Our Code of Ethics

Our Employees

We treat each other with fairness, respect, and dignity, offering equal opportunities for employment to all individuals. We value different backgrounds and encourage different perspectives and ideas - understanding that Diversity is a strength that unlocks our full potential and helps us achieve our goals. Intimidation, harassment, or discrimination based on race, sex, age, color, religion, national origin, veteran's status, sexual orientation, or disability is not tolerated. We take personal responsibility for individual and organizational success, while recognizing the value that each of us contributes.

Safety & Health
We do not compromise safety and health. Because we care, we value the health and safety of each other, our contractors, and the public by conducting business in a manner designed to preserve the well-being of all. We work safely, watch out for each other, and report and correct unsafe situations. We keep our workplace free from illegal drugs and the inappropriate use of alcohol.

The Environment
We are committed to improving our environmental performance and the communities we serve by being good environmental stewards and working to conserve valuable natural resources. The health of our Employees, Customers, and the Public, and the protection of our natural environment are among our highest priorities.

Compliance with Laws and Regulations
We respect the Law. We comply with all laws and regulations. We have a responsibility to understand the laws and how they apply to our jobs. The Company supports each employee in this responsibility and provides the necessary resources for compliance. If it is found that any laws or regulations have been violated, corrective and responsible action will be taken.

Confidential Information
We use confidential information only for the business purpose for which it was developed or given. We respect the confidentiality of information about the Company, its customers, employees, vendors and partners. Confidential information will not be used for personal benefit. We comply with the laws and regulations which prohibit insider trading of securities. We protect the intellectual property rights, including copyrights, patents, licenses and trademarks, and other proprietary information of the Company and others.

Conflict of Interest
We avoid conflicts, or the appearance of conflicts, between personal interests and official responsibilities on behalf of the Company. We use corporate resources - time, personnel, equipment and supplies - for Company business or Company approved activities.

We do not take personal advantage of business opportunities that are discovered through the use of Company property, information or position. The Company's directors, officers and employees do not engage in business activities in competition with the Company.

Gifts and Gratuities
We do not accept, offer or authorize gifts, entertainment, or other favors that are not a reasonable part of a business relationship. We exercise hospitality with discretion, so as not to jeopardize the integrity of those with whom we do business.

Political Activities
We value and encourage Citizenship. Employees have the opportunity, as individuals, to support political candidates and engage in political activities of their own free choice. Company resources are not used, directly or indirectly, to support political candidates.

Because rules regarding gifts and gratuities to public officials can vary from state to state and even from agency to agency, we do not offer a gift of any type, including meals, to any public official unless we have determined that such a gift is appropriate and legal.

Competitive Practices
We compete vigorously, but fairly, on the basis of price, superior services, dependability and products. We do not enter into understandings or agreements between competitors regarding prices, terms of sales, division of markets or customers, or any other activity that restricts competition.

We conduct competitive marketing activities, including the advertising of products and services and gathering of competitive intelligence, fairly and honestly.

Financial Integrity
We are prudent in our expenditures on behalf of the Company and we record all business transactions in accordance with accepted accounting principles. We maintain appropriate internal controls designed to prevent or detect fraud and ensure every accounting or financial record, and supporting data, describes the transaction accurately without omission, concealment or falsification. Our financial integrity commitment also extends to business transactions between subsidiary companies to ensure all activity is properly reflected. We maintain and retain all business records accurately and in compliance with applicable laws and Company policy.

We believe in making full, fair, accurate, timely and understandable disclosure in the reports we file under securities laws and in other public communications.

External Relationships
Customers... Vendors... Contractors... Regulators... Stockholders... We are known by our customers for the quality and value of the products and services we provide. We value the relationships we have established and realize they are built on trust and cooperation.

We are committed to building a culture of Trust, not only with our Employees, but also our Customers, Vendors, Contractors, Regulators and Stockholders. Southern Company seeks to always maintain the highest standards of integrity and objectivity in our working relationships and will not conduct business with anyone who does not operate with integrity or who compromises the Company's values and ethical standards.

Duty To Act
Our people are our Company. We will be recognized by the actions of our people. Each of us has a clear legal mandate to act ethically on the Company's behalf and is obligated to report promptly to management any activities that may be in violation of this Code of Ethics or any applicable laws or regulations. The Company has in place appropriate processes to provide for the timely and effective review of such reports and will not tolerate any retaliation against those fulfilling this obligation.

We encourage our suppliers to discuss concerns or questions with the Workplace Ethics Network (1-800-754-9452), or a Concerns Program or Compliance Officer. The Workplace Ethics Network (800) line may also be used to report concerns regarding accounting practices, internal accounting controls or auditing matters directly to the Southern Company Audit Committee.