Compliance
Ethics and compliance programs do far more than prevent violations of the law. They help to create a culture that's based on ethical decision-making and encourages employees to consistently do the right thing.
Before the Enron scandal, an ethics and compliance program often was viewed as a positive, but nonessential, part of a corporate business strategy. That is no longer true. Both the Sarbanes-Oxley Act of 2002 and the U.S. Sentencing Guidelines contain requirements for programs that support an ethical business culture and commitment to compliance with the law. Companies today are not only expected to be ethical; they must publicly demonstrate a commitment to ethical behavior to their stakeholders; customers, investors, employees and the public.
An effective ethics and compliance program, such as the one GSOC has employed since 2004, meets this requirement by defining a process to teach employees about legal and regulatory responsibilities. Endorsed and supported by our executive team and Board of Directors, our program educates our employees via newsletters, a dedicated intranet site and other communication vehicles.
The electric utility industry also is focused on compliance. NERC's bulk electric system reliability regulations became part of our corporate framework beginning in 2007, and each year GSOC must meet critical infrastructure requirements and deadlines.
In support of GSOC’s ongoing regulatory efforts, GSOC's Operations division was realigned in 2009. The NERC compliance team was moved from System Operations — the group it monitors — to Legal, Finance & Compliance. We now have teams dedicated to NERC bulk electric system compliance, NERC critical infrastructure protection compliance and internal compliance. The new group manages our compliance framework, issuing guidelines and procedures pertaining to NERC requirements, corporate ethics and corporate compliance. Primary responsibility for executing the business in compliance with all regulatory requirements continues to belong to the operating departments.
