Prohibited Investments List
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1 Prohibited Investments List Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 1 of 10
2 REVISION HISTORY VERSION NO. DATE REVISED BY DESCRIPTION /1/12 C. Snay Initial release of standalone document to replace Appendix B to Guide to Employees Code of Conduct and Ethical Principles 1.1 1/1/13 C. Snay Quarterly Update, effective January 1, /10/13 K. King Quarterly Update, effective April 1, /9/13 K. King Quarterly Update, effective October 1, /7/13 K. King Corrected list to include General Electric Company which was inadvertently omitted from the last quarterly update 1.4 1/1/14 K. King Quarterly Update, effective January 1, 2014; changed table format for readability 1.5 4/1/14 K. King Quarterly Update, effective April 1, 2014; updated cover page to clarify the rules for investing in mutual funds and for doing business with or owning financial products offered by companies on the Prohibited Investments List 1.6 7/1/2014 K. King Quarterly Update, effective July 1, 2014; updated document overview to clarify the rules for investing in Exchange-Traded Funds ( ETFs ) 2.0 9/19/2014 K. King Updated the guidance section and substantially reduced the list of prohibited investments reflecting new prohibited investment rules resulting from recent NYISO and MISO FERC Orders. A complete list of additions and deletions to the 7/1/2014 Prohibited Investments List is included as Appendix A /1/2015 K. King Quarterly Update, effective January 1, 2015; streamlined the list by removing the ISO Agreement Holder or Project Name column from the Prohibited Investment table. A complete list of additions and deletions to the 9/19/2014 Prohibited Investments List is included as Appendix A /1/2015 K. King Quarterly Update, effective April 1, /1/2015 K. King Quarterly Update, effective July 1, 2015; changed corporate logo /1/2015 K. King Quarterly Update, effective October 1, 2015 Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 2 of 10
3 VERSION NO. DATE REVISED BY DESCRIPTION 4.0 1/1/2016 K. King Quarterly Update, effective January 1, 2016; combined equity and bond lists into a single prohibited investments list; expanded the definition of security beyond stocks and bonds to include any financial or ownership interest; limited the definition of affiliate to electric sector affiliates /1/2016 K. King Quarterly Update, effective April 1, /1/2016 K. King Quarterly Update, effective July 1, /1/2016 K. King Quarterly Update, effective October 1, /1/2017 C. Billing Quarterly Update, effective January 1, /1/2017 C. Billing Quarterly Update, effective April 1, /1/2017 C. Billing Quarterly Update, effective July 1, /1/2017 C. Billing Quarterly Update, effective October 1, /1/2017 C. Billing Quarterly Update, effective January 1, /1/2018 C. Billing Quarterly Update, effective April 1, /18/2018 C. Billing Corrected list to include Calpine Corporation s bonds as a prohibited investment 7/1/2018 C. Billing Quarterly Update, effective July 1, 2018 Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 3 of 10
4 Prohibited Investments The following is a list of market participants for which having any financial interest in is prohibited under the California ISO Employees Code of Conduct and Ethical Principles. While it is not exhaustive, it is intended to provide a helpful starting point in making investment decisions consistent with the Code. Among the limitations of the list is that it is updated only quarterly. However, entities can become ISO market participants at any time. These entities may not be on the list until the next update. Also, the list may not reflect the latest corporate transactions that might add new companies to the list or reflect changes of ownership. If you hold a financial interest in a company that appears on this list or that has a similar name to a company that appears on this list and you think you need to divest, or if you want to check whether a potential investment is prohibited, please contact Greg Fisher in Legal at x7206 (gfisher@caiso.com) or Christina Billing in Finance at x2204 (cbilling@caiso.com), to determine the appropriate action. Also, the Prohibited Investments List does not track entities that are not publicly traded. If you are considering investing in an entity that is not publicly traded, you must contact Christina Billing in Finance to determine whether the investment is permissible. Employees, Governors and their immediate family members (i.e., spouse and minor children) are prohibited from holding a financial interest in a market participant. For the purpose of this prohibited investments rule only, the term market participant will be limited to entities and their electric sector affiliates (including parent companies), that are currently active in the California ISO market, if: (1) the entity or its affiliate is an electric sector company based on its North American Industry Classification System (NAICS) classification or otherwise determined by the California ISO to be in the electric, power, generation, transmission or distribution business; or (2) the total activity in the California ISO market (purchases and sales) for all entities affiliated with the publicly traded company at issue during its most recently completed fiscal year is equal to or greater than 0.5 percent of its gross revenues for the same time period; or (3) the total activity in the California ISO market (purchases and sales) for all entities affiliated with the publicly traded company at issue during its most recently completed prior calendar year is equal to or greater than three percent of the total California ISO market activity (purchases and sales) for the same time period. Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 4 of 10
5 In addition to the above-listed criteria, an entity and its electric sector corporate affiliates, including its parent company, will be considered a market participant if the entity is a project sponsor that is actively participating in the competitive solicitation process under the California ISO s transmission planning process pursuant to the ISO tariff and FERC Order No This rule implements FERC authority regarding entities that are considered prohibited investments. (See New York Indep. Sys. Operator, Inc., 145 FERC 61,294 (2013) and Midcontinent Indep. Sys. Operator, Inc., 147 FERC 61,265 (2014)). Passively-managed index mutual funds and Exchange-Traded Funds ( ETFs ) as well as well-diversified actively managed mutual funds are acceptable investments. Focused or highly-concentrated energy or utility sector mutual funds or ETFs require HR disclosure and follow-up review to determine if divestiture is required. The decision to require divestiture will be based on a number of criteria including but not limited to the number of market participants in the fund s top 10 holdings, the total number of market participants in the fund and their percentage of total net assets. The Code of Conduct and this Prohibited Investments List pertains specifically to investments in stocks and bonds but also pertains to any financial or ownership interest in a company or its affiliate that is active in the California ISO market. Doing business with or owning financial products offered by companies on the Prohibited Investments List does not pose a conflict of interest. Note: Although this document is classified as a California ISO INTERNAL USE document, employees may provide the Prohibited Investments List to their financial advisors, so long as the financial advisors keep the list confidential. Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 5 of 10
6 Prohibited Investment 8point3 Energy Partners, LP Abengoa S.A. AES Corporation Algonquin Power & Utilities Corporation American Electric Power Company, Inc. Atlantic Power Corporation Atlantica Yield, Plc Avangrid, Inc. Avista Corporation Berkshire Hathaway Energy (fka MidAmerican Energy Holdings Company) Bonneville Power Administration British Columbia Hydro and Power Authority (BC Hydro; Powerex) Brookfield Renewable Energy Partners, LP California Department of Water Resources California Independent System Operator Corporation Calpine Corporation Capital Power Corporation Centrica, Plc City and County of San Francisco City of Anaheim City of Azusa City of Banning City of Burbank City of Cerritos Stock Exchange: Symbol(s) NASDAQ: CAFD NASDAQ: ABGB; Spain: ABG NYSE: AES Toronto: AQN NYSE: AEP NYSE: AT; Toronto: ATP NASDAQ: ABY NYSE: AGR NYSE: AVA Toronto: BEP.UN; NYSE: BEP Toronto: CPX London: CNA Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 6 of 10
7 City of Colton City of Corona City of Glendale City of Pasadena City of Rancho Cucamonga City of Rancho Mirage City of Riverside Prohibited Investment City of Roseville (Roseville Electric) City of San Jacinto City of Santa Clara dba Silicon Valley Power City of Solana Beach City of Tacoma, Department of Public Utilities, Light Division City of Vernon Comision Federal De Electricidad Consolidated Edison, Inc. Covanta Holding Corporation Dominion Resources, Inc. DTE Energy Company Duke Energy Corporation Dynegy, Inc. E.ON SE EDF Group Edison International EDP - Energias de Portugal EDP Renovaveis Stock Exchange: Symbol(s) NYSE: ED NYSE: CVA NYSE: D NYSE: DTE NYSE: DUK XETRA: EOAN; Frankfurt: EOAN Paris: EDF.PA NYSE: EIX Lisbon: EDP.LS Lisbon: EDPR.LS Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 7 of 10
8 Prohibited Investment Electric Power Development Company (aka J-Power USA Development Co) Emera, Inc. Enel Green Power Group Enel S.p.A. EnerNOC Exelon Corporation Great Plains Energy Incorporated Iberdrola S.A. IDACORP, Inc. Imperial Irrigation District Infigen Energy, Ltd. Just Energy Group, Inc. Korea Electric Power Corporation Los Angeles Department of Water and Power Modesto Irrigation District NextEra Energy Partners, LP NextEra Energy, Inc. Northern California Power Agency NRG Energy, Inc. NRG Yield, Inc. Ormat Technologies, Inc. Pattern Energy Group, Inc. PG&E Corporation Pinnacle West Capital Corporation Placer County Water Agency Stock Exchange: Symbol(s) Tokyo: 9513.T Toronto: EMA BIT: EGPW BIT: ENEL NASDAQ: ENOC NYSE: EXC NYSE: GXP Spain: IBE; OTC: IBDRY NYSE: IDA Australia: IFN NYSE: JE; Toronto: JE; France: 1JE NYSE: KEP NYSE: NEP NYSE: NEE NYSE: NRG NYSE: NYLD NYSE: ORA NASDAQ: PEGI NYSE: PCG NYSE: PNW Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 8 of 10
9 Prohibited Investment PNM Resources, Inc. Port of Stockton (Stockton Port District) Portland General Electric Company Public Service Enterprise Group, Inc. Sacramento Municipal Utility District Sempra Energy Sky Solar Holdings, Ltd. Southern Company SunPower Corporation Sunrun, Inc. TerraForm Power, Inc. Stock Exchange: Symbol(s) NYSE: PNM NYSE: POR NYSE: PEG NYSE: SRE NASDAQ: SKYS NYSE: SO NASDAQ: SPWR NASDAQ: RUN NASDAQ: TERP Tokyo Electric Power Company, Inc. Tokyo: 9501 TransAlta Corporation NYSE: TAC Turlock Irrigation District Vistra Energy Corporation NYSE: VST Xcel Energy, Inc. NYSE: XEL Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 9 of 10
10 Appendix A Changes from the 4/18/2018 Prohibited Investments List Prohibited Investments added to the list City of Rancho Mirage City of San Jacinto City of Solana Beach Dynegy, Inc. (bond) PNM Resources, Inc. Vistra Energy Corporation Prohibited Investments removed from the list Dynegy, Inc. (stock) Owner: Finance California ISO INTERNAL USE. For use by all authorized California ISO personnel. Page 10 of 10
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