DTE Energy Way Code of Conduct

DTE

ENERGY

WAY

CODE OF CONDUCT

Our Purpose

We serve with our energy, the lifeblood of communities

and the engine of progress

TABLE OF CONTENTS

A Message from Our Chairman ............................................. ii

Our Values ............................................................ A

Our Commitment .................................................... B

• What’s the DTE Energy Way? ......................................... B1

• Expectations ....................................................... B1

• Boundaries You Should Not Cross .....................................B3

• Asking Questions or Reporting Concerns ..............................B3

• Non-Retaliation .....................................................B4

Our Workplace ...................................................... C

• Health and Safety on the Job ......................................... C1

• Public Safety .......................................................C3

• Fitness for Duty .....................................................C3

• Workplace Violence .................................................C4

• Diversity ...........................................................C5

• Nondiscrimination and Equal Opportunity .............................C6

• Harassment ........................................................C6

• Investigations .......................................................C7

• Employee Privacy ...................................................C8

Our Company ........................................................ D

• Keeping Records Right .............................................. D1

• Understanding Conﬂicts of Interest ..................................D2

• Proper Use of Assets ...............................................D5

• Intellectual Property and Proprietary Information ......................D5

• Government and Compliance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D7

Our Community .......................................................E

• Customers ........................................................ E1

• Environment .......................................................E2

• Corporate Citizenship ...............................................E3

• Suppliers/Vendors (including Entertainment, Gifts and Gratuities) ........E5

Our Market ............................................................F

• Insider Trading ......................................................F1

• Fair Competition ...................................................F2

• External Communications (including Social Media) ......................F3

Our Resources ....................................................... G

As we seek to achieve our aspiration, we ﬁnd guidance in a set of values and standards

that apply to everyone at all levels across DTE Energy. The DTE Energy Way, our

company’s code of conduct, describes the behaviors we aspire to. It guides how we

behave on the job and helps us resolve issues in line with our values. It helps us know

what’s in bounds and what’s out of bounds.

The DTE Energy Way doesn’t address every situation, rule or policy. And it’s not a

substitute for good judgment or talking with your leader. It is, however, a guide to promote

dialogue with co-workers and leaders and a place to ﬁnd the appropriate policies, tools

and other resources to help you do the right thing every day.

In addition, these pages offer guidance about what to do if you have questions or concerns.

If you have concerns, I encourage you to report them, without any fear of retaliation.

And so I’m asking you to think of the DTE Energy Way as an important resource that will

keep us headed in the right direction – toward our aspiration – in the right way. That’s

why I encourage you to review it and use it as a reference tool.

A MESSAGE FROM OUR CHAIRMAN

“We’re all part of a winning team…a team that’s

making progress toward becoming the best-operated

energy company in North America and a force for

growth and prosperity in the communities where

we live and serve.”

OUR VALUES

OUR

VALUES

Our values deﬁne what we aspire to stand for and what we aspire to create at

DTE Energy. They have a strong connection to tangible business results and shape

the way we think about our company and our work on a daily basis. Values are far

more than posters on a wall or things that we occasionally refer to or talk about.

Our values only have real power if we routinely live them, act on them – and do so

with conviction.

We put the health and safety of people ﬁrst

…and know this responsibility rests with each of us.

We are the lifeblood of communities and the engine of progress. That’s why we do what

we do each day

. But w

e never forget that for many of our people, this is dangerous work

So in a company lik

e ours with a long history of focusing on safety, we believe diligence is

vital

. T

hat’s why we embrace the principle of 200 percent accountability

. “I am 100 per

cent

responsible for my own safety and 100 percent responsible for the safety of those around

me – because I care about my own family, my colleagues and their families, and the people

in the communities we serve.”

This includes the environment – we are dedicated to protecting our employees, neighbors

and the environment around us, to make sure we minimize our impact

Also vitally impor

tant is our focus on health. This is an increasingly important issue for us

as a company – and as a country

. A health

y workforce contributes to stronger – and safer –

performance on the job. But it’s more than that: the choices we make today – healthy or

not – will dictate our quality of life well into the future

. T

hey will also determine whether

we pass along a ﬁnancially healthy country to our children and grandchildren.

We act with integrity and show respect

…and understand this deﬁnes our company’s character.

Integrity is about honesty, ethics and full transparency in the way we approach our business.

We are committed to operate with integrity. We are committed to being completely

forthright in everything we do.

And as for respect, we believe it’s something everyone at DTE Energy deserves – no matter

your position. The rule of thumb we live and work by is to show a high level of respect and

consideration for our fellow employees, customers, suppliers, contractors and neighbors. To

do otherwise is not the “DTE Energy Way.”

We are committed to building a work environment in which we treat one another fairly and

respect the company’s commitment to the diversity of people, experiences and viewpoints.

OUR VALUES

We bring our best energy and focus to our work

…and are fully engaged and accountable for results.

For most of us, our time at DTE Energy is more than just a job. We spend half of our

waking hours at work and share a uniﬁed purpose: to serve with our energy, the lifeblood

of our communities and the engine of progress. The work we do is vitally important to

the people, companies and communities that we serve. As a result, how well each of us

does our job matters. That’s why we pay so much attention to how we show up on the job

– with high accountability, high energy and a strong work ethic. We believe our work

deserves our best energy and our best focus.

If we each take personal accountability for our results, we can make a difference for

the people around us. This is the right thing to do for our co-workers, customers and

shareholders. It is also something we can take pride in.

OUR VALUES

We see our work through the eyes of those we serve

…and know that our work is a powerful means to serve others.

This value brings to mind the Golden Rule: “Do unto others as you would have them do

unto you.” We must provide the kind of service that we’d like to receive if we were the

customer. This challenges us to look at the ways we’re carrying out our work and ask,

“If I could view my work through the eyes of my customers, would I be proud of the way

that I’m doing it?”

It’s easy to think this value applies only to employees who work directly with customers.

But employees in power plants or gas operations or the corporate center should also ask:

“Am I using resources, like my time, in a way that serves our customers well? Would I be

proud of my actions and choices if customers were watching me?”

That doesn’t mean we’re not going to have challenging interactions with some of our

customers. That’s inevitable. But it does mean that we will do our best to put ourselves

in their shoes and see the interaction through their eyes ﬁrst.

OUR VALUES

We play to win as a team

…and put the needs of our enterprise ﬁrst.

Our work is interconnected. That’s why we need to work together – respecting our

individuality and differences while we pursue a common cause. In a big company like ours,

it’s easy for us to be siloed and separated as we pursue our individual goals and priorities.

Instead, we need to focus on what our customers need. And part of what our customers

need is for all of us to be on the same page. We need to be crystal clear about

responsibilities, handoffs and interdependencies. We must support each other and have

each other’s back. It’s about collaborating across boundaries to ﬁnd new and better ways

to get things done. Playing to win as a team is an expression of positive energy that

strengthens our culture and is an expression of our commitment to put the needs of

customers ahead of our individual or departmental goals.

We believe that improvement is our daily responsibility

…and know those we serve have the right to expect that from us.

Our daily focus on Continuous Improvement (CI) will set the stage for operational excellence.

We can’t just show up and work in our business; we all have a responsibility to work on our

business – ﬁnding new and better ways to get things done and deliver value to our customers

and communities. Each of us expects the products and services we buy from other companies

to improve over time. Our customers have the right to expect the same from us.

We bring energy and creativity to our innovation and problem-solving efforts. We take pride

in recognizing our gaps, learning from our mistakes, and “reserving the right to get smarter”

as we get closer to becoming the best-operated energy company in North America. We

celebrate our progress along the way, but we never rest on our laurels.

We are passionate about the success of our company

…and know that its health and growth generate prosperity.

Vibrant, healthy and growing companies help our society and economy to thrive. So one

of the best things each of us can do for our communities is make sure that our company

is healthy and strong.

Each of us hopes that the companies in which we invest our personal savings will produce

great returns for us. Our investors – many of whom are individuals like us, saving for their

family’s future – have the right to expect the same from DTE Energy.

And DTE Energy can only succeed if each of us is accountable for our own actions and

behaviors. We can acknowledge the reality of a situation, own it, ﬁnd solutions and move

conﬁdently forward. When we do this, we have a positive inﬂuence on our business results,

our personal success and the health of the communities we serve.

OUR VALUES

OUR COMMITMENT

OUR

COMMITMENT

OUR COMMITMENT

What’s the DTE Energy Way?

The DTE Energy Way, our highest level policy, is the centerpiece of our commitment

to living our values and conducting our business according to the highest ethical

standards and in compliance with the law. It highlights the principles that guide our

business conduct. The DTE Energy Way also provides a common reference point

to help you understand what is expected of you. It will always be a good place to

start the search for guidance about how to put our values into practice every day.

• It provides practical advice on how to comply with laws and regulations.

• It provides requirements and guidance on how you should relate to

colleagues, customers, communities, vendors and government entities.

• It directs you on where to look for other policies and provides useful

information sources.

• It can help you resolve difﬁcult questions about business conduct, and it

explains how to seek guidance or report a concern.

The DTE Energy Way also includes guidance about what actions are “in bounds”

and “out of bounds” as well as practical questions and answers about situations

that you might encounter on the job. Remember, however, that the DTE Energy Way

does not provide exhaustive information about every single company policy or

every situation in which a question of ethics or compliance may arise. Doing

so would be virtually impossible. The company relies on you to exercise good

judgment in deciding whether the DTE Energy Way covers your issue in sufﬁcient

detail to help you make the right decision and act in accordance with our values.

If not, then you should seek further guidance from your leader or any of the other

sources identiﬁed here.

Expectations

Who has to follow the DTE Energy Way?

The DTE Energy Way applies to all employees, leaders, ofﬁcers and Board members

of DTE Energy and its subsidiaries. Additionally, pursuant to contract terms with

DTE Energy, contractors and consultants are expected to act consistently with the

DTE Energy Way when working on our behalf.

*Note: If there are conﬂicts between this document and collective bargaining agreements

that are in effect for bargaining unit employees, the collective bargaining agreement applies.

Expectations for All Employees

When we follow the DTE Energy Way, we demonstrate our commitment to living

our values. As employees, we are responsible for:

• Being familiar with and following the DTE Energy Way at all times.

• Seeking help when we have a business conduct, ethics or compliance question

that isn’t answered here.

Do a Quick

“Gut Check”

If you have a question

about your conduct that

is not answered here,

you should ask yourself:

• Is it legal?

• Is it consistent with our

core values?

• Am I being fair and

honest?

• Would I be unwilling

or embarrassed to tell

my family, friends or

co-workers about my

actions?

• Could my actions

appear inappropriate?

• How would I feel if my

conduct or actions

were printed on the

front page of the

newspaper?

• Could my decision

affect my reputation

or the company’s?

These questions may

help you perform an

instant “gut check.” If

the answers make you

uncomfortable, then

trust your gut, and seek

further guidance before

you act.

OUR COMMITMENT

• Complying with all applicable laws and regulations in performing our duties.

• Reporting any conduct that may violate the DTE Energy Way.

Failure to comply with the DTE Energy Way can result in disciplinary action, up

to and including termination of employment.

Expectations for Leaders

Leaders are also responsible for:

• “Casting a positive shadow” – leading by example – modeling our values and

living up to these standards at all times.

• Helping team members understand and follow these standards as well as any

other policies, practices, requirements or laws that apply to their work.

• Fostering an environment where employees feel comfortable asking questions,

seeking guidance and reporting issues.

• Supporting those who raise a concern – and never taking or allowing

retaliatory action against someone for reporting a concern or suspected

violation in good faith.

I think one of my coworkers violated a company

policy, but I can’t be sure. I am not an expert on the

subject. What should I do?

You should always speak up if you think misconduct

has taken place. You are not responsible for getting

enough information to be sure, only for reporting in

good faith what you observed.

OUR COMMITMENT

• Creating, displaying, or using hate

group words or symbols on company

business or company property

• Unauthorized possession of ﬁrearms

or other weapons on company

business or company property

• Physical assaults

• Willful safety violations

• Possession, sale, use, manufacture

or distribution of illegal drugs on

company business or company

property

• Being involved in an occupational

accident or unsafe work act while

unﬁt for duty, including vehicle

accidents while driving a company

vehicle, either on or off duty

• Theft of company, employee or

customer property, including theft of

company funds through falsifying pay

or business expense records

• Being absent from work without

reporting in for three consecutive days

• Willfully, materially misstating

ﬁnancial information

Asking Questions or Reporting Concerns

We hope the DTE Energy Way and supporting policies are easy to understand,

but we recognize that there may be times when an employee has additional

questions about the information provided. Likewise, while we hope the occasions

are few, there may also be times when an employee wishes to raise a concern

about a potential violation of our policies.

In either situation, and based on your comfort level, talking to your leader is usually

a good ﬁrst step. Being open, honest and direct is often the most effective and

efﬁcient way to resolve questions and possible problems. However, if you are

uncomfortable asking questions or discussing the matter with your leader, or if

your concern involves your leader, there are other avenues for you. These include:

• Your next level leader

• Employee Relations, Human Resources 313.235.8943

Boundaries You Should Not Cross

The company works to attract great people... and we understand the value of

keeping employees highly engaged and productive. We also understand that you

cannot maintain a healthy culture with a heavy-handed approach to discipline.

To that end, the company uses positive discipline to address behavior that does

not meet our standards. Our goal is to help employees understand the expectations

we have around behavior in the workplace. Your knowledge of those expectations

takes the guesswork out of keeping individual practices in sync with company values.

That said, there are certain boundaries that we just cannot cross. The violations

listed below are examples (not an all-inclusive list) of boundaries that can’t be

crossed. The company will hold employees strictly accountable for crossing

these lines, and violations of this type will likely result in termination, even on

a ﬁrst offense.

OUR COMMITMENT

Non-Retaliation

What if I’m worried about retaliation?

Retaliation is not tolerated.

If you, in good faith, raise a concern or report

misconduct – rest assured you are doing the right

thing. DTE Energy will not tolerate retaliation against

any employee who, in good faith, brings forward a

compliance or ethical issue.

The company takes claims of retaliation seriously.

We’ll investigate allegations of retaliation and will take

proper action. Anyone found responsible for retaliation

against an employee who reports suspected misconduct

or other risks to the business is subject to disciplinary

action, up to and including termination of employment.

If you suspect that you or someone you know has

been retaliated against for raising a compliance or

ethical issue, contact your supervisor, Employee

Relations, the Ethics and Compliance Ofﬁce or

call/login to the Ethics-in-Action Helpline.

POLICY

• Zero Tolerance Memo

I’m concerned that if I ﬁle a report about my co-worker’s

misconduct, they will know that it’s me and our work

relationship will be difﬁcult. What should I do?

First, investigations of employee concerns are done

conﬁdentially and shared with others only if they need

to know. However, the Ethics-in-Action Helpline gives

you the additional option of asking a question or

reporting misconduct anonymously if that is a better

option for you.

• Ethics and Compliance Ofﬁce 313.235.4777

• Ethics-in-Action Helpline 877.406.9448 (www.ethicsinaction.dteenergy.com)

These avenues will treat questions or concerns conﬁdentially and share the

information only as needed to thoroughly and promptly investigate all reports.

OUR WORKPLACE

OUR

WORKPLACE

OUR WORKPLACE

At DTE Energy, we want a workplace where the health and safety of our employees

is a top priority and each employee feels valued for their ideas and perspectives.

Working together as a team – embracing our unique differences in thinking,

background, talent and life experience – gives us the greatest opportunity for

success in serving each other, our customers and the community.

Health and Safety on the Job

At DTE Energy, we embrace the principle of 200 percent accountability: “I am

100 percent responsible for my own safety and 100 percent responsible for the

safety of those around me, including the public and our customers.”

Ensuring a safe work environment means knowing the rules and following them.

This includes the simple ones, like always wearing your seat belt or using handrails

when taking the stairs. And the not-so-simple rules, too. There is no task that is so

urgent that we cannot invest the time and energy to perform it safely.

Our commitment to 200 percent accountability includes things like:

• Having the courage to speak up to remind other employees and visitors of our

health and safety practices when necessary.

• Saying something to leaders when we identify procedures

that aren’t consistent with our health and safety value.

• Reporting all near-misses and accidents so we can determine

the root cause and learn how to avoid recurrences.

Living our safety value also requires vigilance. If you know of an unsafe condition

– or even the potential for an unsafe condition – immediately contact your

supervisor. If you have previously reported an unsafe condition, and it has gone

uncorrected, contact Corporate Safety.

As part of our commitment to health and safety, DTE Energy cooperates with

government reviews of our company facilities and operations and has procedures

in place to guide employees and leaders with these reviews. If you are contacted

by a government regulatory ofﬁcial, ask contact information and the purpose

of the call or visit. Let the person know you will have a representative of the

appropriate area of the company follow up.

One more thing: our commitment to safety includes complying with all applicable

health and safety regulations. We simply cannot tolerate willful violations of safety

regulations, policies or procedures.

ACCOUNTABLE FOR

SAFETY

200

I AM

OUR WORKPLACE

We put the health and

safety of people ﬁrst

…and know this

responsibility rests

with each of us.

I was injured at work, but don’t want to report it

because of how it will affect our group’s safety goal.

What should I do?

Report injuries to your supervisor immediately and get

medical treatment, if required. Each of us is responsible

for reporting workplace injuries. The group’s desire to

achieve the safety goal should not prevent any employee

from reporting a workplace injury, and supervisors

must never encourage employees to cover up a safety

incident. Reporting an injury could prevent others from

experiencing a similar injury.

POLICIES

• EM2 Health and Safety

• EM5-3 Protective

Tagging System

• EM12 Using Vehicles or

Equipment on Company

Business

What’s in bounds? What’s out of bounds?

• Following all safety policies and

procedures

regarding tools, equipment

and working environments.

• Using all personal protective equipment

(PPE) as required for the work.

• Following all laws and company

standards regarding vehicle

operation and trafﬁc safety.

• Ensuring that we keep our safety

training up-to-date.

• Taking shortcuts without

consideration for safety procedures

and precautions.

• Being distracted by personal issues,

and letting safety slip.

• Not reporting a hazard.

OUR WORKPLACE

Public Safety

We are committed to operating our businesses in a manner that keeps communities

safe. We’re also committed to educating our neighbors so they can recognize

potential dangers associated with our products and equipment.

Fitness for Duty

DTE Energy is committed to protecting the health and safety of its employees and

the public. In order to provide a safe working environment, employees must be

able to perform their job duties in a safe, secure, productive and effective manner.

Employees who are not ﬁt for duty may present a safety hazard to themselves or

others. You are always expected to report to work ﬁt for duty, and to remain ﬁt

while on duty. This means:

• You may not use, possess, sell, distribute or be under the inﬂuence of illegal

drugs on company property or while conducting DTE Energy business, whether

on or off company property.

• You may not use, possess, sell, distribute or be under the inﬂuence of alcohol

while conducting DTE Energy business or while on company property. You

also must comply with speciﬁc alcohol and drug standards and any other

ﬁtness-for-duty regulations that apply to your job, such as those required by

the Nuclear Regulatory Commission or the Department of Transportation.

• Where company business is conducted in conjunction with an after-hours social

function, alcohol consumption in moderation is permissible as long as it is limited

and does not violate other legal requirements. Alcoholic beverages may be

served on company property at after-hours company events with approval from

an appropriate sponsoring Vice President.

What’s in bounds? What’s out of bounds?

• Correcting unsafe conditions

immediately upon discovery.

• Standing by down wires to protect

the public.

• Reporting public safety incidents,

such as an injury to a member of

the public, equipment damage or an

emergency that might endanger lives

or interrupt service.

• Demonstrating our customer

commitment by performing Storm or

Public Safety jobs promptly and

being fully prepared when activated.

• Letting emergency response

training lapse.

• Reporting for emergency response

duty unprepared.

• Knowingly and willfully providing

false or misleading information to

the public and media.

We bring our best

energy and focus

to our work

...and are fully engaged

and accountable

for results.

OUR WORKPLACE

Drug and alcohol testing is required for employees involved in a work-related

accident, employees who exhibit signs of substance abuse or aberrant behavior,

and employees who are involved in an incident resulting in damage to company

property. Random or periodic testing related to drug and alcohol program

requirements is needed for some speciﬁc jobs.

Workplace Violence

There’s just no place for it at DTE Energy.

To help ensure a safe and secure workplace, the company reserves the right to

search persons, parcels, vehicles and any company property at any time – including

property located off-premises.

Corporate Security will respond to and investigate reports of workplace violence.

Criminal prosecution will be pursued, where appropriate.

The use or possession of weapons or explosives anywhere on company property,

in company vehicles, or while conducting company business is strictly prohibited,

even if you have a permit or license to carry them. Only the Chief Security Ofﬁcer

can authorize exceptions.

What’s in bounds? What’s out of bounds?

• Notifying Disability Case with Claims

or designated medical personnel if

you’re taking prescription drugs or

over-the-counter medications that

you reasonably believe could affect

your ability to work safely or efﬁciently.

• Knowing and following ﬁtness-for-

duty guidelines.

• Using, possessing, selling, offering

to sell, providing, sharing or

purchasing illegal drugs while on

duty or on company property.

• Reporting to work unﬁt for duty

as a result of on or off-the-job

use of any medication, illegal

drug or alcohol.

POLICIES

• EM3 Fitness for Duty

• EM3-1 Fitness for Duty

– Nuclear Generation

OUR WORKPLACE

We play to win

as a team

...and put the needs of

our enterprise ﬁrst.

Report any concerns about security in the workplace to Corporate Security at

313.235.9113.

Diversity

Our commitment to respect each other and create an inclusive environment goes

beyond just race and gender to appreciating and valuing each other and our

diverse backgrounds and life experiences. We believe that a diverse work force

with a healthy mix of educational experiences, backgrounds, ages, cultures,

religions and personal interests expands our base of knowledge, skills and

cross-cultural understanding. This, in turn, helps us better connect with our

customers. And that makes us a better company.

POLICY

• OP8 Physically Protecting

People, Property and

Operations

What’s in bounds?

What’s out of bounds?

• Reporting any potential or actual

physical threat or harm to yourself

or others.

• Seeking to understand and include

others, regardless of differences.

• Collaborating as a member of a

diverse team and seeking out

diversity of thought.

• Supporting programs and initiatives

to further our commitment to

diversity.

• Threatening or referencing physical

harm or violence – even if you feel

you have a good reason to be

angry. And even if you claim later

you “weren’t really serious” about

following through on your threat.

• Using tools, supplies or anything

else in a manner that implies it is

a weapon.

• Shoving, punching or other hostile

physical contact.

• Disregarding different perspectives.

• Discouraging others from offering

their opinion.

OUR WORKPLACE

Harassment

Harassment based on race, color, sex, sexual orientation, gender identity, age,

religion, disability, national origin, citizenship, height, weight, genetic information,

marital status, pregnancy, protected veteran status or any other status protected

by law is also discriminatory. Conduct that creates an abusive or hostile working

environment is also prohibited by the company. Respect is one of our core values,

and harassment simply has no place here.

Sexual harassment is misconduct that deprives employees of a workplace free

from unwanted and unwelcome sexual overtones. Sexual harassment may include

unwelcome sexual advances, requests for sexual favors, or other verbal or physical

contact of a sexual nature. Such conduct can create an offensive, hostile and

intimidating working environment, and prevents individuals from effectively

performing the duties of their position.

Sometimes an action that is not intended to be discriminatory or harassing can

nevertheless be viewed or perceived by the other person, employee or guest in a

different way and thereby becomes a problem. The best rule of conduct is simple:

“Treat everyone the same way you expect and want to be treated.”

Nondiscrimination and Equal Opportunity

DTE Energy is committed to having a workplace that promotes equal opportunity

and is free of discrimination – not only because it is required by law, but also

because it is core to our value of acting with integrity and showing respect –

a value that deﬁnes our company’s character.

It is the policy of DTE Energy to provide equal employment opportunity to all

individuals and to prohibit discrimination on the basis of race, color, sex, sexual

orientation, gender identity, age, religion, disability, national origin, citizenship,

height, weight, genetic information, marital status, pregnancy, protected veteran

status or any other status protected by law. The company makes reasonable

accommodations to promote the employment and advancement of qualiﬁed

individuals with disabilities and disabled veterans, unless such accommodations

would impose an undue hardship on the company’s business. The company also

has Afﬁrmative Action Programs to promote the employment and advancement

of minorities, women, persons with disabilities, and protected veterans. The

company’s EEO and Afﬁrmative Action Policies apply to all employment actions

including, but not limited to, recruitment, hiring, promotion, and separation.

POLICIES

• EM7 Hiring, Movement

and Separation of

Employees

• EM7-3 Recruitment,

Hiring and Job Changes

One of my employees came to me complaining of

discrimination by a co-worker, but I’m unsure if

discrimination is really occurring. What should I do?

As a leader of the company, you need to bring this

issue to Employee Relations in Human Resources. It is

not your role to determine the validity of a discrimination

complaint.

Examples of conduct

that may create a

hostile working

environment include:

• Inappropriate touching

• Derogatory comments,

name-calling or continual

taunting based on a

protected group.

• Conduct that is

physically threatening,

harmful or humiliating.

• Taking advantage of

employees with physical

or mental disabilities,

such as encouraging

inappropriate behavior.

• Offensive jokes, drawings,

photographs, etc.,

especially if based on

a protected category.

OUR WORKPLACE

Investigations

DTE Energy investigates all reported allegations of harassment, discrimination

or retaliation. We expect individuals involved in these investigations to provide

their full cooperation. The company maintains conﬁdentiality throughout the

investigation process to the extent possible and consistent with the company’s

need to responsibly address these types of allegations and take corrective action.

The company prohibits retaliation against any individual who, in good faith, reports

discrimination or harassment, or any individual who participates in, or otherwise

supports, an investigation of such reports. Anyone who exhibits retaliatory

behavior against an individual under such circumstances will be subject to

disciplinary action up to and including termination.

We act with integrity

and show respect

...and understand

this deﬁnes our

company’s character.

What’s in bounds? What’s out of bounds?

• Recruiting, selecting and

compensating based on merit,

experience and work-related criteria.

• Treating others with respect and

dignity any time and any place you

represent the company.

• Thinking carefully before making

off-hand jokes that may

unintentionally offend others.

• Reporting any perceived bias based

on differences protected by law or

company policy.

• Unwanted physical contact

(e.g., a “friendly” neck massage).

• Offensive comments about an

individual’s appearance, ethnicity

or sexual orientation.

• Inappropriate, sexually explicit or

offensive jokes (even if you think

you are just emailing them among

friends).

• Possessing, displaying or distributing

offensive materials, such as cartoons,

pictures, grafﬁti, paraphernalia or

pornographic materials.

Respect is one of our core values, and harassment and discriminatory conduct

toward fellow employees, customers, or others encountered while on the job is

prohibited and simply has no place here.

OUR WORKPLACE

Employee Privacy

Personal Information

The company collects and retains personal employee information as needed to

support functions such as beneﬁts, compensation and payroll. The company is

committed to protecting private personal information and using it only for

legitimate business purposes. Access to records containing personal information

is limited to personnel who have appropriate authorization and a clear business

need for that information. If you have access to personal information, you must

treat it appropriately.

Use of Company Communications Systems and Property

When it comes to use of company resources for personal communications, we

must balance employee privacy with the need to maintain a safe and efﬁcient work

environment. For that reason, the company reserves the right to lawfully monitor

its assets and work environments.

This means that even though limited personal use of company electronic information

and communications systems is permitted, we should not assume that use of a

company computer or other communications in the workplace – such as telephone

calls, voicemail, email, mobile devices, instant messaging or Internet use –

will be private.

This also means that the company retains the right to lawfully search any company

property at any time (e.g., ofﬁces, desks, lockers, vehicles) including company

property located off-premises. The company also retains the right to search persons,

parcels and vehicles on company property.

DTE Energy is not typically concerned with conduct off the job, unless it impairs

an employee’s performance on the job, or affects the reputation or business

interests of the company.

POLICIES

• EM22 Background

Checks

• GV11 Conﬁdentiality

and Privacy of

Information Used for

Company Purposes

• OP3 Information Security

• OP8 Physically Protecting

People, Property and

Operations

If I am allowed to send personal email from my

company computer, why would the company invade

my privacy and look at it?

We don’t read an employee’s email without reason;

however, the company can and does monitor for

inappropriate use (e.g., sending hate mail or

pornography) or to investigate misconduct. For that

reason, you should not have an expectation of privacy.

If you need to send a personal email that you really

want to keep private, it’s best to send it from home or

by using a personal device.

OUR COMPANY

OUR

COMPANY

OUR COMPANY

For our company to be successful, we all need to do our part. We can start by

being accountable for our actions – from keeping accurate records to avoiding

conﬂicts of interest, to protecting private information and assets. Some of this

accountability may seem like minor details – while other issues seem signiﬁcant.

Whether big or small, all of it is important to our success.

Keeping Records Right

Keeping complete, accurate and honest company records is serious business.

Failing to keep good records may result in ﬁnes and penalties and even damage

our business and reputation.

We deﬁne company records as all data and knowledge purchased, produced,

acquired, reported or otherwise used by the company. These records might be

in computer ﬁles, on paper or on other media. Some examples include:

• Reports

• Timesheets

• Invoices

• Payroll and service records

• Customer records

• Proprietary data or conﬁdential information

• Nuclear safeguards information

• Engineering design documents

• Measurement or performance records

• Other essential data

We are passionate

about the success of

our company

…and know that its

health and growth

generate prosperity.

What’s in bounds? What’s out of bounds?

• Being honest and careful in keeping

accurate records.

• Promptly correcting errors.

• Protecting company information

and keeping it conﬁdential.

• Complying with legal, company and

accounting requirements for afﬁliate

transactions.

• Following the record retention

schedule for your organization.

• Changing or destroying records

without proper authorization.

• Thinking accurate record keeping

is a low priority.

• Willfully, materially misstating

ﬁnancial information.

• Approving your own expenses;

including having a subordinate

put your expenses on their expense

report for your approval.

POLICIES

• FC3 Business Expense

and Reimbursement

• GV11 Conﬁdentiality

and Privacy of

Information Used for

Company Purposes

• OP6 Corporate Records

Retention

OUR COMPANY

Understanding Conﬂicts of Interest

What’s a conﬂict of interest? It’s when your private interests interfere…or even

appear to interfere…with the interests of the company as a whole. A conﬂict of

interest occurs when you have difﬁculty performing your work objectively and

effectively due to the inﬂuence of your personal interests. This could happen in

your personal interests or relationships, outside activities, or ﬁnancial transactions.

Personal Relationships

Sometimes our personal relationships can lead to a conﬂict of interest when those

close to us become involved, directly or indirectly, in our work responsibilities.

That’s why we can’t have family members or personal friends reporting to each

other where one has inﬂuence over work assignments, performance evaluations,

compensation or hiring decisions of the other. This also extends to family members

or personal friends that have outside businesses or who conduct transactions

with the company. If you ﬁnd yourself in any of these situations, you should

immediately disclose this to Human Resources to ensure that any potential

conﬂict of interest can be avoided.

POLICY

• EM18 Personal

Relationships

When I complete a project, can I throw out all the

documentation?

First check the company’s record retention schedule.

Retention guidelines differ depending on the record

type, and there could be a legal reason to hang on

to the documentation. Contact Records &

Information Management for assistance at

recordsmgmt@dteenergy.com.

We act with integrity

and show respect

...and understand this

deﬁnes our

company’s character.

Your brother is part owner of a ﬁrm that does work

with DTE Energy in an area where you have some

oversight responsibilities. Is this a conﬂict of interest?

Yes, because a conﬂict of interest may exist not only

due to your work responsibilities, but also from the

interests of your family members. Remember,

appearances do matter.

OUR COMPANY

Outside Activities

Being involved in activities or organizations outside of work (e.g., local public ofﬁce

or non-proﬁt organization) is a good way to energize our lives. However, some

situations could create a potential conﬂict of interest. And that is why we should

avoid conversations or interactions with external parties that could be perceived

as providing preferential treatment or a personal beneﬁt. It is always wise to check

with a leader ﬁrst.

Financial Interests

DTE Energy’s business cannot be bought. Likewise, acting with integrity means

that we do not buy others’ business. This is why we should never offer or accept

personal loans or other guarantees, preferences or discounts that are not widely

offered to others for business. Not only could this be illegal, but it also is a conﬂict

of interest. Additionally, we should never use company funds to make political

contributions or support political organizations except where permitted by law and

supported by company policy.

How to handle questions or concerns

If you believe you might have a conﬂict of interest, notify your leader. Your leader

will be able to provide you guidance on your situation or suggest appropriate steps,

which may include completing a conﬂict of interest disclosure form, contacting

the Ethics and Compliance Ofﬁce directly, or the Ethics-in-Action Helpline at

877.406.9448.

Depending on your question, you may also wish to review the policies on page D4.

Hold Public Ofﬁce?

If you hold a public ofﬁce,

either elected or appointed

it may be appropriate to

be involved in discussions

that relate to DTE Energy

or its competitors

because of your expertise.

But it is not appropriate

to participate in the

voting or decision-making

processes. When these

situations happen, you

should disclose the

potential conﬂict and

remove yourself from any

decisions or agreements.

OUR COMPANY

Is this situation a problem? Alex, a ﬁeld tech,

advises a customer that the gas will need to be shut

off at her home and equipment repaired. Alex then

gives the customer a business card for his brother,

who is a contractor, and suggests the customer call

him to arrange the repair.

Yes. This demonstrates a conﬂict of interest

because Alex is inappropriately soliciting business

from a DTE Energy customer for the personal gain

of his brother.

POLICIES

• EM7 Hiring, Movement

and Separation of

Employees

• FC3 Business Expense

and Reimbursement

• GV5 Ofﬁcer Code of

Business Conduct

and Ethics

• GV14 Segregation

of Duties

What’s in bounds? What’s out of bounds?

• Receiving approval from your leader

before serving as a director, manager

or member of a board or committee

of any business where there may

appear to be a conﬂict of interest.

• Separating your personal and company

interests to eliminate the appearance

of or an actual conﬂict of interest.

• Owning or investing in a business that

is not a competitor, supplier or other

business partner to DTE Energy.

• Using company information only for

its intended business use.

• Disclosing to Human Resources that

you supervise or report to a person

with whom you have a close personal

relationship.

• Involving yourself, directly or

indirectly, with a company

transaction or account that involves

someone with whom you have a

close personal relationship.

• Misrepresenting yourself as a

DTE Energy employee when

performing outside work.

• Using company resources for

outside activities without

appropriate leader approval.

• Soliciting personal business on

company time or using company

resources for personal business.

• Giving or receiving cash or cash

equivalents in any amount from

suppliers or customers.

OUR COMPANY

Proper Use of Assets

We all play an important role in managing the company’s assets. The protection

and proper use of company resources helps keep costs in line, which helps keep

rates affordable for customers and improves shareholder value. Company assets

include things like computer resources, money, time, inventory, facilities, equipment

and tools.

DTE Energy empowers employees with the authority to use company resources

necessary to perform their jobs (in accordance with company policies).

If you have questions or concerns, talk to your leader or ask a question through

the Ethics-in-Action Helpline at 877.406.9448.

Intellectual Property and Proprietary Information

To continuously improve, we need to be creative in developing new ideas and

products. And we need to protect these ideas so we don’t risk losing the advantages

associated with our intellectual property and proprietary information.

Like intellectual property, proprietary information plays a key role in our business,

so it is important to protect it from unauthorized disclosure or use. Proprietary

information is owned or controlled by DTE Energy and provides economic value;

however, it also has value to our competitors and other third parties, and if

inappropriately released, it could have a negative impact on us. Some examples

of proprietary information include customer and employee information, business

and marketing plans, ﬁnancial and operating data, and planned outage schedules.

POLICIES

• GV6 Signature Authority

for Contracts and

Financial Transactions

• GV11 Conﬁdentiality

and Privacy of

Information Used for

Company Purposes

• OP3 Information Security

• OP8 Physically Protecting

People, Property and

Operations

What’s in bounds? What’s out of bounds?

• Spending company money only when

authorized and for legitimate

business needs.

• Using work time productively and

being on the job when scheduled.

• Taking care of company property and

only disposing of it when authorized

and in accordance with procedures.

• Asking your leader for approval to

use company assets for personal or

outside activities in accordance with

established practices.

• Theft of company, employee or

customer property, including theft

of scrap or salvage materials.

• Theft of company funds through

falsifying pay or business expense

records.

• Operating a personal business with

company resources.

• Connecting an unsecure thumb

drive or other storage device to the

company’s network.

Inventions or Other

Creative Works

Advise your leader of

any inventions or other

creative works developed

in your job, so we can

obtain proper legal

protection for DTE

Energy’s property. Some

examples of intellectual

property we want to

protect from disclosure

are unpatented

technology, trade secrets,

trademarks, technology,

artwork, and other forms

of graphics.

OUR COMPANY

We believe that

improvement is our

daily responsibility

...and know those we

serve have the right to

expect that from us.

I often give presentations at conferences sponsored

by professional organizations to which I belong.

Should I be concerned about proprietary information?

How should I approach this?

You should be sensitive about DTE Energy information

you plan to share. Review it with your leader and

also check to see if Corporate Communications wants

to review the presentation. While knowledge sharing

is encouraged, if the information is conﬁdential, or

if it could be used by others in securing a business

advantage over DTE Energy, the information should

not be shared.

What’s in bounds? What’s out of bounds?

• Obtaining conﬁdentiality and non-

disclosure agreements from potential

suppliers, consultants, etc. where

appropriate.

• Advising your leader of intellectual

property developed while working

for the company.

• Respecting the intellectual property

and proprietary information rights

of others, including our suppliers

and competitors.

• Distributing intellectual property

or proprietary information to third

parties without proper authorization.

• Using intellectual property or

proprietary information for

nonbusiness related matters, or

without proper authorization.

• Copying, distributing or modifying

third-party copyrighted materials,

documents or computer programs

without permission.

• Taking intellectual property or

proprietary information with you

if you leave the company.

OUR COMPANY

Government and Compliance

We value our relationships with government and regulatory personnel and recognize

they are important to our continued success. To sustain and continue to build

upon these relationships, it’s critical that we avoid the appearance of any impropriety

when dealing with government or regulatory agencies, ofﬁcials or employees. If

we don’t, both parties could be subject to ﬁnes and penalties, and our good

reputation will be tarnished.

In addition, as DTE Energy employees, we all must commit to complying with

relevant laws, rules and regulations. To do so, it’s helpful to understand both “why”

we’re doing something and “how” to do it. Getting clear on both the “why” and

“how” helps us understand the particular requirements of the laws and regulations

that we must fulﬁll as part of doing business. When we’re in compliance, the

community, our customers and our shareholders can feel conﬁdent that they are

involved with a company that demonstrates integrity and compliance with laws,

rules and regulations in everything we do.

I have a personal social media site that I use to blog

about things happening in the community, of which

DTE Energy is a part. I want to display our company

logo on my site. Is the use of the logo permitted?

Yes, as long as all copyright and other intellectual property

laws are respected. For DTE’s protection as well as your

own, it is critical that you show proper respect for the

laws governing copyright, trademarks, including DTE’s

own copyrights, trademarks and brands.”

POLICIES

• OP6 Corporate Records

Retention

• OP7 Patents

• OP24 Miscellaneous

Product or Service

Offerings

What’s in bounds? What’s out of bounds?

• Testifying in a legal or regulatory

proceeding truthfully and based

on facts.

• Complying with all federal, state

and local laws and regulations.

• Cooperating with government and

regulatory ofﬁcials in reviews of

company facilities or operations.

• Giving government employees,

public ofﬁcials or members of their

immediate families, gifts, bribes,

or any preferential treatment for

business transactions or policy

decisions.

• Failing to report a potential

incident or activity that does

not comply with an applicable

law or regulation.

• Misrepresenting facts or data on

government or regulatory reports.

OUR COMPANY

If you are approached or contacted by a government or regulatory ofﬁcial, ask

for contact information and the purpose of the call or visit. Let the person know

you’ll have a representative of the appropriate area of the company follow up.

There are a number of departments that are key in assisting with these issues.

Please reach out to one of the following groups as soon as you are approached

or contacted.

• Regulatory Affairs

• Corporate and Government Affairs

• Legal

• Ethics and Compliance Ofﬁce

• Corporate Safety

• Environmental Management & Resources

OUR COMMUNITY

OUR

COMMUNITY

OUR COMMUNITY

DTE Energy is proud to serve a highly diverse community throughout our service

territory and across the country through our non-utility businesses. We want to be

a force for growth and prosperity everywhere we operate.

Customers

Every employee has a role to play as an ambassador to our customers. Challenge

yourself and ask, “If I could view my work from the customer’s perspective, would

I be proud of the way that I’m doing it?” As we provide many essential services to

customers, we have a responsibility not only to deliver those services reliably and

efﬁciently, but also to deliver them in a way that demonstrates our commitment to

excellence. Inevitably, we’ll have tough interactions with some of our customers,

which will put us to the test. And that’s when it’s most important to put ourselves

in their shoes and see the interaction through their eyes.

We see our work

through the eyes of

those we serve

...and know that our

work is a powerful

means to serve others.

What’s in bounds? What’s out of bounds?

• Interacting with customers in an

engaging and respectful manner.

• Using “I Can Help!” to assist

customers whose concerns with our

company have not been resolved

through our Customer Service Line,

800.477.4747, or our website

(dteenergy.com).

• Using resources, like time, in a way

that would make customers proud.

• Respecting and maintaining

customers’ privacy and trust.

• Missing appointments or

deliverables with customers.

• Being dishonest in any way in

customer interactions.

• Accessing or disclosing conﬁdential

customer information without an

authorized business or emergency

purpose for doing so.

• Failing to protect the security of

our customer information systems.

OUR COMMUNITY

Environment

We are committed to minimizing our impact on the environment, developing

cleaner ways to produce energy, helping our customers use energy more efﬁciently,

and partnering with educational and business institutions to enhance the environment

for plants, animals and people. This commitment to environmental stewardship

includes operating our facilities and equipment in a manner that complies with

government standards and protects our employees and surrounding communities.

Can I delay a shutoff notice for a family friend, who

asked me for help?

No. But you can empathize and tell your friend that

while you can’t promise anything, you can ﬁle an “I Can

Help!” eform. The “I Can Help!” team, working with the

Customer Service Advocacy group, may be able to help.

POLICY

• Environmental Program

Guidelines

What’s in bounds? What’s out of bounds?

• Reporting incidents that may create

a threat to the environment.

• Cooperating with government and

regulatory ofﬁcials regarding

environmental inquiries or inspections,

and notifying the environmental

group, Legal, or a local employee

authorized to deal with these matters.

• Identifying and weighing

environmental risks when making

decisions.

• Not reporting a potentially

hazardous spill since you cleaned

it up yourself.

• Ignoring environmental procedures

when using equipment or

performing business operations.

• Misrepresenting the occurrence

or severity of an environmental

incident.

OUR COMMUNITY

My work is always 100 percent compliant with all

environmental regulations and permits. What other

environmental expectations should I be aware of?

While compliance with regulations and speciﬁc permits

is our ﬁrst priority, DTE is committed to going beyond

compliance where practical. There may be additional

speciﬁcations related to special environmental

designations (ISO 14001 certiﬁcations for example).

And you should always look for opportunities to be

environmentally friendly, such as reducing energy or

water use and increasing recycling.

I am running a project that involves the temporary

use of a generator and mobile fuel tank. The contractors

performing the work will bring all their own materials

and dispose of all the waste generated. Do I have any

environmental responsibilities?

Yes. Work with your environmental representative as

you plan your project and remind the contractors they

must follow environmental policies and procedures.

There are a number of issues to address; for example,

a generator may impact an existing air permit, and fuel

tanks must meet environmental and safety standards.

Corporate Citizenship

At DTE Energy, we are part of the communities in which we live and serve. That’s

one reason we work hard to be a good corporate citizen, which includes charitable

and political contributions and community involvement.

Charitable Contributions

The DTE Energy Foundation and Corporate Contributions manage corporate

charitable contributions. Organizations should follow company policy and procedures

for requesting or making corporate charitable contributions, including in-kind

services. If you have questions about donating company resources, or would like

to make or request a charitable contribution, contact Corporate Contributions in

Public Affairs.

OUR COMMUNITY

POLICY

• OP10 Corporate

Political Participation

Political Contributions

We hope that our employees take an active interest in the political process. We

are all free to make personal contributions to candidates or political organizations

and to participate in legal activities that reﬂect our individual choices. DTE Energy

administers political action committees (PACs) that accept voluntary contributions

from employees who wish to participate in the political process in a way that supports

DTE Energy.

Community Involvement

DTE Energy employees are active community volunteers and work to address

a wide range of community needs. If you participate in volunteer activities, it is

expected that you do so on your own time unless given approval by your leader

to do otherwise.

What’s in bounds? What’s out of bounds?

• Using a volunteer opportunity as a

group team building activity with

leader approval.

• Approaching Corporate Contributions

to request a corporate charitable

contribution to a non-proﬁt whose

mission is consistent with company

community involvement priorities.

• Making sure any cash or non-cash

company donation is properly

authorized before promising it to

a charity.

• Conducting volunteer activities

during business hours, unless given

approval by your leader.

• Donating company funds to any

political party, candidate or

campaign without authorization.

• Using company funds, time,

equipment, supplies or facilities

when making personal political

contributions.

• Speaking as a designated ofﬁcial

of DTE Energy on political, public

or regulatory matters without

authorization to do so.

Your choice to participate

(or not) in one of our

PACs will have no impact

on the terms and

conditions of your

employment here.

OUR FUTURE.

POLITICALACTIONCOMMITTEE

OUR COMPANY.

OUR COMMUNITY

Suppliers and Vendors

Giving and receiving entertainment, gifts and gratuities

The exchange of small business courtesies, such as a modest meal, is a common

practice that can help to form and build business relationships. But we need to be

careful that receiving these small courtesies doesn’t sway our decisions, or even

give the appearance of swaying our decisions, about what we buy or who our

business partners are. Before you accept any entertainment, gifts or gratuities from

someone who supplies products or services to DTE Energy, it’s a good idea to let

them know about our policies to ensure a clear understanding.

The ﬂipside is just as important: We need to steer clear of using entertainment,

gifts or gratuities to try to sway the decisions of our customers, suppliers, regulators,

business partners or anyone else. In fact, improper gifts may be considered bribery,

which violates the law! So before offering any entertainment, gifts or gratuities,

it’s important to know and abide by customers’ and government ofﬁcials’ policies.

That demonstrates integrity and keeps us in line with our values.

We act with integrity

and show respect

…and understand

this deﬁnes our

company’s character.

What’s in bounds? What’s out of bounds?

• Seeking guidance from my leader

and disclosing the offer or receipt

of gifts or entertainment (from our

business partners) that may be

questionable or not conform to

our policy.

• Communicating our policies

regarding business courtesies to

our suppliers and vendors.

• Giving or receiving infrequent,

moderate gifts or hospitality as part

of a vendor relationship, including

meals, gift baskets, or books. Tickets

to charity, sporting, entertainment

or cultural events is in bounds only

when there is a speciﬁc business

purpose or for establishing or

strengthening business relationships

and with leader approval.

• Partnering with suppliers and

vendors who exhibit behaviors

consistent with our core values and

diversity principles.

• Avoiding unnecessary contact with

suppliers who are currently involved

in the bid process.

• Soliciting any entertainment, gifts

or gratuities from anyone with

whom we do business.

• Accepting or offering entertainment,

gifts or gratuities that could

inﬂuence, or be perceived to

inﬂuence, our purchasing or

contracting decisions.

• Participating in gambling or

sexually explicit entertainment.

• Giving or receiving money, gift

cards or other cash equivalents,

loans, special privileges, personal

favors, beneﬁts, services or any

other favor that may be considered

a bribe or kickback.

Accepting Gifts?

We should only accept

gifts, entertainment or

other gratuities on an

infrequent basis. They

should be minimal in

value ($75 or less).

They can only be

accepted in the normal

course of an existing

business relationship

and they can’t be meant

to improperly inﬂuence

our decisions.

OUR COMMUNITY

Questions?

If you are offered or given entertainment, gifts or gratuities you think might be

outside the lines, report it to your leader. If it is a gift, politely return it with an

explanation that company standards don’t permit you to accept it.

If you have questions, contact the Ethics and Compliance Ofﬁce, the

Ethics-in-Action Helpline at 877.406.9448 or Supply Chain Management.

One of my suppliers has invited me and my team to

lunch to discuss product quality issues and their

resolution. Who pays for this lunch?

It’s acceptable for a supplier with whom we have an

established business relationship to pay. It would not

be acceptable, however, for you to ask the supplier to

take you to lunch or to pay.

I have been working with the same vendor for two

years. The vendor has invited me to a Red Wings

hockey game! They say not to worry because they

had the extra ticket. Can I attend?

It depends. Check with your leader. You should

consider the value of the ticket as well as if the

vendor’s contract may be coming up for bid soon and

the role you play in the selection. If there could be a

perceived degree of inﬂuence, you should politely

decline the invitation.

POLICIES

• FC3 Business Expense

and Reimbursement

• OP4 Procurement

to Pay

• OP22 Contract

Management &

Administration

OUR MARKET

OUR

MARKET

OUR MARKET

We all play a part in ensuring our company is healthy and strong. The bottom

line is that we compete in the market based upon the merits of our products and

services, by maintaining the trust of our shareholders, and by building and protecting

our reputation. This includes being honest and responsible when dealing with

material non-public information, and using common sense and good judgment

when engaging in external company communications. We do these things not only

because they are legally required, but because it’s the right thing to do.

Insider Trading and Hedging Transactions

Insider Trading

Among many other things, operating with integrity means that we must never

use inside information for personal gain. Inside information is material non-public

information that could inﬂuence an investor’s decision to buy, sell or otherwise

trade securities of the relevant company.

Federal law and Securities and Exchange Commission (SEC) regulations make it

illegal to buy or sell securities on the basis of inside information. Inappropriately

using or sharing inside information undermines trust and can lead to criminal

prosecution, including prison. Keep inside information inside.

Due to my job responsibilities, I often have access

to earnings information before it is released. If

someone asks me how the numbers look before

the SEC ﬁling, is it OK to provide them a general

indication of the earnings?

No, any type of disclosure of material non-public

information including estimates or other types of tipoffs

is prohibited. Material non-public information should

only be discussed among employees who have a need

to know in order to complete their job responsibilities

and who understand the insider trading rules.

What’s in bounds? What’s out of bounds?

• Protecting company inside

information from those that do

not have a need to know.

• Adhering to SEC regulations and

company policy for buying/selling

DTE Energy stock.

• Discussing inside information in

public places.

• Using or sharing inside information

for personal gain.

• Trading in the securities of DTE

Energy when you have material,

non-public information that has

not yet been released to the public.

Examples of what

could be considered

material non-public

information include:

• Judicial or regulatory

decisions

• Dividend declarations

• Plans to issue or buy

back securities

• Earnings announcements

• Pending acquisitions or

mergers

• Joint venture and

contract negotiations

• Potential DTE Energy

transactions with other

companies

POLICIES

• GV5 Ofﬁcer Code

of Business Conduct

and Ethics

• GV9 Form 8-K

Signiﬁcant Events

Reporting

OUR MARKET

Hedging Transactions

DTE believes that it is important that the interests of our directors, ofﬁcers and

employees always be aligned with the interests of our shareholders. For this reason,

DTE considers it inappropriate for any director, ofﬁcer or employee to engage in

any hedging or monetization transaction involving DTE securities that has the

effect of limiting or eliminating the full risks and rewards of ownership of DTE

securities. These hedging and monetization transactions are therefore prohibited.

How to Handle Questions or Concerns

Talk to your leader, the Corporate Secretary’s Ofﬁce or the Ethics and Compliance

Ofﬁce if you are unsure whether something qualiﬁes as inside information or hedging.

Fair Competition

Not all of our business takes place in regulated utility markets. We also offer

some of our products and services in competitive marketplaces. Regardless of the

marketplace, our competitive strategies and activities are governed by federal and

state laws, rules, policies and regulations.

My family and friends sometimes ask me how

DTE Energy is doing and if they should buy our stock.

I feel the company is doing well and I am proud to

work for DTE Energy so I recommend that they buy it.

Is this a problem?

It is great to be proud of our accomplishments. To avoid

any potential problems, it would be best to refer them

to the Investors tab on dteenergy.com, where there are

presentations and other investor-related materials for

their review.

OUR MARKET

External Communications

What we do has a big impact on our reputation. But what we say has consequences

as well.

Media Inquiries

Customers, shareholders, regulators and the general public count on DTE Energy

to provide accurate and reliable information about our operations. In an age when

information can be disseminated widely and instantaneously, it is important that

our communications with external audiences are truthful, timely, compliant with

legal and regulatory requirements, and consistent with our values. For this reason,

it is important that only authorized persons communicate publicly on behalf of

the company.

POLICIES

• OP1 Conﬁdentiality of

Information Related

to Constellation New

Energy Gas (CNEG)

Easement Customers

• OP4 Procurement

to Pay

• OP24 Miscellaneous

Product or Service

Offerings

What’s in bounds? What’s out of bounds?

• Understanding and complying with

government regulations and policies

regarding competitive practices,

including antitrust.

• Safeguarding legally obtained

conﬁdential information about

competitors from others who could

improperly beneﬁt.

• Representing accurately and

truthfully the quality, performance,

features and availability of products

and services in conversations,

advertising and other public

communications.

• Directly or indirectly discussing,

agreeing or contracting with

competitors to restrict competition.

Some practices that restrict

competition include ﬁxing prices,

allocating markets, or dividing up

customers.

• Engaging in industrial espionage,

sabotage or bribery.

• Misrepresenting our identities, or

allowing outside entities we work

with to misrepresent themselves,

when gathering competitive

information.

• Providing illegal preferential

treatment to another DTE Energy

company or other business partner

to potentially gain a ﬁnancial or

market advantage.

It is common practice, and completely proper, to do benchmarking about the

marketplace in which we compete, including information about our competitors’

products and services. In doing this, however, we never cheat or attempt to acquire

a competitor’s trade secrets or other proprietary information through unlawful

means, including theft, spying, misrepresentation, omission or a breach of a

competitor’s non-disclosure agreement by a customer or other party.

Consistent with our commitment to integrity, we always compete fairly, ethically

and lawfully.

OUR MARKET

A reporter approached me in the ﬁeld and asked me

to comment on how long it was taking to restore power.

It was a great opportunity for me to set the record

straight, but I didn’t think I should say anything.

Your instincts were right. Unless you are an authorized

representative or given speciﬁc talking points, you

should not speak on behalf of the company. Direct the

reporter to Corporate Communications, Media Relations

team at 313.235.5555.

Speaking Engagements and Publications

You should seek approval from your leader and Corporate Communications before

you make presentations, give speeches, or submit external publications that relate

to DTE Energy’s operations or business interests – unless you are authorized to do

so as part of your job. And without prior approval, you should not suggest that you

are speaking on behalf of DTE Energy when presenting your personal views at

professional or community functions. You should also keep in mind that use of the

company brand and logo must adhere to approved speciﬁcations. For guidance on

proper use of the DTE Energy brand, visit the Corporate Communications intranet site.

We play to win as

a team

...and put the needs of

our enterprise ﬁrst.

To avoid giving misinformation to the media, it is imperative that only those

persons designated to make public statements on behalf of the company do so.

If you receive a request from a member of the media for information or comment,

don’t attempt to answer it yourself. Instead, offer to put them in touch with our

Corporate Communications Media Relations team.

OUR MARKET

Social Media

We know that social media enhances our relationships with our customers and

the communities we serve. While you work hard in your role, the Corporate

Communications team works daily to make sure our customers are well informed

about the impact DTE Energy makes in the communities where we serve. That is

why we have a number of designated social media spokespeople across the company

who are authorized to participate in social media on behalf of DTE Energy.

Even though you are not an authorized spokesperson, supporting our company

through social media is as simple as following DTE Energy on Facebook, LinkedIn,

or Twitter, reading our blog Empowering Michigan, and sharing the content you

like. Just be sure that you do so in accordance with the DTE Energy Way.

The best advice is to approach the online world in the same way you do the physical

one. Use common sense and good judgment. The following are some guidelines* for

using social media in a way that is appropriate and consistent with our values:

• When it comes to posting about the company, your activity should be consistent

with our values and is subject to the DTE Energy Way and other relevant

company policies and procedures.

• Always consider what you are saying before posting. One way to think about it,

if you would not be comfortable making your comment in a staff meeting or be

proud to have your comment broadcast on the evening news, do not post. This

can include, but is not limited to, making threats, using racial slurs, and using the

internet to intimidate or harass people.

• Discriminatory or threatening comments made toward fellow employees in

social media may be considered a violation of policy – just as if it happened in

the workplace.

• Regardless of where you are posting from, respect your obligation to protect

conﬁdential company and customer information.

* Nothing in these social media guidelines is designed to interfere with, restrain or

prevent employee communications regarding wages, hours or other terms and

conditions of employment.

I have been asked to make a presentation at a trade

association meeting. Is this okay?

Yes, but if the presentation involves your work at

DTE Energy, it requires approval by your leader, and

may need to be reviewed by Corporate Communications.

You should also be sensitive to issues related to security

and the protection of customer information.

OUR MARKET

Facebook: facebook.com/dteenergy

Twitter: twitter.com/DTE_Energy

LinkedIn: linkedin.com/dteenergy/dte-energy

Empowering Michigan: empoweringmichigan.com

How can I engage in social media?

You are encouraged to retweet or share messages

from ofﬁcial company pages, share job postings, and

use our “I Can Help” tools if friends and/or connections

have concerns.

OUR RESOURCES

OUR

RESOURCES

OUR RESOURCES

Audit Committee

Concerns regarding ﬁnancial statements, auditing, accounting practices or internal

controls may be submitted to the Audit Committee through its reporting channel.

Call 877.406.9448, visit ethicsinaction.dteenergy.com, or write:

DTE Energy

Audit Committee

One Energy Plaza

Room 2337 WCB

Detroit, Michigan 48226-1279

Corporate Safety

Call your Corporate Safety representative or 734.326.4096 during normal

business hours or 313.235.8015 during non-business hours for:

• Reporting uncorrected personal safety hazards or conditions

• Reporting accidents or an injury when you don’t know where to call

• Arrival of a representative of a regulatory agency at your facility

• Questions on safety regulations

Corporate Secretary’s Ofﬁce

The Corporate Secretary is responsible for corporate governance matters, including

the Board of Directors, the DTE Energy Way and corporate policies.

Call 313.235.8870 to report violations of our standards related to inside

information or insider trading, or for questions about DTE Energy’s Board of

Directors or corporate policies.

To view corporate policies, visit Quest and search on policies.

Corporate Security

Contact Corporate Security’s 24-hour desk at 313.235.9113 to report any crime

committed against the company, an employee or contract worker including:

• Workplace violence

• Threats, real or perceived

• Unauthorized weapons on company property

• Theft/embezzlement

• Illegal drugs

• Trespassing or suspicious behavior

• Any serious accident and any type of accident involving the public

For security pertaining to Nuclear Generation, call 734.586.5215.

OUR RESOURCES

Customer Inquiry or Concern

When customers have a concern or complaint that hasn’t been resolved

through our website (dteenergy.com) or by calling the Customer Service Line

800.477.4747, go to the I Can Help! icon on your computer and complete the

eform. If you don’t have easy access to a computer, ask your supervisor to submit

the eform for you.

Ethics and Compliance

For help with conﬂict of interest situations, information about compliance with

laws and regulations, or other related concerns, contact the Chief Ethics and

Compliance Ofﬁcer at 313.235.4777.

Environmental Management and Resources

Report spills of toxic or hazardous materials to the environmental group at your

location or to Environmental Management and Resources at the 24-hour

emergency contact number: 313.268.1191 (cell).

General Auditor

If you are uncomfortable reporting violations or misconduct to your leader, you

may report them to the General Auditor at 313.235.5426 or the Ethics-in-Action

Helpline at 877.406.9448. You should also contact the General Auditor to

report concerns about ﬁnancial statements, auditing, accounting practices or

internal controls.

Human Resources

Call the manager, Employee Relations at 313.235.8943, the Employee Resources

Connection Line at 313.235.3077 or 877.440.9797 for any of the following:

• Reporting alleged acts of discrimination or harassment

• Reporting suspected misconduct

• Reporting uncorrected personal safety hazards

• Questions about collective bargaining agreements

• Questions about the dispute resolution program

• Questions about disciplinary actions

Call 888.327.4347 to request help from the Employee Assistance Program.

In case of emergency, call 313.468.2000.

OUR RESOURCES

Information Technology

For help with safe computing best practices, information protection policies, and

cyber-security awareness, call the manager, Information Protection & Security (IPS)

at 313.235.9452 or the IT Helpdesk at 313.235.7123.

Legal Support

If you are personally sued or prosecuted as an individual defendant in a legal or

investigatory proceeding in connection with your job at DTE Energy, contact the

General Counsel’s Ofﬁce at 313.235.3882 right away. The company will generally

provide you with a defense and agree to indemnify you against liabilities incurred

while carrying out your duties provided that, in the company’s assessment, you

were acting in good faith and within the scope of your job responsibilities for

the company.

For questions about the Securities and Exchange Commission, contact the

Associate General Counsel at 313.235.3260.

To report personal injuries, property damage, or line contacts, or incidents

involving public safety or serious injury, contact the Legal Investigations Hotline

at 313.235.3604.

OUR RESOURCES

Ethics and Compliance Ofﬁce

The Ethics and Compliance Ofﬁce is responsible for the governance and oversight

of the Ethics-in-Action program; handling reports of suspected inappropriate

behavior, misconduct or work practices that are inconsistent with the standards

established in the DTE Energy Way.

To ask questions, seek guidance, report concerns, or to make a conﬁdential –

and if desired – anonymous report through a third party, contact the

Ethics-in-Action Helpline:

By Intranet: Reporting Ethics Concerns on the Quest home page

By Intranet:: ethicsinaction.dteenergy.com

By Email: ethicscomp_ofﬁce@dteenergy.com

By Phone: Ethics-in-Action Helpline

877.406.9448, 24 hours a day

By Mail: DTE Energy

Chief Ethics and Compliance Ofﬁcer

One Energy Plaza

Room 2188 WCB

Detroit, MI 48226-1279

Nothing contained in this handbook creates an express or implied contract of employment.

For employees who are not represented by a union, the relationship between you and the

company is referred to as “employment at will.” This means that your employment can be

terminated at any time for any reason, with or without cause, with or without notice, by

you or by the company. No representative of the company has authority to enter into

any

agreement contrary to the foregoing “employment at will” relationship. For employees

represented by a union, the employment relationship is as described in the applicable

collective bargaining agreement.

161542/1.6M/EPI/11-16

Revised Nov. 2016