Technology Policy. The Company reserves the broadest possible rights to ensure that all electronic communication systems, including electronic mail (“e-mail”), voice mail, internet access and faxes, computers, peripherals and related software (“business tools”) are provided by the Company and used by Trading Representatives to perform their job responsibilities in the most productive and efficient manner. E-mail or Internet access is provided to conduct official Company business. Limited and incidental use not related to Company business must be kept to a reasonable level consistent with what would be appropriate for personal phone calls or personal e-mail usage. Users with Internet access must abide by all software license agreements, copyright laws, trademark laws, patent laws, intellectual property laws, and applicable State and Federal laws. Communications systems are the sole property of the Company and not the individual property of Trading Representatives. As such, Trading Representatives should not consider any information created or disseminated through the use of communication systems to be private. The Company reserves the right to inspect and monitor all business tools for compliance at any time. All computer systems are password protected. Each user is responsible for preserving the security of their password, workstation, and company data, which includes periodic password changes. Users are responsible for the activity performed with the User ID, whether or not they executed the task. No user shall access another user’s communication systems without express permission from the senior officer of the business unit to do so. Such permission is not necessary in the event of an audit, or other Company action referred to above. Further written policies regarding technology matters are available from the Chief Compliance Officer. Consistent with its general policy to support the development and publication of natural gas price indices, as well as the general standards embodied herein, it is the Company’s policy to furnish accurate, complete and timely trade data to approved index developers in accordance with the following principles: • Confidentiality - Trade data will be submitted only where protected by a confidentiality agreement with the index developer. • Separation from Trading Function - The NJRES Manager of Credit and Contracts is responsible for reporting trade data to index developers, for verifying the accuracy and completeness of such data, and for supervising the Company’s involvement in trade data reporting. No Trading Representatives directly involved in the trading of natural gas shall be involved in the reporting process. • Data Reported - Only bilateral, arm’s-length transactions in the physical markets with non-affiliates are reported. Financial ▇▇▇▇▇▇, financial transactions, or swaps or exchanges of gas are not reported. For each transaction, the Company endeavors to report all key terms of the transaction separately, including (a) price; (b) volume; (c) buy/sell indicator; (d) delivery/receipt location; (e) transaction date and time; and (f) term (next day or next month), but does not disclose the identity of the counterparty. • Error Resolution - The Company strives to report errors promptly as they are identified and to cooperate with the error resolution processes and timelines adopted by the index developers to which the Company reports in order to resolve any identified errors or discrepancies in reported data. The NJRES Manager of Credit and Contracts is responsible for error resolution. • Data Retention - The Company retains data relating to reported trades for not less than the period required by applicable FERC rules (currently, five years). • Audit - At least once annually, either an external or internal auditor independent from the Company’s trading and reporting departments and personnel will review the Company’s data gathering and submission process. The Company will make the results of these audits available to the index developers to which the Company submits trade data, and allow the index developers to recommend changes to improve the accuracy and timeliness of the Company’s data reporting. Consistent with the FERC Standards of Conduct for Transmission Providers as they apply to affiliates of a “transmission provider” performing “marketing functions”, Trading Representatives actively and personally engaged in marketing functions are prohibited from receiving non-public “transmission function information” from any source regarding any transmission provider affiliated with the Company. All officers, directors and employees of the Company are prohibited from acting as a conduit for the disclosure -19- of non-public transmission function information to Trading Representatives actively and personally engaged in marketing functions. As used in this Code of Conduct, “marketing functions” means the sale for resale in interstate commerce, or the submission of offers or bids to buy or sell natural gas or capacity, demand response, virtual gas supply or demand in interstate commerce; “transmission function information” means information relating to the natural gas transportation, storage, exchange, backhaul, or displacement services operations and the planning, directing, organizing or carrying out of such transmission operations, including the granting and denying of transmission service requests; and “transmission provider” means any FERC-regulated interstate natural gas pipeline or storage provider that transports or stores gas for others pursuant to FERC regulations. Transmission providers affiliated with the Company include ▇▇▇▇▇▇▇▇ Ridge, LP, but do not include any transmission provider of which the Company owns, controls or holds with power to vote less than 10 percent of the outstanding voting securities. As required under the New Jersey Resources Corporation (“NJR”) Contract Review Policy and Procedure, Administrative Procedure 90, all “Wholesale Transactions” must be reviewed under this Contract and Credit Policy for Wholesale Transactions (referred to herein as the “Policy”). A “Wholesale Transaction” includes:
Appears in 1 contract
Technology Policy. The Company reserves the broadest possible rights to ensure that all electronic communication systems, including electronic mail (“e-mail”), voice mail, internet access and faxes, computers, peripherals and related software (“business tools”) are provided by the Company and used by Trading Representatives to perform their job responsibilities in the most productive and efficient manner. E-mail or Internet access is provided to conduct official Company business. Limited and incidental use not related to Company business must be kept to a reasonable level consistent with what would be appropriate for personal phone calls or personal e-mail usage. Users with Internet access must abide by all software license agreements, copyright laws, trademark laws, patent laws, intellectual property laws, and applicable State and Federal laws. Communications systems are the sole property of the Company and not the individual property of Trading Representatives. As such, Trading Representatives should not consider any information created or disseminated through the use of communication systems to be private. The Company reserves the right to inspect and monitor all business tools for compliance at any time. All computer systems are password protected. Each user is responsible for preserving the security of their password, workstation, and company data, which includes periodic password changes. Users are responsible for the activity performed with the User ID, whether or not they executed the task. No user shall access another user’s communication systems without express permission from the senior officer of the business unit to do so. Such permission is not necessary in the event of an audit, or other Company action referred to above. Further written policies regarding technology matters are available from the Chief Compliance Officer. Consistent with its general policy to support the development and publication of natural gas price indices, as well as the general standards embodied herein, it is the Company’s policy to furnish accurate, complete and timely trade data to approved index developers in accordance with the following principles: • Confidentiality - Trade data will be submitted only where protected by a confidentiality agreement with the index developer. • Separation from Trading Function - The NJRES Manager of Credit and Contracts is responsible for reporting trade data to index developers, for verifying the accuracy and completeness of such data, and for supervising the Company’s involvement in trade data reporting. No Trading Representatives directly involved in the trading of natural gas shall be involved in the reporting process. • Data Reported - Only bilateral, arm’s-length transactions in the physical markets with non-affiliates are reported. Financial ▇▇▇▇▇▇, financial transactions, or swaps or exchanges of gas are not reported. For each transaction, the Company endeavors to report all key terms of the transaction separately, including (a) price; (b) volume; (c) buy/sell indicator; (d) delivery/receipt location; (e) transaction date and time; and (f) term (next day or next month), but does not disclose the identity of the counterparty. • Error Resolution - The Company strives to report errors promptly as they are identified and to cooperate with the error resolution processes and timelines adopted by the index developers to which the Company reports in order to resolve any identified errors or discrepancies in reported data. The NJRES Manager of Credit and Contracts is responsible for error resolution. • Data Retention - The Company retains data relating to reported trades for not less than the period required by applicable FERC rules (currently, five years). • Audit - At least once annually, either an external or internal auditor independent from the Company’s trading and reporting departments and personnel will review the Company’s data gathering and submission process. The Company will make the results of these audits available to the index developers to which the Company submits trade data, and allow the index developers to recommend changes to improve the accuracy and timeliness of the Company’s data reporting. Consistent with the FERC Standards of Conduct for Transmission Providers as they apply to affiliates of a “transmission provider” performing “marketing functions”, Trading Representatives actively and personally engaged in marketing functions are prohibited from receiving non-public “transmission function information” from any source regarding any transmission provider affiliated with the Company. All officers, directors and employees of the Company are prohibited from acting as a conduit for the disclosure -19- of non-public transmission function information to Trading Representatives actively and personally engaged in marketing functions. As used in this Code of Conduct, “marketing functions” means the sale for resale in interstate commerce, or the submission of offers or bids to buy or sell natural gas or capacity, demand response, virtual gas supply or demand in interstate commerce; “transmission function information” means information relating to the natural gas transportation, storage, exchange, backhaul, or displacement services operations and the planning, directing, organizing or carrying out of such transmission operations, including the granting and denying of transmission service requests; and “transmission provider” means any FERC-regulated interstate natural gas pipeline or storage provider that transports or stores gas for others pursuant to FERC regulations. Transmission providers affiliated with the Company include ▇▇▇▇▇▇▇▇ Ridge, LP, but do not include any transmission provider of which the Company owns, controls or holds with power to vote less than 10 percent of the outstanding voting securities. As required under the New Jersey Resources Corporation (“NJR”) Contract Review Policy and Procedure, Administrative Procedure 90, all “Wholesale Transactions” must be reviewed under this Contract and Credit Policy for Wholesale Transactions (referred to herein as the “Policy”). A “Wholesale Transaction” includes:
Appears in 1 contract