TRANSMISSION SYSTEM, L.P.
CONDUCT FOR TRANSMISSION PROVIDERS
Transmission System, L.P. (“Iroquois”), as an interstate natural gas pipeline
company, is a Transmission Provider, and is required to comply with the
regulations promulgated by the Federal Energy Regulatory Commission (“FERC”) in
Standards of Conduct for Transmission Providers, Order No. 717 (73 FR 63796
(October 27, 2008)) )), on reh’g, Order No. 717-A (Oct. 15, 2009) (“Standards
of Conduct”). The Standards of Conduct rules are codified at 18
C.F.R. Part 358.
procedures (“SOC Written Procedures”) reflect Iroquois’ commitment to comply
fully with the letter and spirit of the Standards of Conduct.
Specifically, these SOC Written Procedures advance the four general principles
of the applicable FERC regulations:
- First, Iroquois commits
that it shall treat all transmission customers, affiliated and
non-affiliated, on a not unduly discriminatory basis, and that it shall
not make or grant any undue preference or advantage to any person or
subject any person to any undue prejudice or disadvantage with respect to
any transportation of natural gas. This principle is referred to as “The
Non-Discrimination Requirements.” (§ 358.2(a)).
Iroquois commits that all of its employees, contractors, consultants
and agents engaged in transmission function activities (“Transmission Function
Employees,” as further explained below) shall function independently from the
employees of its affiliates engaged in marketing function activities (which
shall be referred to herein as Iroquois’ “Marketing Function Employees,” as
further explained below). This principle is referred to as “The Independent
Functioning Rule.” (§ 358.2(b)).
- Third, Iroquois commits
that its employees, contractors, consultants and agents are prohibited
from disclosing, or using a conduit to disclose, non-public transmission
function information to Iroquois’ Marketing Function Employees. This
principle is referred to as “The No Conduit Rule.” (§ 358.2(c)).
- Fourth, Iroquois commits
to provide equal access to non-public transmission function information to
all of its customers, affiliated and non-affiliated, except in the case of
confidential customer information or Critical Energy Infrastructure
Information, and generally to comply with the Commission’s posting
requirements so that interested persons and the Commission can confirm
Iroquois’ adherence to the foregoing principles. This principle is
referred to as “The Transparency Rule.” (§ 358.2(d)).
Any questions about
these SOC Written Procedures or about Iroquois’ compliance with the Standards
of Conduct should be addressed to Iroquois’ Chief Compliance Officer, Helen
M. Gallagher, as follows:
By mail: One Corporate Drive, Suite 600, Shelton, CT 06484
By e-mail: firstname.lastname@example.org
Iroquois has established a specific subject-matter category on its telephone
hotline for Standards of Conduct reports/inquiries. The hotline number is:
Any person with
knowledge or concerns regarding activities that may be in violation of these
SOC Written Procedures or Iroquois’ compliance with the Standards of Conduct
must report them immediately, either directly to Iroquois’ Chief Compliance
Officer or to the Iroquois hotline. There will be no retaliation for reports
made in good faith.
Iroquois takes its
responsibility to promote full compliance with the Standards of Conduct
very seriously. Any Iroquois Personnel (as defined below) determined to have
engaged in a knowing, willful violation of these SOC Written Procedures shall
be subject to heavy sanction, including (among other possible disciplinary
actions) discharge, civil action, and/or criminal prosecution.
AND IROQUOIS TRANSMISSION FUNCTION EMPLOYEES
Iroquois is operated
by its wholly-owned subsidiary, Iroquois Pipeline Operating Company (“IPOC”).
For purposes of compliance with the Standards of Conduct generally and
with these SOC Written Procedures in particular, all employees of IPOC shall be
treated as if they were employees of Iroquois.
As used in these SOC
Written Procedures, the term “Iroquois Personnel” shall include (i) the Members
of the Iroquois Management Committee, (ii) all employees of IPOC, and (iii) all
contractors, consultants or agents of Iroquois who act as Transmission Function
Employees (as described below).
In addition to
responsibilities that apply to Iroquois and all Iroquois Personnel, the Standards
of Conduct establish certain additional responsibilities for the Iroquois
Personnel determined to be “Transmission Function Employees.” These personnel
include employees, contractors, consultants and agents of Iroquois who actively
and personally engage on a day-to-day basis in transmission functions. Transmission
functions are comprised of the planning, directing, organizing or carrying out of
day-to-day transmission operations, including the granting and denying of
transmission requests. Field, maintenance, construction, engineering, and
clerical employees who are not normally involved in the day-to-day operation of
the pipeline system will not be considered Transmission Function Employees.
Transmission Function Employees include the following employees of IPOC:
President & General Counsel
Vice President, Marketing, Development & Commercial Operations
Vice President, Engineering & Operations
Director of Legal Services & Secretary
Development & Commercial Operations
Director, Market Development & Customer Service
Market Development Manager
Manager, Commercial Operations & Gas Control
Chief System Controller
Senior System Controller
Manager, Transportation Systems
Capacity Marketing & Asset Optimization Manager
Contracting & Credit Services Representative
Transportation Services Coordinator
Senior Business Analyst
Senior Engineer, Planning
Project Development Manager
Transportation Services Representative
Senior Transportation Representative
Treasurer and Director, Finanacial Services
Senior Staff Accountant
Manager, Field Operations & ROW
Manager, Engineering Services
Senior Engineer, Pipeline Integrity
Senior Engineer, Compression Integrity
Engineer, Electrical & Controls
Senior Engineer, Major Projects
Senior Engineer, Measurement
Senior Pipeline Engineer
Senior Engineer, Electrical & Controls
MARKETING FUNCTION EMPLOYEES
The Standards of
Conduct define “marketing functions” in the natural gas context as the sale
of natural gas for resale in interstate commerce, or the submission of offers
to sell natural gas in interstate commerce, with the exception of (i) bundled
retail sales, (ii) incidental purchases of gas to operate interstate pipeline
transmission facilities, (iii) sales from the seller’s own natural gas
production, (iv) sales from the seller’s own gathering or processing
facilities, and (v) sales by an intrastate gas pipeline, a Hinshaw pipeline, or
a local distribution company making an on-system sale. The act of purchasing
natural gas (i.e., for consumption by an electric generation facility)
is not considered a marketing function for Standards of Conduct
Iroquois is a
transportation-only pipeline that does not offer natural gas sales service and
therefore does not itself engage in any marketing functions. Thus, no
employees of IPOC or contractors, consultants or agents of Iroquois are
Marketing Function Employees.
Based on prior FERC
rulings and the definition of “affiliate” in the Standards of Conduct (§
358.3(a)), Iroquois’ only corporate affiliation, for Standards of Conduct
purposes, is with TransCanada PipeLines, Limited (“TransCanada”). The
following affiliates of TransCanada have been determined to engage in marketing
TC Ravenswood, LLC
TransCanada Energy Ltd.
TransCanada Power Marketing Ltd.
TransCanada Gas Storage USA, Inc.
contractors, consultants or agents of the foregoing affiliates of Iroquois that
engage in marketing functions are therefore deemed under the Standards of
Conduct to be Iroquois Marketing Function Employees. Those individuals
have been identified to Iroquois’ Chief Compliance Officer by its
affiliates, and those affiliates have been charged with notifying Iroquois’
Chief Compliance Officer promptly in the event of any change in such
personnel. Iroquois’ Chief Compliance Officer shall provide this
identifying information to all Iroquois Transmission Function Employees and
promptly provide notification of any changes received from the affiliates. In
addition, Iroquois’ Transmission Function Employees shall be notified of the
function and job responsibilities of an Iroquois Marketing Function Employee,
and shall be instructed to treat as an Iroquois Marketing Function Employee any
employee, contractor, consultant or agent of the above-named Iroquois
affiliates that engages in marketing functions, regardless of whether such
individual has been identified to Iroquois as an Iroquois Marketing Function
general Commission policy, in the event that Iroquois enters into a merger
agreement with another company, Iroquois shall treat all employees,
consultants, contractors or agents of any affiliates of its merger partner that
engage in marketing function activities as if they were Iroquois Marketing Function
Employees during the pendency of the merger transaction.
TO COMPLY WITH THE NON-DISCRIMINATION REQUIREMENTS.
The Standards of
Conduct require Iroquois to ensure that it and all Iroquois Personnel
refrain from unduly discriminating in favor of, or against, any shipper,
whether affiliated or not affiliated. Accordingly, and in conjunction with the
other policies and procedures established herein, Iroquois is establishing and
implementing the following rules and procedures to comply with the
Enforcement of Tariff Provisions (§ 358.4(a))
FERC Gas Tariff provisions that do not permit the use of discretion shall be
strictly enforced. In the event that Iroquois deems circumstances to warrant
any divergence from a non-discretionary tariff requirement, Iroquois shall seek
approval for such divergence from FERC and shall make any such divergence
available on a non-discriminatory basis to all similarly situated shippers.
B. Fair, Impartial, Non-Discriminatory Exercise of Tariff
Discretion (§§ 358.4(b) and 358.7(i))
1. All Iroquois FERC Gas Tariff provisions that permit the use
of discretion shall be administered in a fair and impartial manner that treats
all shippers on a not unduly discriminatory basis.
2. In the event that a waiver is granted to an Iroquois
affiliate that engages in marketing functions (i.e., any of the
companies identified in Section III., above), the Iroquois Transmission
Function Employee responsible for granting the waiver shall notify the Iroquois
employee responsible for administering Iroquois’ internet website postings so
that the necessary information may be posted as set forth in Section VI.D.4.,
C. No Undue Preference in Sale of Transmission Services (§
358.4(c) and (d))
1. Iroquois shall not, through the administration of its FERC
Gas Tariff or otherwise, give undue preference to any shipper or prospective
shipper in matters relating to its sale of transmission service, including but
not limited to issues of price, curtailment, scheduling, or balancing.
2. All similar requests for service shall be processed in the
same manner and within the same period of time.
3. When receiving telephone, e-mail or other inquiries from
third parties regarding the status or availability of transmission service,
Iroquois Personnel shall disclose to Marketing Function Employees only
information that has been posted on Iroquois’ internet website, Iroquois OnLine
(“IOL”) or that is otherwise available to the general public without
restriction. Changes in the status or availability of transmission service
shall not be disclosed until IOL has been updated.
TO COMPLY WITH THE INDEPENDENT FUNCTIONING AND “NO CONDUIT” RULES.
of Conduct require Iroquois to ensure that its Transmission Function
Employees function independently from the Iroquois Marketing Function Employees,
except in emergency circumstances. In this regard, Iroquois is required to
maintain and enforce procedures for preventing access by its Marketing Function
Employees to non-public transmission system and customer information, and for
ensuring that No Iroquois Personnel act as, or utilize a third party to act as,
a conduit for the conveyance of non-public transmission or customer
information. The following policies and procedures implement these rules.
A. Procedures for Maintaining Separation of Functions (§
358.5(a) and (b))
Iroquois Transmission Function Employees are prohibited from engaging in
marketing functions, as those functions are defined in Section III, above.
Iroquois Marketing Function Employees are prohibited from engaging in or
conducting any Iroquois transmission functions, except in Emergency
Circumstances as provided in Section V.E.
All communications between Iroquois Personnel (other than senior
management personnel) and Iroquois Marketing Function Employees should be
disclosed to the Iroquois Personnel’s immediate supervisor so that a
determination can be made whether additional steps should be taken to ensure
compliance with these SOC Written Procedures.
Subject to the exceptions set forth in Sections V.E. and F., below,
Iroquois Personnel are prohibited from disclosing to an Iroquois Marketing Function
Employee any transmission function information pertaining to Iroquois that is
not already posted on IOL or otherwise publicly available without restriction.
All communications with Iroquois Marketing Function Employees pertaining
to the status or availability of transmission service shall be handled in
conformity with the procedures set forth in Section V.F. of these SOC Written
Particular care must be exercised by Iroquois Personnel when
communicating non-public information pertaining to Iroquois’ transmission
system operations through electronic media such as e-mail, in order to protect
the confidentiality of such information and avoid inadvertent dissemination to
a distribution list that may include an Iroquois Marketing Function Employee.
B. “No Conduit” Restrictions (§ 358.6)
1. Iroquois is prohibited from using anyone as a conduit for the
disclosure of non-public transmission function information to any Iroquois
Marketing Function Employee.
2. All Iroquois Personnel, as well as all contractors,
consultants, and agents of Iroquois and all employees, contractors, consultants
and agents of the affiliates of Iroquois that are engaged in marketing
functions are prohibited from disclosing non-public transmission function
information to any Iroquois Marketing Function Employee.
C. Procedures for Limiting Access to Facilities and
Information Systems (§ 358.5(b)(1)(ii))
All visitors to Iroquois’ corporate offices are required to register at
the reception desk and be escorted by an Iroquois employee throughout their
visit. Iroquois’ visitor log records shall be maintained by the Manager of
Administrative Services for a period of not less than three years.
Iroquois’ system control center (“Gas Control”) shall be subject to
additional restricted access protections. Access to Gas Control is controlled
by a key card access system, and key cards are only issued to authorized
Iroquois personnel. Iroquois Marketing Function Employees are prohibited from having
access to Gas Control that differs in any way from the access available to
other Iroquois shippers. Appropriate signage shall be affixed prominently to
the entrance of Gas Control to remind all entrants of the applicability of
these SOC Written Procedures and, in particular, this restricted personnel
Iroquois does not presently share any computer systems with its affiliates,
and does not anticipate developing any such sharing in the foreseeable future.
To ensure the confidentiality and protection of all non-public Iroquois
transmission and customer information, Iroquois’ Information Technology (“IT”)
department has erected and maintains appropriate password requirements,
firewalls and other security measures for all of the pipeline’s information
systems. The IT department shall conduct an annual review of passwords,
firewalls and other security measures to ensure that the integrity of Iroquois’
information systems are not compromised.
D. Procedures for Maintenance of Independent Books and Records
Iroquois maintains its books and records (as specified under 18 C.F.R.
Parts 201 and 225) separately from the books and records of any of its affiliates
that employ or retain Marketing Function Employees.
Iroquois’ Treasurer and Director of Financial Services shall restrict access to all non-public books and
records relating to Iroquois’ transmission system operations, and ensure that
such books and records are not accessible to Iroquois Marketing Function Employees.
Applicable to Emergency Circumstances Affecting System Operations or Reliability
(§ 358.7(h), § 358.7(g)(2))
Iroquois Personnel are authorized to deviate from these SOC Written
Procedures as necessary to keep Iroquois’ transmission system in operation
during emergency circumstances that affect system reliability, such as an
earthquake, flood, fire or hurricane that severely disrupts Iroquois’ normal
business operations (“Emergency Conditions”).
In Emergency Conditions, if required, Transmission Function Employees
may call upon Iroquois Marketing Function Employees to assist in maintaining
system operations or restoring the system to a normal operating state.
In the event of an Emergency Condition in which Iroquois’ Transmission
Function Employees and Marketing Function Employees exchange any non-public
information, the supervisor of the affected Iroquois Transmission Function
Employee(s) shall direct the creation of a record of such exchange. The record
shall be made either contemporaneously or as soon as practicable after the
fact, and shall take the form of written or electronically or telephonically
recorded notes. The record shall be forwarded to the Iroquois Chief
Compliance Officer and shall be retained by Iroquois for a period of not less
than five (5) years. The report shall include:
a. The nature of the Emergency Condition, as well as the date on
which it occurred and its duration;
b. The names of all Iroquois Transmission Function Employees and
Marketing Function Employees who engaged in such sharing of non-public transmission
function information; and
c. A summary or description of the non-public information shared.
4. In Emergency Conditions, if required, Iroquois may
temporarily suspend its posting requirements as provided in these SOC Written
Procedures. However, if the disruption lasts for longer than one (1) month,
Iroquois shall notify the FERC and, as necessary, seek approval for a further
exemption from the posting requirements.
F. Procedures Applicable to Permitted Communications
Pertaining to An Affiliate’s Request for Service (§ 358.7(b))
1. Iroquois Personnel, including Transmission Function
Employees, are permitted to communicate with Iroquois Marketing Function
Employees, and are not required to publicly disclose, information that relates
solely to that Marketing Function Employee’s specific request for transmission
service or interconnection.
2. All requests by Marketing Function Employees for new
transmission service shall be handled through IOL or in accordance with other
procedures specified in Iroquois’ FERC Gas Tariff that are available and
applicable to all Iroquois shippers.
G. Procedures Governing Use of Third Party Contractors and
With respect to
all contractor/consultant relationships entered into by Iroquois in which the
contractor/consultant shall function as a Transmission Function Employee,
Iroquois shall (a) require that individual to refrain from acting as an
Iroquois Marketing Function Employee for the duration of his or her engagement
as an Iroquois Transmission Function Employee, (b) treat the
contractor/consultant as a “new employee” for purposes of dissemination of, and
training regarding, these SOC Written Procedures, and (c) establish additional
protocols, as necessary, to protect the confidentiality of Iroquois
transmission system and customer information.
H. Procedures for Collection and Maintenance of Transportation
Discount Information (§ 250.16(d))
1. Iroquois’ Marketing, Development and Commercial Operations
Department shall create a record of the following information for each
discounted rate transaction and for each billing period:
The name of the shipper and whether it is an affiliate or whether
an affiliate is involved in the transaction (and if so, what that affiliate’s
role is - i.e., shipper, marketer, supplier, seller),
The rate or fee actually charged during the billing period,
The maximum rate,
The time period for which the discount will apply,
The quantity of gas scheduled at the discounted rate,
The delivery point(s), and
Any conditions or requirements of the discount.
These discount transaction records shall be forwarded to the
Iroquois Chief Compliance Officer promptly upon their creation.
I. Exception to Information Sharing Prohibitions Following
Voluntary Consent (§ 358.7(c))
1. An Iroquois shipper may voluntarily consent, in writing, to
allow Iroquois to share the non-affiliated shipper’s non-public information
with an Iroquois Marketing Function Employee. In each such instance, the
following procedures shall be followed:
a. A copy of the consent shall be forwarded to the Director,
Market Development and Customer Service for review and confirmation and to the
Chief Compliance Officer for recordkeeping; and
b. Iroquois shall post a notice of the consent on IOL along with
a statement that it did not provide any preferences, either operational or
rate-related, in exchange for the voluntary consent.
FOR COMPLIANCE WITH THE TRANSPARENCY RULE.
of Standards of Conduct Information (§ 358.7(g))
1. “Iroquois Online” (“IOL”) is Iroquois’ electronic
website for customer transactions and information. Iroquois’ website address
is www.iroquois.com. All SOC-related information required to be posted
on Iroquois’ internet website shall be posted in the Informational Postings
section of IOL.
2. Iroquois shall update its IOL postings within seven (7)
business days of any change, and post the date on which the information was
B. Postings in the Event of Prohibited Disclosures (§
1. In the event that any non-public Iroquois transmission
function information (other than non-public shipper information or information
that is considered Critical Energy Infrastructure Information (“CEII”) or
otherwise prohibited by FERC from public disclosure) is disclosed to any
Iroquois Marketing Function Employee in violation of these SOC Written
Procedures, Iroquois will take immediate steps to post the information that was
disclosed on IOL.
2. In the event that any non-public Iroquois shipper information
or CEII or information otherwise prohibited by FERC from public disclosure is
disclosed to any Iroquois Marketing Function Employee in violation of these SOC
Written Procedures, Iroquois will take immediate steps to post on IOL a notice
of the fact of the disclosure (without posting the actual information).
C. Information Required to be Maintained in Postings
1. The following information shall be maintained on IOL:
A copy of these SOC Written Procedures, as such may be updated
from time to time. (§ 358.7(d))
The name and contact information of Iroquois’ Chief
Compliance Officer and telephone number of Iroquois’ SOC hotline. (§
The names and addresses of all affiliates that employ or retain
Marketing Function Employees. (§ 358.7(e)(1))
A list of all employee-staffed facilities shared by Iroquois and
any Iroquois Marketing Function Employees. (§ 358.7(e)(2))
The job titles and job descriptions of all Iroquois Transmission
Function Employees. (§ 358.7(f)(1))
D. Other Periodic Standards of Conduct Postings
1. Posting of Employee Transfer Information (§ 358.(f)(2))
transfers between the transmission function and the marketing function are
permissible so long as they are not used as a means to circumvent any provision
of the Standards of Conduct rules. When an Iroquois Transmission
Function Employee transfers to a position as an Iroquois Marketing Function
Employee, or vice versa, the following information shall be posted and remain
on IOL for 90 days:
The name of the transferring employee;
The titles the employee held while performing each function; and
The effective date of the transfer.
2. Posting of Merger Information (§ 358.7(e)(3))
concerning potential merger partners (which shall disclose such information as
would be required to be disclosed if the merger partner and its affiliates were
already affiliates of Iroquois) shall be posted on IOL within seven (7) days of
the public announcement of the proposed merger.
of Information Regarding Non-Compliance
post on IOL information detailing the circumstances and manner of any deviation
by Iroquois Personnel from these SOC Written Procedures. Such posting shall be
made within twenty four (24) hours of the determination that such a deviation
of Affiliate Waivers (§ 358.7(i))
post a notice of each waiver of any of its FERC Gas Tariff provisions in favor
of an affiliate, unless such waiver was approved by FERC. The posting shall be
made within one (1) business day of the grant of the waiver. Iroquois shall
also maintain a log of all such waivers, which shall be made available to the
Commission upon request. All waiver records shall be kept for a period of five
(5) years from the date of each act of waiver.
post information pertaining to all discount transactions as part of its firm
and interruptible transaction postings on IOL required pursuant to 18 C.F.R. §
and Audit of Posting Procedures
Compliance Officer shall monitor the informational postings required under
these SOC Written Procedures for compliance and accuracy, and shall perform
annual audits of the informational posting data collection, evaluation, and
posting process to assess whether additional procedures need to be developed.
The Standards of
Conduct require certain Iroquois Personnel and its Marketing Function
Employees to attend either in-person or electronic training sessions and to sign
or complete forms certifying that they have been trained regarding the Standards
of Conduct requirements. (§ 358.8(b) and (c).) Iroquois is implementing
the following rules and procedures to comply with these training requirements:
All Iroquois Personnel with the exception of clerical, maintenance and
field personnel shall receive Standards of Conduct training on an annual
B. All Iroquois Personnel receiving training shall be
distributed a copy of these SOC Written Procedures, and shall be required to
execute a certification declaring that they have received such procedures and
participated in such training.
C. All new Iroquois Personnel (other than clerical, maintenance
and field support personnel) shall be required to take Standards of Conduct
training within thirty (30) days of their arrival, and to certify their attendance
at such training and receipt of the SOC Written Procedures. Such new training
shall be conducted either in person or via an electronic training program.
D. Iroquois’ Chief Compliance Officer shall coordinate with
Iroquois’ affiliates that employ or retain Marketing Function Employees as well
as any Iroquois contractors, consultants or agents whose employees function as
Iroquois Transmission Function Employees to ensure compliance with the
training, certification, and SOC Written Procedures dissemination requirements,
as provided in Section VIII.B.2 and 4.
The Standards of
Conduct require that Iroquois designate a Chief Compliance Officer to be
responsible for standards of conduct compliance. (§ 358.8(c)(2).) Iroquois has
established the following duties and responsibilities for its Chief
A. As a general matter, Iroquois’ Chief Compliance Officer
shall be responsible for oversight of Iroquois’ Standards of Conduct
compliance, including the implementation of, compliance with, and periodic
updating of these SOC Written Procedures.
B. Specific responsibilities of the Chief Compliance Office
shall include the following:
The Chief Compliance Officer shall be responsible for coordinating
and supervising the dissemination of these SOC Written Procedures to all
applicable Iroquois Personnel and Iroquois Marketing Function Employees.
The Chief Compliance Officer shall be responsible for coordinating
and supervising initial Standards of Conduct training for all applicable
new Iroquois Personnel, as well as annual refresher training for all Iroquois
Personnel; provided that the Chief Compliance Officer may coordinate with
Iroquois’ affiliates to provide the training for Iroquois Marketing Function
Employees and shall coordinate with the company that employs any consultant,
contractor or agent of Iroquois that serves as an Iroquois Transmission
Function Employee for that employee to be trained regarding the Standards of
The Chief Compliance Officer shall assist in an annual
external audit of these SOC Written Procedures by one of the partners in the
Iroquois limited partnership.
The Chief Compliance Officer shall be responsible for coordination
with Iroquois’ affiliates (as defined pursuant to the Standards of Conduct
and the Commission’s regulations and orders) that employ or retain Marketing
Function Employees with respect to all aspects of compliance. Such
coordination shall include development of protocols to obtain information
regarding any changes in Marketing Function Employee personnel, the affiliate’s
dissemination of these SOC Written Procedures, initial and annual training of
Marketing Function Employees, and other compliance activities.
The Chief Compliance Officer shall maintain a hotline for customers,
competitors, and other interested parties to report any alleged or potential
violations of these procedures.
The Chief Compliance Officer shall take reasonable steps to
investigate all instances of alleged violation of these Written Procedures or
the Standards of Conduct generally, and shall report the results of such
investigations, including any recommended disciplinary actions, to the
President & General Counsel of IPOC.
The Chief Compliance Officer shall be responsible for maintaining
Iroquois’ records pertaining to the Standards of Conduct. Such records
of compliance issues and their resolution;
c. employee certifications and all other records pertaining to
d. records pertaining to permitted instances of communications
between Iroquois Transmission Function Employees and Marketing Function
Employees, as provided in Section V.E.;
e. records pertaining to discount rate transactions, as provided
in Section V.H.;
f. quarterly reports submitted to the President &
General Counsel of IPOC with respect to Standards of Conduct compliance,
as required in this section;
Standards of Conduct compliance audit reports; and
h. historical informational postings required by the Standards
pertaining to Standards of Conduct compliance shall be retained for a
period of not less than five (5) years.
The Chief Compliance Officer shall submit a quarterly written report
to the President & General Counsel of IPOC on the status of Iroquois’
compliance with the Standards of Conduct.
IROQUOIS GAS TRANSMISSION SYSTEM, L.P.
STANDARDS OF CONDUCT FOR TRANSMISSION PROVIDERS
I hereby certify that
(i) I have received and reviewed the Iroquois Gas Transmission System, L.P.
Written Procedures for Implementation of Standards of Conduct for
Transmission Providers (“SOC Written Procedures”), (ii) I have
participated in and completed either an on-line or live training session
pertaining to these SOC Written Procedures, (iii) I will comply fully with all
aspects of these SOC Written Procedures that apply to an individual with my job
responsibilities, and (iv) I will bring to the attention of my immediate
supervisor or Iroquois’ SOC Chief Compliance Officer any questions or concerns
that I have regarding these SOC Written Procedures or Iroquois’ compliance with
the Standards of Conduct for Transmission Providers.