COMPLIANCE WITH ALL LAWS
Williams is committed to treating every customer fairly and equitably , and as an energy company is committed to compliance with FERC regulations .
Gifts to Government and Regulatory Officials and Employees
There are very strict rules pertaining to giving things of value to government officials and employees , including officials and employees of foreign , federal , state , local , and other governments and agencies , whose rules , in some cases , include a complete ban on gifts . Williams employees are prohibited from giving gifts to government and regulatory officials or employees due to the potential appearance of impropriety and the potential for mistakes due to the complexity of the rules . This policy applies even if the government or regulatory official or employee agrees to reimburse Williams or the employee for the gift ( See “ Gift Policy Pertaining to Government and Regulatory Employees ”). It is the responsibility of all Williams employees to comply with the prohibition on gifts and understand that there are penalties for non-compliance ( See also the Section below on Gifts and Entertainment ).
Further , those of us involved in global business must be particularly aware of and comply with international laws , which are frequently complex and unique . One of the most significant laws in this area is the U . S . Foreign Corrupt Practices Act ( the “ FCPA ”), which makes it illegal to offer anything of value to a non-U . S . government official , directly , or indirectly ( through a third party ) in order to influence official action or otherwise obtain an improper business advantage . The FCPA also requires that accurate books and records be kept and sufficient internal controls be designed and maintained to ensure transparency and adequately manage corruption risks .
Lobbying Requirements
Lobbying generally is seeking to influence government action ( legislative or executive / agency action ) by written or direct communication . There are a number of exceptions to the definition of lobbying including but not limited to :
� Engaging in a routine government process ( e . g ., applying for a permit ) �
Responding to a public request for comments ( e . g ., responding to a request for comments on a proposed regulations )
� Routine communications with lower-level executive branch or agency employees
Lobbying is regulated at the federal , state , and local levels . If Williams or its employees engage in lobbying , they generally must register in the appropriate jurisdictions and make disclosures regarding their lobbying activities . Additionally , registered lobbyists often have limitations on political contributions and the interactions that can be had with certain officials . Failure to comply with lobbying requirements can result in both penalties and reputational harm for Williams . In order to comply with these laws , Williams must track all lobbying activities . Before an employee engages in an activity that might be considered lobbying ,
24 WILLIAMS CODE OF BUSINESS CONDUCT