When and How to Escalate Matters to Compliance

Handled By: Resolution Specialists

Background: There may be instances where a homeowner’s concern requires escalation to EverBright’s Compliance team.

STEP	ACTION
1	Does the customer’s concern warrant Compliance’s involvement? If yes: Advise: We’re happy to discuss this with your attorney if you would like, but I believe we can work through this together if you’ll allow me the opportunity to earn your confidence. Follow appropriate process(es) and Stop If no, go to Step 2
2	Determine if the matter qualifies for escalation to Legal If yes: Advise: EverBright’s Legal team will work directly with the customer’s attorney All communication going forward regarding the customer’s concern must be handled between our Legal team and the customer’s attorney If Legal’s contact information is requested, provide LEGAL@GOEVERBRIGHT.COM Send an internal notification to our Legal team Notify Account Servicing that the customer has obtained legal counsel and to cease all customer communication Input a note in the milestone feed within the customer’s job in Engine indicating that Legal has been involved Stop If no, follow appropriate process(es) and Stop

Examples of Compliance Issues

EXAMPLES

Accusation of fraud or unlawful activity (e.g., falsifying records, mischaracterization, theft)
Violation of an agreement
Nonregistered and/or unlicensed company
Unauthorized activities or actions
Customer privacy

Note: A compliance issue is any violation or failure to adhere to laws, regulations, policies, or ethical standards that govern an organization's operations. If there is doubt on whether a matter could be a compliance problem, please seek validation from Cassandra Mercado.

Sending an Internal Notice to Our Legal Team

STEP

ACTION

1

Notify Legal via Email:
- Recipients: Madeline.Rice@NexteraEnergy.com, Jillian.Wheatley@GoEverBright.com, Cassandra.Mercado@GoEverBright.com
- Email Subject: Legal Escalation: [TYPE (OPTIONS LISTED BELOW)] – [Customer’s Name]/[Customer’s State] – [Name of the Installer]
- Complete and include the internal notice Legal form
- Download and attach documents referenced in the internal form (e.g., customer’s contract, change orders, signed documents, etc.)

“TYPE” Selection: ATTORNEY DEMAND, AG (Attorney General) COMPLAINT, LITIGATION, LEGAL QUESTION, ESCALATED CUSTOMER

Internal Notice Legal Form

*Customer Name:	[TEXT]
*State:	[TEXT]
Utility:	[TEXT]
Name of spouse / child / other complainant (If applicable):	[TEXT]
Project Address:	[TEXT]
*Demand (What are they asking for?):	☐ Monetary compensation (other than FULL tax credit amount) in the amount of $____________ ☐ Monetary compensation – full tax credit amount of $____________ ☐ Contract cancellation – keeping the System ☐ Contract cancellation – removing the System ☐ Waiver of balance in the amount of $____________– keeping the System ☐ Waiver of balance in the amount of $____________ – removing the System ☐ Additional panels – Qty: N/A ☐ Battery – Qty: N/A ☐ Removal & reinstallation (re-roofing / roof repair) ☐ Paying third-party contractor invoice ☐ Other:______________________________________________
*Contract Type:	☐ PPA ☐ Lease ☐ RIC 1.0 ☐ RIC 2.0
*Installer Name:	[TEXT]
Contract Price:	[TEXT]
Contract Signed Date:	[TEXT]
Project Type:	[TEXT]
*Project Stage:	[TEXT]
PV Install Date:	☐ [DATE] ☐ N/A
PTO Date:	☐ [DATE] ☐ N/A
Status of Financing:	[TEXT]
Summary (Include discussions or involvement of other third parties, the person that notified us of the complaint, the customer review / company reputation aspect, etc.)*: