Use of Insider Information

ONE Gas employees, officers and board members must exercise care not to use insider information in trading securities.

It is illegal to buy or sell securities (including, for example, stock, bonds or options) of a company including company securities at a time when you are aware of “material, non-public information” or “insider information.”

Communicating insider information to someone who may buy or sell company securities is also prohibited. The prohibition on insider trading applies to the company’s securities and to securities of other companies if the employee, officer or board member learns of material non-public information about those other public companies in the course of his or her duties for the company. This prohibition also extends to certain non-employees who may learn about material non-public information about the company, such as spouses, relatives and close friends of employees, officers and board members.

Violations can lead to significant penalties. Such a violation could occur when, for example, an employee buys or sells company stock based on material, non-public information they learned in the workplace. A violation also may occur if such insider information is communicated (or “tipped”) to another person.

Company board members, officers and certain designated employees are subject to further restrictions such as trading in company securities only during trading windows. The trading window generally opens on the third business day following a public quarterly and/or annual earnings announcement and remains open until the first day of the following calendar quarter.

Information about potential acquisitions or other significant corporate transactions poses special insider trading risks. Even within the company, such information should be shared only with those employees who have a “need to know” the information. ONE Gas employees who become aware of such information should avoid trades in ONE Gas securities and any other company involved in a potential transaction (or communications with others that lead to such securities trades).

If you have any doubt whether it would be appropriate to trade ONE Gas securities, consult with the Corporate Secretary.

Insider trading is both unethical and illegal. To review the policy and for specific employee reporting procedures, refer to the ONE Gas Securities/ Insider Trading Policy posted on the ONE Gas Hub.

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