Corporate Securities Trading Policy

The purpose of the Corporate Securities Trading Policy (CSTP) is to set forth standards to help all Company personnel avoid the severe consequences associated with violations of insider trading laws. This policy also is intended to prevent the appearance of improper conduct on the part of anyone employed by or associated with the Company. The CSTP is a comprehensive policy that sets forth minimum guidelines with respect to transactions involving any form of WEC securities while in possession of material, non-public information. The policy generally covers the following:

• transactions involving WEC securities under the various Company Plans;
• prohibited transactions;
• mandatory pre-clearance requirements for directors, officers, and certain employees designated by the Compliance Officer;
• reporting requirements for Section 16 insiders; and
• compliance certification (all directors, officers and certain employees designated by the Compliance Officer are required to certify their understanding and intent to comply with the policy).