Guiding corporate principles

Vision Statement. We Energies, the trade name of our principal utility subsidiaries, has established a vision to be the industry leader in customer satisfaction.

Values. The following values define what each employee is called upon to model every day. How well the organization is doing is measured with every interaction with fellow employees and with customers.

Safety
Diversity
Inclusion
Customer Focus
Sense of Urgency
Financial Discipline
Personal Responsibility for Results

Code of Business Conduct and Corporate Securities Trading Policy. Wisconsin Energy Corporation (WEC) has a Code of Business Conduct and a Corporate Securities Trading Policy, each of which applies to all directors and employees and covers all of our affiliates. The code, which can be reviewed by clicking on Code of Business Conduct, addresses, among other things, conflicts of interest, confidentiality, fair dealing, protection and proper use of corporate assets, and compliance with laws, rules and regulations (including insider trading laws). Click on Ethics and Compliance for more information concerning the code. Our Corporate Securities Trading Policy sets forth standards for compliance with insider trading laws. Learn more about our trading policy by clicking on Corporate Securities Trading Policy.

The WEC Corporate Secretary serves as the Corporate Compliance Officer and is responsible for overseeing and administering programs established to achieve compliance with the Code of Business Conduct and the Corporate Securities Trading Policy.

Reporting Ethics Concerns; Seeking Guidance. As stakeholders in our success, each of our employees is obligated to report suspected ethics violations and to seek advice in doubtful situations. In such situations, employees are encouraged to use the Code of Business Conduct and other corporate policies as a reference, speak with their supervisor, as appropriate, or contact the Corporate Compliance Officer or Corporate Security. We have also contracted with an independent call center for employees to confidentially report suspected violations of the code or other concerns regarding accounting, internal accounting controls or auditing matters. The Company prohibits retaliation against employees who report questionable ethical conduct in good faith, provide information or otherwise assist in an investigation, or file, testify, participate in or otherwise assist in any related proceeding of matters brought to our attention.

Internal Controls. Corporate management is responsible for establishing and maintaining adequate internal control over financial reporting. Under the supervision and with the participation of company management, including our principal executive and financial officers, we conducted an evaluation of the effectiveness of our internal control over financial reporting, based on the Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission. Based upon the evaluation performed under this framework, management concluded that Wisconsin Energy Corporation and its subsidiaries' internal control over financial reporting was effective as of December 31, 2011. Management's report on internal control over financial reporting may be found in Wisconsin Energy Corporation's 2011 Annual Report on Form 10-K. The Form 10-K also includes an attestation report of our independent registered public accounting firm on the effectiveness of our internal control over financial reporting.

We have designed processes to monitor these controls on an ongoing basis and to support management's quarterly evaluation that disclosure controls and procedures are effective (1) in recording, processing, summarizing and reporting, on a timely basis, information required to be disclosed in our reports filed with or submitted to the Securities and Exchange Commission (SEC) under the Securities and Exchange Act of 1934, as amended (Exchange Act), and (2) to ensure that information required to be disclosed in the reports that we file or submit under the Exchange Act is accumulated and communicated to our management, including our CEO and Chief Financial Officer, to allow timely decisions regarding required disclosure.