Code of

Entegrity

2 | CODE OF ENTEGRITY

Introduction

Each and every one of us contributes toEntergy’s culture of integrity as we conduct
our work consistently with Entergy’s corevalues.
The Code of Entegrity applies to all of us,
regardless of our role and level at Entergy,
and is our overall guide to ethical behavior
and compliance excellence. The Codereferences various system policies thatdeal with specific topics in greater detail.
For more information please read therelevant full policy on myEntergy.1
1 The Code of Entegrity applies to employees of any subsidiaryor affiliate company of Entergy Corporation (each an “Entergy
System Company” and collectively in this document “Entergy”).

3 | CODE OF ENTEGRITYTABLE OF CONTENTS

4 | Message from the CEO
5 | Entergy Values
6 | Our Expectations
8 | We Lead with Entegrity
14 | We Care About Our Workplace
23 | We Do Business Fairly

29 | We Care About Our Communities
33 | We Follow the Rules & Guidance of Our
Regulators
36 | Waivers, Notices & Disclaimers
38 | Topic Index

4 | CODE OF ENTEGRITY

Introductory letter from

Chairman of theBoard and CEO
Our Code of Entegrity is not just a set ofrules – it’s the embodiment of our collective
commitment to ethical conduct, fairbusiness practices and steadfast integrity.
These principles guide us along our path tobecoming the premier utility.
In every interaction – be it with ourcustomers, employees, communities
or owners – we prioritize honesty andtransparency. We are united in enhancing
our customers’ lives and continuallysurpassing their expectations.
This commitment extends to our endeavors
in environmental sustainability and our

evolving work culture that champions
diversity, inclusion and belonging.
Our core values – which underpin every
action we take – are safety, teamwork,
always learning, integrity and respect.
These are the principles that guide how
we work and live every day. They define
our uncompromising pledge to makeethical decisions, even when it’s tough,and to comply with all laws, regulations andpolicies. And if you are ever concerned thatsomething isn’t legal, compliant, or just feels
off, I encourage you to speak up without
fear of retaliation.

Drew Marsh
Chairman of the Board and Chief Executive Officer

Our culture of integrity is critical to creating
an inclusive workplace, safeguarding ourassets and delivering safe, reliable energy
to our customers. It’s what drives us topower life today and for future generations.
I am profoundly privileged to lead acompany that exemplifies these principles
every day.

Drew Marsh

Chairman of the Board and Chief Executive Officer

5 | CODE OF ENTEGRITYEntergy Values

SafetyTeamwork
Always learning
Integrity
Respect

6 | CODE OF ENTEGRITY

Our

expectations
To accelerate our Path to Premier, we have adopted a new setof expectations for all employees regardless of level or business
function.

Our expectations define how we compete, operate and deliver
outcomes for our stakeholders. The objective is to involve all
employees in continuously driving performance improvement andinnovation for customer success.

Each of us must proactively learn about these new expectations
and apply them to our daily work. Adopting these behaviors willbuild a stronger culture of integrity and keep us on our path tobecoming the premier utility.

7 | CODE OF ENTEGRITY

Our expectations

How our expectations look in practiceMake customers more successful••

We expand our knowledge of external customers and their goals.
We use our understanding of external customer input and feedback toachieve their outcomes.

•

We prioritize innovation and continuous improvement initiatives with visible
sponsorship from leaders.
We are encouraged to try new things and lead innovation, benchmarking
and improvement initiatives.

Innovate and continuously
improve••

Collaborate and share knowledge••

Be accountable for results••

Recognize and reward outcomes•

We collaborate and share knowledge across boundaries and quickly apply
learnings and best practices.
We regularly discuss our strategy, goals and priorities, and we are involvedin how we achieve results.
We embrace challenging performance goals for continuous learning andperformance improvement.
We are accountable for results and the measurement of performance istransparent.
We have non-financial rewards and recognition to encourage highperformance and results.
We have financial incentives to motivate and drive achievement ofoutcomes.

8 | CODE OF ENTEGRITY

We Lead with

Entegrity
What is Entegrity?

Entegrity is the practice of being
honest and showing a consistent anduncompromising commitment to strong
moral and ethical principles and to
excellence in following the rules andregulations that govern our important work.

Responsibilities
Shared Responsibilities
We all share responsibilities for upholding
our reputation for good and fair corporate
behavior. Follow the letter and spirit of ourCode and system policies, applicable laws,
rules and regulations, and always observe
the highest ethical and legal standards.
We cannot assist others in breaking thelaw. We must conduct ourselves with
Entegrity in accordance with this Code, as
well as its underlying policies.
As employees, we take personal
responsibility for:•

Promptly reporting known, suspectedor potential violations of this Code orsystem policies in accordance with theReporting Violations policy.

•

Cooperating with investigations
and audits, and providing forthright
responses.

••

Work with the Ethics and Compliancedepartment to ensure that employees
for which the supervisor is responsible
are aware of the Code and system
policies, and ensure they complete
required compliance training.

•Work with appropriate personnel
to promptly address and respondto compliance issues raised by orconcerning employees, consultants,
suppliers or agents.

•

Take appropriate and timely action,
through reporting, discipline or otherappropriate measures, to address
known or suspected violations by
employees.

•

Prohibit retaliation against those who
speak up.

•

Admit mistakes or uncertainty, andseek guidance.

Completing compliance training andother requirements.

Leader Responsibilities•

Speaking up, listening and following
up.

•

Treating others with respect.

In addition to the responsibilities of all
employees, those in leadership positions
have an obligation to lead by example
and to provide direction, guidance andencouragement to those whom they lead.

•

Knowing the Code and system policies
related to our work.

••

Helping uphold the Code and system
policies.

Leaders must:
Build trust and create an inclusive
environment that helps employees feelsafe when sharing ideas and concerns.

10 | CODE OF ENTEGRITYThe Ethics andComplianceDepartment

If you have any questions
regarding the Code of Entegrity
or any of the topics herein, pleasecontact the Ethics & ComplianceDepartment at ethics@entergy.com

The mission of the Ethics and Compliance department is to lead an ethics and compliance program that is designed to:•Promote and foster an organizational culture of integrity, ethical decision-making and commitment to Entergy’s values.

•

Assure that directors, officers and employees conduct business with the highest standards of integrity and in compliance with allapplicable laws, regulations and Entergy system policies.

•

Provide employees a haven for reporting concerns.

11 | CODE OF ENTEGRITYThe Ethical Decision-Making Model
This Code addresses many topics, and our System policies go into even greater detail. But this Code and our complianceprogram cannot specifically address or cover all situations. And even when a topic is addressed, the proper response may
not be obvious. There are various ways to answer ethical questions and solve problems. Give these steps a try:

01
step

Gather the Facts and Identify the Issue(s)Use Available Resources
Including the Code of Entegrity, system policies, computer-based training modules,
myEntergy announcements and the Ethics and Compliance department.

03
step

Find Out Which Laws, Regulations, Company Values or Policies Apply

Consider the Options and Their Consequences

05
step

02
step

Is my decision consistent
with the values of fairness,honesty and integrity?

Before Deciding, Ask Yourself the Following Questions:

Does my decision reflect the laws
and principles that support Entergy’s
compliance program?

Am I worried thatmy decision will be
discovered?

Would I be comfortable if
my decision was reported
in the news?

Choose the Best Option Based on Your Answers

04
step
What would I tell achild to do?

06
step

12 | CODE OF ENTEGRITY

Reporting Violations
If you become aware of a violation, youhave a duty to report it, even if reporting
feels difficult. Reporting violations takes
courage, but it helps everyone who has aninterest in Entergy’s success.

by nuclear business unit policies(immediate supervisor, Corrective
Action process, Open Door policy or
Employee Concerns Program), by oneof the methods outlined in the Should I
Call the Ethics Line? - Decision Tool, or
via the Ethics Line. Employees, agentsand contractors also have the right,
protected by law, to report nuclear
safety concerns directly to the Nuclear
Regulatory Commission.

Employees, agents and contractors must
report known, suspected or potential
violations of law or system policies.
•••

In the event of violence or imminent
danger to the safety or securityof persons or property, call law
enforcement (911) immediately, andreport the matter to the Ethics Line assoon as possible. If potential workplace
violence or security concerns do not
involve imminent danger, report thematter to the Ethics Line.
Known, suspected or potential
violations of law, such as harassment,
discrimination, fraud, financial reporting
concerns, and violations of safety or
environmental laws and regulations
must be reported to the Ethics Line.
Nuclear employees, agents andcontractors shall immediately reportother known, suspected or potential
violations of the law or policies via
nuclear site protocols as defined•

Report all other known, suspected or
potential violations of system policies
through one of the methods outlinedin the Should I Call the Ethics Line? Decision Tool or the Ethics Line.

Anyone having a reasonable belief ofthe existence of a known, suspected or
potential violation of the law, the Code or
any system policy must report the violation,even if he or she is not involved in theviolation in any way.
Employees who have been involuntarily
terminated, due to anything other than alayoff, including inadequate performanceor attendance, misconduct, and violationof company policy or procedure, are noteligible to be rehired.
Relevant Policies: Reporting Violations

The Entergy Ethics Line
We take concerns seriously. The Ethics
Line is staffed 24 hours a day by an outsidecompany. Entergy employees and others
may contact the Ethics Line by phone oronline.
Call: 1-888-257-ETHIC (1-888-257-3844)
Visit: www.compliance-helpline.com/
entergyethicsline.jsp
People contacting the Ethics Line do
not have to identify themselves. Once a
concern is submitted, a case number anda personal identification number will be
provided for follow-up.
All matters reported to the Entergy Ethics
Line will be appropriately reviewed.

Should I Call the Ethics Line?
Decision Tool
The Should I Call the Ethics Line? –Decision Tool (ELDT) was developed toassist you in finding the best company
resources to discuss and report such
issues. The ELDT addresses a wide varietyof concerns, including safety, security,
fraud, phishing, performance, and potential
violations of law, regulation or policy.
Information is tailored for nuclear, utility andcorporate employees.

13 | CODE OF ENTEGRITY

Zero Tolerance for Retaliation
Entergy does not tolerate retaliation andwill take appropriate action to correct
any known retaliation. This may include
disciplinary action, up to and including
immediate termination of employment,
against the retaliator.
Contact the Ethics Line if you feel thatyou or another employee are being
retaliated against for making a goodfaith report based on reasonable belief
of wrongdoing or participating in an
investigation of a complaint.
Sometimes a report of a violation
turns out to be wrong – there was no
violation. But this must not prevent us
from making a good faith report. If you
have reasonable belief that a violation
has occurred, system policy prohibits
you from being disciplined for raising theconcern.
Relevant Policies: Reporting Violations

Why should I report potential wrongdoing?
It’s the right thing to do

It helps prevent wrongdoing

It’s our personal ethical obligationeven beyond rules and regulations.

Most of us do our best to act ethically andwith compliance excellence at all times. When
we know others will hold us accountable forcommitting misconduct, we are less likely tocommit wrongdoing and will act to determine
the right course of action.

It protects our company
By identifying potential threats
and risks we can put an end to any
actual violations and try to preventnew ones from happening. Speaking
up can also help to prevent
potentialfines and lawsuits.

It takes the burden off of you
Reporting actual, suspected, or
potential violations of laws andSystem policies meansthat you don’t
have to decide which policy may
be being violated and how best toaddress the situation.

It provides more detailed insight into issues
Reporting concerns can provide the crucial
information or examples that management
needs to piece together the precise picture,and then develop the appropriate response.
It drives better communication and trust
A culture of integrity and a willingness to
speak up, even when it’s hard, creates a
better environment and culture of inclusion
and belonging for everyone.

14 | CODE OF ENTEGRITYWe Care About Our

Workplace

The workplace is more than a physical space. It’s an environment in which we work thatencompasses places, people and processes. we are committed to upholding a diverse
and inclusive environment that promotes belonging, health and safety in all we do.

Health and Safety
Entergy is dedicated to becoming the premier utility, and we are consistently anindustry leader in safety and occupational health performance. We focus on proactively,
responsibly and sustainably managing our business operations to protect our employees,
contract partners, customers and the communities in which We serve. We believe
individuals have a right to safe and healthy working conditions, and we are committed toproviding a safe, secure, healthy and productive work environment. You are expected tomaintain safe and healthy working conditions, comply with the safety standards of your job
and report actual or potential safety or health hazards.
Relevant Policies: Environmental, Occupational Health & Safety, No Smoking

Our guiding safety
principles
1. I own safety
2. Prevention is critical
3. We must always improve
4. Zero harm is possible

15 | CODE OF ENTEGRITY

Diversity, Inclusion and Belonging
We’re focused on taking the necessary
steps to create an inclusive culture,eliminate unconscious bias and foster
an environment of belonging. We arecommitted to developing and retaining aworkforce that reflects the rich diversityof the communities we serve. The
diversity of employee ideas, backgrounds,
perspectives, abilities, skills and knowledge
enables us to create innovative businessand customer solutions. To ensure that wefully realize the potential of our diverse
workforce, we are also focused on creating
and nurturing a culture of belonging, withthe goal of assuring that all employees
feel valued, heard and respected. A
powerful and dynamic culture retains top
talent, provides an environment for moreengaged employees, and empowers ourworkforce to deliver on customer-centric
opportunities and continuous improvement
to create further sustainable value for all our
stakeholders.
Relevant Entergy Documents:
Diversity & Inclusion Vision and Mission
Statements
Entergy has multiple employee resource groups that promote
inclusivity and collaboration among employees from different
generations, genders, cultural backgrounds and professional
experiences.

16 | CODE OF ENTEGRITY

Discrimination and Harassment
Prevention
We seek to maintain a work environmentthat recognizes the dignity and worth ofeach individual and is free from harassment
and discrimination based on:•

Protected characteristics, including
race, color, sex, religion, pregnancy
condition, national origin, age (40and over), sexual orientation, gender
identity and/or expression, veteran’s
status, marital status, qualified disability,
genetic information (which includes

family medical history), and or any othercharacteristic protected by law.
•

Protected activities, including the“good faith” filing of a claim with
the Equal Employment Opportunity
Commission or another governmental
entity.

Examples of prohibited conduct whenbased on a protected characteristic ora protected activity include, but are notlimited to:•

Denying equal employment
opportunities.

•

Making, transmitting, intentionallyaccessing, displaying or circulating
offensive or derogatory statements,
comments, jokes, slurs, gestures,
pictures, emails or links.

•

Creating an offensive, hostile orintimidating work environment.

•

Engaging in unwelcome flirtation,
sexual advances, requests for sexual
favors, propositions, touching andother verbal or physical conduct of asexual nature.

17 | CODE OF ENTEGRITYThe Discrimination and Harassment
Prevention policy is intended to extend
further than the law to maintain a work
environment that is inclusive for all
employees. It prohibits behavior that, ifleft unchecked, could become unlawful
or undermine a safe, productive or
collaborative work environment. It also
prohibits conduct, whether occurring
during or outside of working time, that
could cause reputational harm to Entergy
or could be negatively associated withEntergy, such as inflammatory or divisive
statements posted on social media.
You should immediately report known,suspected or potential violations of thispolicy to the Entergy Ethics Line.

influence of illegal drugs or alcohol* isprohibited while:•

On Entergy premises (including in apersonal vehicle).

•

Operating a vehicle or other equipment
owned or leased by an Entergy systemcompany.

•

Operating a personal vehicle on
Entergy system company business.

•

Using property owned or leased by anEntergy system company.

•

Working (including remotely).

•

Otherwise conducting company
business.

Relevant Policies: Communications Systems,
Discrimination & Harassment Prevention,
Employee Use of Internal or External Social
Media Sites*Note: The use, possession or sale ofalcoholic beverages is not prohibited
where there is prior approval byauthorized personnel. (e.g., an Entergy
event).

Drugs and Alcohol

If you are taking prescribed or over-thecounter drugs that affect your ability
to perform some or all job duties or toperform job duties safely, you must advise
your supervisor about:

You are required to be fit for duty whenreporting to work.
The use, possession, promotion, sale,
distribution and act of being under the•Side-effects of the medication affecting
your ability to perform existing job
duties or on-the-job safety.

•

Job duties affected.

•

Any safety concerns.

To the extent allowed by applicable law
or policy, employees may be required tosubmit to drug and alcohol screenings.

Substance Abuse Assistance
You are encouraged to seek assistancefrom the Employee Assistance Program(EAP) for any issues relating to drugs
and/or alcohol. The EAP is available for
employees to use on a confidential basis.
Relevant Policies: Drugs & Alcohol18 | CODE OF ENTEGRITY

Physical Security
Weapons and Workplace ViolencePrevention
We are committed to a work environment
free from violence and threats. Any threator act that would create fear, hostility,
intimidation or concern of harm in anotherperson is forbidden.
If violence is occurring or imminent danger
exists, do not place yourself in harm’s way.
Call law enforcement (911) immediately.
Then, as soon as possible, report thematter to the Ethics Line.
If there’s no imminent danger, but direct
or implied threats are occurring or otherworkplace violence issues exist, contact
the Ethics Line.

Weapons are prohibited in the workplace
unless authorized by system policy.
Weapons include, but are not limited to:•Guns, BB guns, automatic weapons,ammunition, bows, arrows, tasers/stunguns, mace spray*, pepper spray* andany type of explosive.

*Note: An employee may carry a legally possessedcontainer of mace or pepper spray to be used for selfdefense purposes only, provided that the capacity does
not exceed 150 cubic centimeters (150 cc).

Securing Our Assets
We are all responsible for protecting
company property from theft, fraud,
unauthorized access and use, damage
and destruction. Unauthorized or improperuse of company material, time, equipment,
credit cards, procurement cards or otherproperty is prohibited. You must not offer
company property, company loans or
unpaid company services to persons
outside the company without prior written
approval of senior management. Allcompany property must be returned to thecompany at the termination of employment.
Always report any theft or vandalism ofcompany property.
Relevant Policies: Bank Accounts, BusinessContinuity Planning, Enterprise Security,
Investment Recovery, Protection of Company
Property, Real Estate, Transportation, Workplace
Violence Prevention & Weapons

19 | CODE OF ENTEGRITY

Information

Security
Protection of Information

Do this...

... Not this•Use caution when discussing confidential employee
information.

•

Disclose confidential employee information to unauthorizedindividuals.

•

Protect personnel files, performance evaluations, salarylevels, medical data and other information pertaining toindividuals and their employment with Entergy.

•

Disclose company information to parties who are notauthorized to receive it and who do not have an Entergybusiness need to know.

•

Protect social security numbers, customer credit and bankinformation and usage data.

•

Use or access customer information unless authorized forEntergy business.

•

Prevent the misuse, theft and improper disclosure ofcompany information.

•

Take care in handling, discussing, transmitting, storing anddestroying company information.

•

Follow the company’s Protection of Information policy.

•

Report concerns about protected employee information.

20 | CODE OF ENTEGRITY

Employee Information
We must protect employee information.
Employee records include:•

Personnel files.

•

Performance evaluations.

•

Salary levels.

•

Medical data.

•

Other information pertaining toindividuals and their employment.

These records may only be accessed by ordisclosed to individuals having a legitimate
business reason to review the information
contained in those records.

Customer Information
We must also protect confidential customer
information, such as social security
numbers, credit card and bank accountinformation, and usage data.
None of us may use or access customer
information except for legitimate businesspurposes, in accordance with the law,the company’s Privacy policy, and theProtection of Information policy.

Company Information
We must prevent the misuse, theftor improper disclosure of company
information. Information that is used
to provide customer service, carry out
operations and report accurate data isan essential company asset and must be
protected.

We must take care in handling, discussing,transmitting, storing and destroying
information according to the rules set forthin the Protection of Information policy.
We must protect such information against
disclosure, either accidental or intentional,
to parties, both inside and outside ofEntergy, who do not have a legitimate
business “need to know.” This obligation
continues even when we are no longer
employed by Entergy.
Relevant Policies: Disclosure & Public
Communication, Disclosure Controls &Procedures, Disclosure for Compliance with
Regulation FD, Enterprise Security, Privacy,
Protection of Information, Security Management
Manual21 | CODE OF ENTEGRITY

Accounting andBusiness Records
Accuracy of Books and Records
You have a responsibility to prepare
all records in a prompt, complete andaccurate manner. These records include
vouchers, reimbursement requests, bills,
timesheets, performance and payroll
reports, and all other company books
and records. Records must not be false,
misleading, artificial or incomplete.

Entergy requires compliance with generally
accepted accounting principles, the FERC
Uniform System of Accounts, and Entergy’s
internal system of accounting and auditing
controls. Accurate, reliable information andrecords are critical to meeting the financial,legal and management obligations of thecompany. You must comply with all laws,
rules, regulations and company policies
so that financial reports and records areaccurate.

Relevant Policies: Accounting, Approval
Authority, Business Travel & Expense, Internal
Controls, Project Delivery System, Time Entry &Pay22 | CODE OF ENTEGRITY

Records Management and Document
Retention
We have an obligation to maintainrecords according to the Entergy Records
Management and Retention policy as wellas the retention periods set forth in theEntergy Records Retention Schedule. The
retention periods are prescribed by federal
and state statutes, government regulations
and business needs. All records areclassified by the company as Official
Records, Administrative and General
Records, or Reference Materials.
We also have a duty to preserve records
relevant to anticipated, threatened or
pending litigation. Once a Legal Hold
Notification has been issued by the Legal
department or Tax Services, the recipient
is required to preserve all relevant records
until receipt of a Legal Hold Release
Notification.
Relevant Policies: Records Management &Retention

23 | CODE OF ENTEGRITYWe Do
Business

FairlyCommitment to our Customers

Acting with Entegrity means that we mustalso do business fairly. That means we holdourselves accountable to upholding thisCode, avoiding conflicts of interest, fighting
corruption and competing fairly.
As the utility business evolves, so docustomer needs and expectations. We are
putting the well-being of our customers at
the center of everything we do.
It is on us to make sure all our efforts are
directed toward enhancing our customers’
everyday lives. By continuing to find new
ways to improve, we are working today
for a better tomorrow. We are laying
the foundation for our future: better

communities, economies and lifestyles thatwill provide opportunities for all.

Conflicts of Interest
A conflict of interest exists when our
responsibilities to the company and our
personal interests are at odds. You must
avoid activities that cause your personal
interests to interfere with your ability tomake sound business decisions on behalfof Entergy or otherwise keep you fromacting in the best interest of the company
when performing your job duties. If any
actual, potential or perceived conflictsof interest exist, timely disclose themby following the steps provided in the
Conflicts of Interest policy.

24 | CODE OF ENTEGRITY

Business Courtesies

Business courtesies are gifts or favors given or received during a business relationship,such as a business relationship with a customer, supplier or contractor. You must decline any
business courtesies that could give the appearance of granting an unfair advantage or doing
anything that is unethical, unlawful or against Entergy policies.

May I Accept a Business Courtesy?

Receiving Gifts
You may never request a businesscourtesy and never accept cash or cash
equivalents. You may accept articles ofsmall value ($200 or less) on an infrequentbasis, such as occasional meals or
entertainment provided by an existing or
potential customer or supplier. However,even these items cannot be accepted
if they are an attempt to get you to
grant an unfair advantage or to motivate
you to do anything that is unethical or
unlawful. Otherwise, you may accept abusiness courtesy only if it is allowed by
the Business Courtesies policy and it isdetermined that the business courtesy
does not create a conflict of interest.

Giving Gifts
When in a position to offer gifts andentertainment to customers or suppliers,
use common sense and good judgment.
Do not create circumstances that are
inappropriate or give the appearance ofimpropriety. Also, do not provide businesscourtesies that are illegal, that violate therules of the recipient’s organization or thatare offered for something in return.

25 | CODE OF ENTEGRITY

Outside Employment and Service

Conflicts of interest may also arise in yourwork outside of Entergy, including in roles
such as service in elected office and externalboard positions. You must not allow these
positions to interfere with or improperly
influence your work with Entergy.

Employment of Relatives and Personal
Relationships (Nepotism)
The Nepotism policy describes who isconsidered a relative and specifies prohibited
situations involving the employment ofrelatives. Consult the policy any time a relativeis also working for Entergy.
Even if there is no prohibited situation
under the Nepotism policy, other personal
relationships can give rise to an appearanceof impropriety in a workplace situation. These
personal relationships are potential conflictsof interest and must be resolved according
to the Conflicts of Interests policy. Examples
include cohabitation or a dating relationshipbetween a worker and a supervisor in theworker’s chain of command and a close
personal relationship between an employee’s
spouse and an Entergy vendor.

26 | CODE OF ENTEGRITY

Personal or Family Financial Interests
A potential or actual conflict of interest exists if you influence or try to influence an Entergy
business decision or transaction that could benefit you or your family member financiallybased upon an outside business interest.
Relevant Policies: Business Continuity Planning, Business Courtesies, Conflicts of Interest,
Nepotism, Service to Unaffiliated Entities

Anti-corruption and Anti-bribery
Entergy will not tolerate corruption, bribery, extortion or embezzlement by employees or
suppliers.
You must never give, offer, authorize or promise any form of a bribe or kickback. Similarly,
employees, agents and suppliers must never seek or accept bribes or kickbacks from anEntergy customer, agent or supplier.

Anti-Corruption and Anti-Bribery
Terms to Know
Bribe: money or other incentive offered or given to persuade someone to act in one’s
favor.
Kickback: an illegal payment intended as compensation for preferential treatment or
any other type of improper services received. Kickbacks include money, a gift, credit
or anything of value.
Money Laundering: the concealment of the origins of illegally obtained money,
typically by means of transfers involving foreign banks or legitimate businesses.

26

27 | CODE OF ENTEGRITY

Fair
Competition
Human Rights and Employment
PracticesEntergy respects the human rights of
all individuals, and we are committed
to the advancement and protection ofhuman rights in all our operations. This
commitment is spelled out in our Human
Rights Statement, which is publicly
available at Entergy.com.
This Code and Entergy’s Human Rights
Statement are closely aligned. Both
documents reflect the values Entergy
strives to live by as a business leader,
employer and corporate citizen.

Foreign Corrupt Practices Act (FCPA)

Export Control

The Foreign Corrupt Practices Act prohibits
payments or gifts of any value to foreign
government or political officials. It also
requires the company to maintain accurate
books and records and a system of internal
accounting controls documenting domestic
and international assets and transactions.
Anyone who conducts Entergy businessoutside of the United States or with foreign
officials must understand and abide by theprovisions of the FCPA.

Export control laws regulate the export ofcertain goods, information and technology
outside the United States. These lawsalso regulate sharing certain controlled
items with individuals who are not citizens
or lawful permanent residents of the U.S.
who do not have refugee or asylum status,
regardless of whether they are outside
the U.S. For example, this includes sharing
controlled items with such individuals
located in Jackson, Mississippi, or allowing
foreign nationals located offshore toaccess remotely controlled items that arelocated in New Orleans, Louisiana.

Antitrust Laws and Fair-Trade
Practices
Antitrust laws are based on the belief
that free and open competition helps toensure that consumers obtain the bestproduct at the lowest price. The purposeof antitrust laws is to prevent activities that
unreasonably restrain free competition.

Entergy follows legally compliant
employment practices, including:

To ensure we abide by the laws
concerning antitrust and fair trade, we mustnot:•No employment of under-age
individuals in violation of any applicablechild labor laws.

•

Engage in unfair pricing or marketing
practices.

•

No use of forced or involuntary labor.

•

Misrepresent the products and services
of Entergy or its competitors.

•

Compliance with wage and hour laws
and regulations.

Contracting with the Government
We have an obligation to comply withthe laws and regulations that apply togovernment contracting. Certain systemcompanies may be subject to special
regulations governing procurement andcontracts. It is necessary to adhere to
the terms and conditions of any contract
with, or grants from, federal, state or local
governments. Any employee whose
job responsibilities include government
procurement and contracts must familiarize
themselves with the applicable rules andregulations.

28 | CODE OF ENTEGRITY

Government Investigations

Procurement and Supplier Diversity

Entergy is committed to cooperatingwith government agencies inspecting
company property or investigating or
auditing activities. Entergy must provide
complete and accurate information andprotect its legal rights. The Government
Investigations, Inspections and Audits
policy explains when employees may
respond to government inquiries directly
and when employees should engage thecompany’s Legal department.

Entergy’s purchases of products andservices are based on the total cost ofownership that includes safety, quality,
pricing, sustainability, and diverse andlocal supplier status. This practice helps toensure that Entergy obtains the necessary
products and services at a fair priceand meets its environmental, social andgovernance goals.

Intellectual Property and Copyrights
You may not use, reproduce, modify,
download, distribute or otherwise copy
any copyrighted, trademarked or patented
works of others without written approval
from the owner (which may include alicense) or consent of Legal Services. You
also may not allow others to use company
resources to do so.
Relevant Policies and Documents:
Anticompetitive Behavior, Economic Espionage,
Export Control, Foreign Corrupt Practices
Act, Government Contracts, Government
Investigations, Inspections & Audits, Human
Rights Statement

The Supply Chain organization oversees
the procurement process and assures that
Entergy’s interests are protected when
products and services are purchased. Only
Supply Chain is authorized to commit tosuppliers or service providers. Exceptions
to using Supply Chain are detailed inEntergy’s Procurement policy.
Relevant Policies: Procurement

28

29 | CODE OF ENTEGRITYWe Care About Our

Communities
Entergy’s sustainability mission is to create sustainable value for our customers,
employees, owners and the communities we serve by using sustainable businesspractices that integrate environmental, social and economic objectives and concerns.

30 | CODE OF ENTEGRITY

Environment

We see environmental stewardship as
both a responsibility and an opportunity.
Among other imperatives, environmental
stewardship is comprised of compliancewith applicable laws and regulations and avigorous approach to addressing climatechange. As such, the environmental
component of our broader sustainability
strategy is inseparable from our businessstrategy.
We proactively ensure that both the letterand spirit of environmental laws andregulations are adhered to throughout thecompany and with our contract partners.
We recognize the challenges posedby climate change and will continue toadvance, as a business priority, our morethan two-decades-long focus on finding
and implementing solutions.
We partner with industrial customers inmanufacturing, port management andtransportation to electrify their energy
needs and operations with clean energy
solutions that help them reduce theirown greenhouse gas emissions. We

also recognize and act on the criticalstewardship role we play as a utility withrespect to optimizing water use, minimizing
waste, reducing air emissions, and avoiding
or mitigating instances of environmental
injustice. Whether you work in a plant, thefield or an office, you are expected to beenvironmentally conscious. You must follow
proper environmental procedures in yourdaily work. Immediately report any actual,suspected or potential environmental
compliance issues via the Ethics Line.
Relevant Policies and Documents: Entergy’s
Environmental Vision Statement, Environmental,
Occupational Health & Safety

SocialFor more than 100 years, Entergy has
powered life in our communities throughstrategic philanthropy, volunteerism
and advocacy. Our corporate social
responsibility initiatives help create andsustain thriving communities, position
the company for sustainable growth
and are aligned with the United Nations
Sustainable Development Goals.

Giving back and volunteerism are an
integral part of our mission because
we can only be as successful as thecommunities we serve. Our top corporatesocial responsibility priorities are education
and workforce development, poverty
solutions and environmental programs.
Entergy annually makes significant
donations via shareholder funded grants tohundreds of nonprofits across our service
territory. In addition, our employees andretirees annually volunteer thousands ofhours in our communities. These volunteer
hours are valued at millions in economic
impact.
Relevant Policies and Other Documents:
Charitable Contributions & Volunteering,
Human Rights Statement

Governance
We operate our business withtransparency, accountability and integrity.
Strong governance enables us to deliveron our commitments and to create
sustainable value for our stakeholders.

31 | CODE OF ENTEGRITYThe Entergy Brand
Public Communications
At Entergy, we speak with one voice andare committed to communicating truthfully
and transparently with the public. If you
receive a request for comment from themedia or you are asked to speak at an
external event or conference, contact the
Corporate Communications department
immediately.

Social MediaUse good judgement and be respectfulwhen using internal and external social
media tools. When talking about Entergy,
be transparent about your association withthe company. Always think before you
post. Social media posts can be seen byanyone and remain on the internet forever.
Employee participation in social media isgoverned by the Employee Use of Internalor External Social Media Sites policy
and the Discrimination and Harassment
Prevention policy. Both of these policies
cover not only work-related conduct but

also other conduct that could have anegative impact on Entergy or our work
environment. Examples include, but are
not limited to, inflammatory or divisive
statements posted on internal or externalsocial media.

Endorsements and Trademarks
You may not endorse any outside-party
goods or services and shall not grant any
outside party the right to use Entergy’s
logo or trademarks, except as advised by
Legal Services and with the consent ofcertain authorized individuals.
Relevant Policies: Disclosure & Public
Communication, Employee Use ofInternal or External Social Media Sites,Intellectual Property & Endorsement, Public
Communications on Behalf of Entergy via
Internet or Social Media

32 | CODE OF ENTEGRITY

33 | CODE OF ENTEGRITY

We Follow the Rules
and Guidance of Our

Regulators

A great deal of information comes to Entergy
because we are a vertically integrated public utility
with generation, transmission and distribution
assets. For this reason, much of our business issubject to federal and state regulatory rules andlaws. We are expected to know and comply with allapplicable regulatory requirements.
We must work to ensure the reliability of thebulk electric system and to ensure the way
we conduct business does not disadvantage
other market participants. There are numerous
specific regulatory requirements, and it is yourresponsibility to know and comply with therequirements for your business area. If you havea question regarding whether or how certain
regulations apply to your work, you should contact
Ethics & Compliance.

34 | CODE OF ENTEGRITY

Business Unit Interactions
Entergy is subject to “affiliate rules”
governing the interactions between
Entergy’s affiliated entities and business
units. These rules ensure that any
information the Entergy system operatingcompanies obtain because they aremonopoly service providers is not used toprovide an unfair business advantage tounregulated Entergy system business or toEntergy’s system companies’ generating
assets bidding into the wholesale energy
market.

In addition, through the establishmentof the North American Electric Reliability
Corporation (NERC), FERC issues
numerous reliability requirements for theassets comprising the bulk electric system.
The requirement to protect Entergysystem’s bulk electric system assets
applies to both physical and cyber assets
and requires all employees to be vigilant
in following all applicable policies andprocedures. To ensure compliance with
its regulatory requirements, FERC could
assess penalties of over $1 million per day
for each violation of its rules.

Relevant Policies: Affiliate Interactions

NRC

Federal and Local Regulators
FERC
Entergy’s wholesale operations are
subject to the jurisdiction of the Federal
Energy Regulatory Commission (FERC).
FERC regulates the way Entergy systemcompanies operate in the transmission
system and the way Entergy’s systemcompanies’ generating assets participate
in the market for the wholesale sale ofelectricity.

The Nuclear Regulatory Commission(NRC) is an agency of the United States
government tasked with protecting publichealth and safety related to nuclear energy.
Because Entergy has nuclear power plants,
we are required to comply with all NRC
issued rules, regulations and standards.
Public Service Commissions
Each Entergy system operating company issubject to the jurisdiction of a retail public
service commission. Retail public service

commissions reference those regulators
responsible for overseeing how theoperating company interacts with its enduse customers (i.e., residential, commercial
businesses and industrial customers). Retailregulators dictate the price, terms andconditions of service for their jurisdictional
operating company. Any questions related
to Entergy’s operations at the retail levelshould be directed to the appropriate
operating company’s Regulatory Affairs
department or the Regulatory Legal
department.
Relevant Policies: FERC Compliance, NERC
Reliability Standards, Nuclear policies &procedures

Political Activity
You are responsible for complying withapplicable federal, state and local laws
relating to political activity. Our Political
Activity – Contributions, Lobbying andElective Office policy provides direction,
guidance and information on how best toensure compliance with these laws. It also
specifies requirements regarding corporate
political contributions.

35 | CODE OF ENTEGRITY

You are encouraged to be personally involved in the political process, and you may
contribute to the cause or candidate of your choice. But you must do so using your own
time, money and resources.
Relevant Policies: Political Activity – Contributions, Lobbying & Elective Office

Insider Trading
Insider trading is illegal, unethical and strictly prohibited. Insider trading is engaging ina transaction involving Entergy’s securities while in possession of material nonpublic
information. This information includes any information that may influence an investor’s
decision to buy, sell or hold the securities of a company. Tipping – providing confidential
information to others who may trade on it – is also prohibited.
Members of Entergy’s board of directors, executive officers and certain restrictedemployees may engage in trades in Entergy securities only during a “window” period.
Entergy will notify these individuals of when a “window” period occurs.
Relevant Policies: Insider Trading

Insider Trading
Terms to Know

Material Information: information that a reasonable investor would consider
important in making a decision to buy, hold or sell Entergy securities.
Material, Nonpublic Information: material information that has not been publicly
disclosed (made available to investors generally).

36 | CODE OF ENTEGRITY

Waivers andDisclaimers
Waivers

No waivers will be granted for the Code of
Entegrity.

Notices and Disclaimers

The Code is not a human resources
handbook. It does not address orreference many policies relating toimportant personnel issues such as
benefits, time off or employment rights.
For help with such issues, contact
Human Resources Employee Services or
consult the appropriate system policy on
myEntergy.
This Code replaces all prior versions of
the Code of Entegrity. In the event that
there are differences between a printed

and online version, the online version isthe current statement of the Code. The
online version can be found on myEntergy(Policies & Forms > Code of Entegrity). If
myEntergy is not available, a copy canbe provided by supervisors, the Ethics
and Compliance department or Human
Resources Employee Services.
The description of policies, practices
or procedures contained in this Codeor a referenced policy, or as told to you
by an Entergy representative, does notcreate any terms and conditions of an
employment contract. This Code does
not constitute or create any contractual
obligation between you and an Entergysystem company. All Entergy system
employment is at will and can be ended

by either party, at any time, without priornotice or cause, except as provided in acollective bargaining agreement or otherauthorized express written employment
contract between an employee and an
authorized representative of the applicable
Entergy system company.
The Code is not intended to, and will not
be construed to, interfere with or restrict
any rights provided by law, including
those afforded under the National Labor
Relations Act. Nothing in this Code will be
construed to limit an employee’s right tospeak with others regarding wages andother terms and conditions of employment
or to exercise any other legally protectedright.

38 | CODE OF ENTEGRITY

Index
A

C

Contract Workers

Diversity

ReportingFitness for Duty

Accounting

Charitable Entities,
Service with Child
Labor

Contracts

Documents

Environmental Justice

Forced Labor

Contributions, Political

Drugs

Controlled SubstancesE

Equal Employment
Opportunity

Foreign Corrupt
Practices Act

Copyrights

Elective OfficeCore Values

Email

Espionage, Industrial/
Economic

Foreign Countries andGovernments

Corruption

Employee Information/
Records

Ethics

Fraud

Ethics and ComplianceDepartment

Fraud, Reporting

Accuracy
Acknowledgment ofCode Compliance
Affiliate Rules
Affiliate Interactions
Alcohol
Anticompetitive
Behavior

Climate Change
Cohabitation
Communications
Community
Company Assets
Company Information

Anti-corruption

Company Property

AntitrustCompetitors

Assets, Protectionof Audits

Competition

B
Behavior

Complaints, Reporting
Compliance Program

BelongingCompliance Violations,
ReportingBoard Service, Outside

Concerns

Brand

Confidential Information

BribesConfidentiality

Business Courtesies

Conflicts of Interest

Business Unit

Consultants

Credit Cards
Commitment toCustomers
Customer Information
Customer Relationships
D

Employee Assistance
Program (EAP)
Employee
Responsibilities
Employment At Will

Ethics Line
Ethics Line Decision
Tool
Expense Accounts
Export Control

Danger

Employment ofRelatives

Data Privacy

Employment Contracts

F

DatingEmpowerment

Fair Trade Practices

Decision-Making

Endorsements

FamilyDisabilities

Entegrity

FERC Compliance

DisciplineEntertainment

Disclaimers

Environment

Financial Concerns,
Reporting

Discrimination

Environmental
Compliance Issues,

External Boards

Financial Records andReportingG
Generally Accepted
Accounting Principles
Gifts
Good Faith
Governance
Government Contracts
Government
Investigations
Government Officials/
Employees
H
Handling Difficult
Situations
Harassment

39 | CODE OF ENTEGRITY

HazardK

and Activities

Commissions

HealthKickback

Over-the-Counter Drugs

R

Hostile Work
Environment

LP

Raising a Concern

Laws, Duty to Comply

PatentI

LeadershipResponsibilities

Penalties for Violation

Records Management
and Retention

Illegal Drugs

Legal Department

Inclusion

Loans

Information, Protectionof Inside Information

Lobbying

Human Rights

Insider Trading
Inspections,
GovernmentIntellectual Property
Internal Controls
International
Transactions
Internet
Intoxication
Investigations, Duty to
Cooperate
Involuntary Labor

M
Material NonpublicInformation
Media/Media Inquiries
Money LaunderingN
Nepotism
NERC Compliance
Nonretaliation
Nuclear

Policies
Personal Relationships
Political Activities
Political Contributions
Political Officials
Privacy
Procurement
Property
Proprietary Information
Protected Activities
Protected
Characteristics
Protected Information

O

Protecting Company
AssetsOccupational HealthPublic Communications

Outside Employment

Public Service

Records, Accounting
and Business

Substance Abuse
AssistanceSupervisor
Responsibilities
Supplier Diversity
Suppliers
Sustainability

Regulators

T

Relatives

Theft

Reliability

Tipping

Reporting Violations

Trade, International

Responsibilities, Shared

Trademarks

Retaliation

Training

S

Transactions, International

SafetyTrust

Securities and Stock
TradingV

Sexual Harassment
Should I Call the Ethics
Line Decision Tool
SocialSocial Media
Speaking Up

ValuesVendors
Violations, Reporting
Violence
Volunteering

W
Wage and Hour Laws
Waivers
Weapons
Window Periods
Workplace ViolenceZ
Zero Tolerance for
Retaliation

Code of Entegrity© 2023 Entergy Corporation, All Rights Reserved. The Entergy name andlogo are registered service marks of Entergy Corporation and may not be
used without the express, written consent of Entergy Corporation.

www.entergy.com