Principles of business ethics.

ENMAX Principles of Business Ethics

On our cover:

AL ROGERS
Lead Hand, First Line Response
ENMAX Power

Contents.

5 Our principles.
5 Core values.
6 Tone at the top.
6 Leadership attributes.

7 This handbook.
8 Where to get help.
9 HOW DOES THE ENMAX SAFETY AND ETHICS HELPLINE WORK?

10 Ethical conduct in the workplace.

10 Diversity.
10 Harassment.
11 Health and safety.
11 Work performance.

12
12
13
14
16
16
16

17
17
18
19
19
20

Ethical conduct in external business relationships.

Purchasing and suppliers.
Gifts and entertainment.
Relationships with customers.
Fair competition.
Relationships with non-profit and professional organizations.
Conducting international business.
Ethical use of Company property and information.
Confidential and private information.
Use of the Companys assets.
Accounting and financial reporting.
Managing risk.
Using e-mail and the internet.

21 A TOOL FOR TRUST.

22 Corporate responsibility.

22
22
22
22
23
25

26
26
27
27
27

Ethical conduct as individual employees.

Avoiding conflict of interest.
Travel on Company business.
Outside business activities.
Investments.
Disclosure of investment information.
Our conduct as employees, supervisors, officers and Directors of ENMAX.
Employees.
Supervisors and managers.
Officers.
Directors.

28 PUTTING PRINCIPLES INTO PRACTICE.

ENMAX Principles of business ethics. pg2

Message from the Chairman and the President.

At ENMAX, nothing is more important than our commitment to integrity no
financial objective, no marketing target, no effort to out-do the competition. Our
commitment to integrity must always come first.
For more than a century the Calgary Electric System, and now ENMAX, has been
committed to the highest ethical standard in business. Now and every day, we
must continue to work together in a manner that is consistent with our long
standing values. The way we treat each other and how we conduct our business is
a responsibility we all share. Our integrity is at the heart of our reputation and a
strong reputation is integral to attracting people, business partners and capital
that are necessary for us to create long-term value.
At ENMAX, we are committed to the principle that how we earn profits is equally
as important as the level of profits we earn. We are accountable to our shareholder and the citizens of Calgary for ensuring prudence in our management of
the organization and for demonstrating this through the highest standard of
shareholder engagement, oversight and transparency.

GREG MELCHIN
Chair, ENMAX Board of Directors

GIANNA MANES
President and Chief Executive Officer

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To reinforce our commitment to integrity, we have prepared these Principles

of Business Ethics. They reaffirm and also strengthen the basic requirements for
our business and the behaviour expected of each of us. We have developed the
Principles of Business Ethics to ensure that we act with integrity and respect the
trust placed in us by each other, our customers, shareholder, regulatory agencies,
supply chain partners and communities where we live and work. Please read these
Principles carefully and embrace them as the way we do business at ENMAX.
Sincerely,

GREG MELCHIN
Chair, ENMAX Board of Directors
ENMAX Corporation

ENMAX Principles of business ethics.

ENMAX
pg2
Principles of business ethics. pg2

GIANNA MANES
President and Chief Executive Officer
ENMAX Corporation

Our
commitment
to integrity.

ENMAX Principles of business ethics. pg3

Our principles.
Trust, responsibility, ethics and respect are central to ENMAXs core values and
leadership attributes. By being genuinely ethical in all we do, ENMAX will attract
and keep the best employees and be the choice of customers and investors, every
day. Operating in an ethical manner is essential to our success. The City of Calgary,
our customers, regulators and other stakeholders all rely on us to be transparent,
prudent, accountable and fair. We must behave ethically in communities where
we operate in order to maintain the confidence of our customers and other
stakeholders and ultimately to keep their business. We can instill this trust and
confidence with every business action and decision we make.

Core values. Our core values define whats important to us and are the foundation
for our principles. Each of us embodies these values in all that we do so that its
clear to everyone we deal with that we are a worthy and responsible organization.

1 Trust We build trust by always acting with integrity, and maintaining a high
standard of ethical, honest, safe and transparent business practice.

2 Excellence Each of us has responsibility to ensure that we deliver prudent

and superior results that align with our strategy and the needs of our
shareholder.

3 Responsibility We value clean and sustainable energy and the safety of our

employees and the public. We will sustain these through socially responsible
operations and innovative leadership in our industry.

Customer focus We listen to our customers and deliver a high level of

value and service.

5 Safety Our first priority is ensuring the safety of ourselves, our co-workers,
our community and the environment.

6 Accountability We are all accountable for the impact of our actions,

behaviours and decisions on fellow employees, customers, ENMAXs overall

success, our shareholder and the communities in which we operate.

Focus on people Our people are our strength and the knowledge,
commitment and talent of our diverse population of employees is what
drives our success and enables us to be an industry leader.

ENMAX Principles of business ethics. pg5

Tone at the top. Transparency, prudence, accountability and corporate responsibility

are very important. The example set at ENMAX's Board and Executive level is
carefully observed by our employees, customers, business partners, and the
citizens of Calgary and other stakeholders. Their trust and confidence that the
right tone at the top has been established is extremely important for ENMAX to
be able to successfully execute its strategic plan. ENMAXs Board and Executive
are committed to the principle that how we earn profits is equally as important
as the level of profits we earn.
The relationship between ENMAX and our shareholder is different from a typical
company/shareholder relationship. We at ENMAX recognize:
Calgarians deserve to feel immensely proud of their ENMAX
The ENMAX Board and management are accountable to City Council who
itself is accountable to the citizens of Calgary for ensuring ENMAX is operated
in a prudent and transparent manner

Leadership attributes. Our leadership attributes are an expression of the behaviours

we are all expected to master and practice.
ATTRIBUTE

DEFINITION

Shares knowledge
effectively

We speak and write clearly and succinctly in a variety of settings and

styles. We secure information, listen effectively and convey messages
with transparency.

Contributes to the
vision

Everyones contribution is important to the success of their team,

the company and the shareholder. We are personally responsible to
ensure we understand ENMAXs strategy and how we contribute.

Is an ethical
practitioner

We understand that sustained shareholder value can only be delivered

by people of strong character. We will act with integrity, take
accountability for our actions, and honour the spirit and intent of our
commitments and promises.

Masters the art of

being respectful

We promote an environment that is respectful, inclusive, celebrates

our diversity and minimizes perceived and real barriers.

Is an ambitious
problem solver

We seek out and embrace new technologies and processes and

respond effectively to changing conditions. We continuously act
with prudence, drive operational excellence and learn from past
experiences.

Has ownership of
company success

The opportunity to be the utility that everyone follows is in our hands.

It means ensuring personal and team execution excellence and pride
in our accomplishments and in the reputation of the company and
shareholder.

ENMAX Principles of business ethics. pg6

 I think my supervisor is doing something that the Principles of

Business Ethics say is wrong. I am afraid to report her because
she might make my job more difficult for me. What should I do?
If you dont feel comfortable talking to your supervisor about
it directly, you can try calling the ENMAX Safety and Ethics
HelpLine at 1-800-661-9675 (or go online at enmax-eweb.com).
ENMAX will not tolerate retaliation against you in any form for
making a good faith report.

This handbook.
ENMAXs commitment to integrity and ethics is the foundation of our Principles
of Business Ethics and for the Corporate Policies that reinforce them. They are the
standards for ethical behaviour we use when dealing with our Board of Directors,
shareholder, employees, customers, suppliers, contractors, government authorities
and the public.
The Principles apply to members of the Board of Directors and employees of
ENMAX Corporation and its direct and indirect subsidiaries (collectively ENMAX
or the Company). We expect everyone to whom these apply to conduct himself
or herself in accordance with these Principles and will hold them accountable for
their conduct. If anyone does not comply with the Principles, they may be subject
to disciplinary measures up to and including termination of employment or directorship, in the case of our Board of Directors. The same expectations of ethical
conduct and consequences apply to our agents and contractors. Therefore, it is
important that you read these Principles and ensure that you understand them.
This handbook is available online on both our internal and external websites and
in print form from the Vice President, Corporate Responsibility upon request.
As a starting point, it is critical that everyone who represents ENMAX use good
judgment and common sense. This is the best way to ensure that our company
continues to meet high standards of business conduct. Since we cannot anticipate every situation that may arise, you may need to seek guidance. When in
doubt, always endeavour to ask first, act later. Please speak to your supervisor or
the Vice President, Corporate Responsibility if you have:

Doubts about the ethics of a particular situation;

Questions or concerns about a business practice;
Questions about potential conflicts of interest; or
Concerns about potential or suspected illegal or unethical behaviour.

ENMAX Principles of business ethics. pg7

Where to get help. You might be guided in your assessment of a potentially unethical
situation by asking yourself these questions:

Is this legal?
Is this fair?
Would I want other people to know I did it?
How would I feel if I read about this in the newspaper?
How will I feel about myself if I do it?
What would I tell my child or close friend to do in a similar situation?

You may report suspected illegal or unethical behaviour without fear of retaliation.
ENMAX does not condone retaliation of any kind against anyone who makes a
report in good faith of suspected illegal or unethical behaviour. Confidentiality
will be maintained to the extent consistent with the best interests of the employees involved, and ENMAXs obligations under the law.
If you are uncomfortable bringing your suspicions to your supervisor, you may
use the ENMAX Safety and Ethics HelpLine to make your good faith report
anonymously. Directors should raise their concerns with the Board Chairman or
the Chair of the Corporate Governance Committee.

ENMAX Principles of business ethics. pg8

How does the ENMAX Safety and Ethics HelpLine work?

An independent outside party has been tasked to provide a round-the-clock, confidential service for
the collection of employee and contractor reports to the ENMAX Safety and Ethics HelpLine over the
phone and the web.
Each report is reviewed by the Vice President, Corporate Responsibility who assigns it to the Director,
Employee Relations (for HR-related issues), the Director, OH&S (for safety-related issues), the Director, Internal Audit (for fraud- or theft-related issues) or keeps it (for ethical issues and questions) for
appropriate investigation and follow-up. When a report is substantiated, it can result in changes in
process or disciplinary action. Every effort is made to provide as much information as possible to the
person making the report about the investigation and resolution of the matter while always respecting
the privacy of other individuals and the confidentiality of ENMAX information.
Anonymity is guaranteed.
What happens when
I make the call?

What happens when

I submit a Web report?

How is anonymity
guaranteed?

When you phone the ENMAX Safety

and Ethics HelpLine at 1-800-661-9675,
your call is answered by a professionally-trained Call Assistant from an
external company (As it is an
external company, they will answer
the phone as ConfidenceLine). You
will not be asked to give your name,
but you may if you choose to. You
will be given a personal Caller
Information Number (CIN), the only
identification you will require when
making subsequent calls to the
HelpLine.

When you visit the ENMAX Safety

and Ethics HelpLine web page at
www.enmax-eweb.com, it will
display the ConfidenceLine branding
of the external company who
provides the service to us. The page
provides you with a secure and
unique User Name and Password
when you first log in. You are then
taken through an automated process
to make an anonymous report. Your
User Name and Password may be
used to log back in at a later date to
view messaging from the Director
or Vice President responsible for
resolving your report that may
include further questions or an
update of the resolution of the issue
you reported.

When you call the ENMAX Safety

and Ethics HelpLine, you will be
speaking to a Call Assistant who
works for an external company. That
person will not ask you for your
name or recognize your voice and
does not have call display. When you
file a Web report, you determine the
information that will be provided to
ENMAX. IP addresses are not
tracked. The Director or Vice
President responsible for resolving
your report may only communicate
with you by placing information on
the electronic file for the Call
Assistant to read to you if you
choose to call back for an update or
that you can read on the Web if you
log back in after submitting a Web
report. Occasionally, the anonymity
of the person making the report may
be an obstacle to the investigation
and resolution of a matter, because
there is no independent evidence
available to substantiate the report.
Whenever this is the case, the
responsible Director or Vice President
may ask if you are willing to reveal
your identity to aid in the investigation. You are not required to do so.

The Call Assistant will listen to your

report and ask you questions to
clarify all the facts. The more specific
the information you are able to
provide, the faster and more effectively ENMAX can respond to the
issue. If you would like to follow up
on the status of your report, you can
call back, quoting your CIN, and a
Call Assistant will provide you with
any updated information. ENMAX
will not tolerate retaliation against
you in any form for making a good
faith report.

It can be arranged for you to hold an

anonymous chatline real-time
conversation with the Director or
Vice President responsible for
resolving your report by pre-arranging a date and time when you both
can be logged in at the same time.
Web reporting provides an alternative to employees when they prefer
to disclose their information directly
to ENMAX and not through a third
party. ENMAX will not tolerate
retaliation against you in any form
for making a good faith report.

ENMAX Principles of business ethics. pg9

 I am a female employee. A male co-worker frequently makes

personal comments about my appearance that make me
uncomfortable. Ive asked him to stop but he wont. What can
I do about it? You can and should contact your supervisor,
the Human Resources Department, or call the ENMAX Safety
and Ethics HelpLine.

Ethical conduct in the workplace.

We cannot have a positive and productive workplace unless we treat each other
with respect and trust. ENMAX strives to be an employer of choice by offering a
work environment that is healthy, secure and respectful.

Diversity. As a company, we recognize that the imagination, energy, capability and

commitment of our employees and Directors are critical to our business success.
We value highly the backgrounds, experience, viewpoints and talents of our fellow
employees and Directors. We do not discriminate in hiring and employment
practices on the basis of race, gender, culture of origin, age, religion, marital and
family status, physical disabilities or sexual orientation.

Harassment. We treat customers, stakeholders and colleagues with dignity and

respect. We work together to create a respectful and respectable workplace. We
do not tolerate behaviour that harasses, demeans, threatens or humiliates a
person or group of people. We do not tolerate any behaviour that may promote
physical violence in the workplace. We do not tolerate sexual or racial harassment. If we encounter harassment or violence or any conduct that ridicules or
disparages a group of employees, even if not directed at a particular employee,
we report it to the Vice President, Human Resources or we report it using the
ENMAX Safety and Ethics HelpLine.

The official ENMAX Principles of Business Ethics is located on

Intramax. Printed copies may not include the most current
information.

ENMAX Principles of business ethics. pg10

Health and safety. Healthy employees working safely are essential to our success.
ENMAX strives to provide a safe and healthy work environment for all employees.
Our commitment to health and safety involves the co-operation and support of
everyone in the Company. We have a responsibility to help ensure ENMAX is
complying with health, safety and environmental laws and regulations by reporting
accidents, potential hazards and other concerns immediately to our supervisor.
We respect that ENMAX provides a smoke-free workplace and we refrain from
smoking anywhere on ENMAX property or in ENMAX vehicles. We participate in
ENMAXs health and safety programs and maintain our awareness of applicable
safety legislation and industry standards.

Work performance. Our employees create our success. In order to attract and retain
the best and brightest employees, we invest in the development of our human
resources and reward superior performance. As employees, we are accountable
for our performance at ENMAX and accept full responsibility for what we do. We
know our work is evaluated on the basis of quality and quantity, and for being
performed safely, on time and on budget. We are never expected to achieve
business performance at the expense of these Principles or our ethical standards.
We are committed to giving our best effort to everything we do. Employees are
hired and promoted on the basis of ability and potential to develop and rewarded
on the basis of performance.
We expect the Company to maintain an environment where high performance is
encouraged. We expect our management to be clear about their expectations and
provide the kind of support that stimulates high achievement. We expect supervisors to encourage the professional development of their staff.

 We need to contract a firm to provide cleaning services and are

spending a lot of time looking for the right one. Couldnt we
save ENMAX a lot of time and effort by hiring my brothers
cleaning firm because I know that they can be trusted to do the
job right? No, simply hiring a firm because you trust your
brother is not a sound business practice and it contravenes our
employee spending policy. Further, this creates a conflict of
interest between your desire to help your brother and your
objectivity in selecting the most competitive supplier. However,
if you make a proper disclosure to your supervisor and remove
yourself from the selection process, and no one who reports to
you is involved, your brothers company can compete for the
work with other qualified vendors.

Ethical conduct in external business relationships.

Our business depends on sound relationships with customers, the community,
other business organizations and our stakeholders. Maintaining these relationships
means taking extra care when giving or receiving gifts, when selecting suppliers
and when sharing information with others.

Purchasing and suppliers. ENMAX is committed to fair competition in all its dealings
with suppliers. Any purchases we make on ENMAXs behalf are made honestly
and objectively. Our main criteria in making wise use of Company funds are
competitive pricing, quality, quantity, delivery and service.
If we are associated in any way with agreements between the Company and
suppliers or any organization in which we or someone we are close to, such as a
family member or friend, or a business enterprise in which we or they have an
interest, financial or otherwise, has an interest or which might result in personal
gain, we must disclose this association immediately to our supervisor.
Where appropriate, ENMAX informs suppliers of the Principles of Business Ethics
and we require similar high standards to govern their conduct in their dealings
with ENMAX. Where we have reason to suspect unethical conduct by a supplier,
an appropriate ENMAX manager should be asked for guidance. A relationship
with a supplier will be ended where unethical conduct is confirmed, subject to
any contractual obligations.

ENMAX Principles of business ethics. pg12

 I want to give one of our best customers a special gift to say

thanks. I have access to some hockey tournament tickets that I
know she would appreciate, but I think it is against her companys
policy for her to accept them. If she doesn't care about the
policy, can I give her the tickets? No. If you know that giving a
gift will violate the policy of the recipient company, you may
not give the gift. Just as we want others to respect our standards,
we will respect theirs.

Gifts and entertainment. ENMAX employees and Directors will not under any circumstances offer, give, solicit or receive any form of bribe or kickback. We make
every reasonable effort to ensure anyone acting on ENMAXs behalf is also not
offering or receiving bribes or kickbacks.
We recognize that the exchange of business gifts and hosting is a commonly
accepted business practice that is used from time to time to strengthen business
connections and goodwill. However, offering or accepting gifts, entertainment or
other benefits can be mistaken for improper payments. ENMAX employees and
Directors do not allow such gifts or exchanges to compromise, or even appear to
compromise, our business decisions. If this occurred, we could be involved in a
conflict of interest situation. We use good judgment in limiting such exchanges to
modest amounts that could not possibly constitute personal enrichment, impose
an obligation on the recipient or reflect unfavourably on ENMAX.
Gifts are more likely to be misconstrued than entertainment, so where a gift is
offered with a value greater than $100, we discuss it first with our supervisor and
get his or her written approval before accepting it. We do not accept gifts of
travel; when a third party offers us travel for business purposes and it would not
be practical or reasonable for ENMAX to pay for it directly, we discuss it first with
our supervisor and get his or her written approval, including reasons, before
accepting it. If it is not practical to speak to our supervisor in advance, we disclose
our acceptance of the travel to our supervisor to determine whether reimbursement is appropriate. The Board Chairman and Chair of the Corporate Governance
Committee act as supervisor to Directors for the purposes of this paragraph. We
do not accept travel from vendors during supply negotiations. In no circumstances
do we give or receive cash or cash equivalents.

ENMAX Principles of business ethics. pg13

Entertainment is different from a gift as it involves the attendance at an event or

meal in which we accompany the host as a guest. No specific value limit has been
set for entertainment but we are expected to be thoughtful and exercise sound
judgment relative to our role and position in the organization. Because of the
potential impact to our reputation of a poor decision, if there is any doubt about
any gift or entertainment, we consult our supervisor. Directors will consult with
the Board Chairman and Chair of the Corporate Governance Committee for this
purpose.
Social activities that could reasonably be associated with ENMAX are conducted
with propriety and with appropriate regard for alcohol and drug laws.
As a normal marketing practice, ENMAX may engage in promotional activities
that involve prizes or give-aways. Their purpose is to promote ENMAXs products
and services and they are an accepted industry practice. They are conducted in
compliance with laws governing prizes and give-aways.

Relationships with customers. ENMAX works hard to build strong and mutually
beneficial relationships with customers. We understand that every employee and
Director is an ambassador of ENMAX with a duty to treat our customers with
courtesy and respect. We demonstrate that ENMAX is a customer-focused
company, every day, delivering reliable products and services. We respect our customers views on issues affecting them. Customers must be able to voice their
concerns easily and we must deal with complaints and disputes fairly and quickly.
We protect their privacy. We give customers the truthful information they need
to make informed choices about the products and services ENMAX offers. All
ENMAX Directors and employees must be careful not to mislead customers or
other stakeholders about the financial status, products or services of ENMAX or
its competitors. We must never make promises the Company cannot keep. No
Director or employee of the Company should take unfair advantage of anyone,
including customers. Taking unfair advantage includes manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any
other unfair-dealing practice.

The ENMAX Safety and Ethics HelpLine is available to you to

make your good faith report anonymously if you suspect illegal
or unethical behaviour and are uncomfortable bringing your
suspicions to your supervisor. Call 1-800-661-9675 or go online
at www.enmax-eweb.com

ENMAX Principles of business ethics. pg14

Fair competition. ENMAX seeks to outperform its competitors fairly and honestly.
We gain competitive advantage through superior performance, never through
unethical or illegal business practices. We are knowledgeable of and compliant
with the laws governing competition. We do not conspire with anyone to lessen
fair competition or engage in anti-competitive practices such as price-fixing or
bid-rigging.
We acquire information about competitors in a lawful manner. We do not, either
directly or through a third party, misrepresent ourselves or offer inducements to
solicit proprietary information about competitors. Where an ENMAX employee
or Director has previously worked for a competitor, we do not attempt to obtain
the competitors proprietary information from that individual.
We protect information about customers of our regulated products and services
from disclosure to affiliated and unaffiliated retailers where doing so would create
an unfair marketing advantage for any retailer or would violate our duty to
comply fully with the Alberta Electric Utilities Acts Code of Conduct Regulation.

Relationships with non-profit and professional organizations. When we contribute to

our communities and professional organizations, we do so in a way that does
not interfere with our duties to ENMAX. Where it may be appropriate for an
employee to perform services for an outside organization during business hours,
we obtain prior approval from our supervisor. If an employee or Director acts as a
spokesperson for an organization or speaks publicly in a non-business capacity, it
must be clear to the audience that he or she is not acting as a representative or
expressing the views of ENMAX.
As private citizens, we might choose to take part in the political process, a right
that is respected and supported by ENMAX. Employees may, however, engage in
these activities only on their own time, and participation in the political process
by employees or Directors must be kept separate from their duties or association
with ENMAX.

Conducting international business. We apply ENMAXs Principles of Business Ethics

in all our activities on behalf of the Company, international as well as domestic.
When conducting business outside Canada, we adhere to the local laws and standards
to the extent they are permitted under Canadian law. We promote all trade practices that conform to international norms and standards and all applicable laws.

ENMAX Principles of business ethics. pg16

 I have just been hired from another company. I have a box of

materials from my former employer that would be very helpful
in developing marketing plans for ENMAX. May I bring this with
me? No, you should not bring materials that may contain
confidential information from a prior job. Just as it would be
wrong for someone to take our confidential information, we
should not use the confidential information of others.

Ethical use of Company property and information.

Confidential and private information. Information is one of the Companys most
vital assets. ENMAX takes care to protect confidential competitive information,
customer information and personal information.
Any information belonging to ENMAX that is not made generally available to the
public is considered to be confidential competitive information. Confidential
competitive information includes all non-public information that might be of use
to competitors or harmful to the Company or our customers and other stakeholders if disclosed. This may include proprietary and technical information,
marketing strategies, financial data, trade secrets, intellectual property, joint
venture information, and personal information about customers, employees and
Directors. It is important that you understand how sensitive this information is,
and how significant it is for competitiveness and individual privacy.
Customer information is any information that could tend to identify a customer,
that is uniquely associated with a customer, or that has been provided by a customer
to ENMAX. Personal information is any information about an identifiable individual
(customer, employee or Director) that is recorded in any form. Examples are a
persons marital status, home address, medical history or employment file.
Business contact information is not considered personal information.

To learn more about how our business values are put into
practice, review the online ethics training modules on the LMS.
ENMAX Principles of business ethics. pg17

We are responsible for knowing what information must remain in confidence and
for seeking clarification from our supervisor if in doubt. In addition, we do not
disclose confidential competitive information about ENMAX to anyone outside
the Company, including family and friends, even after we have left ENMAXs
employ. An exception is made where disclosure is required by law or by a regulatory
authority. Within ENMAX, we do not disclose confidential information to colleagues
other than that which is required for the performance of their assigned work.
Further, we are knowledgeable about the provisions of the Code of Conduct
Regulation, and do not disclose customer information between affiliate ENMAX
companies, except as permitted by that Regulation.
We collect, use and disclose personal information about employees, Directors
and customers only in ways that are fully compliant with all legislation protecting
personal privacy. Personal information must be kept confidential by using security
safeguards that are appropriate for the degree of sensitivity of the information.
We protect all confidential information against theft, fraudulent use, loss, unauthorized access and misuse. We recognize that any unauthorized disclosure of
confidential information exposes ENMAX to legal, financial, commercial and
liability risks.

Use of the Companys assets. We all share responsibility for protecting the Companys
assets, which include physical property, data, intellectual property, credit cards,
information networks and commodities. We use them carefully, safely and only
for their intended purpose. We keep our workplace at ENMAX safe and clean.
We protect ENMAXs assets from theft, misuse, damage, loss and neglect. Whenever ENMAX property is entrusted to our use we accept full accountability for it
and maintain it in good condition. We dispose of Company property only in an
ethical and approved manner. Company time, property and services, including
assets such as stationery, computers and mail services, may normally not be used
for a personal or non-business reason. However, because ENMAX recognizes that
the work we do for the Company may take us away from the personal or family
aspects of our life, limited personal or non-business use of these resources may
be acceptable where the purpose of such use is lawful and not contrary to
ENMAXs interests or these Principles. Limited personal use of Company cellular
phones is permitted where no other method of communication is reasonably
accessible, or when traveling on ENMAX business.

ENMAX Principles of business ethics. pg18

 It is the last week in the financial reporting period. My supervisor wants to make sure we meet our numbers for the quarter, so
he asked me to record a contract now that won't be finalized
until next week. I guess this won't hurt anyone. Should I do what
he says? Definitely not. Costs and revenues must be recorded
in the right time periods. The contract has not officially been
completed until it has been duly executed. Until then, it would
be a misrepresentation to include it in an earlier period.

Accounting and financial reporting. ENMAX conducts its financial affairs lawfully. All
financial transactions are undertaken in compliance with approved delegations of
authority and are reported in accordance with generally accepted accounting
principles. No undisclosed funds or accounts may be established. All cash and
bank accounts and other business transactions are handled in a transparent manner that avoids any suspicion of bribery, kickback or illegal or improper payments.
All ENMAX financial reports, accounting records, invoices, research and sales
reports, expense accounts, time sheets and other financial documents must
accurately and clearly represent the relevant facts and true nature of each transaction, and must be retained in accordance with ENMAXs records retention policies
and applicable law. Making false, fictitious or inappropriate entries with respect to
any transaction of the Company or the disposition of any of the Companys assets
is prohibited, and no Director or employee may engage in any transaction that
requires or contemplates the making of such false entries. We are responsible for
the accuracy and completeness of any reports or records we create or maintain. If
we become aware of questionable or suspicious financial transactions or entries
we must disclose it to our supervisor, or by using the ENMAX Safety and Ethics
HelpLine. Directors will raise their concerns with the Board.

Managing risk. Risk is loosely defined as any possible event that might adversely
affect the Company. We identify the risks to ENMAX as they arise and control
them within the limits of our accountabilities and resources. This does not mean
attempting to eliminate all risks completely. It means finding the acceptable
balance between potential reward and intolerable risks. It means reducing the
risks to what the Company considers to be acceptable levels. It also means making
sure our own activities do not ignore obvious risks or unintentionally create new
risks or liabilities for ENMAX. If there are situations where, in our opinion, risks are
not being properly controlled, either by other ENMAX employees or Directors, or
by contractors, we discuss the situation with our supervisor and if not resolved,
we consult with the EVP, Finance and Chief Financial Officer for direction.

ENMAX Principles of business ethics. pg19

 I sometimes e-mail my spouse to make personal plans, such as

who will pick up the kids after work. Am I allowed to use the
company's computer for this kind of thing? Yes, as long as
personal use is reasonable and kept to a minimum.

Using e-mail and the Internet. E-mail and the Internet are made available to promote
effective work-related research and enhance internal and external communication. The Internet is an open environment that is accessible to the public so we
take reasonable care to protect the Companys reputation and information when
we communicate using this medium, particularly when information is of a
commercially sensitive or confidential nature.
When using e-mail or the Internet we will not download any software or any data
that is unreasonably large in size, except with explicit prior approval from the
Information Services department. We do not use ENMAX computers to participate in non-work-related chat lines, access sites carrying socially or politically
offensive material, send chain letters, send slanderous, threatening or harassing
messages or send, view or obtain material of a sexual nature.
ENMAX recognizes that our work commitments may require us to conduct
personal business over the Internet during work hours. Limited personal use of
ENMAXs computer resources for purposes which are lawful, ethical and not
inconsistent with the spirit and intent of ENMAX policies dealing with a respectful
workplace or business conduct is permitted, so long as such usage does not interfere with our proper performance of the obligations we owe to ENMAX. While
ENMAX allows reasonable personal use of its information technology, we do not
use the Internet to play games, gamble, conduct personal outside business or
financial ventures, or post or send messages under disguised identification.
ENMAXs electronic mail and voicemail systems (including data on these
systems), Internet access and computers are ENMAXs property. We cannot
expect any personal privacy for communications that we send, receive or store on
these systems.

ENMAX Principles of business ethics. pg20

1-800-661-9675
A tool for trust.

The ENMAX Safety and Ethics

HelpLine is a confidential 24/7
service provided by an independent
outside party through a service
called ConfidenceLine and is available for employee and contractor use
online as well as over the phone to
support our commitment to the
ENMAX Principles of Business Ethics.

Since its inception in 2004, the

HelpLine has fielded confidential
reports falling into the following
general categories:
Discrimination
Ethical conduct
Harassment
Policy breach

The purpose of this service is to help

you make a good faith report
anonymously if you suspect illegal or
unethical behaviour and are uncomfortable bringing your suspicions to a
supervisor.

Question
Safety violation
Substance abuse

Our independent service provider

advises us that the average company
using their service will receive a
report from approximately 1% to 3%
of their employee population
annually. For ENMAX, that would be
somewhere between 15 and 30
reports each year. Were tracking
about half a percent below that
range, but have confirmed through a
survey conducted in 2008, that the
slightly lower than average usage of
the HelpLine is due to the fact that
employees are comfortable with
having direct conversations with
their supervisors when they have
ethical concerns and do not often
feel the need for anonymity.
The Safety and Ethics HelpLine has
proved itself to be a beneficial tool
for employees to ask questions or get
resolution on issues that concern
them when they are not comfortable
with speaking directly to a supervisor. This has allowed ENMAX to
discover issues that it might not
otherwise hear about and then be
able to address them.

ENMAX Principles of business ethics. pg21

Corporate responsibility.
We will comply with all environmental laws and regulations. We will seek to
increase our competitiveness and maximize value to our shareholder while understanding and embracing responsibility for the impact of ENMAX activities on the
environment, consumers, employees, communities, the citizens of Calgary, and
all other stakeholders to the extent that is reasonably achievable.

Ethical conduct as individual employees.

Avoiding conflict of interest. A conflict of interest occurs when undisclosed personal
interests influence, or even appear to influence, our decisions in the performance
of our duties at ENMAX. Conflicting interests may be direct or indirect. For example,
the interest may be ours or that of someone we are close to, such as a family
member or friend, or a business enterprise in which we or they have an interest,
financial or otherwise.
We must all disclose any situation that may create a conflict of interest between
our personal interests and those of ENMAX. We never put ourselves in a position
where our personal interest benefits in any way, or even appears to benefit, from
our business decisions or knowledge acquired at ENMAX without prior disclosure
to, and approval of, our senior management or, in the case of a Director, the Board.
The business decisions we make at ENMAX are based on merit and made strictly
in the best interests of the Company. We understand that we have an obligation
to immediately declare any actual, potential or perceived conflict of interest to
our supervisor and to the EVP, Regulatory and Legal Services or, in the case of a
Director, to the Board.

Travel on Company business. When we travel on Company business, we comply with

ENMAX guidelines on acceptable business expenses.

Outside business activities. Certain business activities we might undertake outside

ENMAX could create a conflict of interest. We do not serve as directors of any
organization that supplies goods or services to ENMAX, or competes with
ENMAX, without the approval of our senior management or, in the case of a
Director, without prior disclosure to the Board.

ENMAX Principles of business ethics. pg22

 I have noticed that my supervisor's breath often smells of

alcohol, even early in the morning, and he seems impaired. I
am afraid that if I confront him or tell anyone, it may cause a
scene or he may try to get me fired. What should I do? There is
enough evidence to believe a problem may exist, so speak right
away with another supervisor, a representative from Human
Resources, or call the ENMAX Safety and Ethics HelpLine.
A safe, secure working environment is absolutely critical to
ENMAX. ENMAX will not tolerate retaliation against you and
will take steps to protect you from any retaliation.

We may work for another organization, including one set up by ourselves, as long
as it is not a supplier, a commercial or industrial customer or a competitor of ENMAX,
and does not affect our work performance at ENMAX. Where it is not clear whether
external work interferes with our duty to ENMAX, we understand that we are
responsible for disclosing the situation to our supervisor and getting direction.
We do not perform work for the other organization on ENMAXs time, nor do we
use ENMAXs equipment, supplies, personnel or intellectual property for the benefit
of the other organization. Customers and colleagues from the outside activity
may not contact us at ENMAX workplaces. Employees do not promote any nonENMAX product or service to others during working hours except with the
approval of our supervisor.

Investments. To ensure there is no conflict of interest created through our personal

investments, ENMAX employees and Directors and their immediate relatives
normally may not have an ownership or financial interest in any company that
competes with ENMAX or that sells goods and services to ENMAX. An immediate
relative is the husband, wife, children, parents, brothers, sisters (including foster
or step) and parents-in-law, brothers-in-law, sisters-in-law, sons-in-law, and
domestic partner or common law spouse of a person.

ENMAX Principles of business ethics. pg23

 A supplier sold ENMAX a software system on a trial run basis. I

have heard the trial run was a success and we are going to buy
this company's system. I bet other companies will follow our
lead. My sister-in-law invests in tech stocks and knows a lot
about them. Can I tell her about this and let her decide whether
she thinks this software company is a good investment?
Absolutely not. The information you have about our plans to use
this company's product is confidential inside information. If you
convey it to your sister-in-law, you are violating our policy not
to divulge proprietary information. If you or your sister-in-law
use the information to invest, you may also be violating securities laws.

There are exceptions to this:

We may own shares in a publicly traded company that does business with or
competes with ENMAX provided our ownership does not exceed five per cent
of the shares of the company.
We may own any portion of a company that has business relations with
ENMAX through private ownership or publicly traded shares if the
investment is done on our behalf through a blind trust such as a mutual fund.
We understand that we are responsible for reporting to our supervisor and to the
EVP, Regulatory and Legal Services, any situation that violates, or may even be
perceived as violating, this standard on conflict of interest. This includes situations where the investment is made in the name of ourselves or an immediate
(including common-law) family member. Directors will report such situations to
the Board.

The ENMAX Safety and Ethics HelpLine is available to you to

make your good faith report anonymously if you suspect illegal
or unethical behaviour and are uncomfortable bringing your
suspicions to your supervisor. Call 1-800-661-9675 or go online
at www.enmax-eweb.com.

ENMAX Principles of business ethics. pg24

Disclosure of investment information. Persons or companies that receive private

information about ENMAX that ought to be released publicly, according to securities legislation, may be in a position to benefit unfairly from that knowledge.
This applies to any information that could influence anyones decisions with
regard to investment in ENMAX, including information about the Companys
performance and plans and changes to its operations and capital. ENMAX ensures
that the disclosure of information about the Company to the public is timely,
factual and accurate and broadly disseminated in accordance with all applicable
regulatory and legal requirements. We understand that the selective disclosure of
such information is illegal and places ENMAX and all persons concerned at great
risk. We do not disclose such information to any person or company before it is
publicly announced. We also ensure that when information has not been publicly
disclosed it remains confidential. We protect such information by sharing it internally only on a need-to-know basis.
Disclosures of material information by ENMAX are to be made by way of press
release approved by the President and Chief Executive Officer or his designate,
and carried out only by those individuals authorized by the terms of the relevant
corporate policies.

ENMAX Principles of business ethics. pg25

Our conduct as employees, supervisors,

officers and Directors of ENMAX.
Employees. Employees throughout ENMAX Corporation and its direct and indirect
subsidiaries are required to comply with the Principles of Business Ethics. At
ENMAX we consider this to be one of the conditions of employment. This means
reading the Principles and making sure you fully understand them. If you are
aware of any conduct involving yourself or another ENMAX employee or a contractor or agent or other person acting on behalf of the Company that may violate
the Principles, you have an obligation to report it to your supervisor without
delay. You may also take your concerns about compliance to any Officer of ENMAX.
You are assured that you are at no risk of reprisal for any concern expressed in
good faith. To the extent possible, ENMAX will endeavour to keep your identity
confidential. You may also make an anonymous report by using the Safety and
Ethics HelpLine.

ENMAX Principles of business ethics. pg26

Supervisors and managers. Supervisors and managers, in addition to their responsibilities as employees, are responsible for enabling their subordinates to understand
and comply with the Principles. As the first point of contact for employees who
have questions regarding the Principles and ethical issues, supervisors and
managers need to be a knowledgeable and reliable source of advice.
Supervisors and managers should make it possible for their staff to comfortably
express their concerns about possible violations of the Principles. This means
advising the employee when it becomes necessary to disclose the employees
concern to senior management.

Officers. Company Officers, in addition to their responsibilities as employees and

supervisors, are accountable for ensuring all employees are educated and knowledgeable concerning the Principles and their individual responsibilities. Within
their respective business unit, subsidiary Presidents and Executive Vice-Presidents
must monitor compliance with the Principles, address actual and suspected
violations, and report on compliance to the Chief Executive Officer and the Board
of Directors.
The President and Chief Executive Officer will submit the Principles of Business
Ethics for approval by the Board of Directors of ENMAX Corporation and is
accountable for developing and implementing any policies and procedures
required for putting the Principles into practice. The President and Chief Executive
Officer is ultimately responsible for ENMAXs compliance with the Principles.

Directors. Members of the Board of Directors must understand their legal duties as
Directors and act in accordance with those duties, including the duty to act
honestly and in good faith with a view to the best interests of ENMAX. Members
of the Board of Directors should address any real or possible conflicts of interest
with the Board. Individual Directors may also retain outside advisors, at the
Companys expense, to provide advice on any matter before the Board or a Board
Committee with the prior approval of the Corporate Governance Committee.
It is the responsibility of every member of the Board of Directors to acknowledge
and sign the Directors Code of Conduct upon becoming a Director of ENMAX and
to keep relevant information up to date by filing a Declaration of Interest form.
This form should be filed with the Corporate Secretary.

The official ENMAX Principles of Business Ethics is located on

Intramax. Printed copies may not include the most current
information.
ENMAX Principles of business ethics. pg27

The Ethical Scenarios

training available on
the LMS is a helpful
tool for teams to put
the Principles of
Business Ethics into
practice together.

Putting principles into practice.

We all know that mastering any skill
takes practice. That goes for recognizing and properly dealing with
ethical issues. Every ENMAX
employee has taken basic online
training about the Principles of
Business Ethics, either in 2006 when
the training was first developed or
subsequently for new hires. If you
ever want a refresher, you can review
the training again through the LMS
(search for Principles of Business
Ethics" in the course catalogue).
More recently, weve provided
another way you can develop your
skills as an "ethical practitioner"
through our advanced Ethical
Scenarios online training module.
This online training depicts a series of
animated situations in which an
ethical lapse has occurred or where
an ethical decision has to be made.
Heres a sample of one situation
youll see:

ENMAX Principles of business ethics. pg28

An employee is hospitalized, and a

rumor spreads that she fell ill from a
leaky pipe in the workplace. Employees demand to know the circumstances of her illness. The employee
has asked the supervisor to keep the
terms of her sickness confidential.
What should the supervisor do?
The training is intended to be taken
in a work group setting so that team
members can discuss the situations
and explore each others points of
view. No "answers" are given in the
training; the goal is to generate a
discussion of ethical standards and
appropriate behaviour, and to open
lines of communications for ethical
concerns. After all, there are no
answers given in real life.
Your work group can include one or
two scenarios as part of your teams
regular weekly or monthly meeting
schedule, or set up a special session
to explore all of the situations at one
sitting. If a computer and projector
are not available in the team's
meeting room so that members can
view the training together, work
group members can be assigned
particular scenarios to review online
in advance of the meeting.

The ethics training can be accessed

through LMS from the Quick Hits
menu on Intramax. Just search for
"Ethical Scenarios" in the course
catalogue.
Please participate fully in the
discussions with your work group.
Give your colleagues the benefit of
your experience and listen to the
views that they have. You will find
that the experience will be more
interesting and challenging if
everyone trusts each other enough
to engage in an open, unfettered
dialogue. Then, when real ethical
issues arise, you will have a familiar
process in place to deal with them.

Notes

Notes

ENMAX Principles of business ethics. pg30

ENMAX Safety and Ethics HelpLine.

There for you to anonymously make a
good faith report if you suspect illegal or
unethical behaviour and are uncomfortable
bringing your suspicions to a supervisor.
1-800-661-9675
www.enmax-eweb.com

ENMAX Safety and Ethics HelpLine.

There for you to anonymously make a
good faith report if you suspect illegal or
unethical behaviour and are uncomfortable
bringing your suspicions to a supervisor.
1-800-661-9675
www.enmax-eweb.com

ENMAX Principles of business ethics. pg31

Printed in Canada

enmax.com