Code of Ethics for Senior Officers

In my role as (Chief Executive Officer, Chief Financial Officer and Chief Accounting Officer) of Williams, I recognize that my position holds an important and elevated role in corporate governance. I am uniquely capable and empowered to ensure that stakeholders' interests are appropriately balanced, protected and preserved. Accordingly, this Code provides the following guidelines and responsibilities governing my professional and ethical conduct, and to which I am expected to adhere and advocate.

I certify that I adhere to and advocate:

1. Honest and ethical conduct, including the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships;

2. Avoidance of conflicts of interest, including disclosure to the Chief Ethics and
Compliance Officer of any material transaction or relationship that
reasonably could be expected to give rise to such a conflict;

3. Full, fair, accurate, timely, and understandable disclosure in reports and
documents that the Company files with, or submits to, the U. S. Securities and
Exchange Commission and in other public communications made by the
Company;

4. Compliance with applicable governmental laws, rules and regulations;

5. The prompt internal reporting of Code violations to the Chief Ethics and
Compliance Officer; and

6. Accountability for adherence to the Code.

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(Signature)