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Message from the CEO
Core Values & Beliefs
Guidance for Resolving and Reporting
Concerns
1. Where to Seek Guidance
2. Quick Ethics Check
3. Reporting Suspected Violations
4. Investigations and Corrective Actions
Our Work Environment
1. Equal Opportunity, Affirmative Action and Diversity
2. Harassment/Violence
3. Health, Safety and the Environment
4. Alcohol and Substance Abuse
5. Employee Privacy
6. Q&As
Compliance With All Laws
1. Antitrust
2. Trading on Inside Information
3. Public Disclosures
4. Political Contributions
5. Commercial Bribery
6. Fraudulent Conduct
7. Obstruction of Justice
8. FERC Standards of Conduct
9. Foreign Business Dealings
10. Q&As
Conflict of Interest
1. Corporate Opportunities
2. Outside Employment
3. Financial Interests
4. Gifts and Entertainment
5. Relatives
6. Q&As
Protecting Company Assets
1. Use of Company Assets
2. Recording of Funds, Assets, Etc.
3. Confidential Information
4. Intellectual Property
5. Q&As
Williams Ethics & Compliance
Program
1. Program Description
2. Organizational Structure
3. Contact Information
Message from the CEO
Williams' success has been and always will be tied to our employees'
commitment to the company's Core Values & Beliefs. It is not enough
to achieve the right results. They must be achieved the right way.
Of course, business conduct issues are not always black and white. That
is where this Code of Business Conduct can help. The Code, which was approved
by the Executive Officer Team and Williams' Board of Directors, was designed
as a guide for all our employees and directors to help them put the Core
Values & Beliefs into practice when performing their duties on behalf
of Williams. While no Code can be totally comprehensive, it does provide
guidance for some of the more common issues we might face at Williams.
This Code also identifies other resources available to all of us to help
resolve ethical issues at work. The company understands there are times
when we all need help deciding the right thing to do, and it is important
we know where we can turn for assistance in resolving such issues.
Corporate governance is taken very seriously at Williams, and we are
all responsible for reading, understanding and adhering to the business
conduct standards outlined in this Code. Though not anticipated, any waiver
of this Code must be approved by the Williams Board of Directors, and
such waiver for directors and executive officers must be promptly disclosed
to shareholders.
Thank you for your continued commitment to the company's Core Values
& Beliefs and doing business the right way. Williams' future success
depends on it.
Sincerely,
Alan Armstrong
Chairman, President and Chief Executive Officer
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Core Values & Beliefs
Integrity
Integrity must not be compromised. Honest relationships and trust are
essential for long-term business success. We deal fairly in all our business
relations.
Investors
We are committed to providing our investors an attractive return over
the long term.
Customers
Customers are the essence of our business. Customers are all parties with
whom we deal. We work to satisfy our customers' requirements and anticipate
their expectations. To succeed, we must work with our customers to help
make them winners, too.
Employees
People are the company's most valuable resource. Employees possess immense
powers of innovation, imagination, skill and a desire to accomplish something
of significance. Working as a team enables all of us to realize our full
potential.
Communities
We recognize and enthusiastically accept our responsibility to the communities
we serve, through acting as a good neighbor and through involvement and
support for community activities. We are committed to protecting the public,
the environment and our natural resources by operating in a safe, reliable
manner.
Entrepreneurial Spirit
We maintain a corporate culture that values originality, invention and
creativity, and that nurtures these qualities through openness and reverence
for the entrepreneurial spirit.
Tolerance for Risk
The company's willingness to take risks in deploying new technology and
investing in large capital projects is central to its culture and its
success.
Efficiency
Efficiency means the difference between success and failure. We will relentlessly
pursue a more efficient way to do everything we undertake.
Autonomy of Operating Units
The autonomy of operating units is important to promote focus, fast decision
making and ultimately commitment, which is essential for success. At the
same time, cooperation must exist so that operating units work efficiently
together and share ideas. Autonomy and entrepreneurial spirit go hand
in hand.
Change
We welcome change for the opportunities it offers.
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Guidance for Resolving and Reporting Concerns
Quick Ethics Check
If you are in doubt when faced with an ethical dilemma at work, ask yourself:
- Is it legal?
- Does it comply with our Core Values & Beliefs?
- Would you want your family and friends to know about it?
If you are still not sure what to do, seek guidance from one of the
reporting channels listed in the next section.
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Where to Seek Guidance
This Code is a guide for helping Williams employees conduct their business
in a manner consistent with Williams' Core Values & Beliefs. Because
our business can be very complex at times, the Code is not meant to provide
all the answers. It also doesn't form the basis for a contract or claim
of any kind. Instead, the Code is intended to be a practical guide to
some of the more common situations that many of us may face from time
to time.
Just like the Code, none of us is expected to have all the answers. When
we have questions or concerns about business conduct, the company expects
us to seek the guidance we need from the following reporting channels.
Personnel in these reporting channels are sensitive to requests for confidential
and anonymous treatment. However, reports involving a threat to life and
property, illegal activities or legal action against the company are examples
of when action required by the company may not allow for complete confidentiality
or anonymity.
Supervisor – It is often most effective to report our concerns
to our immediate supervisor. Supervisors are directly responsible for
providing their employees with the resources necessary to resolve problems
or concerns.
Next Level(s) of Management – In the event an issue is not
handled to our satisfaction or we are not comfortable discussing it with
our immediate supervisor, we can take the matter to the next level(s)
of management. Another effective channel for problem solving is Human
Resources, who has a primary role to support the employee. In addition,
the Legal Department is there to assist us with legal issues.
Functional Vice President – If these previous steps do not
resolve the issue, we can make arrangements to review the situation with
our functional vice president.
Business Ethics Resource Center – If the above channels do
not provide a satisfactory resolution, we may also contact the Business
Ethics Resource Center (see contact information at the end of this Code).
All concerns reported to the Business Ethics Resource Center will be evaluated
to determine the appropriate course of action to be taken. If we want
to report anonymously, we may call the Action Line (1-800-324-3606).
In addition, the Audit Committee of the Williams Board of Directors has
established procedures for the receipt, retention and treatment of complaints
regarding accounting, internal accounting controls or auditing matters.
If we have unresolved concerns regarding questionable accounting or auditing
matters, we should promptly contact one of the reporting channels listed
above. These reporting channels should immediately communicate those concerns
to the Business Ethics Resource Center, which is responsible for reporting
such information to the Audit Committee.
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Reporting Suspected Violations
We all have a responsibility for promptly reporting unauthorized or unlawful
activity. Williams understands employees may be reluctant to report violations
if they believe the reporting employee will be subjected to retaliation.
Therefore, it is important for us to understand that Williams will
not tolerate retaliation against any employee who reports a suspected
violation in good faith.
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Investigations and Corrective Actions
All reports of suspected violations will be evaluated by Williams. An
investigation will be conducted if the evaluation points to a potential
problem. If the results of an investigation indicate that corrective action
needs to be taken, the company will determine the appropriate steps, including
employee discipline, dismissal and possible legal proceedings. Such actions
will also be brought against individuals who have willfully failed to
report known violations.
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Our Work Environment
A good working environment helps support many of our Core Values. It
helps protect our most valuable resource, our employees, and allows us
all to reach our greatest potential. It is also consistent with our recognized
responsibility to serve our communities by helping to protect the public
and the environment.
A positive work environment helps promote a willingness among employees
to embrace change, take risks, and work together as efficiently as possible.
It also creates a culture that nurtures our entrepreneurial spirits, and
supports us when it is more effective to be autonomous.
We all are responsible for promoting the most productive and positive
working environment possible. By doing so, we support our Core Values
and contribute to our company’s future success.
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Equal Opportunity, Affirmative Action and Diversity
Williams has a strong commitment to equal opportunity, affirmative action
and diversity in the workforce. We believe in treating people with dignity
and providing equal employment and advancement opportunities based on
merit, experience and other work-related criteria.
We value the unique contributions that every employee brings to her or
his role within the company and consider the variety of perspectives and
backgrounds that exist within Williams a competitive advantage for us
in the marketplace. Williams is committed to treating all employees fairly,
without regard to any characteristics that have no bearing on job performance.
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Harassment/Violence
Respecting the rights of others in the workplace is a primary focus at
Williams. There are certain behaviors that are not acceptable under any
circumstances – such as harassment and/or violence of any kind. Examples
include any unwelcome behavior such as advances, inappropriate jokes,
intimidation, offensive language, physical contact or anything that creates
a hostile working environment for an ordinary, reasonable employee.
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Health, Safety & the Environment
Williams is committed to the goal of healthy, safe and environmentally
sound business practices and operations. We are responsible for using
all reasonable efforts to operate in a manner that preserves the environment
and protects the health and safety of our employees and others. We are
also responsible for complying with all applicable laws and regulations
relating to the protection of the environment and the maintenance of a
healthy and safe workplace.
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Alcohol and Substance Abuse
Our work benefits from our clear thinking and ability to react quickly.
It is important for us to understand that Williams will not tolerate unauthorized
use, possession and distribution, or being under the influence of alcohol
or illegal drugs in the workplace. A voluntary Employee Assistance Program
(EAP) is available through Williams for those seeking to overcome drug
or alcohol related problems.
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Employee Privacy
At Williams, we respect the privacy of others. We are responsible for
maintaining employee privacy through the careful handling of employee
information at all times. We, as employees, have the right to expect that
our personnel records will only be accessed by those with a legitimate
reason for doing so. In turn, we must understand Williams’ right
to access all company property, communications, records and information
created in the business setting.
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Q&As
What if my supervisor starts to play favorites with job assignments
and overtime, and I begin to feel discriminated against? What should I
do?
You should tell your supervisor in clear and specific terms that you
feel you have not been treated fairly in terms of job assignments and
overtime. If you feel your supervisor has not responded to your concerns
in a fair manner, take advantage of the other reporting channels available
to you and identified in the Introduction to this Code.
If I had a manager that kept asking me out socially after work, even
though I had no interest and had continually refused the invitations,
what should I do?
Tell him or her no. You should immediately report the situation, most
likely to your manager's boss or Human Resources.
If I receive a call from another company requesting a reference check
on a former Williams employee, how should I handle the call?
You should not provide any information, but should politely refer
the caller to Human Resources. By establishing Human Resources as a clearinghouse
for all reference requests, we can ensure that the information we release
is accurate, authorized, and representative of the company's position.
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Compliance With All Laws
Our Core Values talk about integrity and Williams’ commitment to
its stakeholders – investors, customers, employees and communities.
We believe an honest and trusting relationship with all our stakeholders
is essential to our long-term business success. This belief drives our
commitment to be a good corporate citizen and to comply with all applicable
laws and regulations.
We must understand the laws affecting our business activities and be
responsible for compliance. Complying with both the spirit and letter
of the law best serves the interest of Williams and its stakeholders.
The following is a brief listing of some of the major laws that can impact
our business. Because legal issues can be very complex, if in doubt, we
are encouraged to seek guidance from our management and legal counsel.
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Antitrust
Williams believes that fair competition and a free enterprise system
serves the best interest of the company and its stakeholders. The antitrust
laws were enacted to help preserve the free enterprise system by promoting
competition. These laws prohibit business practices that result in unreasonable
restraints of trade or discriminatory trade practices. The following are
examples of practices that may be illegal:
- Creation of a monopoly or attempts to create a monopoly;
- Agreements among competitors to fix prices, divide markets, allocate
customers or limit the quality or production of products; and
- Price discrimination and other predatory trade practices.
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Trading on Insider Information
Williams recognizes the importance of strong and healthy securities markets.
To ensure such markets, and to prevent the misappropriation of a company's
confidential information, the law forbids us from purchasing or selling
securities if we have material information which has not been made public
(inside information). Material information covers such topics as company
earnings, acquisitions or divestitures, new products or services, changes
in strategy, etc.
The law applies equally to Williams securities and the securities of
others who are involved with Williams in what would be a significant transaction
for those other entities. Thus, whenever the company is negotiating an
acquisition of an entity, company employees should not trade in equity
securities of Williams or the to-be-acquired entity. This includes "tipping"
others about material, non-public information.
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Public Disclosures
Williams is committed to complying with all public disclosure laws and
regulations, including but not limited to the Securities Exchange Act
of 1934 and the Sarbanes-Oxley Act of 2002. We must assure that all disclosures
made in all periodic reports and documents filed with the Securities and
Exchange Commission, and other public communications by the company are
fair, accurate, timely and understandable. This is an obligation of all
employees involved in any aspect of the process of preparing and/or certifying
to a public disclosure.
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Political Contributions
It is important to recognize that we have corporate interests at stake at the federal and state levels, and there are times when it is in our best interests to make our combined voices heard by our elected representatives. Laws governing political contributions are complex and vary in each state and country. In the United States, no company funds can be contributed to candidates for federal office or committees formed to support such candidates. However, certain states and foreign countries do permit political contributions by corporations. 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.
In accordance with applicable laws and regulations, Williams has established a Political Action Committee (PAC). Employee participation in the Williams PAC is voluntary, and employees have a right not to participate without fear of retaliation.
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Commercial Bribery
Williams considers one of its most valuable assets to be its reputation
of integrity. We seek fair and honest business relationships with all
our stakeholders. To that end, Williams does not tolerate the offering
or accepting of bribes, kickbacks or other payoffs designed to influence
the recipient’s judgment.
The following are examples of conduct that is prohibited by Williams:
- Payment or receipt of money, gifts, loans or other favors that are
designed to, or may tend to, compromise our ability to make objective
and fair business decisions;
- Payment or receipt of kickbacks for obtaining business; and
- Payment of bribes to government officials to obtain favorable treatment.
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Fraudulent Conduct
Our company is committed to conducting its business dealings in an honest
and non-fraudulent manner. We will not intentionally deceive to gain an
advantage over or injure another party. All company information provided
to any person or entity must be free from deliberate misrepresentation.
For example, when dealing with a business associate, we must not make
representations we know are false or lack the proper authority.
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Obstruction of Justice
Williams has always recognized the importance and benefits of a properly
functioning justice system. We must always conduct ourselves in a way
that does not interfere with or obstruct the operation of any legal or
governmental system. This includes:
- Obeying and not hindering the activities supported by legal and governmental
mandates; and
- Not tampering with or illegally influencing any person who is scheduled
to appear as a witness in any legal or governmental proceeding; and
- Retaining documents consistent with the company's retention policies,
and not destroying any records with the intent to impede or obstruct
any governmental investigation
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FERC Standards of Conduct
Williams is committed to treating every customer fairly and equitably,
and as an energy company is committed to compliance with the FERC regulations.
The FERC Standards of Conduct expressly prohibits Williams interstate
natural gas pipelines (Williams' pipelines) from giving its energy affiliates,
through a tariff provision or otherwise, undue preference over its non-affiliate
customers to ensure that transportation services are provided on a non-discriminatory
basis. This prohibition includes the improper exchange of information
between Williams' pipelines and its energy affiliates as to non-public
transportation information or non-affiliate shipper information.
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Foreign Business Dealings
Those of us involved in global business must be aware of and comply with
international laws, which are frequently complex and unique. One of the
most significant laws in this area is the Foreign Corrupt Practices Act.
This Act makes it illegal to get or keep business by making improper payments
to foreign officials, political parties and governments. The Act also
requires significant accounting practices to deter the creation of slush
funds to finance illegal payments.
Occasionally, the company has found that certain foreign government officials
refuse to perform their ordinary duties without the payment of some small
amount, even though they are not significant policy or decision-makers.
In some situations, a delay in their performance may materially and adversely
affect the regular operations of the company. Under these conditions,
and if allowed by law, officers of the company are permitted to authorize
"facilitating payments" in small amounts to these officials
in order to protect the company’s operations. Because the laws and
interpretations of each foreign country are complex, legal counsel must
be consulted before any payments are made.
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Q&A
I will be attending a trade association meeting next month and I am
curious about our chances for receiving a contract award. I would like
to discuss this with other bidders who will be there. Is that all right?
No. You should not discuss bids, terms of contracts, or similar proprietary
business information with employees of competing firms. This might give
others an unfair advantage, and it might create an antitrust problem.
Don't initiate such conversations or respond to any outside inquiries.
My family and friends often ask me about Williams and whether they
should buy the company stock. If I tell them what I know about our business
prospects and suggest they buy the stock, would that be a problem?
Yes, The rules of "inside" information apply whether you buy
or sell stock yourself or if you give the information to someone else.
If another person buys or sells stock based on non-public information
or "tips" provided by you, both of you could be held liable
for violation of federal securities laws. In any case, you should at all
times refuse to recommend that anyone buy or sell Williams stock. Besides
this concern, employees should never discuss confidential business information
with anyone who does not have a need to know it.
Is it permissible for a business representative to entertain a government
decisionmaker by taking him or her on an extravagant outing in an effort
to speed up a decision on a matter?
Generally the law prohibits any payment, whether direct or, as in this
case, indirect, whose purpose is to influence a government employee's
behavior. The company, the business representative and the government
decisionmaker could all be prosecuted for bribery, if the offer were made
and accepted.
Several of my co-workers and I strongly support a certain political
candidate. May we work together to support this candidate?
Of course. Williams encourages participation in the political process.
However, you may not use company funds, equipment or materials to support
the candidate, claim to represent the company's opinions or views of a
candidate or issue, and you may not engage in political activities while
you are on the job.
We will be attending a foreign trade show and have shipped our product
displays from the United States. What if we experience unusual delays
in getting our displays released by the customs officials of the foreign
country? I'm told it is customary in this country to pay $100 to speed
up processing of the customs document. Would this be proper?
In some foreign cultures, it is customary and necessary to make payments
called "facilitating payments." These payments are for expediting
routine governmental actions such as obtaining a permit or visa. In some
cases, these payments may be illegal or improper. Before making such a
payment, consult first with the Legal Department.
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Conflict of Interest
Our Core Values represent a strong commitment to our investors, customers,
employees and communities. We always want to act in the best interest
of these stakeholders. Therefore, we all are expected to avoid or disclose
any activity that may interfere, or have the appearance of interfering,
with our responsibilities to Williams and its stakeholders. Activities
that cannot be avoided must be disclosed to the immediate supervisor.
That supervisor is responsible to establish and monitor procedures that
ensure Williams is not disadvantaged.
Although no list of potential conflicts of interest can be complete,
the following examples highlight activities which could cause conflicts:
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Corporate Opportunities
We owe a duty to the company to advance its legitimate interests when
the opportunity to do so arises. We should not compete with Williams or
use company property, information or our position to divert business opportunities
away from Williams for our own personal gain.
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Outside Employment
The success of Williams depends on our strong commitment to our job responsibilities.
While we are permitted to work outside of Williams, we must make sure
that such employment does not prevent us from fulfilling our job responsibilities
at Williams. We may not be employed by or perform services for a competitor,
customer or supplier without prior supervisory approval.
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Financial 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 involvements
do not have a negative impact on our ability to make sound and objective
business decisions.
In regard to 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 represents a potential conflict of interest
and should be fully reported to our immediate supervisor. In addition,
the company prohibits the following:
- Employee participation in directed share (sometimes known as friends
and family) programs offered by other business entities that have or
may develop commercial relationships with Williams; and
- 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.
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Gifts and Entertainment
Williams understands that business gifts and entertainment can help build
strong relationships with our business partners. However, we must understand
that Williams does not tolerate the offering or receiving of gifts and
entertainment designed to influence the recipient’s judgment. There
is no substitute for good judgment in this situation and if we are concerned
about any particular situation, we should err on the side of caution.
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Relatives
Situations may arise where a relative (defined as one who is related
to another by blood or marriage) is employed or has a financial stake
in an entity that does business with Williams. Frequently, this is not
a problem, but the potential for actual or perceived conflicts of interest
may exist. Such situations include, but are not limited to, the following:
- A relative involved in a business seeking to provide goods and services
to Williams;
- Gifts or other benefits offered to a relative by any enterprise that
does business with Williams; and
- A relative working for a competitor.
We all need to be cautious of situations that can result in our inability
to make objective business decisions, or lead to the disclosure of competitive
or confidential information.
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Q&A
I am thinking about starting my own outside business to bring in some
extra income. Would this be a conflict of interest?
An outside business activity does not necessarily put you in a conflict
of interest situation. If your outside business activity did not compete
with Williams, and your participation in this business was accomplished
outside your normal work hours and did not adversely impact your ability
to do your job, this would probably not be a conflict of interest. However,
you should review the matter with your supervisor before starting the
activity.
A Williams officer is thinking about taking a potential customer to
an exclusive resort. Would this be acceptable?
If the purpose of this activity is to help build a good working relationship
with the potential customer, then it would be acceptable. However, the
activity would be against company policy if (1) it was offered in return
for securing the potential customer's business or (2) it was an attempt
by the officer to compromise the potential customer's ability to make
objective and fair business decisions.
What are the guidelines if I have a relative who works for one of
Williams' competitors?
There is nothing wrong with relatives (or other personal relations) 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). It would be a good idea to alert
your supervisor, thereby evidencing your appreciation of the potential
sensitivity of the situation.
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Protecting Company Assets
Taking care of our company assets is a critical part of our ability to
be successful. We are all responsible for safeguarding the company resources
entrusted to us. The wise use of these assets significantly benefits Williams
and its stakeholders.
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Use of Company Assets
How we use and care for our company assets can have a direct impact on
our financial success. We are responsible for properly handling those
assets that are entrusted to us. In general, we may not take, loan, donate,
sell, damage or use company assets for non-corporate purposes unless specifically
authorized. However, occasional personal use of certain company equipment
(ie. personal telephone calls, facsimiles, e-mails, Internet access) is
permissible if the frequency and cost of such use is not excessive and
does not conflict with company business or policy.
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Recording of Funds, Assets, Etc.
The proper management and recording of company funds, assets, liabilities
and business transactions is critical for supporting Williams' day-to-day
operations. It allows the company 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.
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Confidential Information
Much of the information developed or held by Williams is confidential
and must be protected from unauthorized disclosure. This information plays
a key role in our business strategies. We are responsible for safeguarding
such information in order to maintain our competitive advantage in the
marketplace.
A few examples of confidential information are financial data, employee
records, marketing research, pricing and sales programs. Materials that
contain confidential data, such as notebooks, e-mail, memos, etc., should
always be securely stored and shared only on a need-to know basis.
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Intellectual Property
Our ideas, concepts and other information we produce are important assets
to Williams. This "intellectual property" is central in developing
new products and attracting new business opportunities. Examples of intellectual
property include patents, trademarks, copyrights and trade secrets.
We are responsible for identifying and protecting Williams’ intellectual
property at all times. In addition to protecting the intellectual property
of Williams, we will also afford this same respect toward the intellectual
property of others.
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Q&A
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 company equipment may be obsolete, there are other factors that
must be considered before the company 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.
If a supplier inadvertently leaves a document in my office that is related
to a competitor's product, can I keep or make a copy of the document and
share it with others to benefit Williams?
No. The document may be confidential and cannot be disclosed without
proper authorization. Reviewing it would violate our policy and may lead
to a lawsuit. Once such a document is discovered, it should be brought
to the attention of your supervisor and the Legal Department.
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Williams Ethics & Compliance Program
Program Description
This Code is just one component of the company's overall Ethics &
Compliance Program, which was established to (a) effectively communicate
the company's 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 & Beliefs, company 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. For
example, Group Compliance Officers (consisting of the top officer of each
operating group, plus the Chief Ethics and Compliance Officer for the
corporate group) are responsible for adopting, implementing and maintaining
the Ethics & Compliance Program within their respective groups. An
Ethics Advisory Panel (made up of high-level representatives from each
of the major groups within Williams) meets regularly to oversee the effectiveness
of the Ethics & Compliance Program. Also, the Ethics & Compliance
Program is overseen by the Audit Committee and the Nominating and Governance
Committee of the Williams Board of Directors.
The chart below shows the organizational structure of the Ethics &
Compliance Program.
Ethics & Compliance Program Organizational
Structure
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Contact Information
If you need to contact anyone within the Ethics & Compliance Program
organization, or have any questions regarding the company's Ethics &
Compliance Program, please contact the Business Ethics Resource Center
as follows:
Call:
(918) 573-7459
(800) 324-3606 (Action Line, if you want to call anonymously)
Stop by: 38-4 Floor of The Williams Tower
Fax: (918) 573-6831
E-mail: actionline@williams.com
Regular Mail:
Williams
One Williams Center
Tulsa, OK 74172
Attn: Business Ethics Resource Center, MD 38-4
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