Political Contributions and Lobbying
Public policy decisions can affect Williams' businesses and it is in the best interest of the company, its employees and stakeholders to be engaged in the political process at the federal, state and local level.
Williams participates in the political process through contributions from the Williams Political Action Committee (WILLCO PAC) and through company contributions where legal and appropriate under state law. Williams has guidelines governing contributions which include prior written approval by the company's executive officer team. All political spending will reflect the company's interests and not those of individual officers or directors. No contribution will be made in anticipation of, in recognition of, or in return for an official act by the recipient of the contribution.
The use of company funds or assets for political purposes must be approved through the government affairs department which, among other things, will obtain legal department confirmation that the proposed use is permissible under federal, state or other applicable law.
As part of its oversight role in public policy, the Nominating and Governance Committee of the Board of Directors reviews, at least annually, the company's political contributions including spending related to trade associations and other tax exempt organizations. The Board also reviews spending guidelines. Corporate officers are available for any questions pertaining to policy or procedures, purpose and spending.
Federal law prohibits companies from contributing to candidates for federal office, but many states allow corporate contributions to state and local candidates, committees, and political organizations and, where allowed, Williams may make such contributions. As described in the company's code of conduct, any contribution of company funds or the use of other assets for political purposes must be approved in advance by the company's executive officer team. Political contributions made with company funds outside the United States must be approved by the company's executive officer team and the legal department. Download the chart listing all political corporate contributions.
Williams and WILLCO PAC make bipartisan contributions to political candidates and initiatives that support the advancement of the company's interests and the interests of the industry in which Williams operates. In determining which candidates and initiatives to support, Williams and WILLCO PAC balance the views promoted by a candidate or ballot initiative, the qualifications and effectiveness of the candidate or organization to which the contribution is made and the appropriateness of the company's level of involvement in the election or ballot initiative. With respect to particular candidates, among other factors, the company considers the candidate's:
- Understanding of our industry and support for our positions on issues concerning our businesses;
- Position on key committees that consider legislation critical to our business interests;
- Leadership position or potential for leadership;
- Representation of districts or states where Williams employees or facilities are located; and
- Viability as a successful candidate.
Williams belongs to a number of trade associations at the national, state and local levels. Williams will disclose all expenditures of corporate funds to these associations used for non-deductible lobbying and/or political expenditures under Internal Revenue Code Section 162(e). A chart of these expenditures is below.
Political Action Committee
Williams has a political action committee, WILLCO PAC. WILLCO PAC is a voluntary fund supported by Williams employees who choose to participate in the political process by pooling their resources to elect candidates who support a free and competitive economic system and who understand and support the interests of our businesses.
WILLCO PAC is an independent, non-partisan entity that raises voluntary contributions from eligible Williams employees and supports candidates for Congressional office and for state office, where Federal PAC contributions are permitted by state law. Contributions to certain national party organizations may also be made as appropriate.
Employee participation in the WILLCO PAC is strictly voluntary, and employees have a right to refuse to participate without fear of retaliation or reprisal. The company will not pressure or coerce employees to make personal expenditures in support of the PAC, or take any retaliatory action against employees who do not participate. Employees who participate in the PAC will not be reimbursed for their contribution or any other personal political expenditure.
Contributions to the PAC are subject to written guidelines. Recommendations for contributions are prepared by the vice president of government affairs, who reports to the General Counsel, and presented to the executive officer team for approval.
The Federal Election Commission regulates WILLCO PAC's activities. Reports detailing its activities are available on the FEC Web site.
Lobbying Disclosure
Federal and state law requires Williams to report expenditures associated with activities that support lobbying. This includes expenditures associated with the activities of our employees and payments made to external entities and trade organizations. It is the responsibility of employees engaged in these activities to report their time at the required reporting intervals. Information on these activities and associated expenditures is available for public inspection on the U.S. House of Representatives Web site.
Gift Rules
There are very strict rules pertaining to gifts to Executive and Legislative Branch employees, and to state legislators and their staff. It is the responsibility of all Williams' employees to know that rules regulate this conduct, that there are penalties for non-compliance and that full compliance is expected.
There is not an absolute ban on the giving of gifts, but due to the potential appearance of impropriety, the complexity of the rules and the potential for mistakes, employees must receive prior approval from the vice president of government affairs before giving a gift to a covered employee.
Williams makes reasonable efforts to track and report payments made to trade associations and other tax exempt organizations that may be used for political purposes, such as lobbying activities that would not be deductible under section 162(e)(1) of the Internal Revenue Code. The following trade associations and tax-exempt organizations have informed the company that the following dollar amounts of our membership dues were used in support of lobbying activities and are not deductible. Lobbying activities do not include contributions to political campaigns.
| 2010 Contributions to Trade Associations and Other Tax Exempt Organizations |
| American Natural Gas Alliance | $1,326,750 |
| American Petroleum Institute | 338,593 |
| Interstate Natural Gas Association of America | 51,987 |
| New Direction Colorado | 50,000 |
| Common Sense Colorado | 50,000 |
| Business Roundtable | 41,886 |
| Marcellus Shale Coalition | 25,000 |
| New Mexico Oil & Gas Association | 20,250 |
| Colorado Oil & Gas Association | 19,020 |
| State Chamber of Tulsa | 16,323 |
| Natural Gas Supply Association | 15,749 |
| Center on Executive Compensation | 12,000 |
| Gas Processors Association | 8,723 |
| HR Policy Association | 7,200 |
| Louisiana Mid-Continent Oil & Gas Association | 6,996 |
| American Exploration and Production Council | 6,900 |
| Erisa Industry Committee | 6,300 |
| National Association of Publicly Traded Partnerships | 5,920 |
| Business Institute for Political Analysis (BIPAC) | 4,800 |
| Texas Oil and Gas Association | 4,500 |
| American Gas Association | 4,375 |
| Louisiana Business and Industry Association | 3,298 |
| Texas Pipeline Association | 2,500 |
| Mid-Continental Oil & Gas Association of OK | 1,800 |
| Association of Washington Business | 1,500 |
| Environmental Federation of OK | 1,100 |
| Tulsa Metro Chamber | 751 |
| Utah Manufacturers Association | 390 |
| Oklahoma Independent Petroleum Association | 386 |
| US Oil & Gas Association | 300 |
| Associated Oregon Industries | 280 |
| Maryland Chamber of Commerce | 217 |
| Georgia Chamber of Commerce | 190 |
| Utah Petroleum Association | 188 |
| Independent Petroleum Association of America | 147 |
| Energy Association of Pennsylvania | 30 |
| Society for Human Resource Management | 13 |
| Total | $2,036,361 |