Sempra Energy Trading Corp.
Code of Conduct

This Code of Conduct ("Code") applies to the commodities and derivatives trading activities of the Sempra Energy Trading group of companies worldwide ("SET") and reaffirms Sempra Energy's standards for maintaining a legally compliant and ethical workplace. This Code is intended to ensure that SET's business activities are conducted in compliance with all applicable laws and regulations and in a manner that is consistent with SET's high values and ethical standards. This Code will also serve to guide the practices and decision-making processes of SET employees in the course of providing commodity and risk management services to SET's customers. Finally, this Code assures that unlawful and unethical trading practices will not be tolerated, that public disclosures of trading information will be accurate, and that SET employees will abide by these ethical standards.

I. Ethical Standards

Sempra Energy's value statement provides that "We act with integrity, honesty, and respect". Our reputation depends on our ability to maintain the achievement of those ideals and to conduct business ethically. Ethical business conduct is essential to our continued success. Accordingly, SET will:

1. Conduct its business in compliance with all applicable international, federal, state and local laws, regulations, tariffs and rules, including, without limitation, the Federal Energy Regulatory Commission's "Market Behavior Rules.".

2. Deal in good faith, with a commitment to honest dealing, and not engage in fraudulent behavior.

3. Not engage in transactions without a legitimate business purpose and which are intended to manipulate market prices, market conditions, or market rules.

4. Not collude with other market participants to affect the price or supply of commodity, manipulate or divide markets, customers or products, or otherwise unlawfully restrain competition.

5. Enforce risk management policies and structures that are designed to ensure that trading activities are conducted in accordance with this Code.

6. Properly record, classify, and summarize transactions in accordance with Sempra Energy's accounting policies to support Sempra Energy's policy of full, fair, accurate, timely and understandable disclosure of financial results and conditions.

7. Comply with rules that are designed to ensure the reliable transmission of commodity.

II. Sound Trading Practices

In the conduct of its trading businesses, SET will:

1. Commit or otherwise bid power or gas supply in a manner that complies with the rules, regulations and guidelines of the applicable market. SET may decide not to bid and schedule resources available to it when such actions would risk jeopardizing public health and safety or damaging facilities, or to comply with facility licensing, environmental or other legal requirements, or when such actions would be uneconomic under the given circumstances so long as no FERC-approved tariff or requirement mandates SET to do so.

2. Not engage in electric energy transactions or schedule electric energy resources with the intent of creating congestion to manipulate prices or to jeopardize the security of dispatch operations.

3. Not offer reliability services to the market that it intends not to provide.

4. Not arrange and execute simultaneous offsetting buy and sell trades that involve no economic risk and no net change in beneficial ownership, i.e. with the same counterparty and price, commodity, location and quantity terms, with an intent to artificially affect reported revenues, trading volumes or prices.

5. Not conduct trading for the purpose of misrepresenting the financial condition of the organization.

III. Information Disclosure and Documentation

SET will:

1. Provide accurate and factual market and transaction information to regulators and market monitors in compliance with all applicable rules and requirements and cooperate with regulators and market monitors as reasonably necessary to assist in their understanding of market operations.

2. Maintain and adhere to internal procedures designed to ensure that all trades are properly documented in a timely fashion and that no trades are concealed or misrepresented.

3. Maintain documentation on all transactions for an appropriate period of time as required under applicable laws and regulations.

IV. Communicating Price and Market Information to Outside Publications

Sempra Energy considers the price indices published by industry publications as important to market transparency and liquidity. Accordingly, SET is authorized to provide pricing and market information, if requested, to these publications provided SET abides by the following guidelines:

1. The individuals providing the information are independent of the trading desk(s) to which the information relates.

2. Exercise due diligence to provide accurate and factual information, and not knowingly submit false or misleading information or omit material information.

3. The response adheres to applicable legal and regulatory requirements.

4. The information provided is documented in such a way that enables subsequent verification and audit against actual deals.

5. In accordance with applicable regulations, exclude from reports to industry indices those transactions that involve natural gas sales to affiliates.