FERC Standards of Conduct Cube Hydro Carolinas, LLC (on behalf of Cube Yadkin Transmission, LLC)

FERC Standards of Conduct Cube Hydro Carolinas, LLC is regulated by the Federal Energy Regulatory Commission (FERC). Title 18 Code of Federal Regulations (CFR) relates to Conservation of Power and Water Resources. Part 358 stipulates the Standards of Conduct for Transmission Providers. The Standards of Conduct rules govern the relationship between a Transmission Provider's transmission function employees and its marketing function employees.

Principles of the FERC Standards of Conduct (a) a Transmission Provider must treat all transmission customers, affiliated and nonaffiliated, on a not unduly discriminatory basis, and must not make or grant any undue preference or advantage to any person or subject any person to any undue prejudice or disadvantage with respect to any transportation of natural gas or transmission of electric energy in interstate commerce, or with respect to the wholesale sale of natural gas or of electric energy in interstate commerce; In other words, the Transmission Provider must provide equal access to non-public transmission information to all transmission customers alike, regardless of affiliation or non-affiliation.

Principles of the FERC Standards of Conduct (b) a Transmission Provider's transmission function employees must function independently from its marketing function employees, except as permitted by the Standards of Conduct rules or FERC order; (c) a Transmission Provider and its employees, contractors, consultants and agents are prohibited from disclosing, or using as a conduit to disclose, nonpublic transmission function information to the Transmission Provider's marketing function employees; (d) a Transmission Provider must provide equal access to non- public transmission function information to all of its transmission customers, affiliated and non-affiliated, except in the case of confidential customer information or Critical Energy Infrastructure Information.

Affiliate Definition (1) Another person that controls or is controlled by or is under common control with, the specified entity. An Affiliate includes a division of the specified entity that operates as a functional unit. (2) “Control” as used in this definition means the direct or indirect authority, whether acting alone or in conjunction with others, to direct or cause to direct the management policies of an entity. A voting interest of 10 percent or more creates a rebuttable presumption of control.

Transmission Function Employee Transmission Function Employee is defined as: an employee, contractor, consultant or agent of a Transmission Provider who actively and personally engages on a day-to-day basis in transmission functions. Transmission Function is defined as: the planning, directing, organizing or carrying out of day-to-day transmission operations, including the granting and denying of transmission service requests.

Marketing Function Employee Marketing Function Employee is defined as: an employee, contractor, consultant or agent of a Transmission Provider or of an affiliate of a Transmission Provider who actively and personally engages on a day-to-day basis in marketing functions. Currently all marketing functions are being performed by Cargill Power Markets, LLC.

Independent Functioning of Transmission Function Employees and Marketing Function Employees The transmission function employees must function independently of the marketing function employees. No non-public information concerning the transmission system shall be discussed (including information about available transmission capability, price, curtailments, ancillary services and the like) . A transmission provider is prohibited from using anyone as a conduit for the disclosure of non-public transmission function information to its marketing function employees.

Physical Separation The primary control center and backup control center has sign-in logs for all persons (employees as well as visitors) who are admitted to these facilities without keycard access (i.e., via "escorted access") are required to sign in and out. Sign-in logs are retained for at least 90 days and periodically reviewed by CIP Compliance. If an employee without approved keycard access attempts to access or requests permission to access the control centers without indicating who their escort is and it is unclear as to whether should be permitted access, CIP Compliance should be contacted to ensure such visit is authorized.

Transparency Job titles and descriptions are posted on the Cube Hydro Carolinas, LLC public OASIS website. Shared facility information (between transmission function employees and marketing function employees) shall be disclosed via the Cube Hydro Carolinas, LLC public OASIS website as well as a list of Marketing Affiliates. Other public information available on the Cube Hydro Carolinas, LLC public OASIS website include s but is not limited to the Open Access Transmission Tariff (OATT), Cube Hydro Carolinas, LLC Available Transfer Capability Implementation Document (ATCID), and information pertaining to outages and studies.

Training and Distribution This information shall be distributed to all transmission function employees, marketing function employees, officers, directors, management, employees/contingent workers, and others likely to become privy to transmission function information. This information is distributed annually with annual FERC training. Any applicable new employees shall receive this information and training within the first 30 days of their employment. Upon completion of training, employees will be required to acknowledge that they have received training regarding the Standards of Conduct and agree to abide by them.

Review, Revisions and Responsibility The FERC Standards of Conduct training will be reviewed and revised as necessary to conform with changes to the Standards of Conduct reflected in Order No. 717 and subsequent orders. All employees are responsible for compliance with the FERC Standards of Conduct. The Chief Compliance Officer is responsible for overseeing implementation and enforcement of the FERC Standards of Conduct, though roles may be delegated to others as appropriate.

Obligation to Report Any employee who knows of or suspects noncompliance with or a violation of these procedures or the Standards of Conduct is required to report such noncompliance or violation immediately. Known or suspected violations can be reported to the employee's supervisor, the Chief Compliance Officer or his/her designee, or the Cube Hydro Legal Department.

Who to Contact Eli Hopson, Chief Compliance Officer; VP, Legal, Regulatory & Policy; (240) 482-2714 (w), (202)368-0828 (m); ehopson@cubehydro.com Amy Kohntopp, Compliance Coordinator; (865)-977-2078 (w), (865) 307-2779 (m); akohntopp@cubecarolinas.com You may also contact your immediate supervisor

Prohibition Against Retaliation Retaliation against an employee for raising concerns with management or regulatory agencies is considered harassment. Cube Hydro Carolinas, LLC will not tolerate harassment of any kind in the workplace, and forbids retaliation against any employee who has brought concerns to management or to regulatory agencies such as the FERC, Equal Employment Opportunity Commission, or Occupational Safety & Health Administration or has participated in the investigation or resolution of a harassment situation.

Consequences for Violations Violations of the Standards of Conduct can have serious consequences for Cube Hydro Carolinas, LLC. Therefore, employees who violate the Standards of Conduct may be subject to disciplinary action up to and including discharge.

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