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.
The Electric Reliability legislation 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 regulators, 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. FERC'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. GSOC complies with all applicable FERC operating and reliability standards, as delegated to SERC Reliability Corporation by the Electric Reliability Organization (ERO), North American Electric Reliability Corporation.
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 & Compliance. We now have staff dedicated to NERC bulk electric system compliance, NERC critical infrastructure protection compliance and internal compliance. This 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.