1. In accordance with the requirements of securities regulations to which Veresen Inc. (the "Company") is subject and to safeguard the continued independence of the Company's external auditors, the Company recognizes that potential independence issues could arise when hiring current and former partners and employees of the Company's current and former external auditors and related entities (the "Auditors"). For purposes of this Policy, all references to "Company" shall include its corporate and partnership subsidiaries.
2. The following individuals will be subject to the stated blackout periods prior to being eligible for hire by the Company:
a. Audit or Assurance partner directly involved with the Company’s account:
2 years from last audit or review engagement signoff date that the partner was involved in.
b. Tax partner directly involved with the Company’s account:
1 year from the last audit or review engagement or tax return signoff date that the partner was involved in.
c. Audit, Assurance or Tax partner working at the same accounting firm as the current or former Auditors:
6 months from the last audit or review engagement or tax return signoff date that the accounting firm was involved in.
d. Senior Manager or Manager directly involved with the Company’s account:
1 year from the last audit or review engagement date that the individual was involved in.
e. Any other individual directly involved with the Company’s account:
6 months from the last audit or review engagement or tax return signoff date that the individual was involved in.
f. Any other individual working at the same accounting firm:
no blackout period.
3. This Policy will be brought to the Audit Committee for review and, if thought appropriate, renewal on an annual basis.
4. The effective date of this Policy shall be March 16, 2005 and was revised January 1, 2011.
