Prohibiting Workplace Discrimination and Harassment Policy

Policy Statement

Consistent with our Core Values and Beliefs, Code of Conduct and our legal obligations, the Company is committed to providing a workplace free of discrimination. Discrimination by anyone is expressly prohibited.

Related Policies

Equal Employment Opportunity

Workplace Violence Risk Reduction and Response

Responsibilities

Williams will make every effort to see that the Company’s actions and those of our agents and supervisory employees are free from forbidden discrimination against or harassment of employees and applicants for employment.

Prohibition Against Retaliation

The Company will not tolerate retaliation against any employee for making a complaint of discrimination or harassment in good faith or for cooperating in an investigation. Appropriate disciplinary action will be taken against any individual who interferes with an investigation or engages in retaliation in violation of this policy. If discrimination, harassment or retaliation in violation of this policy is established, the Company will take appropriate corrective action, up to and including termination of employment. Third parties found to have acted in violation of this policy will be subject to removal from the premises and discontinuance of any business relationship.

Related Procedures

It is a violation of this policy for any individual to discriminate against or harass a Company employee, contractor, vendor, or any other individual who has a working relationship with the Company. It is every employee’s responsibility to promptly report any incidents of suspected discrimination or harassment so that corrective action may be taken. Any incidents of discrimination or harassment should be reported to your Human Resources Business Partner, who is responsible for initiating an investigation and/or appropriate remedial action of any suspected violations of this policy. An employee may also (or alternatively) report suspected violations of this policy to his or her immediate supervisor or any other member of management, the Business Ethics Resource Center or the Action Line at 800-324-3606. Supervisors and managers who receive complaints, or who observe discriminating or harassing conduct, should immediately inform their Human Resources Business Partner so that an investigation and/or appropriate remedial action may be initiated. The Company will keep information regarding complaints of discrimination or harassment and the terms of the resolution in as confidential a manner as possible consistent with a full, fair and proper investigation.

Consequences/Penalty for Non-Compliance

Adherence to policies is mandatory. Non-compliance with this policy may result in disciplinary action up to and including termination.

Reservation of Rights

The Company reserves the right to interpret, modify, terminate, or revise this policy or standard, in whole or in part, without notice. No provision in this policy or standard shall be construed as an employment contract or construed to alter any employee’s at-will status. Similarly, statements within this policy or standard regarding behavior that may result in discipline or termination do not limit, in any way, the rights of the Company to discipline or terminate employees for only those behaviors described or referenced above. Each employee remains free to resign his or her employment at any time and for any reason or for no reason. Similarly, Williams reserves the right to terminate any employee at any time for any reason or for no reason. Williams reserves the right to terminate an employee with or without the use of progressive discipline.

Terms and Definitions

Harassment

Harassment includes, but is not limited to, verbal, physical, and visual conduct, or written or electronic material, that creates an intimidating, offensive, or hostile working environment and that has the purpose or effect of interfering with an employee’s work performance.

Harassing Conduct

Harassing conduct can take many forms and includes, but is not limited to, the following: slurs, epithets, jokes, pictures, cartoons, statements, gestures, threats, assault, unwelcome physical contact, or other conduct that interferes with an individual’s normal work performance.

Sexual Harassment

Sexual harassment, which is one form of forbidden discrimination, is defined as any unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature because of an individual’s sex when: (1) submission to the conduct is made either an explicit or implicit condition of employment; (2) submission to or rejection of the conduct is used as the basis for an employment decision; or (3) The conduct unreasonably interferes with an individual’s work performance or creates an intimidating, hostile, or offensive work environment. Sexually harassing conduct can be by a person of either the same or opposite sex.

Roles and Responsibilities

Employees

All employees are responsible for adhering to this policy and for promptly reporting any suspected violation of this policy at the time they experience or otherwise become aware of it so that an appropriate investigation may be initiated.

Supervisory Employees

All supervisory employees have the responsibility to endorse and support this policy, to serve in a leadership role regarding compliance with this policy, to ensure their respective work areas are free of discrimination and harassment, including sexual harassment, and to take prompt action to notify Human Resources of any suspected violations of this policy.