Williams Code of Business Conduct - External | Page 28

CONFLICTS OF INTEREST
A vendor I regularly work with wants to take my wife and me to dinner while he is in town . Is it ok if we go , and do I need to disclose the value of the dinner to Williams ?
When you think about gifts and whether it is ok to accept them , think about the “ intent .” If the vendor ’ s intent is to influence your decision on whether or not to sign that pending contract , it is not ok to accept a gift . If the vendor is giving the meal or other gift to enhance the business relationship and the gift is of a reasonable value ( not lavish ), it is probably ok to accept it . Use good judgment , and when in doubt , contact the Business Ethics Resource Center for advice .
What are the guidelines if I have a relative who works for one of Williams ’ competitors ?
There is nothing wrong with relatives working for competitors or suppliers . However , you should be doubly aware of any potential conflict of interest ( for example , there should be no discussion or exchange of sensitive information ). Depending on the circumstances , you may need to fill out a related party disclosure form . If you sense the possibility of a potential conflict , disclose the situation to your supervisor .
28 WILLIAMS CODE OF BUSINESS CONDUCT