NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT. Revision 1, Released June 10, 2014

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1 NRG ENERGY, INC. SUPPLIER CODE OF CONDUCT Revision 1, Released June 10, 2014 Ethics toll-free Helpline

2 Table of Contents INTRODUCTION and MESSAGE FROM CEO 3 NRG STRIVE VALUES 4 ETHICS HELPLINE AND ALERTLINE 5 HEALTH, SAFETY AND ENVIRONMENT 6 Health and Safety 6 Workplace Violence Prevention 6 Fitness for Duty 6 Community and Environment 6 CONDUCT IN THE WORKPLACE 7 Equality in Employment 7 Harassment Free Workplace 7 CONFLICTS OF INTEREST 8 Avoiding Conflict of Interest 8 Gifts and Entertainment 8 POLITICAL PROCESS 8 Political Contributions 8 Political Participation 8 INTEGRITY AND BUSINESS DEALINGS 9 NRG Assets; Dishonesty and Theft 9 Bribery and Corruption 9 COMPLIANCE WITH LAWS AND REGULATIONS 10 Antitrust Laws 10 Securities Transactions and Non-Public Information 10 Market Rules and Regulations 10 BUSINESS INFORMATION, RECORDS AND DISCLOSURES 11 Confidentiality Information 11 Accurate Recording and Reporting 11 Use of Electronic Equipment 11 Ethics toll-free Helpline

3 NRG SUPPLIER CODE OF CONDUCT To our Consultants, Contractors and Suppliers At NRG Energy, Inc. ( NRG ), we are committed to conducting our business with honesty and integrity in accordance with the highest ethical and legal standards. Quite simply, we need to live our core values so that they provide a framework for all strategies, decisions, and behaviors. consistent with our Ethics and Compliance Code and our STRIVE Values when dealing with NRG, our employees and our customers. Therefore, we have prepared this Supplier Code of Conduct to describe the minimum ethics and compliance requirements. While the Code cannot cover all circumstances or substitute for sound judgment, it does outline our key responsibilities and the guiding principles intended to support ethical and socially responsible behavior and choices. Suppliers should exercise good judgment in all of its business dealings. Abiding by the law and this Supplier Code of Conduct means acting honorably, ethically, and with integrity at all times. Each NRG supplier is responsible for ensuring that the supplier and its employees and subcontractors understand and comply with these standards. Also, the Supplier is responsible for maintaining and enforcing written company policies requiring adherence to lawful business practices. Safety Teamwork Respect Integrity Value creation Exemplary leadership Our STRIVE values are the standards by which we conduct our daily business, work with one another, and interact within our communities. The Supplier Code of Conduct (the Code ) enables suppliers to become unified around a common set of values, and to understand how they may be applied when performing work and making decisions on behalf of NRG. It is important to understand that violating this Code could result in termination as an NRG Supplier and in legal action. In addition, Suppliers may be subject to a formal assessment of compliance to these policies. There are a number of resources available when seeking guidance or reporting potential violations, including the NRG Ethics Helpline at , or the Ethics Alertline at which, if desired, allows completely confidential and anonymous reporting. NRG strictly prohibits retaliation against any individual for good faith reports or inquiries. Behaving ethically and responsibly is not just good business practice -- it is the right thing to do. NRG Consultants, contractors and suppliers of services or materials and their employees and subcontractors ( Suppliers ) shall adhere to standards of conduct in a manner that is Ethics toll-free Helpline Revision 1, Release Date: June 10, 2014

4 Ethics toll-free Helpline

5 ETHICS HELPLINE AND ALERTLINE If you see or suspect any violation of the Supplier Code of Conduct Ethics toll-free Helpline Helpline is available 24 Hours a day 7 days a week Acts of theft, fraud or embezzlement Questionable accounting, internal accounting controls or auditing matters Willful destruction of property Acts of altering, removing or destroying company records or electronically stored information Business or political dealings that reflect a real, or the appearance of a, conflict of interest or a violation of the U.S. Foreign Corrupt Practices Act Actions that violate antitrust laws or market rules Violations of health, safety, or environmental regulations Harassment, discrimination, or violence in the workplace please contact the Ethics toll-free Helpline, or the web-based Alertline, These resources are available 24 hours a day, every day of the year. All contacts are answered by an independent third party outside of NRG and you may remain anonymous. Ethics toll-free Helpline

6 HEALTH, SAFETY AND ENVIRONMENT Health and Safety At NRG, safety always comes first. NRG is committed to providing a safe and productive workplace. The integration of safety and health considerations in work related activities and processes significantly reduces the risk of injury and illness. A fundamental rule at NRG is if it isn t safe, don t do it. Suppliers performing work on NRG property or elsewhere on behalf of NRG will: Use a best practice approach to safety and health; Provide safe and healthy working environment; Operate with consideration for public safety; Participate in applicable NRG safety program training and activities; Understand and comply with all safety and health rules, regulations, and laws; Use and wear required safety equipment and clothing; Not put at risk the health or safety of others. Workplace Violence Prevention Everyone has the right to a workplace free of violence or threats. Physical or verbal threats, intimidation, coercion or violence of any kind towards NRG employees, contractors, suppliers, or a member of the public while on NRG property or conducting business on behalf of NRG will not be tolerated. NRG also prohibits the possession of weapons or other dangerous or hazardous devices on company property or in company vehicles except where law prescribes otherwise. Where can I report safety, security or environmental concerns? NRG Project Representative NRG Security NRG Environmental NRG Compliance Hotline Fitness for Duty Suppliers are required to report to work in an appropriate condition to perform duties satisfactorily. Suppliers may not use, possess, sell, distribute NRG or Ethics be Hotline under the influence of illegal drugs and/or alcohol on NRG property or while conducting business on behalf of NRG, whether on or off NRG property. Your Supervisor The legal use of prescribed drugs or over-the-counter medications is permitted on Safety the only if it does not impair an individual s ability Security to perform essential functions of the job safely and effectively. Compliance Community Legal and Environment NRG respects its local communities and strives to be a good neighbor Human Resources by conducting its operations in a manner that NRG focuses Ethics Hotline on continual improvement and meets or beats all applicable environmental laws and regulations. Suppliers shall perform work in a way that exemplifies environmental stewardship and that is in accordance with all applicable environmental laws, rules, and regulations, and adheres to NRG Environmental policies and procedures. Suppliers are encouraged to maintain and communicate goals focused on the continuous improvement of overall environmental performance. Business Continuity and Continuous Improvement Suppliers shall have plans in place to ensure that their business operations continue with minimal interruption in the event of a disaster, emergency, crisis situation or security related event. NRG is committed to continuous improvement and strive to incorporate best practices in our business. Suppliers are encouraged to identify and seek improvement in their own work practices. Ethics toll-free Helpline

7 CONDUCT IN THE WORKPLACE Equality in Employment NRG is committed to providing a workplace free of discrimination, intimidation and harassment that promotes equal opportunity. This is not only required by law and NRG policy, but allows for greater collaboration and teamwork. While working on NRG property or elsewhere on behalf of NRG, Suppliers including their employees and subcontractors shall comply with all applicable employment laws and regulations including those concerning immigration, child labor, minimum wage, overtime, payday and other employment related legal requirements. Workplace Behavior Everyone has a right to a workplace free from harassment. There should be no harsh treatment to employees including harassment based on a person s race, national or ethnic origin, color, sex, age, religion, sexual orientation, marital status, family status or disability. NRG will not tolerate from its Suppliers any form of harassment or abuse toward NRG employees or others. This prohibition includes but is not limited to comments, s or other communications that contribute to an offensive work environment. Harassment Includes Intimidation or threats, verbal or physical Unwanted physical contact Offensive comments, e.g. about an individual s appearance, ethnicity or sexual orientation Inappropriate, sexually explicit or offensive jokes or language Equality in Employment Practices Hiring Promotion Transfer Training Layoff or Termination Compensation and Benefits Some suppliers may be required to conduct background checks on their employees and its subcontractor s employees to ensure that they do not pose a risk to NRG assets, employees or others. Suppliers shall provide equal opportunity to all and shall not base employment decisions on race, color, religion, national origin, gender, age, disability, marital status, sexual orientation or veteran status. Suppliers, their assigned employees, and subcontractors performing work on behalf of NRG will: Treat others as they would want to be treated; Not initiate or take part in any form of harassment; Report harassment towards yourself or others. Suppliers shall respect the basic human rights of employees. Employees shall not be forced to work against their will. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Forced, involuntary prison labor, slavery or trafficking of person shall not be used. Suppliers should not use forced, prison or indentured labor or workers subject to any compulsion or coercion. Employees have the right to rest and leisure. Suppliers shall provide employees with workweeks including overtime less than the maximum set by local labor law. Ethics toll-free Helpline

8 CONFLICTS OF INTEREST Avoiding Conflict of Interest It is important to make business decisions based on the best interest of NRG, not on personal consideration or relationships. Even the mere perception of a conflict of interest could cause the intent of your actions to be questioned. Therefore, any situations that could create a real or perceived conflict of interest must be avoided. A conflict of interest arises when a Supplier s duties or his/her position present an opportunity for personal gain, or when personal interests could influence professional judgment for doing what is in the best interest of NRG. This includes (but is not limited to) providing or offering a NRG employee something of value in return for getting NRG work or having an association or relationship that could affect impartiality in business decisions. The requirement to avoid conflicts of interest also applies to situations involving immediate family members. Suppliers, their employees and subcontractors acting on behalf of NRG should consider how their actions might be perceived by others and avoid acting in ways that may be seen as conflicting with NRG interests. Suppliers, their employees and subcontractors must promptly report potential conflicts of interest to NRG Supply Chain and/or the NRG Project Representative or contact the NRG Ethics Helpline, Creating and maintaining good relationships with our Suppliers is important to the success of NRG. The occasional exchange of gifts, meals and entertainment of small value are a common business practice meant to provide a legitimate opportunity to interact, create goodwill and establish trust. Giving or receiving gifts or entertainment to or from NRG personnel must comply with the NRG Gift and Receipt of Business Entertainment Policy. NRG employees (and members of their families or households) are not authorized to accept gifts, entertainment, employment of family, or other favors from Suppliers that could influence or appear to influence the employee to grant an unfair competitive advantage or to motivate the employee Political Contributions NRG is committed to complying with all applicable laws and regulations governing political activities and communications, including accurate reporting of lobbying activities, campaign contributions and gifts to public officials. Suppliers shall not give gifts on behalf of NRG to public officials, or officials of an agency or court that regulates our business, or with whom a matter is pending, without the prior written consent from the NRG Corporate Compliance Officer, General Counsel, and Senior Vice President, Regulatory & Government Affairs. Gifts and Entertainment POLITICAL PROCESS to do anything that is unethical, illegal or prohibited by NRG policy. There must not be any explicit or implicit suggestion of a quid pro quo. Political Participation NRG encourages political participation, always recognizing that such involvement is strictly voluntary. Suppliers shall not be involved in any political activity as a representative of NRG or use the NRG name to participate in political activities without express written consent from NRG Corporate Compliance Officer, General Counsel, and Senior Vice President, Regulatory & Government Affairs. Suppliers shall not use NRG property, including computer systems and addresses, for the benefit of a political candidate or campaign or to express personal views on political issues. Ethics toll-free Helpline

9 INTEGRITY AND BUSINESS DEALINGS NRG Assets; Dishonesty and Theft Suppliers are responsible for safeguarding NRG property and for using such resources for only legitimate business purposes to advance the interests of NRG. NRG assets may not be used for personal purposes. Suppliers, their employees and subcontractors shall not knowingly or willing: Engage in theft, fraud or embezzlement affecting NRG property, funds, securities or other assets of NRG, its employees and customers. Damage or destroy property or materials belonging to NRG, its employees or customers; Divert electric energy, natural gas, or any other product produced or owned by NRG or service provided by NRG for personal gain; Either sell, provide or cause to be provided, NRG resources or services; Remove NRG equipment, property, material or money from its premises, its employees or customers without authorization; Remove, publish, destroy or alter physical and electronic NRG records; or Copy, reprint, duplicate, recreate in whole or in part computer programs or related systems developed or modified by NRG personnel, or acquired from outside suppliers. Bribery and Corruption NRG does not condone the payment or receipt of any bribe, kickback or other similar unlawful payment to or from a public or government official or any other individual, foreign or domestic, to secure business or gain advantage for NRG. This includes payments of money or anything else of value made to or by NRG consultants, agents or other party acting on behalf of NRG. At NRG, we create and support a culture that values integrity and ethical conduct. We are honest, fair and trustworthy in NRG activities and relationships. Fair Dealings NRG does business in a number of countries and may be subject to certain foreign laws and regulations. The guidelines contained in the Code are applicable wherever NRG business is conducted. Where differences exist between Code guidelines and local laws and regulations, Suppliers must apply the strictest standard. Suppliers and their employees are expected not to take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice. In order to compete fairly and to avoid even the appearance of improper agreements and understandings, Suppliers shall act in accordance with applicable laws and accepted ethical industry practices regarding gathering competitive data. Ethics toll-free Helpline

10 COMPLIANCE WITH LAWS AND REGULATIONS Suppliers shall comply with this Code and all applicable policies, laws, rules and regulations while on NRG premises or while conducting business elsewhere on behalf of NRG and must promptly report any known or suspected violations. Suppliers are responsible for the actions of their employees and subcontractors and shall ensure that they are: Trained, fully informed and follow the laws, rules, regulations and NRG policies that are applicable to the work performed; Properly supervised to ensure compliance with laws and regulations; and Not assigned to NRG work if the Supplier has any reason to believe that they may create risk of non-compliance with these policies. Antitrust or Competition Laws NRG is committed to competing lawfully based upon the merits of our products and services. Suppliers and their employees engaged in or seeking to obtain NRG business shall fully comply with applicable antitrust or competition laws. Generally, antitrust laws prohibit combinations of entities from acting together for the purpose or effect of controlling prices or reducing competition. Securities Transactions and Non-Public Information The laws of the United States and many of the other countries where NRG conducts business prohibit transactions in the securities of a company by a person possessing material non-public information about that company. Violations of the securities laws can result in significant criminal and civil sanctions for NRG and the individuals involved. Suppliers must not engage in anti-competitive practices that could harm NRG business. Market Rules and Regulations NRG is subject to many different applicable market rules and regulations, including but not limited to U.S. Commodity Futures Trading Commission (CFTC) rules, Federal Energy Regulatory Commission (FERC) rules, the North American Electric Reliability Corporation (NERC) Reliability Standard in effect, and rules of various other organizations and exchanges. NRG and its Suppliers are accountable for obeying all of them, reporting actual or suspected noncompliance, and cooperating in audits, investigations and appropriate requests for information. Suppliers must adhere to U.S. Securities laws regarding insider trading and shall not trade in the securities of any company while in possession of material non-public information about that company, or provide such information to others leading to a trade in that company s securities. By doing so, those involved could be subject to serious civil and criminal penalties. Ethics toll-free Helpline

11 BUSINESS INFORMATION, RECORDS AND DISCLOSURES Confidentiality Information In the course of work, Suppliers may have access to non-public, confidential information regarding NRG, its employees, customers and other third parties, the unauthorized use or release of which could harm NRG and potentially violate the law. Confidential information includes, but is not limited to, NRG, its customers, employees and competitive data and intellectual property, which generally refers to proprietary information, ideas, writings, designs, artworks, computer programs and software, processes, and the like. Suppliers who have access to confidential information must strictly protect the confidentiality of such information. Confidential and personal information should only be used for the purposes for which it was collected, kept secure at all times, and disclosed only when authorized or legally mandated. It may never be used for personal gain or for the unauthorized benefit of persons outside NRG. Except as explicitly provided otherwise in any written agreements between Supplier and NRG, all copyrights, patents, trade secrets or other intellectual property associated with every idea, concept, technique, invention, process and work of authorship developed or created by the Supplier, individually or jointly with others, in the course of performing work for NRG or that are based on or derived from NRG confidential information or NRG property to which Supplier has access belongs to NRG and, if requested, shall be specifically assigned by the Supplier to NRG. Suppliers must notify NRG Management immediately in the event that any confidential information has been released without authorization. The obligation to protect confidential information continues even after the Supplier s work is completed. Accurate Recording and Reporting Accurate books and records are critical to making sound business decisions and the ability of NRG to meet compliance, legal, financial and management obligations. NRG is committed to full, fair, accurate, timely and understandable disclosures in all public reports and communications, including all documents that NRG files with, or furnishes to, the Securities and Exchange Commission (SEC). Suppliers should keep accurate and complete business records that show all transactions in reasonable detail and prohibits all attempts to create false or misleading records or to deviate from established accounting procedures. This includes all forms of reports and records. Therefore, Suppliers must record and report all financial and other information related to their work for NRG accurately, honestly, objectively and in a timely manner. Suppliers must not hide, alter, falsify or disguise the true nature of any transaction for anything involving NRG nor otherwise take or fail to take any step that could impair NRG from complying with these requirements. The commitment of NRG to maintain accurate books and records requires that you accept orders only when accompanied by an approved NRG purchase order or credit card. Failure to comply with this requirement may impact the ability of NRG to pay for the goods and services in a timely manner. Retaining Business Records Requirements for retaining records are governed by various federal and state laws. Suppliers have an obligation to prevent the destruction of documents related to an investigation, claim or lawsuit. Use of Electronic Equipment Suppliers must use NRG Information Technology (IT) equipment and network systems responsibly and be used primarily for the business purposes for which they are intended. NRG IT equipment and the messages, data, files and software stored or on transmitted on NRG IT systems are NRG property and may be monitored or reviewed for any reason, business purpose or concern, including to ensure compliance with applicable licenses, laws, regulations and NRG policies. Suppliers shall not place any information acquired from NRG IT systems in any other location without prior written approval. Also, Suppliers shall have no expectation of privacy on the NRG network. Ethics toll-free Helpline

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