COMPLIANCE WITH ALL LAWS
My brother often asks me about Williams and whether he should buy Williams stock . If I tell him what I know about our business prospects and suggest he buy Williams stock , would that be a problem ?
Yes , if the information you provide is material and non-public . The rules of “ inside ” information apply whether you buy or sell stock yourself or if you give the information to someone else . If another person buys or sells stock based on nonpublic information or “ tips ” provided by you , both of you could be held liable for violation of federal securities laws ( insider trading ). In any case , you should always refuse to recommend that anyone buy or sell Williams stock .
The law applies equally to Williams securities and the securities of other publicly traded companies . The rule is that you must not trade in the securities , or any derivative thereof , of a publicly traded company while you possess ( i . e . are aware of ) material , non-public information concerning such public company . This prohibition extends beyond just trading in Williams securities . It means that you also may not trade in the securities of another publicly traded company about whom you have obtained material , non-public information in the course of your employment with Williams . Thus , for example , whenever Williams is negotiating an acquisition of an entity , employees should not trade in equity securities of Williams or the to-be-acquired entity . You are also prohibited from “ tipping ” others about material , non-public information about Williams or another publicly traded company . Certain employees may also be subject to additional restrictions on trading Williams securities ( See “ Williams Policy on Securities Trading ”).
Public Disclosures
Williams is committed to complying with all public disclosure laws and regulations , including but not limited to the Securities Exchange Act of 1934 and the Sarbanes-Oxley Act of 2002 . We must assure that all disclosures made in all periodic reports and documents filed with the Securities and Exchange Commission , and other public communications by Williams , are fair , accurate , timely , and understandable . This is an obligation of all employees involved in any aspect of the process of preparing and / or certifying a public disclosure ( See “ External Communication and Disclosure of Information Policy ”).
Political Contributions and Conduct and Government Affairs
Public policy decisions affect our businesses and it is in the best interest of the Company , its employees , and shareholders that Williams be engaged in the political process . Williams engages in the political process through the activities of its political action committee ( WILLCO PAC ), corporate contributions where allowed by law , trade associations , and political organizations , and by engaging in public policy debates on the issues affecting Williams . While it is permissible and encouraged for employees to engage in political activities on their own time in their individual capacities , any activities undertaken on behalf of the Company must be approved by Government Affairs and Legal .
Further , laws governing political contributions are complex and vary at the federal , state and local levels . Williams has guidelines governing direct and indirect contributions made on behalf of the Company , which include the following :
� Review by Government Affairs and Legal to ensure compliance with Williams ’ contribution guidelines and applicable law ;
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Oversight and final authority for political contributions by the company ’ s executive officer team ; and
22 WILLIAMS CODE OF BUSINESS CONDUCT