Code of Conduct: The Power of Integrity
On July 20, 2021, the Board of Directors of FirstEnergy Corp. (the “Company”) approved and adopted a new Code of Conduct (the “Code of Conduct”), entitled “The Power of Integrity," which became effective immediately. The Code is applicable to all Directors, Officers, employees, contractors and temporary workers of the Company, including the Company’s principal executive officer, principal financial officer and principal accounting officer. The new Code of Conduct promotes and emphasizes FirstEnergy’s commitment to compliance and ethics, fosters a “speak up” culture in which stakeholders are encouraged to report actual or suspected Code of Conduct violations without fear of retaliation, improves readability, and promotes understanding of compliance commitments and expectations. Adoption of the Code of Conduct did not result in any explicit or implicit waiver of any provision of the Code of Conduct.
Policies and Reports
FirstEnergy operates in an environment where legislative and regulatory policy heavily influences how we serve customers and operate our facilities. We have a responsibility to our customers, employees, and shareholders to participate in this process. FirstEnergy has implemented this policy and associated practice to ensure we are serving our customers, employees, and shareholders consistent with our values.
FirstEnergy participates in the political and public policy processes in a manner that emphasizes transparency and integrity, supports the diverse communities in which we operate, reflects our Company’s core values, and fulfills our responsibilities to shareholders and other stakeholders. FirstEnergy is committed to compliance with our Code of Conduct and with the letter and spirit of all applicable laws and regulations
FirstEnergy’s Political & Public Engagement Policy has been adopted to promote principled engagement by the Company and its directors, officers, employees, and those acting on the Company’s behalf.
Industry Groups, Trade Associations and Related Organizations
FirstEnergy participates in trade associations and other industry groups, which allow the Company to work collaboratively with industry peers to address key public policy issues. FirstEnergy pays dues to these groups and regularly reviews the Company’s memberships to assess their alignment with the Company’s values and priorities. The Company typically does not make additional, non-dues contributions to support trade and industry groups’ political activities.
- View Corporate Contributions
- View 2020 Lobbying Portion of Trade Association Dues
- View 2019 Lobbying Portion of Trade Association Dues
- View 2018 Lobbying Portion of Trade Association Dues
- View 2017 Lobbying Portion of Trade Association Dues
FirstEnergy and our federal lobbyists are required to file reports with the U.S. Congress and state agencies on a regular basis disclosing information about their lobbying activities. The reports are available for review on the websites of the U.S. House of Representatives and the U.S. Senate, as noted below.
- FirstEnergy maintains and files Lobbying Disclosure Act Registration and Reports (Form LD-2) with the U.S. Congress. These reports detail the particular bills and issues on which individual lobbyists engaged, as well as the total lobbying expenses incurred. These reports may be found at: http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm
- FirstEnergy and its registered federal lobbyists must also file semi-annual reports detailing, among other things, disbursements and personal and/or direct contributions to federal candidates. These forms (LD-203) may be found at: http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm
FirstEnergy and/or its registered state lobbyists file periodic disclosure reports as required by the respective states across FirstEnergy’s geographic territory.
- View 2020 Federal Lobbying Reports
- View 2019 Federal Lobbying Reports
- View 2018 Federal Lobbying Reports
- View 2017 Federal Lobbying Reports
In many cases, State reports, if required, are also made available for review on the applicable state agency website.
Political Action Committee
Eligible FirstEnergy employees, as defined by the Federal Election Commission, may pool their personal financial resources to support federal, state, and local political candidates and organizations through the company’s non-partisan federal Political Action Committee, FEPAC. All FEPAC contributions are strictly voluntary and may not be coerced or reimbursed in any way.
FEPAC contributions are publicly disclosed as required on the website of the Federal Election Commission at http://www.fec.gov/.
Pursuant to FirstEnergy’s obligations in Section 5(D) (“Transparency in Corporate Contributions”) of the Deferred Prosecution Agreement filed on July 22, 2021, in United States v. FirstEnergy Corp., Case No. 1:21cr00086 (SDOH), below are lists of payments made by FirstEnergy to entities incorporated under 26 U.S.C. § 501(c)(4), and to entities known by FirstEnergy to be operating for the benefit of a public official, either directly or indirectly for time periods beginning January 1, 2021.
Payments made between January 1, 2021 - June 30, 2021:
Date Paid Organization Name Organization Address Amount Purpose 1/11/2021 Midwest Renewable Energy Tracking System Inc Lockbox 446023 PO Box 64079 Saint Paul MN 55164 $2,200.00 Subscription for services 1/20/2021-1/25/2021 Association of Certified Fraud Examiners Northeast Ohio Chapter PO Box 14715 Cleveland, OH 44114 $30.00 Membership dues 1/20/2021-3/19/2021 Association of Certified Fraud Examiners Northeast Ohio Chapter PO Box 14715 Cleveland, OH 44114 $135.00 Training 1/25/2021 National Association of Regulatory Utility Commissioners (NARUC) 1101 Vermont Avenue, NW, Suite 200, Washington, DC 20005 $3,950.00 NARUC Winter Summit registration for employee attendance 1/15/2021-6/14/2021 Midcontinent Independent System Operator, Inc. 720 City Center Dr, Carmel, IN 46032 $2,097,947.11
Payments for legacy MISO Transmission Expansion Plan (MTEP) project costs that were allocated to a FirstEnergy subsidiary, as mandated by FERC 2/2/2021 Rotary Club of Youngstown 201 E Commerce St. Suite 450 Youngstown Oh $475.00 Membership dues 3/1/2021-6/11/2021 Resolute Strategies, LLC 331 Knoll Top Lane Haddonfield, NJ 08033 $67,500.00 Regulatory and public affairs consulting 3/16/2021 Three Rivers Pollution Response Council Inc. Westmoreland City PA 15692 $1,000.00* Membership dues 3/31/2021 Potomac Edison Forerunners 22009 Mohawk Drive Smithsburg, MD 21783 $1,100.00 Employee club membership dues 5/1/2021 Lumberport Volunteer Fire Department PO Box 33, Lumberport, WV 26386 $1,000.00 Donation to local fire department 5/15/2021 I-79 Technology Park Association 1000 Technology Drive Suite 3000 Fairmont, WV 26554 $2,379.50 Building association fee for a FirstEnergy facility 5/24/2021 Minardi Public Affairs LLC 1526 Bedford Rd, Charleston, WV 25314 $12,000.00 Government relations and legislative consulting services 6/9/2021 Londonderry Fire Co. 2655 Foxianna Road
Middletown, PA 17057
$1,265.00 Donation to local fire department 6/9/2021 Lower Swatara Volunteer Fire Department 1350 Fulling Mill Road
Middletown, PA 17057
$23,052.50 Donation to local fire department
Payments made between July 1, 2021 - September 30, 2021:
Date Paid Organization Name Organization Address Amount Purpose 7/15/2021-9/15/2021 Midcontinent Independent System Operator, Inc. 720 City Center Dr, Carmel, IN 46032 $1,060,845.33 Payments for legacy MISO Transmission Expansion Plan (MTEP) project costs that were allocated to a FirstEnergy subsidiary, as mandated by FERC 7/14/2021 Greater Berks Development Fund 606 Court Street, Reading, PA 19603 $3,578.10 Purchase of a property to be used for the construction of a new area substation in Reading, PA 7/26/2021 Toledo Rotary Club 101 N. Summit St.#436, Toledo, OH 43604 $550.00 Membership dues 8/27/2021 New Wilmington Rotary Club 132 Shenago Rd., New Castle, PA 16105 $30.00 Rotary event 9/2/2021-9/27/2021 Minardi Public Affairs LLC 1526 Bedford Rd, Charleston, WV 25314 $21,000.00 Government relations and legislative consulting services 9/23/2021 Resolute Strategies, LLC 331 Knoll Top Lane Haddonfield, NJ 08033 $22,500.00 Regulatory and public affairs consulting
Payments made between October 1, 2021 - December 31, 2021:
Date Paid Organization Name Organization Address Amount Purpose 10/4/2021-12/13/2021 New Wilmington Rotary Club 132 Shenago Rd., New Castle, PA 16105 $95.00 Rotary events 10/8/2021-12/9/2021 Association of Certified Fraud Examiners Northeast Ohio Chapter PO Box 14715 Cleveland, OH 44114 $25.00 Training seminars 10/14/2021-12/14/2021 Midcontinent Independent System Operator, Inc. 720 City Center Dr, Carmel, IN 46032 $1,062,322.19 Payments for legacy MISO Transmission Expansion Plan (MTEP) project costs that were allocated to a FirstEnergy subsidiary, as mandated by FERC 11/5/2021 Resolute Strategies, LLC 331 Knoll Top Lane Haddonfield, NJ 08033 $7,500.00 Regulatory and public affairs consulting 12/10/2021 Point Marion Fire Department 1 Cheat St. Point Marion, PA 15474 $3,275.00 Payment for fire department services
Information about FirstEnergy’s subsequent Corporate Contributions, if any, will be updated here on a quarterly basis going forward.
Corporate Responsibility Website
FirstEnergy's Corporate Responsiblity Website
At FirstEnergy, corporate responsibility is about staying true to our mission, core values and commitment to integrity. It’s about understanding the impact our company can make in the world around us and choosing to do what is right and good with that opportunity. For us, that means pursuing initiatives and goals that align with our foundational principles and positively impacting all of our stakeholders. We are proud of the steps we’ve taken to demonstrate our commitment to corporate responsibility, and we look forward to continuously refining our approach and improving our performance on environmental, social and governance (ESG) matters.