Outside Speeches or Presentations
We are often asked to serve on panels , speak at conferences , or make presentations because we are Williams employees or because of our expertise arising from our job responsibilities . A conflict can occur if we are offered payment or reimbursement of our expenses in connection with this type of invitation . Honorariums from our suppliers , customers , and other business partners should not be accepted .
Ask yourself :
� Are we giving the speech or presentation as a part of our job at Williams ?
� Does the speech or presentation describe our work at Williams ?
� Are we introduced as an employee of Williams ?
If the speech or presentation involves matters related to Williams , you should discuss this with your Manager , Legal , Corporate Communications , or the Business Ethics Resource Center regarding the content .
Financial / Personal Interests
We are all encouraged to pursue a secure financial future for ourselves . At the same time , we want to always take care that our financial / personal involvements do not have a negative impact on our ability to make sound and objective business decisions .
Williams understands that business gifts and entertainment can help build strong relationships with our business partners . However , the offering or acceptance by ourselves , a close relative , or associate of gifts and entertainment designed to influence the recipient ’ s judgment is not tolerated at Williams .
Regarding ourselves or a close relative or associate , a direct or indirect financial interest in any enterprise which does business with , or is a competitor of , Williams could represent a potential conflict of interest that should be fully reported to our immediate supervisor .
The following situation requires written disclosure / management approval :
�
Related party interest — defined as a business deal or arrangement that involves a Williams employee / contractor and an outside party who are joined by a special relationship ( e . g . relative , business associate , financial interest ) prior to the arrangement .
In addition , Williams prohibits compensation , either directly or indirectly by an external party , to employees who represent the Company on the advisory boards of key vendors or industry groups .
Gifts and Entertainment
Williams understands that business gifts and entertainment can help build strong relationships with our business partners . However , the offering or acceptance by
29