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FERC Standards of Conduct Compliance Training for New EmployeesRevised July 23, 2012
The Federal Energy Regulatory Commission (FERC) has a set of rules called the Standards of Conduct, or SOC. These SOC rules apply to any interstate natural gas transmission company that transports gas for others and has an affiliate that engages in marketing functions. Williams is subject to the Standards of Conduct.
What You Need To Know About The FERC Standards Of Conduct:
1. Transco and Pine Needle are natural gas Transmission Providers and are subject to the SOC. Transco and Pine Needle are not allowed to disclose any non-public pipeline transmission or customer information to a Marketing Function Employee (MFE). Currently, the MFEs at Williams are John Carmody, Meagan Huff, and any other employees in the Midstream Gas Marketing department. There are also a few employees of Pine Needle affiliates also designated as MFEs. While Northwest and Gulfstream are not currently subject to the SOC, Williams also restricts information sharing between Northwest Pipeline and Gulfstream and the MFEs.
2. The No-Conduit Rule: All employees and contractors of Williams are subject to the No-Conduit Rule, which says you can’t share any non-public pipeline transmission or customer information with any Marketing Function Employee.
3. Independent Functioning: Our interstate pipelines subject to the SOC must maintain an arm’s length relationship with MFEs. In other words, pipeline employees can’t share job functions with marketing employees.
4. Non-Discrimination: Our pipelines must treat all of their customers (affiliated and non-affiliated) the same, and not grant any undue preference or advantage to any customer.
Basic Work Guidelines:
1. If you think you may have inadvertently disclosed information that you should not have disclosed, contact any of the Regulatory Compliance representatives, as shown below. We can address the potential exposure and avoid potential penalties. Our immediate knowledge of a potential problem is critical because the information may need to be posted on the pipeline’s electronic bulletin board.
2. You must restrict access to non-public pipeline transmission or customer information by using appropriate measures such as locked file rooms/drawers, password protection on your computer, and reviewing names on email distribution before sending.
3. When you check the FERC training box on the Policy Receipt Acknowledgment page found in your on-boarding packet, you are certifying that you have read and understand the concepts in this document.
4. Compliance with the concepts in this document is of the utmost importance. Williams could face penalties for non-compliance. Williams expects that you will abide by the requirements and guidelines outlined in this document.
Who To Call:
Andrea Mogab – FERC Compliance Officer (918) 573-3284 [email protected] Karen Peterson – WGP (713) 215-2965 [email protected] Cathy Wiedenhoeft – Midstream (918) 573-4180 [email protected] Carmen Ruiz – IT-Related Questions (918) 573-2486 [email protected] Tina Wiles – Administration (918) 573-3448 [email protected]
Additional information is available on the Regulatory Compliance intranet MyWilliams website: http://my.williams.com/depts/enterprise/compliance/Pages/default.aspx
To report a concern anonymously, please call the Williams Action Line at (800) 324-3606.
© 2012 The Williams Companies, Inc. 02116/072012