Sustainability Report

1.1.1 Board Oversight

Constellation’s Board of Directors closely monitors business operations and performance and assesses enterprise risks and opportunities, including those related to climate. Among other responsibilities, the Corporate Governance Committee reviews Constellation’s climate and sustainability strategies, including the company’s efforts to protect and improve the environment. For more information about our Board’s oversight of other sustainability matters, please see the Board Governance section.

1.1.2 Sustainability Governance

We take a collaborative approach to sustainability governance and various executive team members play a pivotal role in supporting our sustainability initiatives. The Constellation Sustainability Council is overseen by the Vice President of Sustainability and Climate Strategy and consists of a cross-functional group of executive leaders from key departments across Constellation. The Council meets four times each year to assess sustainability policies and initiatives, ensure alignment with our strategic goals, review developing sustainability trends and provide recommendations to senior management.

1.2.1  Generation Assets

Nuclear

For more information, visit the nuclear generation section.

Learn more about how Constellation safely operates our nuclear assets and manages our nuclear waste by visiting the nuclear safety section.

Hydroelectric

For more information, visit the hydroelectric generation section.

Natural Gas

For more information, please see the natural gas generation section.

Wind

For more information, visit the wind generation section.

Solar

For more information, visit the solar generation section.

Natural Gas and Oil

For more information, visit the natural gas and oil generation section.

Oil

For more information, please see the oil generation section.

View more details on our energy generation portfolio and our locations.

At Constellation, we are committed to protecting and sustaining the environment by complying with applicable regulatory requirements while protecting and enhancing the air, water and land. Our executive team, including our CEO and other senior management, is accountable for our environmental compliance and assurance strategy.

Constellation's Environmental Council oversees our environmental program and is composed of leaders from each business unit. The Council is subject to oversight from the Board of Directors and meets quarterly to review policies and initiatives, ensure strategic alignment, discuss emerging environmental trends and make informed suggestions to senior executive leadership. The Board’s Corporate Governance Committee reviews Constellation's climate and sustainability strategies, including the company's efforts to protect and improve the environment.

Our Environmental Policy provides guiding principles for us to uphold compliance obligations, manage and mitigate environmental impacts and promote continuous improvement within diverse operating conditions.

1.3.1 Environmental Management Systems

We maintain a robust environmental management system (EMS) for both our nuclear and non-nuclear operations; the EMS covers 100 percent of Constellation- operated Nuclear and Power business units. We continuously monitor our EMS for conformance through internal assessments and audits, and external audits managed by Constellation Audit Services (CAS) in accordance with our Management Model.

Our business unit EMS program documents are tailored to meet specific needs. This allows each business unit, site and facility to establish custom processes and procedures that satisfy the EMS requirements.

Our Nuclear EMS is recertified every 3 years to maintain International Organization for Standardization (ISO) 14001:2015 certification. CAS conducts third-party EMS conformance audits of our Nuclear, Power and Constellation Energy Solutions (CES) business units' EMS programs annually to validate our conformance with ISO 14001:20153. Nuclear and Power business units also conduct periodic internal EMS audits, which are led by qualified internal or external auditors. Additionally, our Nuclear generating sites are externally audited at least once every three years and staffed Power generating sites are externally audited for environmental, health and safety (EHS) at least once every five years. External EHS compliance audits are conducted at sites operated by other business units, including CES and Constellation Home, on a risk basis, with at least one CES site receiving an EHS compliance audit each year.

Annually, both Nuclear and Power business unit operations conduct targeted environmental program compliance assessments to mitigate potential compliance risks, and we also conduct a focused review of acquired, new operations and assets under construction, as appropriate.

Constellation consistently looks for improvement opportunities. Our facilities establish environmental key performance indicators (KPIs), and goals annually and then track these monthly. Progress on the KPIs is communicated to our leadership team via the annual Nuclear and Power business units' EMS management review meetings, where the effectiveness of our EMSs and other issues related to environmental performance are discussed, and quarterly to the Constellation Environmental Council. For additional information on our environmental performance and metrics, visit the Sustainability Data Table.

In addition, we assess potential suppliers against environmental criteria throughout the vetting process to understand their initiatives and goals. For more information on how we manage environmental impacts in our supply chain, please see our shared values and vision.

Employee Training

All plant employees and full-time contractors at Constellation generation sites receive annual plant access, site-specific environmental awareness and EMS training through our robust training programs. Short-term contractors receive site-specific vendor orientation training. Employees complete additional online and/or in-person training covering topics such as air, water, wastewater, waste, spill prevention, control and countermeasure and biodiversity protection.

Environmental training is reviewed and updated annually.

1.3.2 Air Quality

Nuclear fission emits no greenhouse gases (GHGs), criteria air pollutants such as nitrogen oxides (NOx), sulfur dioxide (SOx), particulate matter (PM), or other toxic air emissions such as mercury. However, we report emissions from nuclear facilities associated with non-generating activities, including the use of boilers, generators, refrigerants and purchased electricity.

For our non-nuclear assets, we report air emission data, including NOx and SOx emissions, in compliance with federal and state regulations. Our measured emissions intensity rates, on a per megawatt-hour (MWh) generated basis, for NOx and SOx emissions were well below the U.S. electric generation industry average.

For additional information on our air emissions data, visit the Other Significant Air Emissions section of Sustainability Data Table.

1.3.3 Water Stewardship

Constellation's commitment to responsible water stewardship is guided by our Water Resource Management Policy, through which we manage water-related impacts, risks and opportunities. We utilize the World Resources Institute Aqueduct tool to broaden our understanding of potential future water scarcity risks caused by climate change and economic growth and how our operations may be impacted or may contribute to those risks. Constellation's largest water-consuming sites are in low- or medium-risk regions, while our operations in high water-risk areas use negligible amounts of water and do not face water scarcity risks. Although we do not have significant water-consuming operations in high-risk areas, our facilities maintain drought contingency management plans documenting how facilities will manage water needs in the case of drought emergencies, where appropriate.

To responsibly manage our water use, many of our facilities implement consumptive water mitigation plans and we work to minimize water use across our footprint through efficiency, technology, best practices and operational improvements. We also act at the site-level to address local water-related challenges through engagement with government agencies, communities, agriculture and industry groups. Our solar, wind and simple-cycle combustion turbine power installations have negligible consumptive water use. Water flows through our hydroelectric facilities to generate clean energy and is returned to the river without adversely impacting water quality.

Our nuclear and combined-cycle natural gas generation facilities primarily use water for steam generation and as a cooling medium through the following processes:

• Closed-cycle cooling systems: At some nuclear and combined-cycle natural gas facilities, we use a closed-cycle cooling system which enables us to reduce our impacts on water resources by reusing water, minimizing freshwater intake and reducing wastewater discharge volumes.
  
  
• Dry condenser cooling technology: We use this technology to allow air to cool and condense steam at two of our largest combined-cycle natural gas generation facilities. This system requires little to no water use and saves approximately 80 percent of the water normally used by a conventional water-cooled condenser.
  
  
• Open-cycle cooling systems: Half of our fleet uses systems where water is withdrawn from nearby water bodies and used as a cooling medium. After the water is used, it is treated (as applicable) to restore it back to the water quality standard required by applicable regulations and station-specific water discharge permits and discharged to local water bodies such as rivers, lakes and seas, except for small amounts of water discharged to municipal sewers. Minor amounts of the water used in our open-cycle cooling systems are lost to evaporation.

1.3.4 Biodiversity Protection

Constellation's commitment to environmental stewardship, along with our ongoing actions to protect the species surrounding our operations, is guided by our Biodiversity Policy. This policy is informed and managed through ongoing engagement with stakeholders, expert and regulatory agencies, research collaborations and community and employee educational opportunities.

Across our power-generating footprint, we apply the mitigation hierarchy – avoid, minimize, restore or offset – to our operational impact on ecosystems. During the development of capital projects, we conduct a thorough environmental review to assess potential impacts on birds, bats and terrestrial and aquatic species and habitats. When construction or operations may impact certain species and ecosystems, we follow site-specific management plans and obtain any necessary incidental take permits, enabling Constellation to minimize impacts to species when possible or relocate affected species.

Constellation is also focused on improving aquatic ecosystems where we operate hydroelectric and nuclear power plants. Our stewardship activities include investing in habitat improvement projects, constructing oyster and freshwater mussel beds, creating artificial reefs, stabilizing river and stream banks, managing fish hatcheries and maintaining fish passages. To minimize biodiversity impacts at our Conowingo hydroelectric power plant, which is situated along the Susquehanna River, we monitor dissolved oxygen levels below the dam for the health and protection of the river's aquatic life. We also observe the minimum water flow requirements of our federal license to maintain healthy water levels in the river to support biodiversity.

1.3.5 Spent Fuel and Waste Management

Nuclear Spent Fuel

Senior management is responsible for the safe operation of our nuclear facilities, including the management of nuclear fuel, with ultimate oversight from the Nuclear Oversight Committee of the Board of Directors. Our nuclear spent fuel management practices are in full compliance with the stringent safety and security requirements from the U.S. Nuclear Regulatory Commission (NRC). For more information on Board oversight of our nuclear safety programs, please see the Board Governance section.

To minimize low-level radioactive waste generation and support the safe transport and disposal at approved off-site facilities, each of Constellation's nuclear stations implements robust programs and procedures in full compliance with NRC requirements. Depending on job responsibilities, employees may receive additional training to help protect their safety and the safety of the public, and all employees who manage radioactive waste must complete annual radiation protection training.

The radioactive waste training outlines required safety procedures employees must execute when managing radioactive waste.

At the end of their useful life, nuclear fuel assemblies are safely moved to spent fuel pools at nuclear facilities, where they cool under 20 feet of water over several years. Once cooled, the spent fuel is loaded into 16-foot stainless steel dry casks and stored inside 20 to 30-inch-thick reinforced concrete casks at the facility's independent spent fuel storage installations (ISFSIs)—safe, secure and well-proven technology. These casks are specifically designed and tested to withstand extreme events, such as earthquakes, projectiles and floods. We store spent nuclear fuel at all 14 of our nuclear stations, including the standalone ISFSI at our decommissioned Zion station, in strict compliance with the robust safety and security requirements of the NRC to limit radiation exposure for our workers and the public.

The U.S. Department of Energy (DOE) is responsible for the development of a permanent geologic repository for the disposal of spent nuclear fuel and high-level radioactive waste from existing nuclear plants in the U.S. Until the DOE proceeds with taking possession of and relocating spent fuel to a federal centralized repository, our spent fuel will be stored safely and securely at our onsite spent fuel pools and ISFSIs. We are collaborating with federal lawmakers to support the government's efforts to build a permanent, centralized repository or interim storage facility for spent nuclear fuel.

Constellation supports efforts to consolidate spent fuel storage to one or more interim sites that meet the NRC's rigorous safety and security standards. This would enable infrastructure management and security protection of spent nuclear fuel at fewer sites until the government develops a centralized repository. Constellation also supports efforts by the federal government and private sector to develop advanced fuel recycling technologies that maximize nuclear fuel's potential energy and reduce the overall volume and lifespan of disposed nuclear waste.

Learn more about our efforts to enhance nuclear plant and public safety.

Hazardous Waste

Our nuclear and non-nuclear operations safely manage nonradioactive hazardous waste in accordance with the Resource Conservation and Recovery Act, a federal law which governs the disposal of hazardous and solid waste in the U.S. At the site level, when hazardous waste is generated, it is labelled properly, stored in designated waste accumulation areas and transported off-site using approved vendors. Hazardous waste is tracked and managed by site environmental specialists. Any Constellation site that is classified as a large quantity generator of hazardous waste in any month submits biennial reports per federal regulations and completes state reporting as applicable. These robust hazardous waste management procedures enable us to maintain compliance with applicable regulations and protect the safety of our employees, communities and the environment.

Non-Hazardous Waste

Constellation implements program and facility-level waste management systems to actively manage our waste footprint and minimize our impact on local ecosystems and communities. We adhere to all applicable local and regional waste regulations. Our robust recycling programs target a large variety of conventional materials like paper, plastic and metals, as well as non-conventional materials such as construction and demolition debris. We also streamline our waste and recycling pickup frequencies to reduce emissions from waste hauling vehicles. Additionally, we capitalize on opportunities to reuse, recycle or recover major asset components to divert these materials from landfills.

We engage with policymakers on critical components of the energy transition, including comprehensive workforce development and retraining programs, community investment and strategies to support communities impacted by retirements of fossil fuel generation plants. Additionally, we support policies that increase the transparency and reliability of climate-related disclosures and risks.

• Constellation keeps our guiding principles top of mind when we engage in public policy.
  
  
• We advocate for resource adequacy—the ability for the grid supply to always meet power demand.
  
  
• We prioritize reliability and affordability as energy demand increases.
  
  
• We advocate for policies that will protect and grow clean, lower-emissions energy and mitigate climate impacts.

These principles remain constant as the future of energy evolves. Learn more about public policy.

We provide our employees with opportunities to advocate for the policies we support. Our employee advocacy group, Constellation Nation, empowers employees with tools and opportunities to advocate for policies that support the preservation and expansion of our nuclear fleet.

Constellation's employee Political Action Committee helps amplify our voice as a catalyst for change through political engagement.

1.4.1 Hourly Accounting of Clean Energy Generation

We support the development of technology to track generation and report GHG emissions more accurately through our advocacy work with policymakers, participation in industry trade groups and involvement with other non-governmental organizations. By enabling an evolution towards hourly accounting, companies can track and match carbon-free energy supply with demand each hour and more accurately report their electricity-related GHG emissions. This enables them to fully achieve zero-emissions goals and promotes investment in reliable grid decarbonization by addressing the hardest-to-decarbonize 

Constellation can connect you with customized solutions throughout your journey to provide data and reporting to help you reduce emissions and meet sustainability goals. 

Explore Constellation's sustainability solutions:
 

• Hourly Carbon-Free Energy Matching
  
  
• Constellation Offsite Renewables (CORe)
  
  
• Constellation Navigator
  
  
• Energy Attribute Certificates (EACs) - Managing Carbon
  
  
• Constellation Sustainable Gas and Carbon Offsets - Renewable Natural Gas and Carbon Offsets
  
  
• Constellation Energy Solutions (CES)
  
  
• Efficiency Made Easy (EME)
  
  
• Electric Vehicle (EV) Charging Solutions

Constellation communicates with stakeholders to shape our community engagement approach, build trust, gain insight into community needs and cultivate mutually beneficial alliances. We also have a proven history of supporting the communities in which we operate through philanthropic and volunteering initiatives. We measure and monitor our community impact and key workforce development metrics.

2.1.1 Community Outreach

We use a variety of outreach channels including active participation and information booths at community events, our philanthropic program, news media outreach and social media to directly engage with key groups including public officials, community leaders and local residents.

Information about our energy generation sites is publicly accessible through our website and we provide crucial updates about our company and our sites through social media.

Listening to community concerns at the site level is vital. Our local government affairs, community relations, workforce development and site leadership team members are accessible to personally hear feedback brought by elected officials and community members. Federal public policy engagement is also crucial, and we are committed to advancing policy positions that equitably improve health and well-being. Further, we seek opportunities to collaborate with and donate funds to organizations serving communities and invest in incubators and accelerators with a focus on startups with unique areas of focus that play a crucial role in energy innovation.

To sustain community support and raise awareness about our operations and their benefits to local communities, we conduct outreach initiatives at each site. Our nuclear sites host “State of the Plant” events annually, inviting key officials and community leaders to receive updates on plant performance, current and upcoming projects, potential challenges and opportunities for community involvement. Additionally, several facilities host Community Information Nights, offering the public a chance to meet plant representatives and learn about nuclear energy generation. Our sites also engage with local communities through site tours for local leaders, school groups and media, collaborating with regulators and supporting regional nonprofits. We also participate in civic events and school programs to share information about our safe, reliable and clean energy practices and address any inquiries or feedback from the public.

Additionally, our Ethics Help Line is publicly available 24/7 for external stakeholders to report any community issues.

2.1.2 Philanthropy and Volunteerism

Through our robust philanthropy and volunteering initiatives, we actively engage with communities to address challenges across the three pillars of our citizenship and philanthropy program:

• Climate and Environment: providing support for environmental conservation and stewardship.
  
  
• Education and Workforce Development: investing in education, STEM and workforce development.
  
  
• Employee Philanthropy and Volunteerism: demonstrating leadership and passion for causes that matter most to our employees.

Initiatives like our Dollars for Doers program incentivize volunteerism by providing financial support of up to $1,000 for every 100 hours volunteered by an employee, and our Impact Leaders program rewards employee volunteer leadership with an additional $1,000 grant, both benefitting the eligible charities of their choice. Additionally, our Employee Charitable Match program offers up to $10,000 in annual matching for every employee to eligible charities of their choice.

Workforce Development for the Energy Transition

As a leader in the transition to a clean energy economy, Constellation is in a unique position to enable the just transition for workers, ensuring no one is left behind as we shift away from polluting energy sources. We collaborate with industry and community organizations to attract and provide training opportunities for these workers to assist them in exploring meaningful career opportunities in the new clean energy economy.

For more information about our Community Philanthropy programs, please visit Powering Communities.

2.2.1 Talent Development

Strategic Talent Sourcing

For more information, visit the Careers section.

Learning and Development

Constellation uses a multi-faceted approach to leadership and professional development that includes formal assessments, feedback, coaching, mentoring, training, leadership development and other developmental experiences. These opportunities increase employee engagement, improve retention and enhance our value proposition. Programs offered include:

• Leadership Development: Our New People Leader Orientation helps to develop our leaders and strengthen their capabilities. We also offer development programs such as THRIVE, RISE and Emerging Leaders, which are aimed at supporting professional and leadership development for individuals preparing to take on broader scope and responsibilities.
  
  
• New Hire Orientation: During onboarding, all new employees are invited to participate in our New Hire Orientation to learn about Constellation and our values.
  
  
• On-Demand Trainings: Existing employees can access self-directed, interactive learning opportunities through platforms, including Talent and Development Webinars and LinkedIn Learning, to sharpen their skills.
  
  
• New Leader Training: We provide on-boarding tools and leadership training to first-line supervisors, mid-level managers, plant managers and directors on track to become plant managers. This training aims to strengthen leadership skills, support professional development and improve succession readiness. We also offer leadership job familiarization guides to new in-role nuclear leaders, which contain required training, activities and learning materials. Together, these resources support the development and proficiency of our leaders, equipping them with the necessary skills to excel in their roles, lead their teams effectively and contribute to the overall success of our business.
  
  
• Tuition Reimbursement: Certain employees are eligible to receive annual tuition reimbursement for pursuing undergraduate or graduate degrees or professional certificates.

Performance Management and Succession Planning

Management and other non-craft employees participate in the year-end review process to gauge the effectiveness of employee performance against expectations. Through this process, we evaluate what employees have achieved against their performance goals, as well as whether these goals have been achieved through behaviors consistent with Constellation's values and core competencies. The year-end review process includes a focus on forward-looking development to drive employees' learning and growth to achieve their career objectives. Managers have meaningful, quality conversations with their direct reports to enable high performance in their current roles and help prepare them for future roles. To enhance the quality of feedback and coaching received, employees can access a variety of resources through our online talent and people development portal.

To enable our employees' career progression, we encourage internal mobility through our internal job posting site. We also talent map all employees at the "manager" level, including individual contributors and people leaders, through vice presidents, conduct succession planning for executive-level roles and review our talent pipeline annually to enable our long-term business success and continuity. To support and accelerate the integration of new leaders, we implement third-party leadership assessments to identify and address developmental opportunities.

2.2.2 Employee Engagement

Formal and informal employee feedback mechanisms inform our human capital management strategy. We promote an open feedback culture and listen to our employees' perspectives through our biennial employee engagement survey, town halls, all-hands meetings, manager check-in meetings, focus groups and special Candid Conversation sessions with C-suite leaders.

Executive Committee members and teams are responsible for developing action plans based on the results of the survey to improve the employee experience. These plans integrate both centralized actions for company-wide issues and leader-led actions for areas unique to specific teams or business areas. We also conduct periodic pulse surveys in between our full engagement surveys to measure engagement and track progress against our action plans.

Additionally, Executive Committee members encourage employees to participate in the survey through recorded videos sharing how their feedback has inspired action over the prior year.

Externally, we gather feedback through public websites such as Glassdoor and Indeed.com, where current, previous and future employees can provide anonymous reviews related to employee experience. We engage with these external feedback mechanisms to benchmark and align our performance related to the experiences we aim to create, and we share themes and updates with leadership quarterly.

We respect and support the right of employees within our workforce and value chain to seek union representation. Approximately 25 percent of our workforce is covered under collective bargaining agreements (CBAs).

2.2.3 We Welcome Every Voice

Core Values

We empower our people because they are the heart of everything we do. We listen openly, act with respect and champion bold ideas. We know diverse perspectives produce innovation and smarter decisions. We recognize that respect for the diverse backgrounds and perspectives of our employees, non-discriminatory processes, and equal access to opportunities supports a culture of belonging and inclusion. We seek input from our nine Employee Resource Groups (ERGs), which are open to all employees, on our efforts to provide an inclusive workspace that values individual merit, where all employees can grow to their full potential. Additionally, we host Communities of Practice, uniting employees from across Constellation to share best practices, define strategies to enhance ongoing initiatives and continue the learning journey together. Our Culture Ambassadors collaborate with leadership to support us throughout Constellation's Commercial organization.

We also offer voluntary educational resources such as our Journey to Belonging educational series and Disability Fundamentals for Hiring Managers and we cover inclusion topics in our quarterly Webinar Series.

We continuously seek new opportunities to help our employees on their career journey. Our newest development initiative, Reach Across Boundaries to Influence, Support and Empower (RISE), highlights that commitment. The program brings together high potential mid-level leaders from across the business to foster growth, spark collaboration and provide a platform to refine leadership skills.

For more information, visit the People, Culture & Workforce section.

Anti-discrimination and Fair Labor Practices

We provide training, perform pay equity analyses and review hiring and promotion processes to ensure non-discrimination and equal opportunities. These actions help to create an environment where all employees can thrive, and advance based on individual merit and as equal members of the workforce.

We provide equal opportunity and do not tolerate any form of discrimination or harassment based on race, color, religion, sex, national origin, disability, age or any other protected characteristics under federal, state or local laws, as stated in Constellation's Policy Against Discrimination, Harassment and Retaliation and reinforced in our Code of Business Conduct, Equal Employment Opportunities Policy and Workplace Accommodations Policy. We also prohibit any form of sexual harassment, as stated in our Policy Against Sexual Harassment, and we provide mandatory training on sexual harassment prevention on an annual basis to foster an environment where all team members are valued, engaged and empowered to deliver their best work in an atmosphere built on respect for human dignity and inclusivity.

Constellation also follows applicable minimum wage, overtime wage, child and forced labor and other wage and hour laws and regulations.

For more information, visit the Ethics & Compliance section.

2.2.4 Employee Benefits and Wellbeing

Our comprehensive benefits package is designed with an overall focus on wellbeing including mental and physical support, retirement, financial and legal support and family care. Company benefits offered to eligible employees include, but are not limited to:

• Mental wellbeing benefits to support a balanced lifestyle, including paid time off for vacation, holidays, sick days and primary caregiver leave for a family member with a critical health condition.
  
  
• Physical health benefits, including medical, dental, vision, prescription drug coverage, fitness reimbursements and gym membership discounts.
  
  
• Retirement, financial and legal benefits to support financial wellbeing, including a 401(k) with company match and an employee stock purchase program.
  
  
• Family care benefits to support the ones you love, including parental leave for up to 16 weeks for birthing mothers and up to eight weeks for non-birthing and adoptive parents, a back-up dependent care for children and adults, and a dependent care flexible spending account.

View the full list of company benefits.

We believe there are many benefits to providing flexible work arrangements and our Alternate Work Arrangements Policy gives employees whose jobs allow for remote work the opportunity to find a flexible working solution that works best for them. The policy outlines the various alternate work arrangements, expectations of employees in these arrangements and requirements for managers and leaders.

Employee Training

Nuclear plant employees must complete training, education and qualification curriculum and the training programs for operations, maintenance and technical employees are accredited by the National Nuclear Accrediting Board and taught by INPO-certified instructors. These trainings are comprehensive, lasting nine months for the initial training program to up to two years for NRC-licensed nuclear control room operators. Employees also regularly complete supplemental training to stay abreast of current technological expertise, sector-specific knowledge and performance-enhancing trends.

For more information about workplace safety, employee engagement in our safety culture, and nuclear plant safety, visit the Safety section.

Emergency Preparedness and Response

Site Closure and Decommissioning

Due to the complexity of upholding safety and environmental quality while decommissioning a nuclear facility, Constellation begins the planning process before sites are even issued operating licenses. For the 21 nuclear generating reactors we currently operate, the NRC requires us to document any radiologically affected areas and maintain and demonstrate evidence of sufficient funding for radiological decommissioning. Constellation has already retired several nuclear units, for which we submitted decommissioning plans and cost estimates to the NRC. We also maintain community engagement activities throughout site decommissioning.

For more information, visit the Nuclear Emergency Preparedness Information section.

Our Corporate Sustainability team is responsible for Constellation's strategic approach to sustainability, including but not limited to setting and managing the company's climate targets, maintaining governance over sustainability initiatives and communications and managing the company's sustainability-related reporting and disclosures. This team is overseen by the Chief External Affairs and Growth Officer, who reports directly to the CEO, and is led by our Vice President of Sustainability. In addition, the Vice President of Sustainability presents sustainability updates to the Corporate Governance Committee at least annually.

Constellation's executive leadership from all areas of our business are also involved in reviewing sustainability policies, programs and initiatives through our Sustainability Council and Environmental Council. The Constellation Sustainability Council, led by the Vice President of Sustainability, is comprised of executive representatives from key functions within Constellation. The Council meets four times per year to review sustainability policies and initiatives, achieve strategic alignment, discuss emerging sustainability trends and make informed suggestions to senior leadership.

The Environmental Council, comprised of senior leaders from our generation and commercial businesses, meets quarterly to review environmental compliance, policies and initiatives and stay aligned across our fleet and business.

For more information regarding board governance, committees, and stakeholder engagement, view the Board Governance section.

3.1.1 Memberships

We also maintain memberships with and actively participate in trade associations and other organizations to further our sustainability efforts, advance the adoption of clean energy technology and expand innovative research.

Constellation is a member of the United Nations Global Compact (UNGC) on 24/7 Carbon-free Energy. We participate in the CEO Climate Dialogue, which comprises corporations and NGOs that support a meaningful market-based approach to GHG emission reductions across the economy. Constellation also collaborates with leading clean energy research institutions across the U.S., including MIT Energy Initiative, Argonne National Laboratory, the Electrical Power Research Institute (EPRI) and GTI Energy Low Carbon Resource Initiative (LCRI), in addition to funding agencies, including the DOE. Furthermore, Constellation is an organizational member of the Climate Leadership Council, alongside other organizations playing a pivotal role in identifying climate solutions and decarbonizing the economy.

We maintain memberships with and actively participate in trade associations and other organizations to further our sustainability efforts. Our current association memberships include the Nuclear Energy Institute (NEI), The Clean Energy Group, Center for Climate and Energy Solutions (C2ES), Energy Strategy Coalition and the Clean Energy Buyers Association (CEBA). As strong supporters of actions that address the climate crisis, membership in these organizations allows us to advocate and influence industry positions on clean energy and climate policies, as well as share safety best practices. We also actively participate in an advisory capacity for other clean energy-focused organizations such as Energy Tag, Center for Resource Solutions, Clean Air Task Force and The Regulatory Assistance Project, among others.

Involvement in industry-specific organizations like CEBA, EPRI, NEI, The Retail Energy Supply Association (RESA), The Energy Professionals Association (TEPA), and many others also provide unique opportunities to gain a more strategic perspective while building technical expertise.

For more information, visit the Risk Management section.

3.3.1 Ethics and Compliance

For more information, visit the Ethics and Compliance section.

3.3.2 Code of Business Conduct

Constellation's Code of Business Conduct (Code) details our expectations for our core values and legal and ethical obligations. Our Code contains guidelines for topics including conflicts of interest, respectful workplace conduct, safety, protecting company assets and confidential information, fighting bribery and corruption, government interactions and competing with integrity. In 2024, we updated our Code to include expectations around additional topics including human rights, anti-money laundering and trade laws.

Employee Training

All employees, directors, officers, subsidiaries and relevant third parties are expected to uphold the standards of the Code. To ensure that employees understand these expectations, they must complete annual training on the Code, which includes anti-corruption topics. Annual training is supplemented by ad-hoc, targeted training as needed, and new people leaders receive specific ethics training to reinforce ethical principles. Employees (other than unionized employees) and Board members complete an annual certification questionnaire to disclose conflicts of interest and affirm their understanding of the Code.

To help ensure compliance with the Code, our Human Resources team participates in meetings to monitor and discuss ethics cases and determine necessary actions.

The Code is also reinforced by supplementary policies, such as our management model policies focusing on anti-corruption, information governance and prevention of discrimination, harassment and retaliation on which employees receive additional training. Additional anti-corruption training is provided for relevant roles.

Our commitment to responsible business practices extends beyond our direct operations and we aim to work with suppliers who align with our values. For more information about our ethical expectations we have for our Supply organization-managed suppliers, visit the Supply Chain section.

3.3.3 Voicing Concerns

We maintain several communication channels for stakeholders, such as employees and local community members, to report concerns or ask questions. This includes our Ethics Office email and a 24-hour Ethics Help Line, which has an anonymous reporting option available via phone and web portal. Additionally, the Nuclear Employee Concerns Program provides a dedicated avenue for nuclear plant workers to raise and address nuclear safety concerns. We maintain a strict policy against retaliation towards any stakeholder who reports in good faith a concern of potential unethical behavior or violations of the Code. The Code is appropriately enforced, regardless of seniority, role or location of those involved in misconduct. Disciplinary actions may include reprimand, suspension, demotion, reduction of performance ratings and incentive awards or termination.

Our cybersecurity risk management strategy is established at the executive level and is implemented through our cybersecurity program, which deploys risk-based security controls and services to protect our customers, personnel, information and cyber assets. The program aligns enterprise cyber and physical security controls with the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) and other industry standards such as the North American Electric Reliability Corporation Critical Infrastructure Protection standards and NRC Cybersecurity Rule (10 CFR 73.54).

3.4.1 Cybersecurity Oversight and Management

We follow processes for assessing, identifying and managing material risks from cybersecurity threats to the company, including governance at the Board-level and executive management accountability for executing our cyber risk management strategy and the controls designed to protect our operations. Our Board is actively engaged in monitoring the performance of Constellation’s cybersecurity program and maintains oversight of the Company’s enterprise risk program, including with respect to commodity markets, market design, enterprise security (physical and cyber), operating risks, and financial performance. While the full Board retains ultimate responsibility and oversight of the Company’s cybersecurity risk management practices, the Nuclear Oversight Committee and the Audit and Risk Committee also have cybersecurity risk management as part of their charters. The Nuclear Oversight Committee is tasked with overseeing compliance with policies and procedures to manage and mitigate cybersecurity risks associated with our nuclear assets. The Audit and Risk Committee oversees policies and processes established by management to identify, assess, monitor, manage and control Constellation’s material strategic, financial, operational, regulatory, business unit, reputational and other risks, including technology and cyber risks.

Our cybersecurity strategy is enhanced by regular review of business continuity plans conducted every two years and annual cyber drills. To continuously improve our efforts, we conduct internal assessments of our security controls program. Additionally, we are subject to external assessment of the cybersecurity program every two years.

For more information on Board oversight of our cybersecurity programs, view the Board Governance section. For more information on our cybersecurity approach, please see Item 1C. Cybersecurity in our 2024 Form 10-K.

Employee Training

Beyond our strong technical safeguards, we place a high priority on employee awareness and mandate cybersecurity training for all new and existing employees and contractors with access to our network. Cybersecurity training is conducted annually for current employees.

Supply chain risks, such as supplier disruptions or market fluctuations, emphasize the vital need for effective risk management strategies to help ensure the continuity of our operations and strengthen organizational resilience.

Additionally, we are focused on embedding resiliency, reliability, transparency and equal opportunities into our supply chain and optimizing our operational efficiency. Our business sustainability is impacted by our direct operations and by the actions and initiatives of the businesses with which we work. We aim to meaningfully engage with contractors, consultants, suppliers and vendors (collectively, our suppliers) that help drive our mission and support our commitment to the highest standards of safety, quality, reliability, technical excellence and economic inclusion.

For more information, visit the Suppliers section.

3.5.1 Supply Chain Evaluation

We use internal metrics to assess the performance of our supply chain function, such as parts quality, safety performance and strategic sourcing savings. During the vetting process for suppliers managed by our Supply organization, we assess suppliers against sustainability criteria to understand their initiatives and goals. We expect covered suppliers to adhere to our or similar standards around fair labor and safeguarding of human rights within all work environments. We also monitor supplier performance and adherence to contractual agreements. Our contracts with suppliers include provisions that prohibit the use of forced and child labor.

Our Supplier Code of Conduct details clear expectations for suppliers to prohibit the use of child labor, forced labor, or involuntary labor whether bonded, imprisoned, or indentured, including debt servitude, as well as prohibit engaging in human trafficking and other human rights violations. We also report on compliance with against the Fighting Against Forced Labour and Child Labour in Supply Chains Act of Canada as well as the UK Modern Slavery Act of 2026. In addition, our Code of Business Conduct includes expectations for employees, suppliers and others with which we do business to support, respect, and promote human rights, including the prohibition of human trafficking, forced labor (including prison labor), and child labor.

Suppliers that fail to meet compliance standards, including those involved in environmental incidents that breach our contracts, may be placed on a Watch List or a Supplier Performance Improvement Plan (SPIP), which outlines areas for improvement to achieve compliance. In cases where Constellation is made aware of supplier-related human rights violations, we may place suppliers on a SPIP or terminate our contracts. Instances of severe non-compliance, such as ethical breaches or safety concerns, can also lead to disqualification from future engagements with Constellation.

Sustainability Criteria Used in Supplier Screening

Suppliers that participate in a request for proposal (RFP) with a scope of work that is over $1,000,000 in total spend undergo Constellation’s strategic sourcing process. This process includes an evaluation of multiple factors, such as safety, technical expertise and cost.

Constellation uses a standardized environmental questionnaire for prospective suppliers invited to participate in applicable RFPs. The questionnaire requests information such as a supplier’s environmental compliance track record over the last five years, GHG emissions tracking and certifications from third party environmental agencies. Scopes of work that fall under categories including, but not limited to, chemicals, gases, fuel, radioactive waste and heavy hauling are subject to reply to this questionnaire.

3.5.2 Support for Small and Local Businesses

At Constellation, we aspire to be recognized as an industry leader by driving value through innovation, competition, agility, cost effective solutions and supply chain stability.

We recognize that a broad and inclusive supply chain provides a strategic competitive advantage through increased innovation, access to new markets and improved resiliency and sustainability. Our mission is to foster a purchasing environment that provides equal opportunities to suppliers, including small and local businesses, and promotes economic inclusion. Such inclusion is woven into the core fabric of our organization, championed by our leadership, embraced across all business units and supported by our supplier base and communities.

We seek suppliers who share our value of delivering outstanding service to our customers. We ask our suppliers to support our goals, including adopting and maintaining non-discriminatory policies and practices. We view our work with certified small and local businesses as a valued component of our resilient supply chain and efforts to uplift and strengthen our communities.

3.5.3 Nuclear Fuel Supply Chain

We place significant emphasis on addressing nuclear fuel supply chain risks that could affect our operational efficiency and success. Our nuclear fuel group takes a diversified approach to uranium extraction, conversion, enrichment and fabrication to mitigate risks associated with the nuclear fuel supply chain. Our strategy engages international and domestic suppliers to build a diverse and resilient portfolio that can withstand volatilities and also implements a multi-year horizon to safeguard against potential disruptions and fluctuations in the nuclear fuel market.