CONTENTS
MESSAGE FROM THE CEO 5
MISSION AND CORE VALUES 7
WHY WE HAVE A CODE 9
� Who Must Follow the Code ? 9
� What Are Our Responsibilities ? 9
� What Are the Consequences for Violating the Code ? 9
GUIDANCE FOR RESOLVING AND REPORTING CONCERNS 11
� Quick Ethics Check 11
� Seeking Advice or Reporting Concerns and Violations 11
� Non-Retaliation Commitment 13
� Investigations and Corrective Actions 13
� We Respect Human Rights 15
OUR WORK ENVIRONMENT 17
� Equal Opportunity and Inclusion 17
� Harassment / Violence 17
� Health , Safety , and the Environment 19
� Alcohol and Substance Abuse 19
� Employee Privacy 19
COMPLIANCE WITH ALL LAWS 21
� Antitrust 21
� Trading on Insider Information 21
� Public Disclosures 22
� Political Contributions and Conduct and Government Affairs 22
COMPLIANCE WITH ALL LAWS
� PAC 23
� Anti-Corruption 23
� Gifts to Government and Regulatory Officials and Employees 24
� Lobbying Requirements 24
� Fraudulent Conduct 25
� FERC Standards of Conduct 25
CONFLICTS OF INTEREST 27
� Corporate Opportunities 27
� Outside Employment 27
� Outside Speeches or Presentations 29
� Financial / Personal Interests 29
� Gifts and Entertainment 29
PROTECTING COMPANY ASSETS 33
� Use of Company Assets 33
� Cybersecurity 33
� Records and Information Management 33
� Maintaining Accurate Records 34
� Confidential Information 34
� Intellectual Property 34
WILLIAMS ETHICS & COMPLIANCE PROGRAM 37
� Program Description 37
� Organizational Structure 37
� Contact Information 37
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