Code of Entegrity

You And The Marketplace 

A. Overview

Customer satisfaction is one of the most important measures of Entergy’s success. It is our goal to listen to our customers, to adapt quickly to market conditions and to meet and exceed our customers’ quality and service expectations. Further, it is the Company’s policy to lawfully compete in the marketplace. This commitment to fairness includes respecting the rights of our competitors and abiding by all applicable laws in the course of competing. You must also interact with vendors and suppliers in a way that will not compromise Entergy’s core values.

The discussions that follow in this section of the Code summarize some of the Company’s key System Policies relating to your responsibilities to the marketplace. Please read and understand the details of any of the System Policies referenced below that affect your work.

System Policies relating to dealings with customers and the public:

• AFFILIATE INTERACTIONS
• DISCLOSURE AND PUBLIC COMMUNICATIONS
• DISCLOSURE CONTROLS AND PROCEDURES
• DISCLOSURE POLICY FOR COMPLIANCE WITH REGULATION FD
• ELECTRONIC INFORMATION SECURITY
• INFORMATION ASSET PROTECTION
• INSIDER TRADING

System Policies relating to dealings with competitors, suppliers and supplier contracts:

• ANTITRUST
• APPROVAL AUTHORITY
• CAPITAL FUNDING PROJECT APPROVAL
• CORPORATE RISK STANDARDS
• INDUSTRIAL ESPIONAGE
• LETTERS OF INTENT AND PRELIMINARY UNDERSTANDINGS
• PROCUREMENT
• PROCUREMENT: IT SOURCING GOVERNANCE

B. Customer Information

Confidential and/or proprietary customer information must be appropriately safeguarded. Such information cannot be published or otherwise released to third parties, including to competitive affiliates, without our customer’s consent or except where authorized by applicable laws and regulations. It cannot be used or accessed for personal reasons, but only for legitimate business purposes.

C. Insider Trading

"Insider trading" means using confidential information about Entergy or any other company gained in the course of doing work for Entergy in an attempt to achieve unfair advantage in the buying or selling of shares or other securities. It includes “tipping” in which the insider provides information to someone else who trades on it. This includes any information that may influence the decision of an investor to buy, sell, or hold the securities of a company, or which alters the overall mix of information publicly available about a company. Insider trading is both illegal and unethical. It is Entergy’s policy to prohibit trading in Entergy securities by directors, officers, employees and other persons while in possession of material nonpublic information. Due to their positions or job functions, Board of Directors members, executive officers and certain restricted employees also are prohibited from trading in Entergy securities except during certain specified “window” periods. Entergy will notify those persons of the “window” periods.

D. Media/Corporate Communications

All media inquiries should be directed to the Corporate Communications department. Corporate Communications personnel are trained and designated to handle media inquiries and to serve as Company spokespersons. Release of Company information, statements about Company position, or requests for interviews should be coordinated by Corporate Communications.

E. Antitrust and Fair Trade Practices

You should support and fully comply with antitrust and fair trade practices laws. Violation of these laws may occur if a Company representative engages in unfair pricing practices, unfair marketing practices, or misrepresentation of the products and services of Entergy or its competitors. Federal and state antitrust authorities (and private plaintiffs) will be particularly sensitive to business activities that appear to fix prices between competitors, fix costs between competitors, restrict output, or divide markets.

F. Bribes and Kickbacks

You should never give or offer anything of value to, or ask for anything of value from, a customer or a government employee or official (whether at the local, state, or federal level) that is illegal. Similarly, you should never ask for any bribes or kickbacks from a customer in return for favorable treatment.

G. Industrial Espionage

You may not steal, unlawfully possess, or unlawfully use material, products, intellectual property, or proprietary information of any supplier, customer, business partner, or competitor. You also may not acquire or use such property if you know it has been misappropriated. Further, you may not obtain a competitor’s confidential or proprietary information by improper means or unethical acts, such as through criminal acts (burglary, wire-tapping), misrepresentation, deception, bribing employees of other businesses (e.g. janitorial services), to covertly collect the information, or searching a competitor's office waste.

H. Procurement

It is the policy of the Company to purchase products and services based on merit and the Company’s overall business needs regardless of source. This will assure that the Company obtains necessary products and services at a fair value while conducting itself in accordance with high standards of business practice and with applicable legal requirements. Supply Chain will ensure that ethnic minority-owned, women-owned, historically under-utilized business zone, veteran-owned and disabled-veteran-owned businesses capable of meeting Entergy's needs are given access to participate in the Entergy business opportunities. Supply Chain also assures that Entergy’s interests are protected in purchasing products and services for the Company, and must be utilized under most circumstances for such procurement. Thus services and goods, such as consulting, temporary workers, contract workers, materials, and equipment, should generally be obtained by individual business units by utilizing Supply Chain.

I. Information Technology Procurement and Servicing

The procurement and servicing of information technology (hardware, software, data privacy, network usage, Internet, etc.) should be coordinated with the Information Technology Department. Only such authorized Company personnel are trained and designated to handle these matters.

J. Contracts/Letters of Intent/Capital Acquisitions

If you intend to enter into any contract, letter of agreement or other intentionally binding document, you are responsible for obtaining advance review and approval of the document and for complying with other requirements of corporate authorization policies. Agreements may only be executed after the signer has confirmed his/her authority and after appropriate legal and other approvals have been received. It is Company policy that “letters of intent” and similar preliminary agreements are limited, carefully controlled, and subject to prior legal review. Capital transactions should be made only after the responsible business unit has evaluated each proposed transaction and they have been approved and reviewed by authorized parties.