Williams Code of Business Conduct - External | Page 37

WILLIAMS ’ ETHICS AND COMPLIANCE PROGRAM

Program Description
This Code is just one component of Williams ’ overall Ethics & Compliance Program , which was established to ( a ) effectively communicate Williams ’ business conduct expectations to all employees and ( b ) provide the necessary means to help prevent , detect , and report violations of law and company policy . Other major components of this program include our Core Values , our policies / procedures / practices , and annual compliance training .
In addition , high-level personnel have been assigned responsibility for ensuring the effectiveness of the Ethics & Compliance Program .
The following chart shows the organizational structure of the Ethics & Compliance Program .
AUDIT COMMITTEE
WILLIAMS BOARD OF DIRECTORS
CHIEF ETHICS & COMPLIANCE OFFICER ( CECO )
GOVERNANCE & SUSTAINABILITY COMMITTEE
Responsible for adopting , implementing , and maintaining the Ethics & Compliance Program for Williams .
FERC COMPLIANCE OFFICER ( FCO )
ETHICS ADVISORY PANEL
Made up of high-level representatives from across the enterprise . Meets regularly to oversee the effectiveness of the Ethics & Compliance Program .
MANAGER , ETHICS & REGULATORY COMPLIANCE BUSINESS ETHICS RESOURCE CENTER ( BERC )
CONTACT INFORMATION
If you need to contact anyone within the Ethics & Compliance Program organization , or have any questions regarding Williams ’ Ethics & Compliance Program , please contact the Business Ethics Resource Center as follows :
Business Ethics Resource Center : 918-573-3284 businessethicsresourcecenter @ williams . com
Cathlene Wiedenhoeft Manager , Ethics & Regulatory Compliance 918-573-4180 cathlene . wiedenhoeft @ williams . com
Stop By 47th floor of the Williams Tower in Tulsa
Regular Mail Williams One Williams Center Tulsa , OK 74172 Attn : Business Ethics Resource Center , MD 47
Williams Action Line 800-324-3606 . Available 24 hours a day / seven days a week and you can remain anonymous .
Visit www . williams . ethicspoint . com to make an online report .
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