AEP Sustainability - Ethics & Compliance

Ethics and Compliance

At AEP, we are committed to health, safety, financial, operational and environmental compliance while holding ourselves to a high standard of ethical conduct – always doing what is right.

AEP’s Principles of Business Conduct places responsibility for acting legally and ethically with every individual – from the Board of Directors and management to employees on the front line. We want employees to speak up, ask questions and report potential violations without fear of retaliation. Our culture supports the interests of both employees and AEP by maintaining a vigilant approach to practicing compliance and acting with integrity. We will continue to build a reputation of trust by holding people accountable and taking appropriate actions when necessary.

In 2018, we updated the Principles of Business Conduct to reflect our cultural transformation and to provide clear direction on our expectations. For example, we enhanced the section on social media to remind employees that they represent the company, even when off the job. We also added a section on our supplier diversity initiatives and highlighted the importance of sustainability and protection of personally identifiable information (PII). We rolled out mandatory training on the updated Principles to all employees. The training consists of evaluating several distinct scenarios in some of our higher-risk areas such as conflicts of interest, appropriate use of company assets, fraud, management of PII, intellectual property and insider information and trading.

The Committee on Directors and Corporate Governance of the Board oversees AEP’s Corporate Compliance Program and receives regular reports from the Chief Compliance Officer.

Our Ethics & Compliance team (including our Chief Compliance Officer) met with employees across AEP in 2018 to raise awareness of our programming and conduct comprehensive work group culture assessments.

Starting in 2019, all employees will be required annually to complete a conflict of interest disclosure as part of their mandatory training. This new process of soliciting potential conflicts of interest will be centralized and documented electronically, allowing our Ethics & Compliance department to review and clear (or flag) conflicts as needed. Our intent is to share what we learn with employees and managers to continuously set clear expectations for ethical behavior.

AEP also offers a confidential 24/7 hotline that allows employees to report concerns anonymously or to seek guidance on ethical, safety or compliance matters. Additionally, we created a quarterly “Ethics Hotspot” feature for managers and supervisors to use while engaging employees on these issues. These “Hotspots” demonstrate what is acceptable or unacceptable conduct and the associated consequences that come with it.

Our Ethics & Compliance team, with input from Human Resources and Legal, identified areas where we could improve training. For example, we will begin rolling out a new Sexual Harassment Prevention Workshop for managers in 2019. We want everyone who works for us to know that abuse of any kind is not only offensive but a violation of company policy and won’t be tolerated. We are committed to providing a work environment that is free from intimidation and harassment.

As our business makes the transition to a clean energy future, we want to be more closely connected with our customers and to be a good corporate citizen. It is important to us that our employees are engaged members of their communities because they carry AEP’s reputation with them wherever they go. We strongly urge our employees to uphold our values beyond the workplace by always acting with integrity.