Compliance and Ethics Program

Iberdrola Solutions’ Compliance and Ethics Program (the “Program”) serves as a resource for establishing a culture of high ethical standards and compliance with applicable laws and regulations. The Program is administered by the Company’s Compliance and Ethics Division, and is based on the criteria for an effective compliance program established under Chapter 8 of the U.S. Federal Sentencing Guidelines. Central to the Program is a focus on continuous improvement and adoption of industry best practices. The following are examples of key components of the Program:

Iberdrola Solutions Code of Business Conduct and Ethics

The Company’s Board of Directors has adopted a Code of Business Conduct and Ethics (the “Code”) applicable to all Iberdrola Solutions directors, officers and employees. The Code describes the Company’s core values, such as Corporate Ethics and Responsibility, Respect for the Environment, Safety and Reliability, and Customer Focus. Consistent with these values, the Code establishes standards of conduct and provides guidance for employees to make appropriate decisions when faced with issues of an ethical nature.

Annual Ethics Training

Employees are trained annually on the Code of Business Conduct and Ethics. The training focuses on key areas of ethics and compliance and scenarios that implicate the Code and reinforces the Company’s commitment to ethics and compliance with applicable laws and regulations. Completion rates for this training have historically achieved near 100% through a commitment of the Company’s leadership and employees. This training is supplemented by additional trainings for certain employee groups that face particular areas of compliance risk in their operations.

Communications Program

Through a collaboration of the Company’s Corporate Communications and Compliance groups, employees receive regular communications intended to provide guidance and raise awareness on common ethics and compliance issues faced in the workplace.

Helpline

Iberdrola Solutions has established a 24/7 Helpline available to employees, contractors, consultants, and suppliers. The Helpline is used both to seek guidance on ethics and compliance-related matters, and to report situations that may require investigation, such as questionable accounting or auditing practices, unprofessional behavior, and potential violations of laws or company policies. Callers are given the option of reporting through the Helpline anonymously. Iberdrola Solutions strictly prohibits retaliation against employees who in good faith report ethics and compliance concerns.

• Help Line: 1-877-606-9171

• Internet: txwind.com/speakup

Compliance Risk Assessments

The Company regularly conducts risk assessments of its business operations that involve important compliance-related activities. These assessments help the Company identify key areas of risk, ensure that internal controls have been implemented for compliance, and focus compliance resources in a risk-based manner.