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Protocols to Limit Access to Non-Public Transportation Information

General

Under clause 3.1.3 of the Ontario Energy Board’s Storage and Transportation Access Rule ("STAR") an integrated utility shall develop and maintain protocols to limit the access to non-public transportation information concerning plans for future facility expansions or timing of upcoming transportation open seasons and transportation operating conditions of shippers, storage companies and consumers to personnel that require this information only.   

Union Gas Limited ("Union") is committed to protecting the confidentiality of its customers’ information and to providing non-discriminatory access to Union’s gas transportation and storage system (the "System") to all of its customers and potential customers, including shippers and those taking storage services from Union (the "Customers").  All employees and third parties performing work for Union are required to comply with the following protocols which are intended to implement that commitment.  Employees or third parties who violate any of the protocols will be subject to appropriate discipline, including up to possible dismissal or the termination of their contracts with Union if circumstances warrant.

Non-Discriminatory Access to Information         

Union will at all times treat its Customers on a non-discriminatory basis.

Union’s employees and third parties performing work for Union are prohibited from providing any Customer with non-public transportation information concerning Union’s plans for future facility expansions or timing of upcoming transportation open seasons or the transportation operating conditions of any of Union’s Customers ("Non-Public Transportation Information").

Non-Public Transportation Information may be provided to an employee of an Affiliate (as defined in the Ontario Energy Board’s Affiliate Relationships Code for Gas Utilities) of Union or to an unaffiliated third party (such as a contractor or consultant) only if that person needs to know the information to perform his or her job function for or relating to Union. 

If an employee of an Affiliate is provided with any Non-Public Transportation Information that employee shall be required to comply with the provisions of this protocol.

All employees of Union or any Affiliate of Union who have knowledge of Non-Public Transportation Information are prohibited from sharing that information with anyone (including other employees of Union) who does not need that information to perform their job functions for or relating to Union.

Compliance

Union will inform all employees of Union or any Affiliate of Union who have access to Non-Public Transportation Information of the requirements set forth in these protocols and Union will periodically remind such employees of Union’s expectation that they conduct themselves at all times in a manner consistent with these protocols. 

Prior to providing an unaffiliated third party (such as consultants or contractors) with any Non-Public Transportation Information, Union will obtain a confidentiality agreement from such third party prohibiting the public disclosure of all non-public information provided by Union to the third party.

Complaint Mechanism

Any complaint respecting the application of these protocols shall be dealt with in accordance with Union’s dispute resolution process for complaints related to STAR which is posted on Union’s website at uniongas.com.

Periodic Review

These protocols shall be subject to periodic review by Union. Any modifications shall be posted on Union’s website.