Ethics

It is the policy of Iroquois Pipeline Operating Company (the "Company") to maintain and enforce the highest standards of integrity in all its business activities. This includes business activities conducted on behalf of, and for, Iroquois Gas Transmission System, L.P. ("IGTS"), a Delaware limited partnership on whose behalf the Company acts as operator. In this regard, as employees, officers, directors and agents of the Company ("Company Representatives"), we strive to conduct our business in strict compliance with applicable federal, state and local laws, rules and regulations so that we may always be regarded as an ethical organization comprised of dedicated and competent individuals of high integrity and credibility.

To ensure continuing attention to matters of ethics and standards on the part of all Company Representatives, our Code of Business Ethics represents a written extension of the personal integrity typically exhibited by Company Representatives who have complied with our policy to protect the interests of the Company, its owners, and those with whom we do business. Each year, the Company distributes a survey to employees to help identify and address potential compliance concerns. Employees have a duty to report any concerns whenever they suspect misconduct or illegality. In all cases, retaliation for good-faith reporting is strictly prohibited. The Company provides a variety of reporting options. A dedicated, confidential compliance telephone line and website allow employees to remain anonymous, if they wish. Employees also may report concerns by contacting the Chief Compliance Officer and other appropriate personnel. Each of us is ultimately responsible for our actions. It is intended, therefore, that all Company Representatives be aware of this Code of Business Ethics and our Harassment: Personal and Sexual Harassment Policy since good business practice dictates that suspected dishonest or unlawful activity be promptly identified and investigated. Moreover, it is expected that all Company Representatives, and anyone doing business with our Company, will exercise the highest level of integrity and judgment in all business matters.