This Code Applies to All of Us

This Code applies to every ONE Gas employee, officer and member of our board of directors, (“board members”).

Additionally, ONE Gas will only engage subcontractors, vendors and other third-parties representing the company who demonstrate business integrity and compliance with applicable laws and regulations.

It is the obligation of each of us to read and understand this Code and to integrate its standards into every aspect of our business. Each of us must follow these standards as we do our daily jobs.

We are each responsible for complying with this Code, reporting suspected violations and cooperating with the company’s investigation of potential violations.

Annual acknowledgment of the Code is required by each ONE Gas employee, officer and member of our Board of Directors. By acknowledging the Code, you are stating you understand the expectations and will follow them.

If you are unsure about how this Code applies to a particular situation, you should contact any of the individuals identified under “Resources for Asking Questions or Reporting Concerns.”

Questions of law and business ethics do not always lend themselves to simple answers. You legitimately may be unsure about how the Code applies to a particular situation. No Code of Business Conduct and Ethics can replace the thoughtful behavior of an ethical employee, officer or board member.

Questions may be directed to the Chief Compliance Officer, who administers this Code. The Chief Compliance Officer is the person responsible for overseeing and monitoring this Code and making it work companywide. Often, a single question asked to the Chief Compliance Officer can help the company and our employees avoid serious ethical and legal problems.

Reporting and Effect of Violations

Every employee, officer and board member has a duty to adhere to this Code and all company policies. Supervisors and others who receive reports of potential code violations play a very important role in upholding the Code. ONE Gas encourages supervisors to talk to their employees about their concerns. Supervisors and others who receive reports of potential Code violations need to be prepared and know how to handle any concerns or reports regarding the Code. ONE Gas is committed to cultivating a culture of trust through the proper handling of potential violations.

Questions & Answers

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