Regency Energy Services, LLC
Code of Business Conduct & Ethics
RES LLC Core Values
HONESTY: We will not say things that are false. We will never deliberately mislead. We will be as candid as possible, openly and freely sharing information, as appropriate to the relationship.
PROMISE-KEEPING: We will go to great lengths to keep our commitments. We will not make promises that can't be kept and we will not make promises on behalf of the Company unless we have the authority to do so.
FAIRNESS: We will create and follow a process and achieve outcomes that a reasonable person would call just, evenhanded and no arbitrary.
RESPECT FOR OTHERS: We will be open and direct in our communication, and receptive to influence. We will honor and value the abilities and contributions of others, embracing the responsibility and accountability for our actions in this regard.
COMPASSION: We will maintain an awareness of the needs of others and act to meet those needs whenever possible. We will also minimize harm whenever possible. We will act in ways that are consistent with our commitment to social responsibility.
INTEGRITY: We will live up to
RES LLC's ethical principles, even when confronted by personal, professional and social risks, as well as economic pressures."
Other than for gifts with a value of no more than U.S. $50 given or received in the normal course of business, neither you nor your relatives may give gifts to, or receive gifts from,
RES LLC’s current or prospective clients, vendors or any other commercial partners.
Presenting or accepting any other gifts to or from private commercial parties requires prior written approval from the RES LLC CEO and President, who must first review the proposed gift and assure it does not violate RES LLC Ethics Policies
Gift Policy Exceptions:
Exempted from this policy are gifts employees obtain, as members of the public, at events
such as conferences, training events, seminars, and trade shows that are offered equally to all members of the public attending the event.
This moderately priced entertainment is provided as part of a “working” meeting or session
to benefit and advance positive working relationships and company interests.
Gifts of food may be given to our clients or potential clients during the holidays and at other times of the year when gift giving is traditional and when it is intended to the entire staff during work hours in central or remote worksite locations.
Travel, Meals, and Entertainment Expenditures
RES LLC permits accepting or incurring proportionate and reasonable expenditures for travel, meals and entertainment expenses legitimately designed to show appreciation to existing business partners, present products and services, or establish cordial business relations, provided that such expenditures:
- are not excessive and always appropriate to the nature of business relationship with the recipient;
- conform to the laws and customs (as recognized by the written local law or a published judicial decision) of the country in which the expenditures are incurred, as well as the policies, rules or codes of conduct of the recipient's organization;
- do not place the recipient under an obligation or expectation to confer any business advantage in return for such hospitality (quid pro quo), or create an impression that the recipient’s independence will be affected; and occur only occasionally.
Before providing or accepting, directly or indirectly, any travel, meals or entertainment
expenditure reasonably valued at more than U.S. $250 per each guest, you must first obtain written permission from the RES LLC President or other Corporate Officer, who must review the proposed expenditure to insure it is within the “reasonable bounds "of ethical business practices and does not conflict with the intent of RES LLC’s Code of Business Conduct and Ethics, as well as the policies, rules or codes of conduct of the recipient’s organization.
Clients or Vendors may be invited on RES LLC excursions under the following condition:
- Travel to and from the excursion departure point, including airfare is the responsibility of the guest and will not be paid for RES LLC or one of our representatives
- All licenses(including hunting and fishing licenses), direct fees, and/ or taxes are the sole responsibility of the client and will not be paid for by RES, LLC or one of our representatives
- Guest can only be invited (attend) one RES LLC sponsored excursion per year.
- The Excursion or function is not in conflict (directly or indirectly) with the clients or vendors ethics policies.
Since the level of appropriate expenditures may vary significantly from country to country,
Managers of local business units are authorized to adopt lower hospitality limits for their
Dealing with government employees is often different than dealing with private persons. Many governmental bodies in the United States and abroad strictly prohibit the receipt of any gratuities by their employees, including meals and entertainment. LES LLC’s Anti
-Bribery Policy contains detailed rules applicable to interactions with government officials. You must be aware of and strictly follow the prohibitions set out in RES LLC’s Anti-Bribery Policy. In all cases, you must never directly or indirectly promise or give any type of gratuity, kickback, bribe, payoff or advantage (whether in cash or any other form) to officials of governmental units or any other organization, whether in the country of your residence or not.
Covering Up Mistakes; Falsifying Records
Mistakes will never be covered up, but should be immediately fully disclosed and corrected. Falsification of any RES LLC, client or third party record is strictly prohibited. If you are uncertain about whether a mistake has been made, you should seek guidance from your immediate supervisor or manager. All safety and environmental incidents, regardless of how small, must be reported immediately, to your supervisor
Protection of ADP, Client or Vendor Information
You may not use or reveal RES, LLC, client or vendor confidential or proprietary information to others. Additionally, you must take appropriate steps –including securing documents, limiting access to computers and electronic media, and proper disposal methods –to prevent unauthorized access to such information. Proprietary and/or confidential information includes, among other things, methods and practices, design,
procedures, pricing, reports, strategy, experimental research, and information about, or received from, RES, LLC current, former and prospective clients, vendors and their
associates. If you learn about any potential RES, LLC acquisition, disposition, joint venture or similar event, you must at all times keep that knowledge confidential and may not discuss it with any other person, including other RES, LLC employees. If you learn of any restricted information, through a rumor or any unauthorized source, you must immediately contact a Corporate Officer or report it though the Ethics hotline.
Gathering Competitive Information
When gathering competitive information, you must not violate our competitors’ rights.
You may not accept, use or disclose their confidential or proprietary information which includes information that provides a competitor with a business advantage and is not known to the public.
You may access and reference publicly available information such as annual reports, company web sites and publications, public presentations and public marketing documents, journal and magazine articles, stockbroker analyses, advertisements and other public media filings and offerings. Particular care must be taken when dealing with a competitor’s present and former clients, vendors and employees. Never ask for, accept or use confidential or proprietary information of our competitors or clients from anyone. Never ask any person to violate a non-compete or non-disclosure agreement or to reveal confidential or proprietary information.
You may never use any type of ruse, scheme, misrepresentation or omission to obtain any information -whether confidential or not. If you use third party consultants to assist in a search you must be extremely diligent that they strictly adhere to both the letter and spirit of this Code of Business Conduct & Ethics and that both the receipt and use of the gathered information is fully lawful. In no event may you use a third party to undertake activities that would be unacceptable or improper if conducted by RES, LLC or one of it’s
As a general rule, you should never engage in any course of action that you feel would be
inappropriate or unethical and/ or could be perceived to be inappropriate or unethical if
conducted by or on behalf of a competitor to obtain ADP information. If you are uncertain what may be obtained or used, a RES Corporate Officer can assist you.
Sales: Defamation and Misrepresentation
RES, LLC representatives will always seek to provide high value, safe, and ethical services, best suited to a client’s or prospect’s request or needs. It is each employee’s
obligation to ensure that clients and prospects are not offered products or services that have no beneficial value to the client or are not well suited to the client’s or prospect’s business needs. Selling must never include misstatements or lies about RES, LLC’s equipment, capabilities, and services; or about client’s or prospect’s needs. Spreading rumors, even indirectly, about our competitors, their products or their financial condition is strictly prohibited
No RES, LLC employee or officer will take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
Fair Competition and Antitrust Laws
RES, LLC and our employees must comply with all applicable fair competition and antitrust laws. These laws attempt to ensure that businesses compete fairly and honestly and prohibit conduct seeking to reduce or restrain competition. If you are uncertain whether a contemplated action raises unfair competition or antitrust issues, anyone of the Corporate Officers can assist you.
Reporting Ethical Violations
Your conduct can reinforce an ethical atmosphere and positively influence the conduct of fellow employees. If you are aware of or suspect misconduct, it is your legal and moral
responsibility to report it to the appropriate level of management. If you are still concerned after speaking with your manager or feel uncomfortable speaking with them, you must (anonymously, if you wish):
- Contact the RES, LLC Ethics Hotline by:
- Direct phone:1-307-857-1885 (Accessible from all locations); or
- Email: Send an email to ethics@Regency-Energy-Services.com ;or
- Mail: Send a detailed note with relevant concerns, to Regency Energy Services, LLC, P.O. Box 1899 Riverton, WY
Any reports or conflicts that involve the President, Chief Executive Officer, Chief Financial
Officer, or General Counsel will be immediately communicated to the remaining Officers.
Your calls, detailed notes and/or emails will be dealt with confidentially, unless it is necessary to share such information in order to address the matter appropriately. Regardless, you have the commitment of RES, LLC and of Corporate Management
that you will be protected from retaliation.
Nothing in this or any other RES, LLC policy prohibits you from providing information to any government agency in a manner contemplated by relevant law or regulation.
In the final analysis you are the guardian of RES, LLC ethics. While there are no universal rules, when in doubt ask yourself:
- Will my actions be ethical in every respect and fully comply with the law and with RES, LLC as well as our Clients or Vendors policies?
- Will my actions have the appearance of impropriety?
- Will my actions be questioned by my supervisors, associates, clients, vendors, family and the general public?
- Am I trying to fool anyone, including myself, as to the propriety of my actions?
If you are uncomfortable with your answer to any of the above, you should not take the
contemplated actions without first discussing them with your regional supervisor or corporate management. If you are still uncomfortable, please follow the steps outlined above in the Section on "Reporting Ethical Violations." All employees, and managers in particular, are responsible for creating an environment that both facilitates open discussion of issues and makes it easy and comfortable to raise concerns without a fear of reprisal.
Any employee who ignores or violates any of RES, LLC's ethical standards, or who penalizes a subordinate for trying to follow those standards, or willfully or knowingly omits to tell the entire truth during any ethics or other RES, LLC investigation, or obstructs, defeats or attempts to stop an ethics or other RES, LLC investigation, will be subject to progressive discipline, up to and including immediate dismissal. Moreover, it is not the threat of discipline that should govern your actions, but your understanding of RES, LLC’s moral responsibility to conduct our business operations with the highest ethical standards.
We hope you share our belief that a dedicated commitment to ethical behavior is the right thing to do and the surest way for RES, LLC to remain a highly ethical and successful company.
Sheldon Van Voast
Regency Energy Services, LLC