Price Reporting Code of Conduct

In accordance with Federal Energy Regulatory Commission's Price Reporting Policy Statement in Docket No. PL03-3 , Morgan Stanley Capital Group Inc. ("MSCG") has adopted the following Price Reporting Code of Conduct. The MSCG Price Reporting Code of Conduct is intended to comply with the requirements of the Federal Energy Regulatory Commission, Commodity Futures Trading Commission, and all other applicable governmental bodies and to reflect and preserve the high standards of business conduct that MSCG expects of its employees. 

All employees that work for or provide services to MSCG in connection with wholesale electricity or natural gas transactions in the United States are expected to comply with the following principles in order to assure that MSCG's reputation is protected and that its obligations under applicable laws and regulations are fulfilled. MSCG is committed to:

  • Full compliance with all applicable laws and regulations that affect MSCG;
  • Full compliance with applicable tariffs, rules and regulations of transmission providers, trading platforms and similar organizations whose services MSCG employs to conduct its business;
  • Accurately reporting relevant transaction data as required by applicable laws, regulators, transmission providers and MSCG's agreements with other parties;
  • Accurately reporting relevant transaction data to all wholesale electricity or natural gas index publishers to which MSCG provides information;
  • Separating, within the company, wholesale electricity or natural gas index reporting responsibilities from trading functions;
  • Maintaining accurate records of wholesale electricity or natural gas transactions and business dealings in compliance with MSCG's internal policies, applicable accounting rules and policies, agreements with counterparties, and all applicable laws and regulations; and
  • Holding its employees to a high ethical standard in dealing with each other and with others, including MSCG's suppliers and customers.

Compliance with the foregoing principles is every employee's responsibility. Any employee who has questions or concerns regarding applicable laws or regulations or the proper application of these principles in particular situations arising from MSCG's commercial activities in the U.S. wholesale electricity or natural gas markets is expected to raise those questions or concerns with his or her superiors or with Morgan Stanley's Law Division. Any employee who is uncomfortable raising his or her concerns with a particular superior or individual should nevertheless present those concerns to attorneys responsible for legal compliance by MSCG. 

These principles of conduct are in addition to all other guidelines that MSCG or its parent company may give to its employees with respect to their conduct and the company's dealings with others.