Code of Conduct and Ethics Corporate Standard by nix10042

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									                             ERCOT CORPORATE STANDARD

      Document Name: Code of Conduct & Ethics Corporate Standard

      Document ID:                 CS1.7

      Effective Date:              August 18, 2009

      Owner:                       ERCOT General Counsel / Texas Regional
                                   Entity Director, Legal Affairs

      Governs:                     ERCOT Employees and Consultants

      Approved:                    Bob Kahn, ERCOT, Inc. President & CEO


                                   Larry Grimm, Texas Regional Entity Chief
                                   Executive Officer and Chief Compliance Officer

1. Purpose
Electric Reliability Council of Texas, Inc. (ERCOT) is committed to the highest possible
standards of operational excellence, including integrity, confidentiality and ethics.
ERCOT requires that all employees and consultants performing services for ERCOT,
including the Texas Regional Entity Division of ERCOT (“ERCOT Representatives”) do
so with integrity and in an ethical manner, while maintaining appropriate confidentiality.

2. Standards
ERCOT has adopted a Code of Conduct describing the specific principals of required
ethical behavior for all ERCOT Representatives. All ERCOT Representatives are
responsible for knowing the contents of the Code of Conduct and applying its principals
in their day-to-day activities on behalf of ERCOT. The Code of Conduct is attached
hereto as Exhibit A.
All ERCOT employees must affirm their understanding of and agreement to follow the
Code of Conduct and all other applicable ERCOT policies, standards and procedures
prior to employment with ERCOT and on an annual basis in an Employee Ethics
Agreement (attached hereto as Exhibit B). Employees should also review the ERCOT
Employee Corporate Standards Manual for relevant information relating to their conduct
as ERCOT Representatives. All ERCOT employees must complete and sign the annual
Employee Ethics Agreement.
All Texas Regional Entity (“Texas RE”) employees must affirm their understanding of
and agree to follow the Code of Conduct and all other applicable ERCOT and Texas RE
policies, standards and procedures prior to employment with Texas RE and on an
annual basis in a Texas RE Employee Ethics Agreement (attached hereto as Exhibit D).

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Employees of Texas RE should also review the ERCOT Employee Corporate Standards
Manual for relevant information relating to their conduct as ERCOT Representatives.
All Texas RE employees must complete and sign the annual Texas RE Employee
Ethics Agreement.
ERCOT consultants who receive confidential information or have unescorted access to
ERCOT facilities or access to ERCOT computers or information systems must affirm
their agreement to follow the Code of Conduct, as well as all other relevant ERCOT
policies, standards and procedures, prior to beginning services for ERCOT, in a
Consultant Ethics Agreement (attached hereto as Exhibit C) or a form otherwise
acceptable to ERCOT’s Legal Department.
Texas RE consultants who receive confidential information or have unescorted access
to ERCOT or Texas RE facilities or access to ERCOT or Texas RE computers or
information systems must affirm their agreement to follow the Code of Conduct, as well
as all other relevant ERCOT and Texas RE policies, standards and procedures, prior to
beginning services for Texas RE, in a Texas RE Consultant Ethics Agreement (attached
hereto as Exhibit E) or a form otherwise acceptable to ERCOT’s Legal Department.

3. Roles / Accountabilities
All ERCOT Representatives must acknowledge their understanding of, and comply with,
this corporate standard. If ERCOT Representatives have questions regarding their
responsibilities under this corporate standard, they should refer those questions to the
ERCOT Legal Department. In addition, the Legal Department periodically conducts
training related to the Code of Conduct and Ethics Agreement.
The Legal Department reviews the Code of Conduct at least annually to determine
whether it needs to be revised and works with the Human Resources and Internal Audit
Departments on any revisions.
The Human Resources Department ensures that employees sign an Employee Ethics
Agreement prior to employment and on an annual basis. Any potential conflicts reported
on the employment or annual affirmation are reviewed by Human Resources and
approved with any modifications by the Legal Department. The Internal Audit
Department conducts an annual review of any reported conflicts and resulting required
modifications, if any
The Legal Department ensures that consultants receiving confidential information or
unescorted access to ERCOT facilities or access to ERCOT computers or information
systems sign a Consultant Ethics Agreement prior to engagement.
The Internal Audit Department audits the Employee and consultant Ethics Agreements
and affirmations and reports the results of its audit to the Legal and Human Resource
Departments, the Finance & Audit Committee of the Board of Directors and ERCOT
management.




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 2 OF 23   ERCOT LIMITED
                                                Exhibit A

              ERCOT CODE OF CONDUCT – THE WAY WE WORK
                                        Shared Responsibility
This Code of Conduct establishes the framework for ethical behavior required of all ERCOT
employees and contract workers (“ERCOT Representatives”) in dealing with our internal and
external constituents. It guides us to make business decisions consistent with our Principles of
Business Conduct and to behave in a manner reflecting high ethical standards. ERCOT
expects all ERCOT Representatives to conduct ERCOT’s business in accordance with this
Code of Conduct. Together, we are responsible for creating, preserving and enhancing
ERCOT’s reputation for honesty, integrity, and operational excellence.


                                      Individual Responsibility
Each ERCOT Representative is responsible for knowing, understanding and complying with this
Code of Conduct and the ERCOT policies, procedures and Protocols applicable to his/her job
functions. In addition, each ERCOT Representative must participate in required ethics training
and must reaffirm compliance with this Code of Conduct on an annual basis. We also have an
obligation to know when to ask for guidance when we encounter ethical questions and
dilemmas. To assist you in making the right decision, consider the following:
     •   Are my actions legal?
     •   Am I being fair and honest?
     •   Would my action or failure to act make the situation worse or allow a “wrong” to
         continue?
     •   How would my actions look if they were reported on the front page of a newspaper?
No single document can deal with the many issues that will arise in a dynamic work
environment. If you have questions about legal matters not covered in this Code of Conduct,
you should consult with the Legal Department. If you have questions about conduct that does
not involve laws, rules or regulations, you should consult with a manager, director or Human
Resources.


                                   Management Responsibilities
The responsibilities of ERCOT Representatives in management positions include
responsibilities in addition to responsibilities required of those in non-management roles.
Managers are expected to build and maintain a culture of compliance with applicable laws and
regulations and with ERCOT standards, policies, procedures and Protocols. Managers are
expected to accomplish this by: ensuring that the applicable principles, policies and standards
are communicated in a timely and effective manner; ensuring that adequate internal controls are
implemented in their areas of responsibility; monitoring compliance; investigating potential
violations; and taking prompt corrective action to remedy any identified weaknesses.


                                         Reporting Violations
All ERCOT Representatives have an obligation to report suspected violations of this Code of
Conduct. You may report your concerns to any ERCOT manager, director or officer, or to
ERCOT’s Legal Department, Human Resources or Internal Audit staff. Texas Regional Entity


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(Texas RE) staff should report any concerns to a Texas RE attorney. Your report will be kept
confidential to the fullest extent possible, consistent with the need to conduct an appropriate
investigation and take appropriate corrective action.
ERCOT has also implemented an ethics reporting tool to provide a means to address
compliance and ethical issues for Stakeholders and ERCOT Representatives who may not feel
comfortable discussing the issue directly with their supervisor or another ERCOT employee.
This reporting tool, operating by EthicsPoint, is available by phone or via the EthicsPoint
website, 7 days a week, 365 days a year. You may call the EthicsPoint toll-free phone number,
1-800-384-4277, or visit www.ethicspoint.com to make a confidential report or to request
guidance about this Code of Conduct and other ERCOT policies.
Calls to EthicsPoint are not traced and callers can choose to remain anonymous. Information
from such calls and from online reports is forwarded to ERCOT staff members who are not
involved in the matter reported. All reports are investigated to the extent possible using the
reported information, and a response to the report is available online to the individual filing the
report.


                                  Principles of Business Conduct
    •   Doing what is right
    •   Respecting the rights of others
    •   Upholding the law
    •   Maintaining the integrity, confidentiality and privacy of information
    •   Avoiding Conflicts of Interest
    •   Conducting ourselves appropriately


                                          Doing what is right
To be ethical is to recognize the difference between right and wrong and to do what is right.
Asking this question and applying this Code of Conduct ensures that our actions are ethical and
consistent with ERCOT’s mission and values. Additionally, ERCOT standards, policies,
procedures and controls are created to guide us in our daily, business-specific activities as
ERCOT Representatives.

                                  Respecting the rights of others

Professional conduct
ERCOT Representatives shall treat each other in a respectful and professional manner and will
not discriminate or harass others on the basis of age, sex, race, color, religion, creed, national
origin, citizenship, veteran status, pregnancy, disability or other basis protected by law. For
more information, read the Equal Opportunity Corporate Standard (CS5.3) and Harassment and
Employee Responsibility Corporate Standard (CS5.4).

Property rights
Company assets, subject to limited approved exceptions, are used only for ERCOT business
purposes. ERCOT Representatives have a responsibility to ensure that ERCOT assets are put
to good use in successfully achieving ERCOT’s mission and goals. For more information read
CS7.1, Acceptable Use Corporate Standard and CS5.25, E-Mail and Telephone Usage
Corporate Standard.

Stakeholder rights

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ERCOT Representatives must conduct themselves with fairness, courtesy and in good faith
during all stakeholder interactions.

Texas law requires that access to the transmission and distribution systems for all buyers and
sellers of electricity in the ERCOT Region is available on non-discriminatory terms. If you have
any discretion in applying any Protocol relating to the transmission of electricity, you must
ensure that you apply the Protocol in substantially the same manner to all similarly-situated
Market Participants.

Supplier rights
Relationships with vendors and suppliers must always be conducted at arm’s-length, consistent
with accepted business practices and in accordance with applicable laws and the applicable
ERCOT Ethics Agreement. In dealing with suppliers, all ERCOT Representatives will conduct
themselves with fairness, courtesy and good faith.

                                           Upholding the law

ERCOT, like other businesses, must abide by laws and regulations of general application,
addressing issues such as safety, employment discrimination, anticompetitive conduct, and
taxes. In addition, ERCOT is subject to mandates from additional sources defining how it must
conduct its business: the North American Electric Reliability Corporation’s (NERC) Reliability
Standards and Rules of Procedure; the Public Utility Regulatory Act (PURA); rules and orders of
the Public Utility Commission of Texas; and ERCOT’s own operating Protocols, market guides
and procedures.

All ERCOT Representatives must comply with and uphold both the spirit and letter of all
applicable laws, rules, Protocols, guides and regulations where ERCOT conducts business.

            Maintaining integrity, confidentiality and privacy of information

Company records and accounting practices
The integrity of ERCOT’s records and financial reporting is critical to its on-going success. All
assets, liabilities and transactions must be accurately reported and supported by necessary
documentation. No asset, liability or transaction is to be concealed from management or from
ERCOT’s internal or external auditors.

All documents and transactions (e.g. contracts) must be authorized and executed in accordance
with ERCOT policies, standards and procedures. Appropriate accounting and financial policies,
standards, procedures, controls and audit processes must be maintained. Financial reports
must be accurate and prepared in accordance with generally accepted accounting principles.



Confidential Information
In order to support ERCOT’s mission and functional requirements, ERCOT Representatives
may receive confidential information from Market Participants, suppliers or others. During the
performance of their roles, ERCOT Representatives may also generate confidential information.
ERCOT Representatives will respect and ensure the confidentiality and privacy of confidential
information and will comply with all standards, policies, procedures and controls for protecting
information, unless disclosure is required by law or order of a regulatory agency or court, or
otherwise authorized by ERCOT.



CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 5 OF 23    ERCOT LIMITED
No ERCOT Representative shall use any confidential information obtained in his/her capacity as
an ERCOT Representative for personal gain or to ERCOT’s detriment.

Personal information
ERCOT Representatives may have access to sensitive or confidential personal information,
such as personnel records, payroll records, protected health information and financial
information. In some cases, this information is subject to protection by applicable privacy laws.
ERCOT Representatives must use extreme care when dealing with confidential, personal or
sensitive information. As a general rule, such information shall not be: (i) released to anyone
inside or outside of ERCOT not authorized or legally entitled to receive it, or (ii) used or
disclosed for any reason except legitimate business purposes or when otherwise required by
law. For more information read CS5.5 Request for Employee Information and Access to
Employment Files Corporate Standard; and CS5.19 Confidentiality Corporate Standard.

                                   Avoiding Conflicts of Interest

All ERCOT Representatives must conduct ERCOT’s business with complete objectivity and
avoid situations in which their personal interests may conflict (or appear to conflict) with
ERCOT’s interests or those of its Market Participants. Conflicts may be difficult to detect and
sometimes it is only a matter of degree between an acceptable and unacceptable activity.
Accordingly, ERCOT Representatives must comply with the letter and spirit of ERCOT’s Conflict
of Interest Corporate Standard. For more information, read CS5.18 Conflict of Interest
Corporate Standard.

                               Conducting ourselves appropriately

Commitment to Community
ERCOT has important responsibilities to support the Texas community: providing reliable
electric service, customer choice and well-functioning Ancillary Services markets. ERCOT’s
corporate citizenship is reflected in the way we fulfill our responsibilities and conduct our
business. To that end, ERCOT Representatives should always remember the importance of
maintaining high standards of ethical and professional conduct, both on the job and off.

Fraud Prevention
ERCOT is committed to maintaining the highest standards of business conduct and ethics in its
accounting standards, disclosures, internal controls, audit practices, and prevention of fraud,
intentional misrepresentations, and deception. ERCOT Representatives must comply with all
applicable legal and regulatory requirements relating to corporate reporting, compliance and
other matters pertaining to fraud prevention. Each ERCOT Representative has the responsibility
to assist ERCOT in preventing fraud and meeting these requirements.



Professional standards
ERCOT Representatives holding professional credentials such as attorneys, accountants and
engineers must comply with all relevant professional standards and rules of conduct when
practicing their vocation in the service of ERCOT.

                                             Interpretations

Interpretations of this Code of Conduct may be made only by the ERCOT General Counsel or
his/her delegate; provided, however that any interpretations involving Texas RE staff must be

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made by Texas RE Director, Legal Affairs after conferring with ERCOT General Counsel. No
employee may authorize a violation of this Code of Conduct and no outside attorney has the
authority to interpret the Code of Conduct.

Any ERCOT Representative (except for Texas RE staff) with concerns or questions about these
requirements and prohibitions should contact the Legal Department. Texas RE staff should
contact the Texas RE Director, Legal Affairs.




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 7 OF 23   ERCOT LIMITED
                                                Exhibit B


                            EMPLOYEE ETHICS AGREEMENT

Employees of Electric Reliability Council of Texas, Inc. (“ERCOT”) must conduct ERCOT’s
business with integrity and total objectivity toward ERCOT, all ERCOT Members and Market
Participants (as listed on ERCOT’s public website), and the Texas Regional Entity (“Texas RE”)
in compliance with all applicable laws, rules, and regulations, NERC Rules of Procedure,
ERCOT Protocols ERCOT corporate policies and standards, and operating procedures and this
Employee Ethics Agreement. ERCOT will not tolerate fraud, misconduct or violations of the
Employee Ethics Agreement or Code of Conduct.

                                       Confidential Information
Employees who receive Confidential Information in the course of their employment must
maintain the confidentiality of such Confidential Information and must take reasonable actions
and precautions to prevent unauthorized disclosure of same.
“Confidential Information” means all information marked “Confidential” or defined as
“Confidential Information” in Section 1500 of the NERC Rules of Procedure and all information
defined as “Protected Information” in Section 1.3 of the ERCOT Protocols, and specifically
includes all documents, knowledge, electronic, tangible or intangible information provided which
is or includes any of the following:
     • Information, technical data or know-how which relates to the business, services or
       products of Texas RE, ERCOT, owners, operators and users of the bulk power system,
       including Registered Entities on NERC’s Compliance Registry and ERCOT’s Members
       and Market Participants, or any of their consultants or vendors, which was developed or
       acquired by that business and which is proprietary or competitively or commercially
       sensitive;
     • Critical Energy Infrastructure information;
     • Personnel information that identifies or could be used to identify a specific individual or
       reveals personnel, financial, medical, or other personal information;
     • Work papers, including any records produced for or created in the course of an
       evaluation or audit;
     • Investigative files, including any records produced for or created during the course of an
       investigation;
     • Cyber Security Incident information; or
     • Information contained on any Texas RE server or in any email sent or received by any
       Texas RE employee.
Any employee providing services to the Texas RE must strictly comply with the NERC Rules of
Procedure governing the protection and non-disclosure of information that may be privileged,
confidential or proprietary, or may constitute critical energy infrastructure information. You may
communicate regarding Confidential Information of the Texas RE only with Texas RE
employees and with ERCOT service providers who have signed a Texas RE Confidentiality
Agreement.



CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 8 OF 23     ERCOT LIMITED
                                          Conflicts of Interest
Employees must conduct ERCOT’s business the influence of any Conflict of Interest of the
employee or any of the following (“Related Parties”): the employee’s immediate family (parents
and stepparents, children and stepchildren, siblings and stepsiblings); the employee’s spouse or
domestic partner; and household members (including roommates).
Any circumstance which might influence or appear to influence the employee to promote the
interest of himself or a Related Party or to provide undue benefit to a Supplier or Market
Participant must be disclosed so ERCOT management can evaluate the potential Conflict of
Interest. “Conflicts of Interest” are defined in CS5.18, Conflict of Interest Corporate Standard.
Examples include, but are not limited to:
   1.   Interest in Supplier - The employee or a Related Party has a financial interest,
        including employment or ownership, in a Supplier currently doing business with ERCOT
        or in a Supplier that seeks to do business with ERCOT, if that employee has any
        influence over the selection of the Supplier or is involving in managing or otherwise
        directing the ERCOT-Supplier relationship in any way. However, the following interests
        in a Supplier are not considered Conflicts of Interest:
                 (a) ownership of less than one percent (1%) of the publicly-traded equity
                 securities of a Supplier, the securities are held as an investment, and the
                 employee or Related Party does not have representation on the Supplier’s board
                 of directors (or equivalent governing body), and does not exercise influence over
                 the entity’s day-to-day management decisions;
                 (b) ownership of mutual funds holding securities of the Supplier.
   2.   Interest in Market Participant – The employee or a Related Party has a financial
        interest, including ownership or employment, in a Market Participant, except for
        ownership of mutual funds holding securities of the Market Participant.
   3.   Conflicting Services – The employee or a Related Party performs concurrent services
        for ERCOT and for Market Participants, Suppliers or other entities that have a business
        relationship with ERCOT.
   4.   Personal Benefit – An ERCOT business decision will result in personal gain or loss to
        the employee or a Related Party, other than gains or losses common to all employees
        and their Related Parties.
An employee who becomes aware of a potential or actual Conflict of Interest must immediately
inform the Legal Department to allow ERCOT officers to evaluate the situation. After full
disclosure by the employee, ERCOT officers may agree to conditions that appropriately limit any
potential influence from a Conflict of Interest.


                                            Securities Laws
Employees may not trade in securities of third-parties (such as Suppliers) if, because of their
position with ERCOT, they have access to material non-public information about that third-party.


                                             Anti-trust Laws
Employees must abide by the ERCOT Anti-trust Compliance Corporate Standard (CS1.10) and
all applicable anti-trust laws.



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                                            Non-Solicitation
In consideration for receiving ERCOT’s Confidential Information, employees shall not, while
employed by ERCOT and for a period of one year from the date of separation of employment
with ERCOT, either directly or indirectly solicit, induce or encourage any ERCOT employee or
consultant to either terminate employment or contract with ERCOT or accept employment with
any other entity. The term “solicit, induce or encourage” includes, but is not limited to, initiating
communications with an ERCOT employee relating to possible employment, offering bonuses or
additional compensation or referring ERCOT employees to personnel, recruiters or other
agents.

                                Reporting Questions or Concerns
Any employee with concerns or questions about these requirements and prohibitions should
contact the Legal Department or file an anonymous report through EthicsPoint
(www.ethicspoint.com or 1-866-384-4277) or other available ERCOT anonymous reporting tool,
if any.
                                         Disclosure of Conflicts
After reviewing the ERCOT Code of Conduct and Employee Ethics Agreement, I wish to
disclose the following potential Conflict(s) of Interest:

     Check this box if you have no Conflicts of Interest to report.


  Potential Conflicts of Interest:


  Name:                  Relationship to Employee:
  Description of Potential Conflict:


  Potential Conflicts of Interest:


  Name:                  Relationship to Employee:
  Description of Potential Conflict:


  Other Disclosure(s) [Please include any disclosures relating to CS5.14.7, Driving on Company
  Business Corporate Standard]:


                                         Employee Agreement
By checking the box, I confirm and acknowledge that:
(i) I have read and understand the requirements of the ERCOT Code of Conduct, this Employee
Ethics Agreement, the Antitrust Compliance Corporate Standard (CS1.10), the Acceptable Use
Corporate Standard (CS7.1), and the ERCOT Employee Corporate Standards Manual (CS5.1-
5.42);




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(ii) I agree to be bound by and comply with all applicable laws, rules and regulations, all ERCOT
corporate policies and standards, operating procedures and Protocols and the NERC Rules of
Procedure.
(iii) I agree to maintain the confidentiality of all Confidential Information and to communicate
regarding the Texas RE’s Confidential Information only with Texas RE employees and ERCOT
service providers that I have confirmed have signed a Texas RE Confidentiality Agreement; and
(iv) If I have signed any previous ERCOT Ethics Agreement, I further confirm that I have
complied with those requirements since the date of such previous Ethics Agreement(s); and
(v) I have made complete disclosure herein of any potential Conflict of Interest involving me or
my Related Parties; and
(vi) If I become aware of a Conflict of Interest involving me or my Related Parties, or if any
information I disclosed herein changes, I will promptly notify the Legal Department in writing and
(vii) I will be subject to disciplinary action, termination, injunction and/or all other available legal
or equitable remedies for any violations of applicable laws, rules, and regulations, NERC Rules
of Procedure, ERCOT Protocols, ERCOT corporate standards, policies and operation
procedures and this Employee Ethics Agreement, whether my violation is intentional or
careless.


                                       I agree to the foregoing terms.




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 11 OF 23         ERCOT LIMITED
                                                Exhibit C
                          CONSULTANT ETHICS AGREEMENT
Consultants of Electric Reliability Council of Texas, Inc. (“ERCOT”) must conduct ERCOT’s
business with integrity and total objectivity toward ERCOT and all Members and Market
Participants (as listed on ERCOT’s public website) and the Texas Regional Entity (“Texas RE”),
in compliance with all applicable laws, rules, and regulations, and in accordance with ERCOT
Protocols and ERCOT corporate policies and standards, and operating procedures. ERCOT will
not tolerate fraud, misconduct or violations of the Ethics Agreement or Code of Conduct.


                                       Confidential Information
ERCOT consultants who receive Confidential Information in the course of their services to
ERCOT must maintain the confidentiality of such Confidential Information and take reasonable
actions and precautions to prevent unauthorized disclosure of same. “Confidential Information”
means all information marked “Confidential” or defined as “Confidential Information” in Section
1500 of the NERC Rules of Procedure and all information defined as “Protected Information” in
Section 1.3 of the ERCOT Protocols, and specifically includes all documents, knowledge,
electronic, tangible or intangible information provided which is or includes any of the following:
   •   Information, technical data or know-how which relates to the business, services or
       products of Texas RE, ERCOT, owners, operators and users of the bulk power system,
       including Registered Entities on NERC’s Compliance Registry and ERCOT’s Members
       and Market Participants, or any of their consultants or vendors, which was developed or
       acquired by that business and which is proprietary or competitively or commercially
       sensitive;
   •   Critical Energy Infrastructure information;
   •   Personnel information that identifies or could be used to identify a specific individual or
       reveals personnel, financial, medical, or other personal information;
   •   Work papers, including any records produced for or created in the course of an
       evaluation or audit;
   •   Investigative files, including any records produced for or created during the course of an
       investigation;
   •   Cyber Security Incident information; or
   •   Information contained on any Texas RE server or in any email sent or received by any
       Texas RE employee.

                               Disclosure of Prior Work at ERCOT
Consultant must disclose herein: (i) all dates (beginning date through end date) during which
Consultant was employed by ERCOT or Texas RE in the past and (ii) all dates (beginning
date through end date) during which Consultant performed services for ERCOT or the Texas
RE in the past.

                                          Conflicts of Interest
ERCOT consultants must conduct ERCOT’s business free from the influence of any Conflict of
Interest of the consultant or any of the following (“Related Parties”): the consultant’s immediate
family (parents and stepparents, children and stepchildren, siblings and stepsiblings); the
consultant’s spouse or domestic partner; and household members (including roommates).

Any circumstance which might influence or appear to influence the consultant to promote the
interest of himself or a Related Party or to provide undue benefit to a Supplier or Market


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Participant must be disclosed so ERCOT management can evaluate the potential Conflict of
Interest. “Conflicts of Interest” are defined in CS5.18, Conflict of Interest Corporate Standard.
Common examples include, but are not limited to:
1.      Interest in Supplier - The consultant or a Related Party has a financial interest,
        including employment or ownership, in a Supplier currently doing business with ERCOT
        or in a Supplier that seeks to do business with ERCOT, if that consultant has any
        influence over the selection of the Supplier or in involved in managing or otherwise
        directing the ERCOT-Supplier relationship in any way. However, the following interests
        in a Supplier are not considered conflicts of interest:
        (a) ownership in the Supplier whose contract has resulted in the consultant’s
        engagement at ERCOT;
        (b) ownership of less than one percent (1%) of the publicly-traded equity securities of a
        Supplier, the securities are held as an investment, and the employee or Related Party
        does not have representation on the Supplier’s board of directors (or equivalent
        governing body), and does not exercise influence over the entity’s day-to-day
        management decisions;
        (c) ownership of mutual funds holding securities of the Supplier.

2.      Interest in Market Participant – The consultant or a Related Party has a financial
        interest, including ownership or employment, in a Market Participant, except for
        ownership of mutual funds holding securities of the Market Participant.

3.      Conflicting Services – The consultant or a Related Party performs concurrent services
        for ERCOT and for Market Participants, Suppliers, or other entities that have a business
        relationship with ERCOT.

4.      Personal Benefit – An ERCOT business decision will result in personal gain or loss to
        the consultant or a Related Party, other than gains or losses common to all Suppliers,
        consultants, and their Related Parties.

A consultant must immediately inform the Legal Department if a Conflict of Interest or even the
appearance of a Conflict of Interest might exist, to allow ERCOT officers to evaluate the
situation. After full disclosure by the consultant, ERCOT officers may agree to conditions that
appropriately limit any potential influence from a Conflict of Interest.

                                   Personal Gifts and Payments
I understand that I may not offer any cash or non-cash benefits or gifts to any ERCOT employee
because such benefits or gifts may affect or appear to affect the judgment of the person
receiving the gift. Payment or acceptance of bribes, kickbacks or other improper payments
while conducting ERCOT’s business is strictly prohibited.

                                            Securities Laws
Consultants may not trade in securities of third parties (such as Suppliers) if, because of their
service to ERCOT, they have access to material non-public information about that third party.


                                             Anti-trust Laws
Consultants must abide by the ERCOT Antitrust Compliance Corporate Standard (CS1.10) and
all applicable anti-trust laws.



CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 13 OF 23      ERCOT LIMITED
                                Acceptable Use of ERCOT Assets
Consultants must abide by the ERCOT Acceptable Use Corporate Standard (CS7.1) and must
refrain from using ERCOT equipment, networks, tools and premises for purposes other than the
conduct of ERCOT business.

                                            Non-Solicitation
In consideration for receiving ERCOT’s Confidential Information and retention by ERCOT,
consultants shall not, while working for ERCOT and for a period of six months after ceasing to
work for ERCOT, either directly or indirectly solicit, induce or encourage any ERCOT employee
to either terminate employment with ERCOT or accept employment with any other entity. The
term “solicit, induce or encourage” includes, but is not limited to, initiating communications with
an ERCOT employee relating to possible employment, offering bonuses or additional
compensation or referring ERCOT employees to personnel, recruiters or other agents.

                                                   Notice
Any ERCOT consultant who has concerns or questions about these requirements and
prohibitions should contact the ERCOT Legal Department. Any consultant who becomes aware
of a violation of the Code of Conduct or the appearance of a violation of the Code of Conduct,
by any person must immediately notify the ERCOT Legal Department or file an anonymous
report through EthicsPoint (www.ethicspoint.com or 1-866-384-4277) or other available ERCOT
anonymous reporting tool, if any.

                              Disclosure of Conflicts and Prior Service
After reviewing the ERCOT Code of Conduct and Employee Ethics Agreement, I wish to
disclose the following prior services to ERCOT and potential conflict(s) of interest:

     Check this box if you have no prior service or conflicts of interest to report.


Prior Services to ERCOT
Dates of Prior Service:
Dates of Prior Employment:


Potential Conflicts of Interest:


Name:            Relationship to Employee:
Description of Potential Conflict:


Potential Conflicts of Interest:


Name:            Relationship to Employee:
Description of Potential Conflict:



CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 14 OF 23     ERCOT LIMITED
                                        Consultant Agreement

By signing below, I hereby confirm and acknowledge that:
(i)I have read and understand the requirements of the ERCOT Code of Conduct and this
Consultant Ethics Agreement, the Antitrust Compliance Corporate Standard (CS1.10), the
Confidentiality Corporate Standard (CS5.19), the Fraud Prevention and Whistleblower
Corporate Standard (CS5.38), and the Acceptable Use Corporate Standard (CS7.1).
(ii) I agree to be bound by and comply with all requirements of all ERCOT corporate policies and
standards, and operating procedures and Protocols; and the NERC Rules of Procedure.
(III) I agree to maintain the confidentiality of all Confidential Information and to communicate
regarding the Texas RE’s Confidential Information only with Texas RE employees and ERCOT
service providers that I have confirmed have signed a Texas RE Confidentiality Agreement; and
(iv) If I have signed any previous ERCOT Ethics Agreement, I further confirm that I have
complied with those requirements since the date of such previous Ethics Agreement(s).
(v) I have made complete disclosure herein of any prior services to ERCOT and any potential
Conflict of Interest involving me or my Related Parties.
(vi) If I become aware of a Conflict of Interest involving me or my Related Parties, or if any
information I disclosed herein changes, I will promptly notify the Legal Department in writing;
and
(vii) I will be subject to contract termination, injunction and/or all other available legal or
equitable remedies for any violations of applicable laws, rules and regulations, NERC Rules of
Procedure, ERCOT Protocols, ERCOT corporate policies and standards, and operating
procedures, and this Consultant Ethics Agreement, whether my violation is intentional or
careless.


Consultant Signature:                                                        Date:
Printed Name:                                                       ______
Consultant Employer: ___________________________________
ERCOT Contact:            ___________________________________
NOTE: You must complete the Disclosure section even if you have no conflicts of
interest to disclose.


                  Note: The signed form will be maintained in the Legal Department




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 15 OF 23     ERCOT LIMITED
                                                 Exhibit D
          TEXAS REGIONAL ENTITY EMPLOYEE ETHICS AGREEMENT
Employees of the Texas Regional Entity an Independent Division of Electric Reliability Council of Texas,
Inc. (“Texas RE”) must conduct all Texas RE business legally, with integrity and total objectivity and in
compliance with all applicable laws, rules, and regulations, Protocols and the standards, policies and
procedures of Electric Reliability Council of Texas, Inc. (“ERCOT”), Texas RE, North American Electric
Reliability Corporation (“NERC”) and this Employee Ethics Agreement. Texas RE will not tolerate fraud,
misconduct or abuse of the Ethics Agreement or Code of Conduct.


Confidential Information
Texas RE employees must maintain the confidentiality of all Confidential Information disclosed to the
employee because of his or her employment with Texas RE and must take reasonable actions and
precautions to prevent unauthorized disclosure of Confidential Information. “Confidential Information”
means all information defined as “Confidential Information” in Section 1500 of the NERC Rules of
Procedure and all information defined as “Protected Information” in Section 1.3 of the ERCOT Protocols,
and specifically includes all documents, knowledge, electronic, tangible or intangible information provided
which is or includes any of the following:
    • Information, technical data or know-how which relates to the business, services or products of
        Texas RE, ERCOT, owners, operators and users of the bulk power system (including Registered
        Entities on NERC’s Compliance Registry and ERCOT’s members and market participants, as
        listed on ERCOT’s public web site), or any of their consultants or vendors, which was developed
        or acquired by that business and which is proprietary or competitively or commercially sensitive;
    • Critical Energy Infrastructure information;
    • Personnel information that identifies or could be used to identify a specific individual or reveals
        personnel, financial, medical, or other personal information;
    • Work papers, including any records produced for or created in the course of an evaluation or audit;
    • Investigative files, including any records produced for or created during the course of an
        investigation; or
    • Cyber Security Incident information.
Any owner, operator, or user of the bulk power system or any other party (“Submitting Party”) may mark
as confidential, in accordance with Section 1500 of the NERC Rules of Procedure, any document or other
information that it submits to NERC, ERCOT, or Texas RE that it reasonably believes contains
Confidential Information. Except as provided by the NERC Rules of Procedure or otherwise by law,
Texas RE employees shall keep in confidence and shall not copy, disclose, or distribute any Confidential
Information or any part thereof without the permission of the Submitting Entity.


Conflicts of Interest
Texas RE employees must conduct Texas RE’s business with total objectivity and without any influence
from any Conflict of Interest and must avoid situations in which their personal or financial interests conflict
or appear to conflict with the interests of Texas RE, ERCOT or an ERCOT market participant. “Conflicts
of Interest” include, but are not limited to, situations where an employee or his/her spouse, dependent or
a member of his/her household or immediate family (i.e. father, mother, children and siblings):
        1. Stands to gain or lose personally from a Texas RE or ERCOT business decision; or
        2. Is employed by any other division of ERCOT, a Market Participant, any Texas RE or ERCOT
             supplier or vendor, or any other entity dealing with Texas RE ERCOT, directly or indirectly, in
             a position which may affect the Texas RE employee’s objectivity in making decisions,
             recommendations or taking other actions on behalf of Texas RE.


CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 16 OF 23               ERCOT LIMITED
Other potential conflicts of interest include situations where a Texas RE employee is aware of the fact
that his/her spouse, dependent, a member of his/her household or immediate family:
         1. Has ownership of or a controlling interest in any Registered Entity, ERCOT Market Participant,
             Texas RE or ERCOT supplier or vendor or any other entity doing business, directly or
             indirectly, with Texas RE or ERCOT; or
         2. Serves in an advisory, consulting, technical or management capacity for any business
             organization that, directly or indirectly, does business with Texas RE or ERCOT or is an
             ERCOT Market Participant (unless such activity is for no compensation and is approved by
             the employee’s supervisor).
An employee must immediately inform Texas RE Legal if a Conflict of Interest or even the appearance of
a Conflict of Interest might exist, to allow Texas RE management to evaluate the situation. After full
disclosure by the employee, Texas RE management may agree to conditions that appropriately limit any
potential influence from a Conflict of Interest.
Employees must disclose any potential conflicts of interest but need not disclose ownership of publicly-
traded equity securities of a Texas RE or ERCOT vendor or supplier (so long as the vendor or supplier is
not a Registered Entity or an ERCOT Market Participant) if the securities are held as an investment and
the employee or related party: (a) owns less than one percent (1%) of the outstanding securities of the
entity, (b) does not have representation on the entity’s board of directors (or equivalent managing entity),
and (c) does not exercise influence over the entity’s day-to-day management decisions. Additionally, an
employee need not disclose ownership of mutual funds having holdings of such entities or Market
Participants.
Texas RE employees may not trade in securities of third-parties (including, but not limited to, vendors,
suppliers, ERCOT Market Participants or Registered Entities) if, because of their position with Texas RE,
they have material non-public information about that third-party.


Non-Solicitation
In consideration for receiving Texas RE Confidential Information, employees shall not, while employed by
Texas RE and for a period of one year from the date of separation of employment with Texas RE, either
directly or indirectly solicit, induce or encourage any Texas RE or ERCOT employee or consultant to
either terminate employment or contract with Texas RE or ERCOT or accept employment with any other
entity. The term “solicit, induce or encourage” includes, but is not limited to, initiating communications
with a Texas RE or ERCOT employee relating to possible employment, offering bonuses or additional
compensation or referring Texas RE or ERCOT employees to personnel, recruiters or other agents.


Antitrust Laws
Employees must abide by the Texas RE Antitrust Compliance Corporate Policy (TRE POL 5.0) and all
applicable antitrust laws.


Notice
Any Texas RE employee with concerns or questions about these requirements and prohibitions should
contact Texas RE Legal or the Texas RE Chief Compliance Officer or file an anonymous report through
EthicsPoint (www.ethicspoint.com or 1-866-384-4277) or other available ERCOT anonymous reporting
tool, if any.


Employee Agreement
By signing below, I confirm and acknowledge that: (i) I have read and understand the requirements of the
NERC Rules of Procedure, the ERCOT Code of Conduct, this Employee Ethics Agreement, all ERCOT
Corporate Standards including, but not limited to, the Antitrust Compliance Corporate Policy (TRE POL


CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 17 OF 23            ERCOT LIMITED
5.0), the Acceptable Use Corporate Standard (CS7.1), and the ERCOT Employee Corporate Standard
Manual (CS5.1-5.42); (ii) I agree to be bound by and comply with all requirements and the intent of these
requirements; and (iii) I will be subject to disciplinary action, termination, injunction and/or all other
available legal or equitable remedies if I violate the NERC Rules of Procedure, the Code of Conduct, this
Ethics Agreement, or the intent behind either, whether my violation is intentional or careless. If I have
signed any previous Texas RE or ERCOT Ethics Agreement, I further confirm that I have complied with
those requirements since the date of such previous Ethics Agreement(s). If my situation or any
information I disclosed changes between the dates on which I sign affirmations of the Ethics Agreement, I
must notify the Texas RE Legal in writing and obtain proper approvals.
Employee Signature:                                                 Date:
Printed Name:




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 18 OF 23           ERCOT LIMITED
                                        Disclosures of Information
                            Complete this Form and send to Texas RE Legal
After reviewing the ERCOT Code of Conduct and Texas RE Employee Ethics Agreement, I wish to
disclose the following potential conflict(s) of interest:


Person:                                                      Relationship:
Description of Potential Conflict:




:                                                  Relationship:
Description of Potential Conflict:




Other Disclosure(s) [Please include any disclosures relating to CS5.14.7, Driving on Company Business
Corporate Standard]:




Signature:
Printed Name:                                                        Date:
Legal Review By:                                                     Date:


              NOTE: The signed form will be maintained in your Human Resources file
                                       [Add more pages, if necessary]




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809    PAGE 19 OF 23      ERCOT LIMITED
                                                    Exhibit E
        TEXAS REGIONAL ENTITY CONSULTANT ETHICS AGREEMENT
Consultants of the Texas Regional Entity an Independent Division of Electric Reliability Council of Texas,
Inc. (“Texas RE”) must conduct ERCOT’s business legally, with integrity and total objectivity and in
compliance with all laws, rules, regulations, Protocols and the policies, standards and procedures of
Electric Reliability Council of Texas, Inc. (“Inc.”)., Texas RE, North American Electric Reliability
Corporation (“NERC”) and this Consultant Ethics Agreement. Texas RE will not tolerate fraud,
misconduct or abuse of the Ethics Agreement or Code of Conduct.
Confidential Information
Texas RE consultants must maintain the confidentiality of all Confidential Information disclosed to the
consultant because of his or her engagement with Texas RE and must take reasonable actions and
precautions to prevent unauthorized disclosure of Confidential Information. “Confidential Information”
means all information defined as “Confidential Information” in Section 1500 of the NERC Rules of
Procedure and all information defined as “Protected Information” in Section 1.3 of the ERCOT Protocols,
and specifically includes all documents, knowledge, electronic, tangible or intangible information provided
which is or includes any of the following:
    • Information, technical data or know-how which relates to the business, services or products of
        Texas RE, ERCOT, owners, operators and users of the bulk power system (including Registered
        Entities on NERC’s Compliance Registry and ERCOT’s members and market participants, as
        listed on ERCOT’s public web site), or any of their consultants or vendors, which was developed
        or acquired by that business and which is proprietary or competitively or commercially sensitive;
    • Critical Energy Infrastructure information;
    • Personnel information that identifies or could be used to identify a specific individual or reveals
        personnel, financial, medical, or other personal information;
    • Work papers, including any records produced for or created in the course of an evaluation or audit;
    • Investigative files, including any records produced for or created during the course of an
        investigation; or
    • Cyber Security Incident information.
Any owner, operator, or user of the bulk power system or any other party (“Submitting Party”) may mark
as confidential, in accordance with Section 1500 of the NERC Rules of Procedure, any document or other
information that it submits to NERC, ERCOT, or Texas RE that it reasonably believes contains
Confidential Information. Except as provided by the NERC Rules of Procedure or otherwise by law,
Texas RE employees shall keep in confidence and shall not copy, disclose, or distribute any Confidential
Information or any part thereof without the permission of the Submitting Entity.
Disclosure of Prior Work at ERCOT and Texas RE
Consultant must disclose on the attached Disclosure Form: (i) all dates (beginning date through end date)
during which Consultant was employed by ERCOT or Texas RE in the past and (ii) all dates (beginning
date through end date) during which Consultant performed services for ERCOT or Texas RE in the past.

Conflicts of Interest
ERCOT consultants must conduct ERCOT’s business with total objectivity and without any influence from
any Conflict of Interest and must avoid situations in which their personal interests conflict or appear to
conflict with the interests of Texas RE, ERCOT, or any Registered Entity (as defined by the NERC Rules
of Procedure) or ERCOT Market Participant (as defined in the ERCOT Protocols). An ERCOT “Market
Participant” includes a person or entity doing business in the ERCOT Region as a Qualified Scheduling
Entity, Load Serving Entity, Resource Entity, TCR Account Holder, CRR Account Holder, Renewable
Energy Credit (REC) Account Holder or Transmission and/or Distribution Service Provider. “Conflicts of
Interest” include, but are not limited to, situations where a consultant or his or her spouse, dependent, or


CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 20 OF 23            ERCOT LIMITED
a member of his or her household or immediate family (i.e. father, mother and siblings):
      1. Stands to gain or lose personally from a Texas RE or ERCOT business decision, other than
          the performance of services for Texas RE under a statement of work;
      2. Is employed by any Registered Entity, ERCOT Market Participant, any other Division of
          ERCOT, any Texas RE or ERCOT supplier or vendor or any other entity dealing with Texas
          RE or ERCOT, directly or indirectly, such that the consultant’s decisions, recommendations
          or other actions on behalf of Texas RE might be affected by the interest.
Other potential conflicts of interest include situations where a Texas RE consultant is aware of the fact
that his/her spouse, dependent, a member of his/her household or immediate family:
        1. Has ownership of or a controlling interest in any Registered Entity or ERCOT Market
           Participant, Texas RE or ERCOT supplier or vendor or any other entity doing business,
           directly or indirectly, with Texas RE or ERCOT; or
        2. Serves in an advisory, consulting, technical or management capacity for any other division of
           Texas RE, ERCOT or any Registered Entity or ERCOT Market Participant.

Consultants must disclose all potential conflicts of interest but need not disclose ownership of publicly-
traded equity securities of a Texas RE or ERCOT vendor or supplier (so long as the vendor or supplier is
not a Registered Entity or an ERCOT Market Participant) if the securities are held as an investment and
the consultant or related party: (a) owns less than one percent (1%) of the outstanding securities of the
entity, (b) does not have representation on the entity’s board of directors (or equivalent managing entity),
and (c) does not exercise influence over the entity’s day-to-day management decisions.

Consultants may not trade in securities of third-parties (including, but not limited to, vendors, suppliers,
ERCOT Market Participants or Registered Entities) if, because of their position with Texas RE, they have
material non-public information about that third-party.

I understand that I may not offer any cash or non-cash gifts to any Texas RE employee because such
gifts may affect or appear to affect the judgment of the person receiving the gift. Payment or acceptance
of bribes, kickbacks or other improper payments while conducting Texas RE’s business is strictly
prohibited.

A consultant must immediately inform the Texas RE Chief Compliance Officer (“CCO”) or a representative
from Texas RE’s Legal Department if a Conflict of Interest or even the appearance of a Conflict of Interest
might exist, to allow Texas RE management to evaluate the situation. After full disclosure by the
consultant, Texas RE may agree to conditions that appropriately limit any potential influence from a
Conflict of Interest.

Antitrust Laws
Consultants must abide by Texas RE Antitrust Compliance Corporate Policy (TRE POL 5.0) and all
applicable antitrust laws.

Non-Solicitation
In consideration for receiving Texas RE’s Confidential Information and retention by Texas RE, consultants
shall not, while working for Texas RE and for a period of six months after ceasing to work for Texas RE,
either directly or indirectly solicit, induce or encourage any Texas RE or ERCOT employee to either
terminate employment with Texas RE or ERCOT or accept employment with any other entity. The term
“solicit, induce or encourage” includes, but is not limited to, initiating communications with a Texas RE or
ERCOT employee relating to possible employment, offering bonuses or additional compensation or
referring Texas RE or ERCOT employees to personnel, recruiters or other agents.




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 21 OF 23            ERCOT LIMITED
Notice
Any Texas RE consultant who has concerns or questions about these requirements and prohibitions
should contact Texas RE Legal or CCO. Any consultant who becomes aware of a violation of the Code
of Conduct or the appearance of a violation of the Code of Conduct, by any person must immediately
notify either Texas RE Legal or the ERCOT Legal Department or file an anonymous report through
EthicsPoint (www.ethicspoint.com or 1-866-384-4277) or other available ERCOT anonymous reporting
tool, if any.

Consultant Agreement
By signing below, I hereby confirm and acknowledge that I have read and understand: (i) the
requirements of the NERC Rules of Procedure, the ERCOT Code of Conduct; (ii) the Antitrust
Compliance Corporate Standard (CS1.10), the Confidentiality Corporate Standard (CS5.19); the Fraud
Prevention and Whistleblower Corporate Standard (CS5.38), the Acceptable Use Corporate Standard
(CS7.1); (iii) the Consultant Handbook; and (iv) this Consultant Ethics Agreement. I agree to be bound by
and comply with all requirements and the intent of these requirements set forth in those documents and
will be subject to contract termination, injunction and/or all other available legal or equitable remedies if I
violate the NERC Rules of Procedure, ERCOT Standard, the Code of Conduct, this Ethics Agreement, or
the intent behind them, whether my violation is intentional or careless. If I have signed any previous
Texas RE or ERCOT Ethics Agreement, I further confirm that I have complied with those requirements
since the date of such previous Ethics Agreement(s).


Consultant Signature:                                               Date:
Printed Name:
Consultant Employer:                                                TRE Contact:




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 22 OF 23               ERCOT LIMITED
                                       Disclosures of Information
                         Complete this Form and send to Texas RE Legal


After reviewing the ERCOT Code of Conduct and Texas RE Consultant Ethics Agreement, I
wish to disclose the following information:
Check this box if you have no conflicts of interest to report:
Please remember to sign the form, below.




Signature:


Printed Name:                                        Date:


Legal Review By:                                             Date:


                                       [Add more pages, if necessary]




CS1.7 CODE OF CONDUCT AND ETHICS CORPORATE STANDARD 081809   PAGE 23 OF 23   ERCOT LIMITED

								
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