GRI Index

	2010 Williams Response
	Strategy and Analysis
1.1	CEO statement	See letter from CEO Alan Armstrong
	Organizational Profile
2.1	Name of the organization	Williams
2.2	Primary brands, products, and/or services	See our company description
2.3	Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures.	See our company description and fact sheets
2.4	Location of organization’s headquarters.	Tulsa, Okla.
2.5	Countries of operation	USA, Canada, Argentina
2.6	Nature of ownership and legal form.	Williams (NYSE:WMB) is a Fortune 500 investor-owned corporation
2.7	Markets served (including geographic breakdown, sectors served, and types of customers/beneficiaries.	See our company description and fact sheets
2.8	Scale of the reporting organization including: number of employees, net sales or net revenues, total capitalization,	See our data tables
2.10	Awards received in the reporting period.	Included in CEO statement. Our Northwest Pipeline won the AGA’s 2010 Safety Achievement Award; the Environmental Protection Agency honored our gas pipeline business with its 2010 Natural Gas STAR award of excellence based on 17 years of continuous methane emissions reduction
	Report Parameters
3.1	Reporting period for information provided.	Jan. 1 – Dec. 31, 2010
3.3	Reporting cycle	Annual
3.4	Contact point for questions regarding the report or its contents.	Julie Gentz, manager, external communications
3.5	Process for defining report content, including determining materiality, prioritizing topics within the report; and identifying stakeholders the organization expects to use the report	See About this report
3.6	Boundary of the report.	The financial data in this report includes all of Williams’ operations, including those outside of the U.S. Our greenhouse gas inventory data is reported on an operational basis. Employee data include our U.S. and Canadian operations. Apco Oil and Gas International, Inc. employees work directly for Apco, a separate entity which trades on NASDAQ – Williams owns a 69 percent interest.
3.12	Table identifying the location of the Standard Disclosures in the report.	Included in this table
	Governance, Commitments, and Engagement
4.1	Governance structure of the organization, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organizational oversight.	See Economic Impact and Governance
4.2	Indicate whether the Chair of the highest governance body is also an executive officer.	Mr. Frank McInnis, chairman of the board of Williams is not an executive officer and is an independent chair of the board.
4.3	State the number of members of the highest governance body that are independent and/or non-executive members.	With the exception of the CEO and president, and two honorary directors, all of the Williams directors are independent.
4.4	Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body.	Shareholders and others may contact Williams’ directors at corporatesecretary@williams.com. Employees may use the ethics hotline anonymously if desired.
4.6	Processes in place for the highest governance body to ensure conflicts of interest are avoided.	See our Business Code of Conduct and information on our ethics hotline.
4.8	Internally developed statements of mission or values, codes of conduct, and principles relevant to economic, environmental and social performance and the status of their implementation.	See our governance documents.
4.12	Externally developed economic, environmental and social charters, principles or other initiatives to which the organization subscribes or endorses.	Williams is a signatory to the Business Roundtable’s Climate Resolve initiative and a longtime member of EPA’s Natural Gas Star program. Williams has adopted the Model Code of Conduct for Corporate Political Spending developed by the Center for Political Accountability.
4.13	Association memberships	See the list of our trade association memberships.
4.14	List of stakeholder groups engaged by the organization.	See the list in the stakeholder engagement section.
4.17	Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting.	See our stakeholder engagement section here.
	Economic Performance Indicators
EC1	Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings and payments to capital providers and governments.	See our economic impact in the data tables.
	Environmental
EN11	Location and size of land owned, leased, managed in, or adjacent to, protected areas.	See the location of our federally leased lands here..(2007 report – page 34)
EN13	Habitats protected or restored.	Williams has worked with landowners, NGOs and state and federal government agencies to protect habitat for many years. See two recent examples in our environmental section.
EN16	Total direct and indirect greenhouse gas emissions by weight.	See our GHG emissions information in the environmental section and in the data tables.
EN23	Total number and volume of significant spills.	In 2010, Williams reported 183 spills. Of those, 123 were from our E&P operations, compared to 100 in 2009. Of those spills from our E&P group, 82 were attributable to our coal bed methane production, and the water released is often suitable for agricultural purposes. Midstream reported 38 unplanned releases, a slight decrease compared to 2009. Our gas pipeline operations reported 22 unplanned releases, compared to 17 in 2009.
EN26	Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation.	Preserving habitat and mitigating our environmental footprint is a large focus throughout Williams’ environmental practices. See more information here. 2009 report, page 16
	Social Performance Indicators
LA1	Total workforce by employment type, employment contract and region.	See the data tables for employment information.
LA4	Percentage of employees covered by collective bargaining agreement.	Williams has no employees covered by collective bargaining agreements.
LA7	Rates of injury, occupational diseases, lost days and absenteeism, and number of work-related fatalities by region.	See the company’s injury rates here. Williams had no work-related fatalities in 2010.
LA12	Percentage of employees receiving regular performance and career development reviews.	100% of Williams employees receive an annual performance review.
LA13	Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership and other indicators of diversity.	See our diversity and inclusion information in the People section.
LA14	Ratio of basic salary of men to women by employee category.	See our diversity and inclusion information in the People section.
	Society Performance Indicators
SO1	Nature, scope and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating and exiting.	See our information in the stakeholder section. In western Colorado where Williams has the large production impact, the company is a founding member of Community Counts – a partnership among operators, contractors, residents, municipalities, counties and the community at large.
SO3	Percentage of employees trained in organization’s anti-corruption policies and procedures.	All of Williams employees are required to take mandatory business ethics training. Employees involved in international business are required to take FCPA training.
SO5	Public policy positions and participation in public policy development and lobbying.	Williams talks directly, and through our trade associations, with state and federal legislators. Our participation in trade associations and lobbying activities are described in our governance section.
SO6	Total value of financial and in-kind contributions to political parties, politicians, and related institutions, by country.	Williams, and WILLCO PAC, disclose financial contributions to political campaigns on its website, and through the FEC website.