ENTERGY SYSTEMPOLICIES & PROCEDURES
Page 1 of 10Title:

Environmental, Occupational Health &Safety (EHS) Policy
Subject Matter Expert:
Responsible Officer:
Paul Leonard
Peter Norgeot

Last Revision: 8/15/2022

Rev. 0.2

Approved By:
Corporate Compliance Committee

I. POLICY SUMMARY•

The purpose of this Policy is to set Entergy’s policy direction and responsibilities
surrounding environmental, occupational health, and safety (EHS) relatedmatters.

•Entergy is committed to being recognized as a leader in EHS management byachieving world-class EHS performance in our business operations.

•Entergy EHS Policies and Standards may be created and revised as necessary tomanage compliance with EHS laws, regulations, and best business practices.
o The Executive Vice President and General Counsel has the authority toapprove, interpret, and administer Entergy Environmental Policies andStandards.
o The Executive Vice President and Chief Operating Officer has theauthority to approve, interpret, and administer Entergy Occupational
Health & Safety Policies and Standards.

•Entergy EHS Policies and Standards apply to all Entergy employees, agents andcontractors.

•Each Entergy Function shall develop, implement, maintain, and regularlyevaluate EHS programs and procedures consistent with the Entergy EHS
Policies and Standards.
o Functional Leadership has the authority to approve, interpret andadminister Functional Environmental Programs and Procedures andFunctional OH&S Programs and Procedures pursuant to their operations.

•All employees, agents and contractors of Entergy shall immediately report
known, suspected, or potential violations of this Policy by following theprocedures described in the Reporting Violations Policy.

•Please refer to the following detailed Policy for further information.

ENTERGY SYSTEMPOLICIES & PROCEDURES
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Environmental, Occupational Health &Safety (EHS) Policy

Last Revision: 8/15/2022

Rev. 0.2

II. DETAILED POLICY
1.0

PURPOSE AND APPLICABILITY
The purpose of this Policy is to set Entergy’s policy direction and responsibilities
surrounding environmental, occupational health, and safety related matters andto set forth the authority to establish, implement, maintain, and administer
Entergy EHS Policies and Standards.
THIS POLICY APPLIES TO ANY AND ALL EMPLOYEES OF ANY ENTERGYSYSTEM COMPANY, UNLESS OTHERWISE EXPRESSLY EXCLUDED, ASWELL AS AGENTS AND CONTRACTORS OF ANY ENTERGY SYSTEMCOMPANY.
THIS POLICY COVERS EMPLOYEES WHO ARE REPRESENTED BY AUNION, EXCEPT THAT ANY CONFLICTING TERMS OF EMPLOYMENT IN ACOLLECTIVE BARGAINING AGREEMENT OR OTHER AGREEMENTREACHED WITH THE UNION(S) SHALL CONTROL.
NOTHING CONTAINED IN THIS POLICY SHOULD BE CONSTRUED TOSUGGEST THAT EMPLOYEES OF A PARTICULAR SUBSIDIARY ORAFFILIATE OF ENTERGY CORPORATION ARE ALSO EMPLOYEES OFENTERGY CORPORATION OR ANY OTHER AFFILIATE OR SUBSIDIARY OFENTERGY CORPORATION. MOREOVER, THIS POLICY DOES NOT CREATEANY EMPLOYMENT RELATIONSHIP BETWEEN ANY PERSON AND ANYENTERGY SYSTEM COMPANY, NOR DOES THIS POLICY CONFER ANYCONTRACTUAL RIGHT TO ANY PERSON TO BECOME OR REMAIN ANEMPLOYEE OF AN ENTERGY SYSTEM COMPANY.
THIS POLICY IS NOT INTENDED TO, AND SHALL NOT BE CONSTRUED TO,INTERFERE WITH OR RESTRICT ANY RIGHTS PROVIDED BY LAW,INCLUDING THOSE AFFORDED UNDER THE NATIONAL LABORRELATIONS ACT. NOTHING IN THIS POLICY WILL BE CONSTRUED TO
LIMIT AN EMPLOYEE’S RIGHT TO SPEAK WITH OTHERS REGARDINGWAGES AND OTHER TERMS AND CONDITIONS OF EMPLOYMENT OR TO
EXERCISE ANY OTHER LEGALLY PROTECTED RIGHT.

2.0

REFERENCES & CROSS REFERENCES
2.1

Entergy System Policies - Reporting Violations

2.2

Entergy EHS Policies and Standards

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Environmental, Occupational Health &Safety (EHS) Policy

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DEFINITIONS
3.1

EHS – Environmental, occupational health, and safety.

3.2

Entergy EHS Management System – The compilation of Entergy EHSPolicies and Standards, Functional Environmental Programs andProcedures, and Functional OH&S Programs and Procedures acrossEntergy that form a risk-based and systematic approach to EHS
management pursuant to ISO 14001 and ISO 45001 standards.

3.3

Entergy EHS Policies and Standards - The policies and standards
implemented by Entergy as Specialized Policies pursuant to Section 5.4 ofthis Policy to manage compliance with environmental, occupational health,and safety laws, regulations, and best business practices.

3.4

Entergy Environmental Policies and Standards – Entergy EHS Policiesand Standards that apply specifically to environmental matters.

3.5Entergy Occupational Health & Safety Policies and Standards(Entergy OH&S Policies and Standards) – Entergy EHS Policies andStandards that apply specifically to occupational health and safetymatters.

3.6Entergy System Company, Entergy, or Company – Entergy
Corporation and all of its regulated and non-regulated subsidiaries andaffiliates in which Entergy Corporation has a direct or indirect majority
ownership interest.

3.7

Function(s) / Functional – A division of Entergy such as a legal entity(e.g., operating company), Power Generation, Utility, Nuclear, or any otherbusiness, department, or sub-division of the organization.

3.8

Functional Environmental Programs and Procedures – Functionspecific documents establishing how a Function will address theexpectations regarding Environmental risks/compliance that areestablished within Entergy Environmental Policies and Standards.

3.9

Functional Occupational Health & Safety Programs and Procedures(Functional OH&S Programs and Procedures) – Function-specificdocuments establishing how a Function will address the expectations
regarding Occupational Health & Safety risks/compliance that are
established within Entergy OH&S Policies and Standards.

3.10

Functional Leadership (Functional Leader) – The senior-most leader ofthe Function developing a Functional EHS program or procedure.

ENTERGY SYSTEMPOLICIES & PROCEDURES
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Title:

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Environmental, Occupational Health &Safety (EHS) Policy

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3.11

Policy – This Environmental, Occupational Health & Safety (EHS) Policy.

3.12

Specialized Policy - As defined in the Entergy system policy titled Policy
Development and Oversight Policy.

3.13

Subject Matter Expert (SME) – The Entergy employee who is thedesignated authority over an area addressed by one or more Entergy EHSPolicies and Standards.

3.14

Vice President, Sustainability and Environmental Policy – Functional
executive responsible for establishing Entergy Environmental Policies andStandards based on delegation by the Executive Vice President andGeneral Counsel.

3.15

Vice President, Safety – Functional executive responsible forestablishing Entergy Occupational Health & Safety Policies and Standards
based on delegation by the Executive Vice President and Chief OperatingOfficer.

RESPONSIBILITY
4.1Employees, agents and contractors are responsible for:••

4.2

Complying with this Policy and the Entergy EHS Management System
Immediately reporting known, suspected, or potential violations of thisPolicy by following the procedures described in the Reporting
Violations Policy

Enterprise Safety is responsible for:
••
•
•
•
•

Developing the Entergy EHS Management System
Developing Entergy OH&S Policies and Standards (in coordinationwith Sustainability and Environmental Policy)
Developing procedures that are specific to Enterprise Safety andpursuant to the requirements established in the Entergy OH&S Policies
and StandardsAdministering the review and approval process for Entergy OH&SPolicies and Standards
Ensuring that the opportunity for prior input and appropriate crossfunctional review occurs for each business unit significantly affected bynew or revised Entergy OH&S Policies and Standards prior to approval
Providing support to Functions in development of Functional OH&S
Programs and Procedures

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Title:

Environmental, Occupational Health &Safety (EHS) Policy•Last Revision: 8/15/2022

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Facilitating appropriate change management for new or revised Entergy
OH&S Policies and Standards

4.3

Sustainability and Environmental Policy is responsible for:• Developing the Entergy EHS Management System (in coordination withEnterprise Safety)• Developing appropriate Entergy Environmental Policies and Standards• Administering the review and approval process of Entergy EnvironmentalPolicies and Standards• Ensuring that the opportunity for prior input and appropriate crossfunctional review occurs for each business unit significantly affected by
new or revised Entergy Environmental Policies and Standards• Providing support to Functions in development of Functional
Environmental Programs and Procedures• Facilitating appropriate change management for new or revised Entergy
Environmental Policies and Standards

4.4

Vice President, Sustainability and Environmental Policy – isresponsible for:• Developing the appropriate Entergy EHS Management System components(based on delegation by the Executive Vice President and General Counsel)• Approving Entergy Environmental Policies and Standards and revisions
thereto (based on delegation by the Executive Vice President and GeneralCounsel)• Designating the SMEs for Entergy Environmental Policies and Standards

4.5

Vice President, Safety – is responsible for:• Developing the appropriate Entergy EHS Management Systemcomponents (based on delegation by the Executive Vice President andChief Operating Officer)• Approving Entergy OH&S Policies and Standards and revisions thereto(based on delegation by the Executive Vice President and Chief
Operating Officer)• Designating the SMEs for Entergy OH&S Policies and Standards

4.6

Executive Vice President and Chief Operating Officer is responsiblefor:• Delegating the responsibility for developing and approving theappropriate Entergy EHS Management System components to theVice President, Safety• Developing and approving Entergy Occupational Health and Safety
Policies and Standards or delegating such responsibility to the VicePresident, Safety

ENTERGY SYSTEMPOLICIES & PROCEDURES
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Title:

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Environmental, Occupational Health &Safety (EHS) Policy

Last Revision: 8/15/2022

Rev. 0.2

4.7

Executive Vice President and General Counsel is responsible for:
• Delegating the responsibility for developing and approving theappropriate Entergy EHS Management System components to theVice President, Environmental• Developing and approving Entergy Environmental Policies andStandards or delegating such responsibility to the Vice President,
Environmental

4.8Responsible Functional Leader, designee, or successor, in consultation
with Enterprise Safety or Sustainability and Environmental Policy, isresponsible for ensuring the implementation of EHS controls referenced inthis Policy and specified in Entergy EHS Management System. Function
specific programs and procedures are subject to the Function’s applicableapproval processes.

4.9

Subject Matter Experts are responsible for:• Ensuring that Entergy EHS Policies and Standards are kept current,
considering emerging laws, regulations, and best business practices• Interpreting the provisions of Entergy EHS Policies and Standards forwhich they are responsible, as needed

DETAILS
5.1

Entergy’s Environmental, Occupational Health, and Safety
Commitment Entergy is dedicated to being recognized as the premierutility and industry leader in EHS performance by proactively, responsibly,and sustainably managing our business operations to protect ouremployees, contract partners, customers, and the communities in which
we serve. This Policy sets forth Entergy’s direction and commitments topromote sustainable practices with the goal of continuously minimizing
potential EHS risks and achieving world-class EHS performance.
Accordingly, Entergy pledges to the following.
5.1.1 Inclusion and Accountability - Ensure that our employees, contract
partners, and leadership have shared responsibility andaccountability for EHS strategies, which include the support andcreation of a sense of community and belonging that empowers ourworkforce to take ownership and feel safe in their work
environment.
5.1.2 Incident Prevention and Corrective Action
5.1.2.1

Provide a safe and healthy workplace for the prevention ofEHS events, injuries and illnesses and empower
employees to actively identify and address hazards andENTERGY SYSTEMPOLICIES & PROCEDURES
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Environmental, Occupational Health &Safety (EHS) Policy

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unsafe working conditions to care for themselves andothers.
5.1.2.2

In the event of an incident impacting EHS, promptly study
the incident and develop any necessary causal-based
corrective actions and establish ownership andimplementation of each causal-based corrective action for
the Company, Function, or location.

5.1.3 Environmental Stewardship and Community Service
5.1.3.1 Protect the environment by responsibly managing
resources; ensuring compliance with all laws, regulations
and permits; and, reducing/minimizing environmental
impacts from operations.
5.1.3.2 Foster opportunities to improve the environment andcontribute to the positive social and economic impact
across the communities we serve.
5.1.4 Risk and Compliance Management
5.1.4.1 Evaluate and manage known EHS risks by minimizingthem to the lowest level possible and controlling EHS
significant aspects and impacts.
5.1.4.2 Equip our employees and contract partners with the tools
and knowledge to comply with or exceed applicable EHS
compliance obligations, internal/external commitments,and legal requirements, meeting not only the letter but also
the spirit of these requirements.
5.1.5 Stakeholder Engagement and Transparency - Build trust andestablish open channels for communication and feedback with all
stakeholders to understand and anticipate their emerging needs
and deliver sustainable value, as measured by consistently positive
customer interactions, and highly reliable and exceptional service.
5.1.6 Goal Setting
5.1.6.1 Establish and integrate EHS management andsustainability objectives into our strategic planning anddecision-making.
5.1.6.2 Create forward-looking, viable strategies and deliver
reliable solutions to maintain quality of life for ourENTERGY SYSTEMPOLICIES & PROCEDURES
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Environmental, Occupational Health &Safety (EHS) Policy

Last Revision: 8/15/2022

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customers and communities and ensure long-term successfor our owners and employees.
5.1.7 Continuous Improvement and Sustainability - Implement andmaintain an EHS management system that is consistent with thisPolicy and supports continuous improvement by providing aframework for the development of standards that drive alignment
across business functions for streamlining our business, andachieving significant EHS milestones that demonstrate ourcontinued progress toward realizing efficiency improvements,
sustainable performance, and our mission to become the premierutility.
5.2

EHS Management System To deliver on this pledge and to drive
continuous improvement, Entergy shall implement an EHS management
system that is compliant with ISO 14001 and 45001 Standards with thegoal of minimizing adverse environmental impacts and being incident free.

5.3

Compliance with Environmental, Occupational Health, and Safety
Laws, Regulations, and Best Business Practices
5.3.1 Entergy requires employees, agents and contractors to comply withapplicable environmental, occupational health, and safety laws,regulations, and best business practices.
5.3.2 Entergy EHS Policies and Standards (see Section 5.4 below) may
be created and revised as necessary to manage and facilitate
compliance with applicable environmental, occupational health, andsafety laws, regulations, and best business practices.

5.4

Entergy EHS Policies and Standards
5.4.1 The Executive Vice President and Chief Operating Officer has theauthority to approve Entergy EHS Policies and Standards that
apply to the topic of occupational health and safety and to approverevisions to Entergy OH&S Policies and Standards. The Chief
Operating Officer also may delegate such authority to an
appropriate member of senior management (i.e., the Vice
President, Safety).
5.4.2 The Executive Vice President and General Counsel has theauthority to approve Entergy Environmental Policies and Standards
and approve revisions to existing Entergy Environmental Policiesand Standards. The Executive General Counsel also may delegate

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Environmental, Occupational Health &Safety (EHS) Policy

Last Revision: 8/15/2022

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such authority to an appropriate member of senior management(i.e., the Vice President, Environmental).
5.4.3 Entergy EHS Policies and Standards are considered SpecializedPolicies, as defined under the Policy Development and Oversightpolicy and must satisfy the Policy Development and Oversightpolicy’s criteria specified for the approval of Specialized Policies
and on-going requirements related to Specialized Policies.
5.4.4 Employees are required to comply with Entergy EHS Policies andStandards.
5.4.5 Entergy EHS Policies and Standards and revisions to Entergy EHSPolicies and Standards shall become effective on the date ofapproval or on another date specified by the Executive Vice
President and Chief Operating Officer or the Executive Vice
President and General Counsel or their designees.
5.4.6 Unless otherwise specified in Entergy EHS Policies and Standards:
5.4.6.1 Entergy EHS Policies and Standards take precedence overFunctional programs and procedures.
5.4.6.2 Entergy EHS Policies and Standards shall control overFunctional programs and procedures in the event ofconflicts.
5.5Functional Obligations This Policy requires each Entergy Function todevelop, implement, maintain, and regularly evaluate programs andprocedures consistent with Entergy EHS Policies and Standards as part ofits overall effort to maximize support for Entergy’s environmental,
occupational health, and safety commitments.

5.6

Non-Controlled Business Interests With respect to entities in which theCompany has a non-controlling business interest, the responsible
Functional Leader or designee shall, in consultation with Enterprise Safety
and Sustainability and Environmental Policy, advocate that such entities
adopt environmental, occupational health, and safety controls to affectpractices that are consistent with this Policy, and, to the extent practicable,
will include provisions in the contracts or agreements establishing thebusiness interest that adequately mitigate environmental, occupational
health, and safety risks.

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Title:

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Environmental, Occupational Health &Safety (EHS) Policy

Last Revision: 8/15/2022

Rev. 0.2

PROCEDURES
6.1

Posting
6.1.1 Following approval by the Executive Vice President and Chief
Operating Officer, or designee, any new or revised Entergy OH&S
Policies and Standards shall be made available to all employees
via posting on Entergy’s intranet and communicated throughagreed upon methods.
6.1.2 Following approval by the Executive Vice President and GeneralCounsel, or designee, any new or revised Entergy Environmental
Polices and Standards shall be made available to all employees via
posting on Entergy’s intranet and communicated through agreed
upon methods.

7.0

ATTACHMENTS
None.