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In addition to jobs and contracts, ComEd’s admissions include other efforts to influence and reward Public Official A. They appointed an individual to ComEd’s Board of Directors at his request. They retained a particular law firm at his request. ComEd accepted into the company’s internship program a certain number of students who lived in the Chicago ward where Public Official A was associated.

ComEd enhances its compliance program

As reported in Compliance Week, ComEd is obligated under the DPA to include enhancements to its compliance program and provide annual reports to the government regarding remediation and implementation of those compliance measures.

While the misconduct was limited to ComEd, the policies are being applied across all Exelon subsidiaries in Illinois and all other jurisdictions where Exelon operates.

Exelon has implemented four new mandatory policies that apply to employees who interact with public officials. These policies outline specific rules, procedures, and tracking methods governing interactions with public officials. They also require vetting and monitoring all ComEd lobbyists and political consultants. Any employment referrals or requests and vendor referrals or requests from public officials will be disclosed and reviewed.

The policies also prohibit the subcontracting of third-party lobbyists and political consultants. Additionally, the hiring of such firms is being overseen by the ethics and compliance team.

The effort is led by David Glockner, Exelon’s executive vice president of compliance and audit. Glockner was hired in March after having previously served as a senior Securities and Exchange Commission official and chief of the Criminal Division in the U.S. Attorney’s Office for the Northern District of Illinois.

In a statement, Exelon said it has fully and substantially cooperated with the U.S. Attorney's Office from the beginning of the investigation, and since that time, has taken extensive remedial measures. The remediation and cooperation efforts were acknowledged by the government in the DPA resolution agreement.

“We are committed to maintaining the highest standards of integrity and ethical behavior,” Exelon CEO Christopher Crane said. “In the past, some of ComEd’s lobbying practices and interactions with public officials did not live up to that commitment.”

“When we learned about the inappropriate conduct, we acted swiftly to investigate,” Crane added. “We concluded from the investigation that a small number of senior ComEd employees and outside contractors orchestrated this misconduct, and they no longer work for the company.”