Williams Code of Business Conduct - External | Page 23

Oversight by the Williams Board of Directors Governance and Sustainability Committee .
Williams ’ political spending will reflect the Company ’ s interests and not those of individual officers or directors . Williams prefers to make political expenditures directly rather than through third-party groups . If Williams makes contributions to third-party groups , Williams will monitor the use of dues or payments for political purposes for consistency with Williams ’ policies and long-term interests . Employees will not be reimbursed for their contributions or any other personal political expenditures .
PAC
Employee participation in the WILLCO PAC is strictly voluntary . Williams will not pressure or coerce employees to make contributions to the WILLCO PAC , or disadvantage or favor any employee based on whether or not they contribute to the WILLCO PAC .
Anti-Corruption
Williams considers one of its most valuable assets to be its reputation of integrity . We seek fair and honest business relationships with all our stakeholders . To that end , Williams does not tolerate the offering or accepting of bribes , kickbacks , or any other improper payments or things of value designed to influence the recipient ’ s judgment , whether the recipient is with the Company or outside of the Company , and whether the recipient is in the private sector or the public sector .
The following are examples of conduct that are prohibited by Williams :
Payment or receipt of money , gifts , loans , sponsorships , contributions , or other favors that are designed , or may appear , to compromise our ability to make objective and fair business decisions
� Payment or receipt of kickbacks for obtaining business �
Payment of bribes to government officials to obtain favorable treatment
Is it okay if I take a government decision maker to a Final Four basketball game so we can talk about expediting their decision on a pending matter ?
No ! Williams Gift Policy Pertaining to Government and Regulatory Employees prohibits giving gifts to government and regulatory officials and employees due to the potential appearance of impropriety . Any exception to this policy , requires prior written approval from the General Counsel .
Several of my co-workers and I strongly support a certain political candidate . May we work together to support this candidate ?
Yes , so long as it is done in your personal capacity and during your own free time . Williams encourages personal participation in the political process . However , you can ’ t use Company funds , equipment or materials to support the candidate , claim to represent the Company ’ s opinions or views of a candidate or issue , and you may not engage in political activities while you are on the job .
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