CONFLICTS OF INTEREST
Our Core Values represent a strong commitment to our stakeholders ( communities , customers , employees and investors ). We always want to act in the best interest of our Company . Therefore , we are all 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 .
When in doubt whether a decision you are making is a conflict of interest ? Ask yourself …
� Could the decision I make be influenced by my personal interests or relationships ?
� Could it look that way to someone else ? If yes , it might be a conflict of interest and we should seek guidance when we are not sure .
Although no list of potential conflicts of interest can be complete , the following examples highlight activities which could or be perceived to cause conflicts :
Corporate Opportunities
We owe a duty to Williams to advance its legitimate interests when the opportunity to do so arises . We should not use company property , information , or our position for personal gain , or in a manner that competes with , disadvantages , or diverts business opportunities away from Williams .
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 ensure 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 .
I ’ m an engineer for Williams . I ’ m thinking of starting a side business to bring in some extra income . Would this be a conflict of interest ?
Having a side business does not necessarily put you in a conflict of interest situation . If your outside business activity does not compete with Williams , and your participation in this business is accomplished outside your normal work hours and does 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 .
When considering an outside employment opportunity , ask yourself :
� Does the business compete in some way with or disadvantage Williams ?
� Does the job interfere with your Williams working hours or ability to complete your job responsibilities ?
� Does it involve Williams ’ assets in any way ?
� Does it involve a customer , vendor , or supplier of Williams ?
Appearances matter , and it ’ s important to disclose the potential outside employment opportunity to your management to make sure that there is not even a perceived conflict of interest .
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