Williams Code of Business Conduct - External | Page 11

GUIDANCE FOR RESOLVING AND REPORTING CONCERNS

Quick Ethics Check
If you are in doubt when faced with an ethical dilemma related to your work , ask yourself :
� Is it legal ? If legal , is it the right thing to do ?
� Is it consistent with Williams ’ policies , procedures , and Core Values ?
� If it were made public , would I be comfortable ?
If you are still not sure what to do , seek guidance from one of the reporting channels listed in the next section .
Seeking Advice or Reporting Concerns and Violations
This Code is a guide for helping Williams employees conduct their business in a manner consistent with Williams ’ Core Values . 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 .
The Code is a guide for helping Williams employees conduct their business in a manner consistent with Williams ’ Core Values .
Just like the Code , none of us is expected to have all the answers . When we have questions or concerns about business conduct , Williams expects us to seek the guidance we need from any of 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 or property , unprofessional conduct in the workplace , illegal activities or legal action against the Company are examples of when action required by Williams may not allow for complete confidentiality or anonymity .
Management – 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 . If 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 .
HR Business Partner – Another effective channel for problem-solving is Human Resources , whose primary role is to provide guidance to the employee .
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