become privy to Transmission
Function Information. 2. New Employees New TFEs, MFEs, officers,
directors, supervisory employees, and any other employees, contractors, or
agents likely to become privy to Transmission Function Information will be
trained as soon as possible upon commencing employment, but no later than
thirty (30) days after commencement. These employees are required to
certify (by signature or electronic certification) that they have
completed the training. XIII. Other Date: April 29, 2019 Page 15 A.
Fines/Penalties: FERC has the ability to impose fines of over $1 million
per day per violation. B. Dominion Energy’s Commitment to Compliance:
Dominion Energy does not condone and will not tolerate violations of the
Standards of Conduct. Employees that violate the Standards will be subject
to disciplinary action, up to and including termination. C. Contacts:
Employees should report any concerns immediately to your supervisor or the
Law Department - Federal Regulation. Regulatory Compliance Coordinator:
Nancy W. Adams 8-738-2534 or 804-819-2534 Nancy.W.Adams@dominionenergy.com
Senior Counsel – Gas: Lois Henry 8-738-2946 or 804-819-2946
Lois.M.Henry@dominionenergy.com Senior Counsel – Electric: Cheri Yochelson
8-738-2691 or 804-819-2691 Cheri.M.Yochelson@dominionenergy.com Dominion
Energy Compliance Line: 800-628-1798 Dominion Energy Compliance Online:
https://ethicsandcompliance.alertline.com/gcs/welcome