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CodeOfConduct 221209

The Code of Business Conduct & Ethics outlines Sunrun's commitment to ethical practices in the clean energy sector, emphasizing integrity, safety, and collaboration. It serves as a guide for employees to make ethical decisions, report concerns, and understand the consequences of violations. The document also highlights Sunrun's core values of loving people, creating, and running together to achieve their mission of providing clean energy to all.

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0% found this document useful (0 votes)
9 views27 pages

CodeOfConduct 221209

The Code of Business Conduct & Ethics outlines Sunrun's commitment to ethical practices in the clean energy sector, emphasizing integrity, safety, and collaboration. It serves as a guide for employees to make ethical decisions, report concerns, and understand the consequences of violations. The document also highlights Sunrun's core values of loving people, creating, and running together to achieve their mission of providing clean energy to all.

Uploaded by

psocid
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Code of

Business
Conduct
& Ethics

October 2022
A message
from Mary
More than 15 years ago, we set out to change
the world by making clean, renewable energy
accessible to every home. In pursuing that
goal, we’ve seen tremendous growth—not
only in the number of people to whom we’ve
provided the joy of solar power but in the
number of incredible people that have joined
our team.

Integral to what we do is how we do it. We


believe that radical collaboration will make us
a better, faster, and stronger organization. So
we strive to create an environment where our
teams are free to dream up answers to the
future’s problems. And above all else, we put
safety first—whether it’s physical, mental, or
emotional. I feel blessed to work with such
an amazing, talented team doing incredibly
important work for the planet.

This Code of Business Conduct & Ethics is a


guide to help you make the right decisions at
all times. Within it, you’ll find our high ethical
standards laid out clearly so that there is no
doubt about where we stand on how we treat
our customers and each other. Doing the
right thing in every situation, no matter the
circumstances, is what sets us apart from the
competition. As leaders in the clean energy
industry, it is our responsibility to lead by
example. So let’s show the world that we can
revolutionize energy without cutting corners,
and without compromise.

Mary Powell
Chief Executive Officer
Contents
Code of Business Conduct & Ethics 1
Sunrun credo
Scope
How to make ethical decisions
How to speak up and report concerns
Retaliation is not tolerated
Investigations
Disciplinary actions

Honesty in the marketplace 5


Fair and honest business practices
Accurate accounting and bookkeeping
Antitrust and competition law
Anti-corruption & anti-bribery
Insider trading
Marketing and advertising
Vendor relationships

Responsibility in the workplace 10


Diversity and inclusion
Discrimination and harassment
Health and safety
Recording your time
Avoiding conflicts of interest
Accepting gifts, gratuities, and entertainment
Protecting Sunrun assets
Safeguarding confidential and personal information
Privacy and data protection
Using social media responsibly
Political participation
External communications

Courtesy in the community 20


Helping the community live more sustainably
Volunteering and community projects
Human rights

Other elements of the Code 22


Waivers
Annual review
Website posting

Resources 23
Sunrun credo
At Sunrun we exist to give all people the joy of clean, abundant energy from the sun. Our mission
is to put control, simplicity, and possibility in the hands of every person to connect with the
cleanest energy on earth.

Three core values guide us in achieving this mission:

We love people
That means we are relentless in our commitment to every Sunrun customer, always putting
their needs and experience first, and standing behind our promises. We recognize that serving
our customers requires communicating clearly, acting swiftly, and with the highest quality in all
that we do. At every level of Sunrun we ask ourselves how we can do more and how we can do
better for our customers, this is how we build trust. In service of our customers and employees,
our leadership leads by example and with integrity in every interaction. Building diverse teams
and fostering an inclusive and respectful work environment are non-negotiables in our journey.

We love to create
Our customers rely on us to be innovative, always searching for new and better ways to harness
the abundant energy of the sun to improve life on this planet. We are curious and creative,
challenging assumptions, and building new products and processes to enhance the lives of
our customers.

We love to run
The need for clean energy solutions to combat climate change is urgent and the opportunity
for impact exponential. We are endlessly ambitious in our race to create a planet where clean
energy is universal, trusting that our collective efforts will bring shared value to our customers,
employees, communities and investors for generations to come.

We run together. We are Sunrun.

Code of Business Conduct & Ethics | 1


Scope
The Code of Business Conduct & Ethics (the Code)
summarizes the ethical standards and key policies that
guide the business conduct of all employees, officers
and directors of Sunrun and each of Sunrun's direct and
indirect subsidiaries.

How to make
ethical decisions
The Code is your guide to working with integrity and
helping you do the right thing. It does not list every ethical
or legal issue that you may face at work. Rather, it is a guide
to be used with common sense and good judgment.

Making good decisions and choices builds trust between


each of us and the people with whom we interact. While
some decisions are obvious and easy to make, not all
situations are straightforward. How do we navigate
situations where the rules are unclear?

When the answer is not clear, ask yourself…

• Is it consistent with Sunrun’s core values?

• Is it consistent with Sunrun policies?

• Is it legal?

• Is it the right thing to do?

• If it were made public, would it harm


Sunrun’s reputation?

If the answer to any of these questions is No,


you should speak up!

Code of Business Conduct & Ethics | 2


How to Scenario

speak up and One of my coworkers frequently


makes inappropriate jokes
during meetings that make me

report concerns uncomfortable. What should I do?

Offensive behavior, including


inappropriate jokes, is not tolerated.
We are each responsible for acting with integrity and following If you are not comfortable speaking
the Code guidelines. Equally, we are each responsible for with your coworker or that approach
speaking up promptly if we believe that someone has violated does not work, you should speak to
Sunrun policy or the law, or has otherwise behaved in a way your manager, People Business Partner,
that could negatively impact Sunrun’s reputation. For more or anonymously submit your concern
guidance on how to report concerns, please review the on the third-party hosted web portal,
Employee Guidebook or Whistleblower Policy and use the [Link] or via our
resources listed. third-party hosted 24-hour hotline at
855-477-8862 (the Ethics Hotline).
Open door policy
Speak with your manager, a member of your
management team, the People Team, and/or executives

Employee Relations Audit Committee Mailing address


employeerelations@[Link] audit@[Link] Sunrun Inc.
Attn: Chief Legal Officer
Legal and Compliance Ethics Hotline 225 Bush St #1400
integrity@[Link] 855-477-8862 San Francisco, CA 94104
[Link]

Retaliation is Scenario

not tolerated I wasn't invited to the team holiday


party this year. Ever since I talked
to Employee Relations about team
morale, I have been treated differently
Sunrun does not tolerate any form of retaliation for reports and excluded from team events. I
of alleged violations that are made in good faith. Sharing a tried talking to my manager to let
concern in good faith means that you honestly believe that him know how I feel, but that didn't
there may be a violation of the Code of Business Conduct & work. Should I report this treatment?
Ethics, policies, or the law. Examples of prohibited retaliation
include but are not limited to firing, demoting, transferring, Yes. All Sunrun employees should
giving unjustified low or negative performance evaluations, have a work environment where they
transfers to less desirable positions or schedules, or verbally feel empowered and that is free
or physically attacking someone. Other, more subtle, acts of from discrimination, harassment, or
retaliation could include avoiding someone or leaving them out retaliation. Please refer to the Employee
of activities. If you believe you have been subject to retaliation, Guidebook for more information on our
please report it promptly. policy prohibiting retaliation.

Code of Business Conduct & Ethics | 3


Investigations
Reported violations will be promptly
investigated. The Board of Directors of Sunrun
(the Board), or its designated committee will
be responsible for investigating violations
and determining appropriate disciplinary
action for matters involving members of the
Board or executive officers. The Board or its
designated committee may designate others
to conduct or manage investigations on its
behalf and recommend disciplinary action.
Subject to the general authority of the Board
to administer the Code, the Chief Legal
Officer will be responsible for investigating
violations (including the initiating of any such
investigation) and determining appropriate
disciplinary action for other employees, agents,
and contractors. The Chief Legal Officer may
designate others to conduct or manage
investigations on the Chief Legal Officer's
behalf and recommend disciplinary action.

The Board reserves the right to investigate


violations and determine appropriate
disciplinary action on its own or to designate
others to do so in place of, or in addition to,
the Chief Legal Officer. It is imperative that
the person reporting the violation not conduct
an investigation on his or her own. However,
employees and directors are expected to
cooperate fully with any investigation made
by the Company into reported violation.

Disciplinary actions
Employees and directors who violate the laws
or regulations governing Sunrun's business,
the Code, or any other Sunrun policy,
procedure or requirement may be subject
to disciplinary action, up to and including
termination. Employees and directors who
have knowledge of a violation and fail to move
promptly to report or correct it, or who direct
or approve violations, may also be subject
to disciplinary action, up to and including
termination. Furthermore, violations of some
provisions of the Code are illegal and may
subject the employee or director to civil and
criminal liability.

Code of Business Conduct & Ethics | 4


Honesty in
the marketplace
The Code reflects our commitment to
delivering results with the highest standards,
especially in the way we do business and
interact with and support our customers.

“Integrity is at the core of our business.


Ultimately, it is up to each of us to uphold our
standards and build a reputation as a company that
puts doing what’s right above everything else.”

Paul Dickson
Chief Revenue Officer

| 5
Fair and honest Antitrust and
business practices competition law
Sunrun excels while operating fairly and Sunrun is constantly working on ways to
honestly, never through unethical or illegal be innovative and competitive because
business practices. We communicate directly our customers should have a best-in-class
and honestly with our customers, business experience and products. Sunrun believes that
partners, stockholders, and community. competition makes us stronger and better, and
We respect others and do not take unfair therefore, Sunrun will never seek to eliminate or
advantage of anyone through manipulation, reduce competition through illegal activities,
concealment, abuse of privileged information, such as agreeing with competitors to charge
misrepresentation of material facts, or any certain prices to customers, coordinating
other unfair dealing practices. We provide with competitors during competitive bidding
accurate information to our employees, processes, or agreeing with competitors
customers, business partners, stockholders, to divide up markets by region, product, or
and creditors, and we do not misuse intellectual customer.
property or confidential information of Sunrun
or anyone else.

Scenario

Accurate accounting I recently learned that two managers


within my department have an informal
and bookkeeping agreement with one of our competitors
that essentially controls pricing and
products, which is not allowing for our
Sunrun properly accounts for all assets, customers to receive fair pricing or
liabilities, and other bookkeeping information creating fair competition in the market,
to adhere to policies and legal requirements. but the company is making a bigger
All of Sunrun’s records, accounts, and financial profit. Should I report this?
statements must be maintained in reasonable
detail and must accurately reflect the Yes. When competition exists, customers
transactions and matters to which they relate. benefit from lower prices, more choices,
False or misleading records or documentation better quality, and greater innovation.
are strictly prohibited. For additional Price fixing is harmful to consumers
information, please review the Global and violates antitrust laws. Antitrust and
Anti-Corruption Policy, Sunrun Spending competition laws protect consumers
Authorization Policy, Sunrun Travel Time Policy, and further fair competition between
Travel & Expense Reimbursement Policy, and companies.
the Employee Guidebook. Additionally, for
questions that are still unclear employees can
reach out to internalaudit@[Link].

Honesty in the marketplace | 6


Anti-corruption Scenarios

& anti-bribery
I overheard a conversation between my manager
and another employee where my manager stated
that he accepted a free trip to Las Vegas from a
private company to advance the interests of the
company. What should I do?
Sunrun believes in conducting business with
integrity and the highest ethical business According to anti-corruption laws, it is illegal to offer,
standards. It is crucial that no one working for promise, or give anything of value to private parties
or on behalf of Sunrun pay or receive a bribe in order to improperly influence a business outcome
or anything of value to or from any person, or to obtain favorable treatment. Therefore, we
including government officials, in order to should always act in good faith and impartially when
improperly influence a business outcome or doing business with private parties, foreign officials,
to obtain favorable treatment. Before offering and non-government officials. Additionally, gifts,
or providing anything of value to any person, entertainment, excessive business promotional
including a government official, you are activities, covering or reimbursing expenses,
responsible for understanding Sunrun’s Global in-kind or political contributions, investment
Anti-Corruption Policy and for obtaining all opportunities, subcontracts, stock options, and
necessary pre-approvals. similar items provided to any person are all things
of value that can violate anti-corruption laws and
internal policies. Please refer to Sunrun's Global
Anti-Corruption Policy for guidance and contact
the Legal and Compliance Team or use the Ethics
Hotline to report your concerns.

One of our vendors offered to take me to dinner


while we were attending the same conference. Can
we accept this offer?

This type of offer would most likely not constitute


a bribe because it would probably not influence a
business outcome or result in favorable treatment.
It would be important to discuss the invitation with
your manager if you are uncertain if the offer can
be accepted.

What is the difference between the scenarios, and


why can one offer be accepted and not the other?

The first scenario is an excessive form of


entertainment that violates anti-bribery laws and
internal policies.

The second scenario describes a reasonable and


customary expenditure that may help foster the
relationship between the vendor and Sunrun, but is
not likely to result in any improper influence.

Honesty in the marketplace | 7


Insider trading
It is illegal to trade in the securities of a
company while in the possession of non-
public information that a reasonable investor
would consider important in deciding whether
to buy, sell, or hold that company’s stock
(“insider information”). If you trade based on
insider information or tip others, you may be
personally liable for civil and criminal fines and
even face the possibility of a jail sentence. To
help protect you from violating insider trading
laws, Sunrun has established quarterly trading
windows and optional 10b5-1 plans. Ultimately,
it is your individual responsibility to avoid
trading on the basis of insider information,
regardless of whether the trading window is
open. Please review the Insider Trading Policy
to understand the do’s and don’ts and what
constitutes insider trading.
“As a publicly traded company, we are
Scenario accountable to not only ourselves,
but those who have invested in our
My colleague mentioned his cousin
asked him if he had any inside mission. We must always act with
information that would help his cousin the utmost integrity. Honesty is
in deciding if he wanted to purchase foundational to doing the right thing,
stock in the colleague's company. I
asked the colleague, “What did you the right way.”
say?” He replied, “I told him that I’m not
allowed to discuss material non-public Danny Abajian
information concerning the company Chief Financial Officer
with friends, family members, or any
other person not authorized to receive
such information.” Did the colleague do
the right thing?

Yes. Any non-public information


about Sunrun or any other company
that we acquire in the course of our
employment may only be used for
legitimate business purposes. We are not
allowed to disclose material non-public
information concerning Sunrun or any
other company to friends, family, or any
other person or entity not authorized to
receive information. Refer back to the
Insider Trading Policy anytime you are
unsure how to respond or act.

Honesty in the marketplace | 8


Marketing and
advertising
At Sunrun we advertise, market, and sell
our products honestly, accurately, and
responsibly per the Marketing and Advertising
Compliance Policy. We treat our customers
with respect, honesty, and fairness. We
substantiate our claims about our products
and do not present misleading information
in our marketing or advertising materials. We
also expect the third parties we work with to
adhere to our standards. Please review the
Marketing and Advertising Compliance Policy.

Vendor
relationships
We do business with responsible third parties.
Sunrun is committed to doing business
ethically and legally, and Sunrun only works
with vendors, suppliers, and other third
parties who share the same commitment.
Sunrun requires that all Sunrun’s vendors
read, understand, and comply with the
Sunrun Vendor Code of Conduct and all other
conditions of doing business with Sunrun.

Honesty in the marketplace | 9


Responsibility in
the workplace
At Sunrun, we succeed by embracing a diversity
of ideas, perspectives, and backgrounds.
Working with integrity and treating each other
with respect is at the heart of Sunrun’s values:
we love people, we love to create, we love to run!

“Integrity and respect are key ingredients to a


creative environment and successful workplace.
These virtues build trust within our teams and
empower individuals to bring their ideas to the
table—unlocking their full potential to make a
positive impact.”

Jeanna Steele
Chief Legal Officer and Chief People Officer

| 10
Diversity
and inclusion
Sunrun values diversity and inclusion within the
workplace. All dealings between employees
are based upon respect and dignity, and
we are committed to providing a workplace
where everyone feels valued. Sunrun policy
prohibits unlawful discrimination on any
protected characteristic such as race, color,
creed, gender (including gender identity,
gender expression, sex stereotype, and
transgender), religion, marital status, age,
national origin, ancestry, ethnicity, physical
or mental disability, medical condition, sex
or sexual orientation, to name a few. Please
see the Employee Guidebook for additional
information and guidance.

What is the difference


between diversity and inclusion?

Diversity is the difference in


characteristics and experiences
such as physical, cognitive,
socioeconomic, gender, or race.

Inclusion is actively creating an


environment where everyone feels
empowered to bring their full selves
and best ideas, through programs that
enable a diverse workforce to thrive.

Responsibility in the workplace | 11


Discrimination Examples of

and harassment discrimination


and harassment
Intimidation
Sunrun is committed to providing a work environment that Yelling or threatening behavior;
is free from discrimination, harassment, and disrespectful intimidating acts, such as bullying
conduct of any kind. Discrimination, harassment, or other
disrespectful behavior can be verbal, non-verbal, or physical. Sexual advances
Sunrun does not tolerate this type of behavior in the workplace. Unwanted physical, verbal, or
Please review the Employee Guidebook for more information sexual requests or statements
on discrimination and harassment.
Offensive jokes
Racial slurs or inappropriate comments

Health and safety “People are our most cherished


and valuable investment. We
make safety, in every aspect, our
The health and safety of our employees, contingent workers,
and customers are of paramount importance. Sunrun does not highest priority so that our people
tolerate workplace violence and any act or threat of physical can not only succeed but thrive in
violence is expected to be reported immediately. Employees the work they do for the planet."
are expected to comply with all safety requirements, policies,
standard operating procedures, and attend all required safety
training. Employees should never be asked to perform a task Christopher McClellan
in which they feel unsafe. If you are concerned about your or Senior Vice President of Operations
others’ safety, you should contact your supervisor immediately
or call the incident reporting hotline at 805-547-2601.

For more information, please review the Health & Safety Manual,
COVID-19 Prevention Program, Heat Illness Awareness and
Prevention Plan, Injury & Illness Prevention Plan, and Employee
Guidebook.

Responsibility in the workplace | 12


Recording your
Recording time accurately

your time
When recording your time, remember
that non-exempt employees should
never:

• Work without pay, including not


Non-exempt (hourly) employees must accurately record all recording hours for work done
hours worked as required by law and Sunrun policy. Non- remotely
exempt employees should take all required meal and rest
breaks, and never work without pay or fail to report overtime. • Fail to report overtime, whether
It is important to follow internal processes when maintaining approved or unapproved
time records and to let a manager know right away if you are
having any problems recording your time. Please review the • Record time worked for someone
Timekeeping section of the Employee Guidebook. other than yourself

• Inaccurately record the time you


worked

• Unnecessarily change hours from


your time record

Responsibility in the workplace | 13


Avoiding
conflicts of interest
Conflicts of interest are prohibited as a matter of Company
policy. A conflict of interest is a situation in which personal
activities or relationships might influence, or appear to
influence, our ability to make decisions objectively and act in
Sunrun’s best interests.

As a representative of the Company, you are expected to act in


the best interests of the Company and avoid any activity that
creates a situation in which your actions or loyalties are divided
between personal interests and the Company’s interests, or
between the Company’s interests and those of another entity
or person.

A conflict situation can arise when an employee or director


takes actions or has interests that may make it difficult to
perform his or her Company work objectively and effectively.
Conflicts of interest may also arise when an employee or
director, or a member of his or her family, receives improper
personal benefits as a result of his or her position with the
Company.

Any business relationship that an employee enters into


outside his or her work at the Company or any of its direct or
indirect subsidiaries requires the employee’s good faith and
common sense. Employees are prohibited from accepting
simultaneous employment with or otherwise working for any
person or entity with which the Company or any of its direct or
indirect subsidiaries has a business relationship, without the
prior written approval from the Chief Legal Officer or his or her
designee (or, in the case of either the CEO or the Chief Legal
Officer, prior written approval from the Board). Employees are
also required to obtain prior written approval from both the
CEO and Chief Legal Officer (or, in the case of either the CEO or
the Chief Legal Officer, prior written approval from the Board)
before serving on the board of directors of any for-profit entity.
In no circumstances will an employee be permitted to work in
any capacity for a competitor of the Company.

Conflicts of interest may not always be clear. You are


encouraged to be transparent so that potential conflicts can
be identified early and appropriate precautions can be taken
to protect both you and Sunrun.

Responsibility in the workplace | 14


Recognize potential conflicts
Some examples:

• You have a second job with a Sunrun competitor or a


company within the energy industry

• You have a direct or indirect reporting relationship with a


family member or best friend

• You offer to do some consulting work for a customer

• You are on the board of directors for another company

• You are competing with the Company

• You are using corporate property, information, or position


for personal gain

If you find yourself in any of these situations, ask yourself if


the action could create or appear to create an incentive or
benefit for you, your friends, or your family. If the answer is
yes, the action you are considering may create a conflict-of-
interest situation. You should discuss this with your manager
and partner with Employee Relations to receive appropriate
guidance and obtain all necessary approvals.

Scenario

My husband has a catering business, and I use him


for all my catering and event needs. I didn’t report
this to anyone since I run the events program. He
always does great work and gives me a great deal.

Should I report this?

Yes. Sunrun permits the employment of family members


in certain conditions, but the appropriate channels were
not followed to obtain this vendor. To avoid a conflict
of interest or an appearance of a conflict of interest, a
manager or Employee Relations should be notified of the
relationship. By being transparent, an immediate manager
and Employee Relations can help determine if any action
is necessary.

Responsibility in the workplace | 15


Accepting gifts, gratuities,
and entertainment
Accepting gifts, gratuities, or entertainment from a potential or
current vendor, supplier, or other provider could be a conflict of Example of gifts or
interest. A gift can be considered anything of value, including entertainment:
cash or gift cards. Consult with your direct manager in these • Tickets to concerts
instances to determine whether accepting the gift could be or other events
an actual or perceived conflict of interest. • Discounts for
services
• Gift cards
• Alcohol
No gifts or entertainment should be given or • Meals
accepted by any employee, director, family member • Travel-related
of an employee, or agent unless it: expenses

• Is not a cash gift

• Is not over $100 in value (unless you obtained prior written approval from the Legal Team)

• Cannot be construed as a bribe

• Does not violate any laws or regulations

• Is not one of a series of small gifts or entertainment that can be construed as part of a
larger, expensive gift

• Is not otherwise prohibited by any other gift and entertainment policies

Regardless of value, before giving or accepting any gifts or entertainment,


always consider:

• Is the exchange intended to influence me or business negotiations?

• Will the exchange appear to others to influence business decisions?

• Will the exchange result in any special or favored treatment?

• Will my participation in the activity reflect poorly on Sunrun?

If we can answer Yes to any of these, we should not participate in the exchange.
Any questions about whether any gifts or proposed gifts are appropriate should be
directed to Legal and Compliance. Additional guidance can be located in the Global
Anti-Corruption Policy regarding specific conditions for gifts and entertainment.

Responsibility in the workplace | 16


“Sunrun has a culture that keeps humanity Confidential
at the core of the business, whether that information examples
is our customers, our partners, or the
• Trade secrets
intentional focus on building an inclusive
and diverse team that understands • Research and
development ideas
everything we do is to serve humanity.”
• Proprietary information
Sandy Anuras, Chief Technology Officer • Contracts, sales, and
pricing data

• Existing or potential client


Protecting Sunrun assets lists

• Non-public financial data


We are responsible for protecting Sunrun’s assets, including physical assets, or projections
technology assets, systems that we use, or anything else that Sunrun owns
or uses to conduct business. These resources should be used only to perform • Potential acquisitions or
legitimate business functions, and for reasonable personal purposes, as investments
allowed by Sunrun policy. We may not use company assets for any illegal • New product or marketing
purpose or for any matter that violates the letter or spirit of the Code or any plans
Sunrun policy.
• Personally identifiable
information: name,
address, phone, email
Safeguarding confidential
and personal information How to protect
confidential information
If Sunrun’s proprietary, confidential, or personal information, or such
information entrusted to Sunrun by third parties, ends up in the wrong • DO NOT share your logins
hands, it could have severe consequences. We must protect all proprietary, or passwords
confidential, and personal information from unintentional or inappropriate
disclosure. Always take appropriate steps to protect information and be on • Password protect
the lookout for phishing and other scams, and think before you share! To proprietary or confidential
learn more about how to protect personal and business information, read information on a shared
the Information Security & Compliance Policy. drive

• Lock your computer


Scenario screen when you are away
from your computer
Yesterday I received an email from the Supply Chain Team marked • Know who you are
Confidential, and it included a client list and product plans. I disclosing information
also noticed that the email distribution list included hundreds of to, restrict information
employees from across the company. What should I do? and access to those who
have a legitimate business
Protection of company information starts with us! An incident like need to know
this was probably sent by mistake, but it should be reported because
disclosure of confidential information to the wrong person could cause • Clearly label all
a significant risk to the Company. This incident should be reported to confidential information
your manager, or you can contact the Information Security Team. "Confidential"

Responsibility in the workplace | 17


Scenario

I accidentally sent confidential


customer data to a supplier.

Privacy and What should I do?

Sunrun has a process in place for

data protection reporting, escalating, investigating,


and resolving information security
incidents. An incident is any event that
intentionally or unintentionally results
At Sunrun, we keep private information and data just that, in misuse, inappropriate disclosure,
private! Our customers, vendors, and employees expect and modification or inability to access
trust that we will handle their information with care. Therefore, information. Sunrun employees
we only use data for its intended purpose and in accordance are required to report a potential
with all privacy laws and Sunrun policies. For more guidance or confirmed information security
review the Information Security & Compliance Policy. incident immediately upon discovery.

For assistance, please contact:


Information Security
infosec@[Link]
415-580-6901
or submit a ServiceNow ticket

Responsibility in the workplace | 18


Using social media If you are unsure about
responsibly whether to post something
on social media, ask yourself:
Sunrun recognizes that social media is an
engaging way to share your passions with Could the post possibly contain
family, friends, and co-workers. With that confidential information
said, social media can pose risks to Sunrun’s or business secrets?
confidential and proprietary information,
reputation, and brand if used inappropriately. Could the post be perceived as
To minimize business and legal risks, avoid disrespectful to our customers,
loss of productivity and distraction from clients, suppliers, vendors,
job performance, and ensure that Sunrun’s partners, or competitors?
technology resources and communications
systems are used appropriately, Sunrun Am I being clear that I am writing
expects you to adhere to Sunrun’s Social the post on my own behalf?
Media Usage Policy.

Political participation
Sunrun supports engaged citizenship. When you engage in political activity,
you should always make clear that your actions and opinions are your own, and
that you are not representing Sunrun. All personal political activities must be
done on your own time, with your own resources. For more information, please
review the Employee Guidebook.

External communications
To establish consistent, effective, and ongoing communications, only authorized
spokespersons may speak with third parties on behalf of the Company. All
inquiries or calls from the press and financial analysts should be referred to
the CEO, the Chief Financial Officer, the Chief Legal Officer or the Investor
Relations Department. Sunrun’s policy governing communications made by
our employees, officers, directors, and independent contractors with media
personnel, members of the investment community, stockholders, and others
not bound by confidentiality to Sunrun, is more specifically set forth in the
External Communications Policy.

Responsibility in the workplace | 19


Courtesy in
the community
Engaging with our community is fundamental
to Sunrun’s values and our mission to create a
planet run by the sun. We work hard to leave a
lasting, positive impact in every place where we
do business.

“In my experience, happiness comes


from three things: the impact
you make in the world, how many
people you are able to help, and the
relationships you forge.”

Chance Allred
Chief Experience Officer

| 20
Helping the community live
more sustainably
Sunrun is committed to ensuring a sustainable world that
supports health, safety, and equality for all. Sunrun offers
access to clean and reliable solar power, so people can meet
their energy needs.

Volunteering and
community projects
Sunrun strives to make a positive impact in the communities
where we live and work to build stronger communities.
Volunteering within the community is a great way to make an
impact, and Sunrun provides avenues to make that happen.
Check out the Employee Guidebook for more details.

Human rights
We love people, and respect for human rights is a fundamental
Sunrun value. We are passionate about people and are
committed to supporting and improving our communities
by electrifying our customers’ homes and fulfilling their
energy needs.

Sunrun does not tolerate the use of underage or forced


labor and will not knowingly work with vendors that utilize
such workers. Sunrun expects its vendors to comply with all
age-related working restrictions and adhere to state, federal,
and international standards. To ensure that our values and
commitments are communicated, operationalized, and
embedded at every level throughout the Company, review
the Human Rights Policy.

Courtesy in the community | 21


Other elements
of the Code
Waivers
Any waiver of the Code for executive officers or directors
may be authorized only by Sunrun's Board or, to the extent
permitted by the rules of the NASDAQ stock market and
Sunrun's Corporate Governance Guidelines, a committee of
the Board, and will be disclosed as required by applicable laws,
rules and regulations.

Annual review
Any changes to the Code may only be made by the Audit
Committee of the Board and will be recommended to the Board
for approval and effective upon approval by the Board. The
Audit Committee will review and reassess the adequacy of this
the Code at least annually and recommend to the Board any
changes the Audit Committee determines are appropriate.
All changes must be promptly disclosed as required by law
or regulation.

Website posting
The Code, as may be amended from time to time, shall be
posted on Sunrun's website. Sunrun shall state in its annual
proxy statement that the Code is available on the Sunrun
website and provide the website address as required by law
or regulation.

Other elements of the Code | 22


Resources
Policies Contacts
For employees, all policies are available on OneSunrun Audit Committee
audit@[Link]
Authorized Driver Policy
Employee Relations
COVID-19 Prevention Program employeerelations@[Link]

Employee Guidebook Ethics Hotline


[Link]
External Communications Policy 855-477-8862

Global Anti-Corruption Policy Information Security


infosec@[Link]
Health & Safety Manual
Internal Audit
Heat Illness Awareness and Prevention Plan internalaudit@[Link]

Human Rights Policy Legal and Compliance


integrity@[Link]
Information Security & Compliance Policy

Injury & Illness Prevention Plan

Insider Trading Policy

Social Media Usage Policy

Spending Authorization Policy

Sunrun Marketing and Advertising Compliance Policy

Sunrun Travel Policy

Sunrun Vendor Code of Conduct

Travel & Expense Reimbursement Policy

Whistleblower Policy
I have read and understand the Sunrun Code of Business Conduct & Ethics.

Signature: ____signHere1_____

Date: ____dateSigned1_______

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