WHY WE HAVE A CODE
At Williams , we are authentic . Our integrity cannot be compromised . We believe that it takes more than good business results to be a great company . We have built a culture based on our Mission and Core Values , where integrity is of the utmost importance and where unethical behavior will not be tolerated .
The Code takes our Core Values and puts them into our day to day actions and interactions with our key stakeholders .
This Code is intended to meet the requirements of a “ code of business conduct and ethics ” under Section 303A of the New York Stock Exchange ’ s Listed Company Manual .
Who Must Follow the Code ?
The Code applies to every Williams employee , officer , and member of our Board of Directors , including the Company ’ s Chief Executive Officer , Chief Financial Officer , and Chief Accounting Officer . It also applies to Williams ’ subsidiaries and , in certain cases , our joint ventures ( JVs ).
What Are Our Responsibilities ?
Conducting business with integrity allows us to preserve our reputation for always striving to do business the right way . To do this , each of us must :
� Read and understand the Code
� Complete training on the Code and other assigned training in a timely manner
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Abide by the Code and use reporting channels to report any violation or potential violation
� Seek advice and guidance when things are not clear
Being a leader at Williams means accepting an additional set of responsibilities . We expect our leaders to demonstrate a strong commitment to both leadership and teamwork .
What Are the Consequences for Violating the Code ?
Violations of our Code , policies , or the law may carry serious consequences for Williams and to the individuals involved . We are each accountable for our actions . Individuals who engage in unethical or illegal behavior , and those who direct , condone , approve , or facilitate such behavior , may be subject to disciplinary action up to and including termination , subject to local laws , and in some instances , may be subject to prosecution by governmental agencies .
Consistent with our Core Values , our disciplinary process will treat each of us with dignity and respect , and disciplinary measures will be applied in a manner appropriate to the situation .
Unethical behavior can damage our reputation , harm our stakeholders , and may subject us , as individuals or as a Company , to fines and civil or criminal liability . It is in all our interest to avoid any violation of our Code , our policies , or the law .
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