Supplier Code of Conduct


Our Code

What’s the purpose of our Code?

At Clearway Energy Group LLC (“Clearway”), we’re on a mission to deliver the best possible company we collectively can create. To do so, we need to work as a single team, with unified, exemplary standards for how we make decisions and conduct our business. This covers not only everyone who works at Clearway, but also our contractors, consultants and agents (collectively, ”Suppliers”). Clearway’s values and operating principles support ethical decision-making and are the foundation of Clearway’s culture.

Clearway’s values are:
• Quality
• Respect
• Possibility

Each employee, director and Supplier must embrace our operating principles with respect to:
• Safety & Health
• Integrity
• Accountability
• Continuous Improvement
• Teamwork

Clearway’s Supplier Code of Conduct (the “Code”) is a guide, translating Clearway’s values and operating principles into the standards of behavior we expect from both Clearway’s employees and Suppliers. The Code provides guidance on solving problems, finding answers, and communicating concerns. In addition, we expect all companies with which we do business to embrace and act consistently with Clearway’s Code and applicable law.

Not every workplace situation will be covered by this Code, however, it does outline key responsibilities and the guiding principles intended to support ethical and socially responsible behavior and choices. Suppliers are responsible for maintaining and enforcing written policies requiring adherence to lawful business practices and ethical conduct consistent with Clearway’s Code for both their employees and subcontractors.

It is important to understand that violating this Code could result in termination as a Clearway Supplier including the termination of associated contracts and legal action. In addition, Clearway reserves the right to conduct an audit to confirm Suppliers’ compliance with this Code.

Suppliers are responsible for ensuring that their employees and subcontractors understand and comply with these standards. Suppliers may require their subcontractors to comply with this Code by insertion of these requirements in any subcontract pursuant to any goods and/or services to be provided as set forth in a Clearway Purchase Order.

In rare cases, applying a Code provision or Clearway policy may not seem like the right thing to do. If you, the Supplier, are unsure please contact your Clearway Site Representative or the Clearway Ethics Alertline.

Clearway’s Ethics Alertlinne

The Clearway Ethics Helpline (844-537-9522) and the Clearway Ethics Alertline are available 24 hours a day, seven days a week. They are administered by an outside company to ensure confidentiality and anonymity if desired. Calls are not traced or recorded, and the company does not keep any identifiable information regarding the sender of an online communication.

Clearway’s Commitment

Clearway’s strength depends on our promise to each other to live by our values and operating principles as we go about the tasks of fulfilling our mission and acting as stewards for our shareholders. That promise is reflected in this Code, and when Clearway and its Suppliers are guided by the Code we ensure:
• An ethical business culture that includes working collaboratively with a spirit of trust
• Compliance with applicable laws and regulations, as well as this Code
• A safe, fair and respectful workplace
• A positive work environment free of harassment, bullying and intimidation
• Decisions that are made in the best interests of Clearway, without personal conflicts or bias
• Confidence that reports of all kinds, made in good faith, will be taken seriously and investigated appropriately and that those reporting will not face retaliation

Standing up and speaking out

At Clearway, we depend on each other, including our Suppliers, to speak out when we have a question, suggestion or concern. Our safety, integrity and success depend on each of us having the courage and commitment to make our voices heard. It’s equally important that when others speak out, we listen carefully with an open mind. If you have a question or concern, please contact your Clearway Site Representative, the Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline).

Warning: retaliation prohibited

Retaliation of any kind against someone making a report that he or she believes to be true — which Clearway calls reporting in good faith — is not tolerated. Doing so would be contrary to our core values and prevent Clearway from building a “speak out” culture. If you see, suspect, or are subject to retaliation for speaking out, please contact the Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline). Of course, acting with integrity and respect requires that we make all of our reports in good faith. Knowingly making a false report or failing to report a suspected violation may result in termination as a Clearway Supplier including any associated contracts.

Clearway operates in a complex, highly regulated environment, subject to oversight, rules and regulations by a wide range of government agencies, industry organizations and energy exchanges. For Clearway to succeed in this environment and maintain our reputation for integrity, it is crucial for each of us, including our Suppliers, to understand our responsibility to participate fully and honestly in any audit, investigation or inquiry, when asked to do so by Clearway. In addition, Clearway and its Suppliers are accountable for obeying all of these rules and regulations, reporting actual or suspected noncompliance and cooperating in audits, investigations and appropriate requests for information.

If you, a Supplier, receive a notice from Clearway asking you to locate or retain documents or records of any kind, you’ll need to do so without hesitation. This applies even if you haven’t received such a notice but have reason to believe that documents or records you have or control may relate to a dispute, investigation or potential litigation. Suppliers have an obligation to never alter, delete, destroy or hide records.

If you, a Supplier, receive a non-routine request for information from a government or regulatory agency directed to Clearway, bring it to the attention of your Clearway Site Representative or Clearway’s legal department immediately. Only Clearway’s legal department is authorized to respond to or accept the service of legal papers (such as subpoenas) on Clearway’s behalf.


Clearway embraces Safety with an ultimate goal of zero injuries, driven by a focus on preventative safety practices and a commitment to returning everyone back home to their loved ones every day. We all share a responsibility to keep each other and our operations safe. Whenever you notice unsafe conditions or see a potential problem, stop what you’re doing and warn others. As soon as possible, Supplier personnel should notify their company’s management and their Clearway Site Representative. By reporting problems immediately, we significantly reduce the risk of accidents, injury and illness.

Rule no. 1: If it’s unsafe, don’t do it

To ensure the health and safety of all:
• Watch for any unsafe or potentially unsafe situations and report them immediately
• Keep public safety at the forefront of our minds
• Participate in all Clearway safety program training and activities
• Understand and comply with all safety and health laws and related company rules and regulations
• Use and wear required safety and personal protective equipment and clothing, and make sure others do as well
• Maintain facilities and equipment in a safe condition
• Stop any activity that puts the health or safety of others at risk

Suppliers, if a safety incident occurs on site, you are required to notify your company’s management and your Clearway Site Representative immediately. For additional Clearway safety information, contact your Clearway Site Representative.

Reporting for duty

Physical and mental health are crucial to our ability to do our jobs effectively. Clearway and our Suppliers can help make our workplace safe and productive by:
• Always reporting to work free from the influence of alcohol or illegal drugs under federal law
• Never using, possessing, selling or distributing controlled substances or drugs deemed illegal under federal law on Clearway property or while conducting Clearway business while on or off Clearway Property

The use of legally prescribed drugs or over-the-counter medications is permitted on the job as long as it does not affect an individual’s ability to perform their job safely and effectively. If there is concern about anyone’s ability to perform a job safely at Clearway, speak up and tell your Clearway Site Representative or contact the Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline).

Building a sustainable future

Clearway is committed to making the world a better place. That begins with our strategic efforts to consider sustainability in everything we do. Clearway respects our neighbors and their communities and strives to keep them safe by operating in ways that meet or exceed all applicable environmental laws and regulations. Clearway takes our environmental responsibilities seriously because we know it’s the right thing to do — for ourselves, our neighbors and future generations. Clearway expects the same from our Suppliers.

Where can I report a safety or environmental concern?

• Your Clearway Site Representative
• The Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline)

Conflict minerals

Clearway supports the purpose of Section 1502 of the Dodd-Frank Act relating to conflict minerals (Conflict Minerals Rule). Conflict minerals include gold, tin, tungsten or tantalum originating from the Democratic Republic of the Congo or an adjoining country, including recycled or scrap materials traceable to this region. We expect that you, as a supplier, have controls and policies in place to ensure that you are in compliance with the Conflict Minerals Rule and do not supply us products containing conflict minerals. If you believe that conflict minerals are contained within products supplied to us, you must investigate and disclose your findings to us regarding the origin of the suspected conflict mineral.

Forced Labor

Supplier shall not manufacture or subcontract for the manufacture of any products for which forced labor is used in the production of that product or material. Supplier shall ensure that each of its and its Affiliates’ subcontractors and suppliers shall not directly or indirectly use (through suppliers or subcontractors) forced labor in the manufacture of any Products exported to or imported into the United States. Seller shall comprehensively implement due diligence procedures for its and its Affiliate’s suppliers, subcontractors and other participants in its supply chains, to comply with the foregoing. Seller shall notify Buyer as soon as it becomes aware of any breach, or potential breach, of its obligations under this provision. For purposes of this provision, “forced labor” shall mean all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.


Conflicts of interest

It is important to make business decisions based upon the best interest of Clearway and not personal consideration. A conflict of interest occurs 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 Clearway. This includes (but is not limited to) providing or offering a Clearway employee something of value in return for getting Clearway work or having an association or relationship that could affect impartiality in business decisions. The requirement to avoid conflicts of interest applies to situations involving both Clearway employees and Clearway employee family members.

It’s important to recognize conflicts of interest and to disclose them when they occur or have the potential to occur. Conflicts of interest harm Clearway because those involved aren’t working toward the same goals, and they can undermine our confidence in one another or create the appearance of unfairness in the workplace.

The best way to avoid conflicts of interest is with timely, complete and honest disclosure to your company’s management and your Clearway Site Representative. Approval from Clearway’s Chief Compliance Officer may be necessary in certain situations.


Diversity and equal opportunity in employment

A diverse workforce is a strength. Therefore, Suppliers should provide equal opportunity to all and
employment decisions shall not be based on an individual’s:
• Race
• Color
• Religion
• National origin
• Genetic information
• Gender, gender identity or gender expression
• Age
• Marital status
• Physical or mental disability
• Sexual orientation
• Veteran status
• Other protected characteristic

Contact the Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline) if discrimination in hiring, promotion, transfer, training, layoff, termination or compensation and benefits is experienced or witnessed. Speaking out about discrimination is a matter of living Clearway’s core values of respect and exemplary leadership. Clearway will not tolerate retaliation against Suppliers who report discrimination in good faith.

Fair employment practices

Fair employment practices do more than keep Clearway in compliance with applicable labor and employment laws. They contribute to a culture of respect. Clearway is committed to complying with all applicable laws pertaining to freedom of association, privacy, collective bargaining, immigration, working time, wages and hours, as well as laws prohibiting forced, compulsory and child labor, and employment discrimination. Clearway requires the same commitment from all of our Suppliers including their employees and subcontractors while working on Clearway property or elsewhere on behalf of Clearway. Beyond legal compliance, we strive to create an environment considerate of all employees wherever Clearway conducts business.

Suppliers should 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 persons is prohibited.

Background checks of Suppliers, their employees and subcontractors may be required in accordance with Clearway’s requirements. Clearway will notify a Supplier if such checks are required.

Keeping Clearway harassment free

Teamwork and respect help ensure a safe, positive, professional work environment. Eliminating harassment and bullying allows everyone at Clearway to thrive. Harassment is speech, behavior or conduct that creates an intimidating, hostile or offensive work environment, or limits someone’s performance or potential, and is based on that person’s race, color, religion, national origin, ancestry, gender, gender identity, gender expression, genetic information, sexual orientation, marital status, family status, age, physical or mental disability, veteran or military status, or other protected characteristic. Even conduct intended as a joke or a compliment can be taken as harassment because it’s the recipient’s perception of the situation, not the intention of the person who created it, that counts. Harassment by anyone (including, but not limited to, employees, supervisors, and Suppliers) is prohibited and should be reported if you become aware of it.

Behaviors to avoid include:
• Unwanted physical contact or sexual advances
• Offensive comments about an individual’s appearance, religion, ethnicity or sexual orientation or any other protected characteristic
• Inappropriate, sexually explicit or offensive jokes or language
• Making hiring, continued employment or positive evaluations dependent on the performance of sexual favors or the receipt of romantic attention
• Retaliation for reporting harassment or threatening to report harassment

Just as there is no place at Clearway for harassment, there is no room for bullying. We do not tolerate or engage in bullying, including physical or verbal abuse, intimidation or threats, aggressive behavior, teasing or practical jokes.
Suppliers, their employees, and subcontractors performing work on behalf of Clearway will not initiate or take part in any form of harassment or bullying. Clearway will not tolerate from its Suppliers any form of harassment or abuse toward Clearway employees or others. This prohibition includes but is not limited to comments, emails or other communications that contribute to an offensive work environment.

Contact the Clearway Ethics Helpline (844-537-9522) or Alertline (Clearway Ethics Alertline) if harassment or bullying is experienced or witnessed. Complaints will be objectively investigated and, where appropriate, remedial measures will be taken. By holding fast to Clearway’s values of teamwork, respect and exemplary leadership, such situations can be avoided.

Workplace violence prevention

Clearway is committed to keeping every Clearway facility a safe and positive workplace, free of violence and threats. Physical or verbal intimidation, coercion or violence of any kind in any aspect of our business is not tolerated. Suppliers shall not bring weapons or other dangerous or hazardous devices onto Clearway property or into Clearway vehicles. If workplace violence is witnessed or there is potential for violence, or you feel anyone’s safety is at risk, ensure your own safety first and then call 911 or other emergency services as appropriate.

Data privacy

In the course of work, Suppliers may often have access to non-public, confidential information regarding Clearway, its employees, customers and other third parties. The unauthorized use or release of such information could harm Clearway and potentially violate the law. Suppliers have a responsibility to keep this information safe and secure.

Employee, customer and other third-party confidential information includes, but is not limited to, Clearway, its customers, employees and competitive data and intellectual property, which generally refers to:
• Contact information including names,emails, and/or phone numbers
• Health and insurance information
• Credit card information
• Social Security numbers
• Driver’s license or government issued identification numbers
• Clearway documents
• Banking information
• Salary and benefit details
• Date of birth
• Mother’s maiden name
• Contracts


Gifts and entertainment

Giving and receiving small gifts and sharing reasonable meals and appropriate entertainment are ways to connect with Clearway employees and deepen business relationships. Integrity requires that Clearway never accepts gifts, entertainment or other favors that are, or may appear to be, intended to influence the business decisions of those receiving them. Clearway employees are not authorized to accept gifts, entertainment, employment of family, or other favors from Suppliers that could influence or appear to influence the Clearway employee to grant an unfair competitive advantage or to motivate the Clearway employee to do anything that is unethical, illegal or prohibited by Clearway policy. There must not be any explicit or implicit suggestion of a “quid pro quo.” Approval for giving or accepting gifts must be submitted to Clearway’s legal department prior to the exchange.

Bribery, kickbacks and corruption

At Clearway, we don’t engage in bribery, kickbacks or corruption, or anything that looks even remotely like them. We’re scrupulous in our business dealings and even more careful in our interactions with public or government officials. Clearway 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. Clearway Suppliers and anyone else acting on our behalf shall meet these same high standards. Any contact with government officials on behalf of Clearway requires express, written pre-approval by Clearway’s SVP of external affairs.

Corruption in all its forms has serious legal consequences for the companies and individuals who become involved in it. More importantly, it is terribly destructive by distorting markets, dragging down economic development and wreaking havoc on local communities. That’s why Clearway recognizes and abides by applicable antibribery and anticorruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA). Clearway complies with the letter and spirit of the law and expects the same from our Suppliers.

Clearway 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 Clearway. This includes payments of money or anything else of value to or by Clearway Suppliers acting on behalf of Clearway.

Suppliers shall not give any gifts on behalf of Clearway to public officials, or officials of any agency or court that regulates our business, or with whom a matter is pending.

Where differences exist between this Code’s guidelines and local, state or federal laws and regulations, Suppliers must apply the strictest standard.

Keeping your distance from decision makers

In the course of our work, Clearway frequently communicates with judges, government employees and
regulators who decide on the permits, applications, bids, contracts, rules and rates that affect our
business. Suppliers should not be involved in any political activity as a representative of Clearway or use
the Clearway name to participate in political activities without express written consent from the
Clearway legal department or the SVP of external affairs.

Fair dealing

Suppliers 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. 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.

Competition and antitrust

Clearway is committed to competing lawfully based upon the merits of our products and services. Suppliers shall fully comply with the applicable antitrust and competition laws everywhere they engage in business on our behalf, whether anyone is watching. These laws vary from country to country, but in general, they protect consumers by prohibiting competitors from acting together to control prices or reducing competition. Prohibited activities include:

• Price-fixing and bid-rigging
• Agreements with competitors not to deal with a customer or supplier
• Agreements with competitors to limit production
• Misrepresentations, including false or misleading advertising, regarding our own or a competitor’s product or service

Suppliers working on our behalf shall not engage in anticompetitive practices that could violate those laws or harm Clearway’s business or reputation.

Compliance with laws and regulations

Suppliers shall comply with all applicable policies, laws, rules and regulations while on Clearway premises or while conducting business elsewhere on behalf of Clearway and must promptly report any known or suspected violations. Suppliers are responsible for the actions of their employees and subcontractors to ensure that they are:
• Trained, fully informed and follow the laws, rules, regulations and Clearway policies that are applicable to the work performed;
• Properly supervised to ensure compliance with laws and regulations; and
• Not assigned to Clearway work if the Supplier has any reason to believe that it may create non-compliance with this Code.

Market manipulation and regulation

When it comes to selling products and services, Clearway has compliance obligations under the rules of the Commodities Futures Trading Commission, the Federal Energy Regulatory Commission, the North American Electric Reliability Corporation, the relevant independent systems operators and many others. Clearway and its Suppliers are accountable for obeying all these regulations, reporting actual or suspected noncompliance, and cooperating in audits, investigations, and appropriate requests for information. Compliance with the market manipulation rules of these agencies, as well as those of the other organizations and exchanges, is vital to Clearway’s and our Suppliers’ integrity, reputation and success.

Market manipulation rules prohibit actions or transactions that have no legitimate business purpose and are meant to — or reasonably could — manipulate market prices, conditions or rules for electric energy or electricity products. Examples include wash trades, transactions based on the provision of false or misleading information and artificially created congestion.

Suppliers should be familiar with the legal and regulatory requirements associated with the work performed for Clearway. Contact the Clearway legal department for assistance.

Insider trading

Many of us, including some Clearway Suppliers, have access to information that, if made public, might affect the share price of Clearway Energy, Inc. or other publicly traded companies, including our suppliers, customers and potential merger and acquisition targets. This is “material nonpublic information” and Clearway Suppliers have a legal and ethical duty not to disclose it to anyone. It’s against the law to trade in the stock (or other securities) of Clearway Energy, Inc. or any company based on material, nonpublic information regarding Clearway or regarding developments that could affect Clearway or any other company, or to provide that information to anyone else for them to trade based on it.

International trade

Whenever Clearway or our Suppliers do business of any kind across national borders, we shall comply with the laws of both the United States and the other countries involved relating to shipping goods, conducting financial transactions, transferring or sharing data or technical information, providing services or otherwise operating across national borders. The U.S. government restricts trade with certain countries, companies and people to prevent nuclear proliferation, to battle terrorism and the global narcotics trade and to impose political sanctions. Clearway and its Suppliers shall abide by these restrictions.

Dishonesty and theft

Suppliers are responsible for safeguarding Clearway property and for using such resources for only
legitimate business purposes to advance the interests of Clearway. Clearway 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 Clearway property, funds, securities or other assets of Clearway, its employees and customers
• Damage or destroy property or materials belonging to Clearway, its employees or customers
• Divert electric energy, natural gas, or any other product produced or owned by Clearway or service provided by Clearway for personal gain
• Sell or provide Clearway resources or services
• Remove Clearway equipment, property, material or money from its premises, its employees or customers without authorization
• Remove, publish, destroy or alter physical and electronic Clearway records
• Copy, reprint, duplicate, recreate in whole or in part computer programs or related systems developed or modified by Clearway personnel, or acquired from outside suppliers


Protecting assets

Suppliers who utilize Clearway assets have a responsibility to ensure that they keep them safe and use them efficiently.

Clearway’s assets include all equipment, materials, systems, records, buildings, real estate, vehicles, plans and intellectual property— everything Clearway owns or leases or is entitled to. Clearway assets are to be used by Suppliers for business purposes only. Whether it’s a phone, laptop, data sheet or vehicle, Clearway assets are to be treated with care — guarding against waste, damage and theft. Suppliers shall not remove, duplicate, re-create, destroy, publish, sell or give away Clearway assets.

Maximizing corporate opportunities

While performing work for Clearway, Suppliers may occasionally come upon valuable business opportunities. Because these opportunities belong to Clearway, Suppliers shall present them promptly to your Clearway Site Representative so that Clearway can evaluate them.

Use of Clearway Information Technology systems

Clearway’s IT systems, including our telephone, email, computer systems, intranet and internet, are company property and critical to the process of creating value. Suppliers may utilize Clearway’s IT systems to perform their work, with Clearway’s authorization. Suppliers must use Clearway’s IT equipment and network systems
responsibly and primarily for the business purpose for which they are intended. Clearway’s IT equipment and the messages, data, files and software stored on or transmitted on Clearway’s IT systems are Clearway property and may be monitored or reviewed for any reason, business purpose or concern, including compliance with applicable licenses, laws, regulations and Clearway policies. Suppliers shall not place any information acquired from Clearway’s IT systems in any other location or non-Clearway system without written approval by Clearway. Suppliers shall have no expectation of privacy on the Clearway network.

Confidential and proprietary information

At Clearway, we’re constantly creating value through the inventions, innovations and improvements that become corporate assets. These assets are the future of Clearway, and our success depends on keeping them confidential. These include Clearway’s intellectual property, trade secrets, patents, registered and unregistered copyrights, trademarks, service marks, ideas and inventions.

Much of our proprietary information is confidential, meaning it’s not available to the public. This includes:
• Unreleased financial results and data
• Undisclosed intellectual property (such as inventions, software, designs, process improvements and other trade secrets not submitted for patent, trademark or copyright protection)
• Strategic and marketing plans
• Supplier lists and bills of materials
• Nonpublic and draft bids, responses and proposals

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, always kept secure, and disclosed only when authorized or legally mandated. It may never be used for personal gain or for the unauthorized benefit of persons outside Clearway.

Except as explicitly provided otherwise in any written agreements between Supplier and Clearway, 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 Clearway or that are based on or derived from Clearway confidential information or Clearway property to which Supplier has access to belongs to Clearway and, if requested, shall be specifically assigned by Supplier to Clearway.

In our increasingly interconnected digital world, the risk of losing valuable information is significant and growing. The loss or theft of a laptop, smartphone or even thumb drive can lead to a massive data breach, damage to our hard-won competitive advantage and significant financial impact. Unless specifically authorized to do so, Suppliers shall never download or transfer confidential or proprietary data to portable or personal devices. If you are authorized, make sure to encrypt the download properly and that the device is protected.

Clearway transfers confidential or proprietary information to third parties only when we have a signed nondisclosure agreement approved by the Clearway legal department. Suppliers must notify their Clearway Site Representative immediately if 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 Clearway to meet compliance, legal, financial and management obligations. Clearway is committed to full, fair, accurate, timely and understandable disclosure in all public reports and communications.

Supplier should keep accurate and complete business records that show all transactions in reasonable detail and prohibit 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 Clearway 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 Clearway nor otherwise take or fail to take any step that could impair Clearway from complying with these requirements.

The commitment of Clearway to maintain accurate books and records requires that Suppliers accept only orders when accompanied by an approved Clearway purchase order or credit card. Failure to comply with the requirement may impact the ability of Clearway to pay for the goods and/or services in a timely manner.

Record Retention

Requirements for retaining records are governed by various federal and state laws. Suppliers have an obligation to prevent destruction of documents related to an investigation, claim or lawsuit. Records retention applies to all records created, electronic or hard-copy.

Because the loss or destruction of records related to investigations or lawsuits can have very significant consequences for Clearway and its Suppliers, “legal holds” must be followed carefully as soon as they are received. If you’re not sure of what’s required, or if you become aware of a subpoena, pending or contemplated litigation, or a governmental investigation, notify Clearway’s legal department immediately.

Public communications and media inquiries

Clearway and its Suppliers have a responsibility to protect Clearway’s reputation and confidential information when communicating with the public. To ensure that Clearway’s public communications are accurate, complete and in compliance with applicable law and internal policy, no Supplier or independent contractor is permitted to speak publicly on Clearway’s behalf nor are they permitted to respond to inquiries from news media, securities analysts and investors. If a Supplier receives an inquiry from an external source, such as the media, and elected official or other public source, the supplier will immediately notify Clearway external affairs.

Social media

When used wisely, social media helps Clearway connect with our customers and spread the word about Clearway’s products and services. However, because content on social media is usually not subject to prior internal review, can move quickly and unpredictably, and is impossible to retract or delete, Suppliers shall not post anything related to Clearway on blogs or other online forums unless specifically authorized in writing to do so by the Clearway SVP of external affairs or their designee. Suppliers are to act with integrity and not publish, post or disclose proprietary or other confidential information related to Clearway. Suppliers should avoid commenting on Clearway customers and business relationships and shall not threaten or harass Clearway employees or share their personal information without their permission.

Remember, contact your Clearway Site Representative, or the Clearway Ethics Helpline (844-537-9522) or
Alertline (Clearway Ethics Alertline). if you have any concerns about any information shared on social media.



Clearway works to create a sustainable energy future for the world by safely providing clean, reliable power that enhances people’s lives and delivers value to our stakeholders. Clearway’s decisions reflect our desire to set an example for the rest of the industry by producing affordable, safe and reliable energy while continually growing our business.

Clearway seeks Suppliers who integrate principles of sustainable development into all areas of their business. Clearway always strives to act in an ethical, transparent and responsible way, and we expect our Suppliers as well as their subcontractors to do the same.


Government relations

As an industry leader and committed corporate citizen, Clearway regularly keeps government and regulatory officials informed about our operations, products and services. Exemplary leadership in government relations means we’re proud of our work, excited to share our positions and eager to shape the discourse. Clearway’s external affairs team is responsible for contact with these officials and compliance with the laws and rules governing lobbying and corporate political activity. Contact with government officials regarding Clearway business requires preapproval from the SVP of external affairs or their designee.

Political contributions

Clearway is committed to complying with all applicable laws and regulations governing political activities and communications. In certain limited circumstances, Clearway may make corporate political contributions to state or local candidates (corporate political contributions to federal candidate campaigns are prohibited by law). Additionally, Clearway may make direct or in-kind contributions to a political party candidate or campaign, depending on whether these are permissible under applicable law. Such in-kind donations may include hosting a site visit or other public event. A Supplier shall not give any gifts (including the use of Clearway sites or Clearway property) to any public officials, or any employee or representative of any governmental entity. Contact Clearway external affairs if there is any question about political contributions.

Political participation

We’re all free to participate in the civic and political activities of our communities. When we do, we must make clear that we are speaking and acting as individuals — not on behalf of Clearway. Suppliers shall not be involved in any political activity as a representative of Clearway. Suppliers shall not be involved in any political activity as a representative of Clearway or use the Clearway name to participate in political activities. Suppliers shall not use Clearway’s computer systems, email addresses or other property to express personal political views or to benefit a political candidate or campaign.