12.10Violations of the Code of Conduct

Any ISO Employee who violates the Code of Conduct or fails to report a known violation may be subject to disciplinary action including suspension or termination of employment, unless such violation involves insider trading whereby such violation will result in the termination of employment.  In addition, any current or former ISO Employee that violates the Code of Conduct may be required to provide restitution to the ISO for financial injury suffered by the ISO as a result of the violation. 

The ISO shall assign the responsibility of reviewing compliance with the Code of Conduct to the ISO compliance officer (e.g., a senior staff member such as the ISO General Counsel) who will be responsible for interpreting the Code of Conduct; responding to questions regarding the Code of Conduct; advising the ISO Employees regarding potential conflicts of interest; overseeing the auditing process; and to follow-up on all suspected violations.  The ISO compliance officer may designate one or more individuals to assist in carrying out these responsibilities.  The ISO also shall establish a “hot-line” to provide a means to anonymously and confidentially report suspected violations over the telephone.