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ONE Gas expects all employees, officers and board members to protect confidential and proprietary information.

ONE Gas employees, officers and board members often will have routine access to confidential information. Confidential information means any information relating or belonging to ONE Gas or any affiliated company that has economic or competitive value and is not available to the general public.

Confidential or proprietary information may include, but is not necessarily limited to: information relating to customers; business plans, strategies, philosophies or dealings; information regarding officers or employees; financial information and plans; information regarding company disputes, litigation or compliance matters; any document marked “confidential”; any information that employees might reasonably expect to be regarded as confidential, such as personally identifiable information and/or medical records; and any information that has been provided to the company in confidence by any customer, supplier or other person. You should assume information about the company is private unless it has clearly been made public by an authorized representative of the company.

With respect to federal and other public sector customers, laws and regulations applicable to ONE Gas’ government contracts business prohibit the unauthorized disclosure and receipt of non-public information, including pricing information and pricing estimates (i) prepared by or for use by a government agency for the purpose of evaluating a government contract bid or proposal (“Source Selection Information”) or (ii) submitted to the federal government by competitors or others as part of or in connection with a federal government contract bid or proposal (“Bid or Proposal Information”). ONE Gas employees must not disclose or receive non-public Source Selection Information or Bid or Proposal Information unless the receipt or disclosure is pursuant to performance of a contract with the government agency and specifically authorized by such contract.

ONE Gas employees must not request, accept, or share nonpublic Bid or Proposal Information or Source Selection Information under any circumstances, absent management knowledge and consent. If you receive information that you are not sure you or ONE Gas should have, contact the Chief Compliance Officer immediately before reviewing the information or sharing it with any other employees or third parties.

Confidential information must not be disclosed to anyone outside the company and should be disclosed internally only to those who need the information to perform their duties. The obligation to safeguard confidential information continues even after the employee, officer or board member leaves the company.