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Violations of Accounting Practices and Internal Controls

Failure to comply with the company’s accounting, internal accounting controls or auditing practices could have severe consequences for ONE Gas and our stakeholders.

If you have concerns with respect to these matters, you have several resources available to you.

Chairman of the Audit Committee

Attn: Brian Shore
c/o ONE Gas, Inc.
P.O. Box 24019
Tulsa, OK 74121

General Counsel

Joseph L. McCormick
[email protected]
918.947.7049

ONE Gas, Inc.
Attn: Legal Department
P.O. Box 24019
Tulsa, OK 74121

Internal Audit

Rex V. Wilson
[email protected]
918.947.7124

ONE Gas, Inc.
Attn: Internal Audit
P.O. Box 24019
Tulsa, OK 74121

ONE Gas has a Whistleblower Policy. Failure to comply with these provisions can lead to disciplinary action up to and including termination. Please review our Whistleblower Policy under the Corporate Compliance tab on the ONE Gas Hub. If you are aware of an actual or potential violation of this policy, you should report your concern to the individuals or departments listed above. You may also call the ONE Gas Compliance & Ethics HelpLine at 855-654-5560, send an email to [email protected], or submit your concern via the web at ethics.onegas.com.

What Happens After Reporting a Suspected Code Violation

Investigation Process

When a report of a possible Code violation is received through any of the channels mentioned above, ONE Gas will investigate the facts. When making reports anonymously, please provide sufficient information concerning the identity of the person(s) involved, dates the incident happened and other details needed for a full investigation. For example, a report that “a supervisor discriminates against me” does not provide sufficient details, but a report that “First Name Last Name discriminated against me by not allowing me the same number of breaks as my co-worker on x date” provides enough details to assist the investigator.

Often, further questions by the investigator are necessary; however, if the reporter is anonymous the investigator will not be able to contact them. The investigation may stall when enough detail is not received and/or the reporter does not answer the questions posed by the investigator. Questions can be posted to Convercent and you can call Convercent or use the Internet-based system using your unique report number and passcode. If you are comfortable giving your name and contact information, please do so. This can help in the investigative process, and ONE Gas enforces the non-retaliation policy fully. However, you can answer anonymously through Convercent. Investigations typically involve confidential interviews and document reviews, and in most cases the results will not be known to the reporter.

Disciplinary Actions

When there is a finding that a violation of law, policy or the Code occurs, employees are subject to disciplinary actions, up to and including termination. Discipline is determined by management. All personnel issues will remain confidential and communicated to only those with a need to know. Contract workers are subject to the Code, and may not be retained if a violation of the Code occurs.

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