At FirstEnergy, Ethics Powers Excellence

Hey, Bill. Good to see you.

And Bill, you know what I would add to that? When I look back to when I arrived at the company in 2021, it was very clear that we needed to establish trust and transparency in our program and to really rebuild the program. And as we went about doing that, it became very clear that it was important that we not only had the right program structures and people, but also the cultural commitment across everybody at the company from the board on down that integrity is something that's unwavering for the company and something that we really are that it is truly part of the fabric of what the company does. So as we went about doing that, we established a program where we had a series of actions that we tracked and very publicly to all of our stakeholders communicated on and our stakeholders not only internally but also externally like our shareholders and we went about that work in a very transparent and methodical way where we clearly communicated the efforts that were going on, the status of them as we completed them. We let people know and I believe that because we were so transparent and intentional about that approach, it really did end up creating greater trust in the company because people could see what we were doing, could measure it, and they could feel it as far as the employees. And it is something that I think Brian and I hear frequently from employees that employees appreciate this commitment and this effort to really embed integrity into everything that we do.

And Bill, what I would add to that is whenever we think about ethics and integrity, we think about it as being a foundational aspect of everything that we do. It is one of the values for the corporation. And it is something that we try to deeply embed in everything that we do. And a couple of the ways in that we do that is the chief ethics and compliance officer is part of Brian's team. I am very fortunate to sit with the rest of what we call our executive council which is our senior most committee of management. And as a result of being part of that group, the ethics and compliance team and integrity as a cultural value is part of all of our conversations. It's part of our strategy retreat with our board. It's part of our conversations about how we're doing operationally. So when we discuss ethics and compliance is not a one-off program or a siloed function. It is part of the company's business strategy and we treat it as such and we hold it accountable as such. So the office of ethics and compliance has operational metrics that it has to accomplish and we report out on it not just to Brian and his management team but out to all employees. And again, I think that tends to also drive greater trust because of the level of transparency around what we're doing. The other thing that I would add is that we are very intentional about our risk assessment. Something that Brian, his team, and managers and employees throughout the company participate in. And we look to see are we spending our time, money, effort in the right things. So, we assess our risks. We compare our risks against our business strategies and the efforts that we have ongoing and we make sure that we rightsize those approaches so that they're tailored to really mitigate to the things that we're really concerned about. So we try really really hard that it's not a one-size-fits-all that it's responding to the needs of management and the company and employees.

And as you think about that population that we just talked about, those middle managers, they often are part of the secret ingredient to unlocking what we always talk about being the operationalization of the ethics and compliance program, right? It's not just something that sits on a shelf. It's not a poster. It's not just your code of conduct that people might open it up to see if they're in trouble when they did something. You try to make sure that this group of people because we know from our employee surveys how this group of people acts, how they communicate with employees has a disproportionate amount of impact to how employees perceive the company's commitment to ethics and compliance. So as a result, we spend a lot of time and effort and resources on really providing that group of people what they need so they can effectively lead. And the way we do that, I'll highlight things that we do that I think are very effective. One, we have established a resource center internally where the managers and supervisors can go and receive training tidbits of information about, you know, if they want to do an integrity minute, what should they cover? How do they do that? On demand training that relates to concern management and creating a good and healthy psychologically safe work environment. So, we try to meet employees where they are and try to make sure that they receive that information in the way that is easiest for them. They're not having to figure out these things on their own. The other thing that we do is that we provide these managers a council, an integrity council which is director employees at that level of employee at the company come together once a quarter with the leadership team of the office of ethics and compliance and they give us feedback. We're very intentional about asking them how are we helping you? Is the training that we're providing you something that meets your expectations? Did you find it boring? Tell me more about that. Really have a very open and candid conversation. And Brian and I talk about these kind of things all the time when he gets his insider trading training. I get live feedback about how him and others feel and that is I think one of the things that is kind of the secret sauce of a good program which is that you're always listening to your internal customers and that the program is giving them what they need. Oftentimes we see sometimes programs are very focused on what the program needs. We really need to move it out to our internal clients and what do they need? What is it that supports them in ensuring that they are being compliant and acting with integrity?

Bill, very hard to follow that. The one thing I'll say and it is something that over my 20 years of doing this that has become more important to me is the performing of a compliance risk assessment. It sounds very in the weeds. It sounds granular. It sounds maybe not as strategic, but it is one of the best ways for you to get a sense for what is it that the company really needs from the program. And we all have limited resources. So when you're trying to prioritize the resources that you have, it's so much better to have that be a metrics driven conversation where you have assessed where the risks of the company sit. You've assessed the quality of the controls that you've placed to prevent those risks or mitigate them and then you can be very purposeful and intentional about where you apply the resources and the people that you have so that you get the best bang for your buck if you will.