Portland General Electric Company (“PGE”) adopts herein a code of conduct for all PGE personnel engaged in the buying or selling of natural gas and/or electricity; and in reporting electricity transactions to index publishers.
Pursuant to the requirements of §284.403 of the Commission’s regulations (18 C.F.R. 284.403 (2006)); Paragraph 34.1 of the Price Discovery in Natural Gas and Electric Markets, Policy Statement on Natural Gas and Electric Price Indices, 104 F.E.R.C. 61,121 (2003); Order on clarification, 105 F.E.R.C. 61,282 (2003); Order on clarification, 112 F.E.R.C. 61,040 (2005), and all subsequent related issuances, PGE hereby makes its Code of Conduct for Price Index Reporting publicly available on its Web site.
Only the Mid-Office Operations department, a non- trading unit, independent of PGE’s trading operations, will provide transaction data and any subsequent corrections to price index publishers. All contacts and requests concerning price data submission or clarification should be directed to the Mid-Office Operations department.
Subject to appropriate confidentiality agreements with specified index publishers and their submission guidelines, PGE will report in raw data form all transactions in the physical (cash) markets at applicable trading locations for which an index is published by such index publishers. PGE will report data elements/fields in PGE’s data reporting form on a disaggregated basis, and electronically submit these to price index publishers. Submission of the data will meet agreed-upon deadlines between the respective price index publisher and PGE, and include all of the applicable transaction data consistent with FERC requirements.
PGE will report the following information to price index publishers with which PGE has confidentiality agreements:
Each bilateral, arms-length transaction between non-affiliated companies in the physical (cash) markets at all electricity trading locations published by the specified price index publisher.
Data will not include financial hedges, financial transactions, or swaps or exchanges of electricity.
Data will be provided for each transaction separately.
For each transaction, the following information will be provided:
transaction date and time; and
term (next day or next month)*
In order to ensure the most accurate data submissions possible, PGE’s Mid-Office Operations department will work to verify the accuracy and completeness of the data and reconcile any discrepancies prior to submission. Consistent with the timing requirements of the index publishers, PGE will provide data to the index publishers in as timely a manner as possible to allow for index publishers to review data and raise any questions or concerns prior to publishing. Should the index publisher discover any issue that requires resolution the publishers have agreed to contact the Mid-Office Operations department at PGE, and the latter will make all reasonable efforts to address issues and correct errors in as timely a fashion as possible.
PGE conducts the following checks and audits to ensure the highest degree of accuracy in its price index reporting:
Monthly electronic files are sent to price index publishers of any revisions made after the initial reporting process.
Semi-annual Review by a Mid-Office Operations employee not responsible for the daily price index reporting function. This Review is done to proactively identify any changes and/or opportunities for improvement in the price index reporting function. Results of this review are provided to the Manager of the Mid-Office Operations department.
Annual internal procedural reviews and updates by Mid-Office Operations department staff responsible for index reporting functions to ensure procedures are implemented as written, and that procedures are revised as necessary to take into account new/revised FERC guidance and business improvement opportunities.
Annual independent audit performed by PGE’s Internal Audit department. Results of this report are made available to the Manager of Mid-Office Operations, the Audit Committee of the Board, and annually communicated to each price index publisher to which PGE reports.
PGE will make all reasonable efforts to adhere to the guidelines established by the index publisher to address the error resolution process, including adhering to the process and timeline for submitting corrections and for responding to inquiries from the index publisher. Like all price index data submissions, this function will be carried out by PGE’s Mid-Office Operations department.
PGE will retain electronically all relevant data relating to reported trades for the longer of five years or as required by legal, regulatory or internal standards. Internal and external reviews and audits will also be maintained electronically for the same period.
*Docket No. PL03-3-000, Policy Statement on Natural Gas and Electric Price Indices, issued July 24, 2003, Section V. Price reporting, Para. 34.3.
Version: May 2020