PROTECTING COMPANY ASSETS
My group is receiving new personal computers and printers . The local elementary school in my neighborhood could really use the old equipment . May I donate it to the school on Williams ’ behalf ?
Though Williams equipment may be obsolete , there are other factors that must be considered before Williams chooses to discard or donate it , such as accounting practices and corporate contribution policies . Therefore , check with Williams management before making a donation of company property .
Maintaining Accurate Records
The proper management and recording of company funds , assets , liabilities , and business transactions is critical for supporting Williams ’ day-to-day operations and meeting our legal and regulatory requirements . It allows Williams to maximize the benefits of all its available resources . Thus , we must maintain books and records , through adequate internal controls and procedures , which reflect actual transactions and conform to generally accepted accounting principles .
Confidential Information
Much of the information developed or held by Williams is confidential and must be protected and only shared with Williams ’ approved parties who have a legitimate “ need to know ” including other Williams employees . Furthermore , a subset of this confidential information is “ sensitive ,” the unauthorized disclosure of which could result in regulatory or legal penalties or expose high-value business or security information . This information plays a key role in our business strategy . We are responsible for safeguarding such information in order to maintain our competitive advantage in the marketplace and comply with legal obligations . Our obligation to safeguard the confidentiality of such information continues even after we leave employment at Williams .
Protecting confidential information doesn ’ t limit an individual contributor ’ s ability to discuss the terms and conditions of our employment , including compensation . In addition , we are not prohibited from reporting possible violations of federal or state law or regulation to any governmental agency or entity , including but not limited to the Department of Justice , the Securities and Exchange Commission , the Congress , and any agency Inspector General , or making other disclosures that are protected under the whistleblower provisions of federal or state law or regulation . We don ’ t need the prior authorization of the Williams Legal Department to make any such reports or disclosures and we are not required to notify Williams that we have made such reports or disclosures .
Documents and other materials that contain confidential data , such as notebooks , e-mail , memos , etc ., should always be securely stored in Williams ’ approved locations or repositories , and depending on the nature of the materials , may only be shared to others on a “ need-to know basis ” ( See “ Acceptable Use Policy ”, “ Cybersecurity Policy ,” and “ Data Classification and Handling Policy ”).
Intellectual Property
Our ideas , concepts and other information we produce are important assets to Williams . This “ intellectual property ” includes patents , trademarks , copyrights , and trade secrets , and is central in developing new products and attracting new business opportunities . We are responsible for identifying and protecting Williams ’ intellectual property at all times ,
34 WILLIAMS CODE OF BUSINESS CONDUCT