Williams Code of Business Conduct - External | Page 13

GUIDANCE FOR RESOLVING AND REPORTING CONCERNS
Business Ethics Resource Center ( BERC ) – The Business Ethics Resource Center is available if you need assistance with a business conduct issue or concern or an unresolved safety concern .
� Phone : 918-573-3284
� Email : businessethicsresourcecenter @ williams . com
We are also welcome to call the Williams Action Line at 1-800-324-3606 or make an online report at www . williams . ethicspoint . com . The Williams Action Line is available 24 hours a day , 7 days a week and the reporter can choose to remain anonymous .
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 .
Non-Retaliation Commitment
We all have a responsibility for promptly reporting unauthorized or unlawful activity . Speaking up is always the right thing to do . Williams understands employees may be reluctant to report violations if they believe the reporting employee will be subjected to retaliation . Williams prohibits and will not tolerate retaliation against anyone who reports a suspected violation in good faith , or against anyone who participates in an investigation . This includes blatant retaliation such as firing , transferring , demoting , or publicly attacking someone , as well as more subtle retaliation , such as excluding someone from an important meeting or team activity . If you ever feel that you have been retaliated against or threatened with retaliation , promptly report the matter to your HR business partner , the Business Ethics Resource Center , or the Williams Action Line ( See “ Internal Reporting and Non-Retaliation Policy ”).
Investigations and Corrective Actions
Williams takes all reports of possible misconduct seriously . Williams will assess all reported allegations of non-compliance with the Code , laws , regulations , and / or company policies and procedures . If the assessment discloses potential non-compliance , an investigation will be conducted by the Company . If the results of an investigation indicate that corrective action is needed , Williams will determine the appropriate steps , including employee
OPTIONS FOR REPORTING A CONCERN
� Your Immediate Supervisor
� Your HR Business Partner
� Your Next Level ( s ) of Management
� Business Ethics Resource Center 918-573-3284
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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