Common use of VEIC POLICY ON POLITICAL ACTIVITY Clause in Contracts

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: • supporting or endorsing any candidate for political office; • opposing any candidate for public office; • publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and • using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: • hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; • holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; • attempting to influence legislation; • forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; • publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; • requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; • conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; • undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: • working for any political campaign during employee’s VEIC work hours or on VEIC office premises; • using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; • using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. • selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and • utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: • supporting or endorsing any candidate for political office; • opposing any candidate for public office; • publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and • using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: • hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; • holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; • attempting to influence legislation; • forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; • publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; • requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; • conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; • undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: • working for any political campaign during employee’s VEIC work hours or on VEIC office premises; • using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; • using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. • selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and • utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Non-Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: • supporting or endorsing any candidate for political office; • opposing any candidate for public office; • publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and • using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: • hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; • holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; • attempting to influence legislation; • forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; • publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; • requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; • conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; • undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: • working for any political campaign during employee’s VEIC work hours or on VEIC office premises; • using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; • using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. • selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and • utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: •  supporting or endorsing any candidate for political office; •  opposing any candidate for public office; •  publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and •  using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: •  hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; •  holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; •  attempting to influence legislation; •  forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; •  publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; •  requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; •  conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; •  undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: •  working for any political campaign during employee’s VEIC work hours or on VEIC office premises; •  using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; •  using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. •  selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and •  utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Non-Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: • supporting or endorsing any candidate for political office; SAMPLE • opposing any candidate for public office; • publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and • using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: • hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; • holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; • attempting to influence legislation; • forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; • publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; • requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; SAMPLE • conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; • undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: • working for any political campaign during employee’s VEIC work hours or on VEIC office premises; • using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; • using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. • selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and • utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. SAMPLE Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. SAMPLE It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.

VEIC POLICY ON POLITICAL ACTIVITY. It is imperative that all VEIC employees clearly understand and abide by the limitations and prohibitions against using VEIC resources to conduct political activity. These restrictions also apply to contractors and members of the VEIC Board of Directors at the time they are representing themselves as and/or conducting work for VEIC. VEIC is a non-profit organization that has been granted tax-exempt status by the federal government under Section 501(c)(3) of the Internal Revenue Code. That status comes with rules that strictly prohibit VEIC employees, Board members and contractors from engaging in any of the following political activities: •  supporting or endorsing any candidate for political office; •  opposing any candidate for public office; •  publishing or distributing campaign literature or statements on behalf of or in opposition to any candidate for public office; and •  using the signature, letterhead, or return envelopes of any candidate for public office in conjunction with any fundraising or service solicitation(s) on behalf of VEIC, particularly if the recipient of the mailing could reasonably infer that the solicitation represents a cooperative effort between the candidate and VEIC. In addition, VEIC employees, Board members and contractors are prohibited from engaging in other campaign-related activity, even if not directed toward a specific candidate, including the following: •  hosting or sponsoring candidates’ debates or forums, unless very specific guidelines for the invitation and participation of candidates are followed; •  holding a public VEIC event to which candidate(s) for public office are invited, unless it is stated explicitly that VEIC neither supports nor opposes any person’s candidacy. However, VEIC may invite a candidate to appear at a public event for reasons unrelated to the person’s candidacy, such as because the candidate has a particular expertise, or holds a particular public office. In such a case, VEIC must avoid any and all references to either the election or the individual’s candidacy.; •  attempting to influence legislation; •  forwarding VEIC or other general energy efficiency educational materials to some candidates in a race for office and not to others or undertaking additional efforts when responding to a candidate’s inquiries concerning VEIC’s position’s on public policy issues. VEIC may send its pre-existing educational materials to candidates, campaigns or political parties, unsolicited, in order to educate the candidates or parties about VEIC’s views and activities only if such materials are sent to all candidates in a race. VEIC may respond to candidates’ inquires with available educational materials, but may not undertake any special work or research to respond to such requests because this would be seen by the I.R.S. as providing services to the campaign.; •  publishing or distributing the voting records of incumbent candidates unless strict nonpartisan guidelines are followed; •  requesting a candidate to pledge her or his support of a VEIC position if she or he is elected; •  conducting voter registration or “Get Out The Vote” drives unless carried out in the context of addressing a wide variety of general, unrelated issues; •  undertaking any activity or disseminating any information that exhibits, either implicitly or explicitly, a preference by VEIC for or against a particular candidate or political party. Employees may engage in political activities only as private citizens and may not do so on behalf of VEIC or in any capacity as a representative of VEIC. An employee may not indicate that he or she represents VEIC or its views while taking part in any political campaign. Any participation in political activities must be conducted on an employee’s own time and without use of any VEIC facilities, equipment or resources. Accordingly, employees are prohibited from: •  working for any political campaign during employee’s VEIC work hours or on VEIC office premises; •  using VEIC letterhead, stationery, envelopes, office supplies, logo, or any other VEIC materials in connection with a political campaign; •  using VEIC’s photocopiers, postage meter, computer hardware or software, office space, or any other VEIC equipment in connection with any political campaign, even if VEIC would be reimbursed by the campaign. This prohibition means that employees may not: - use VEIC telephones, fax machines or e-mails for outgoing messages in conjunction with a political campaign that contain material in opposition or in support of a candidate; - use a VEIC computer to forward any incoming political e-mails to other VEIC employees or to e-mail addresses outside of VEIC’s system; - subscribe via VEIC’s e-mail system to any e-mail list services that automatically sends e-mails in support of or in opposition to a particular candidate. •  selling, loaning, or providing VEIC’s customer, donor, or other mailing lists to any candidate for political office; and •  utilizing VEIC’s mailing list(s) or e-mail lists to distribute any campaign-related literature. Failure to adhere to this policy may result in termination of contracts and employee disciplinary action including termination of employment. ATTACHMENT E: VEIC POLICY 1020 PROVIDING MAILING LISTS BASED ON ENERGY EFFICIENCY UTILITY (EEU) TRACKING SYSTEM DATA Policy Statement Vermont Energy Investment Corporation (VEIC) currently provides services as an Energy Efficiency Utility (EEU) through three separate publicly funded programs: Efficiency Vermont, Efficiency Smart, and the District of Columbia Sustainable Energy Utility. In the course of providing these efficiency services, as well as any similar EEU services in the future, VEIC compiles customer tracking system data. The EEU data tracking system shall not be used for the purpose of providing mailing lists, including electronic mailing lists, for non-EEU purposes. The EEU Director may make exceptions to this policy. It should be noted that this policy includes Vermont Energy Investment Corporation (VEIC) when it is acting as an energy service provider either inside or outside of Vermont. It should also be noted that there is a separate policy on the Release of Customer-Specific Information for Non- Energy Efficiency Utility (EEU) Purposes (Policy #1045). Need Periodic requests have been received from various entities for access to address lists based on the EEU data tracking system. Vermont Energy Investment Corporation needs to have a consistent policy for timely response to these requests. Background All Vermont Energy Investment Corporation staff and contractors have a signed an agreement regarding the handling of confidential information that prohibits providing customer-specific information to any party for non-EEU purposes (see “General Confidentiality Guidelines” at G:\Efficiency Utility\Confidentiality\CIMS General Confidentiality Guidelines Memo.pdf). Under these confidentiality guidelines, we have agreed to “access, use, or disclose Confidential Information only for the purposes of implementing EEU energy efficiency services.” Application Examples Individuals and entities have made inquiries in the past regarding the provision of mailing lists to promote non-EEU conferences or events, to provide information to, or to market products or services to groups of customers or businesses that are identified in the EEU data tracking system. In general, our contractual confidentiality guidelines prohibit such non-EEU uses of tracking system information. There may be some limited situations where providing such information to outside parties may be deemed to be for “EEU purposes.” These exceptions to this policy shall only be made by the EEU Director.