COMPLIANCE WITH ALL LAWS
Our Core Values are engrained in how we do our work , every day , on behalf of our communities , customers , employees , and investors . We stand behind our reputation as a dependable and trustworthy business that delivers on our promises . This drives our commitment to be a good corporate citizen and to comply with all applicable laws and regulations , not only for those who work here , but for all who interact with us .
We must understand the laws affecting our business activities and be responsible for compliance . Complying with both the spirit and letter of the law best serves Williams and its stakeholders ’ interests .
The following is a brief listing of some of the major laws that can impact our business . Because legal issues can be very complex , we are encouraged to seek guidance from our management and legal counsel if in doubt .
Antitrust
Williams believes that fair competition and free enterprise serve the best interest of Williams and its stakeholders . Antitrust laws were enacted to help preserve the free enterprise system by promoting competition . These laws prohibit business practices that result in unreasonable restraints of trade or discriminatory trade practices ( See “ Antitrust Compliance Manual ”). The following are examples of practices that may be illegal :
My business development trade association is meeting next month , and I am curious about Williams ’ chances of receiving a contract award . I want to discuss this with other bidders who will be there . If we meet after hours at dinner , is that all right ?
No . You should not discuss bids , terms of contracts , or similar proprietary business information with employees of competing firms at any time . This might give others an unfair advantage , and it might create an antitrust problem . Don ’ t initiate such conversations or respond to any outside inquiries .
� Creation of a monopoly or attempts to create a monopoly
� Agreements among competitors to fix prices , divide markets , allocate customers , or limit the quality or production of products
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Price discrimination and other predatory trade practices
Trading on Insider Information
Williams recognizes the importance of strong and healthy securities markets . To ensure such markets , and to prevent the misappropriation of a company ’ s confidential information , the law forbids us from purchasing or selling securities if we have material information which has not been made public ( referred to as “ material , non-public information ”). Material information is information that a reasonable investor would consider important in making a decision to buy , sell , gift , or otherwise transfer , hold , or vote securities , given the total mix of available information in the marketplace . Material information includes , but is not limited to , company earnings , acquisitions or divestitures , new products or services , changes in strategy , etc .
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