Code of Business Conduct

Table of Contents

Our Core Values
Introduction
Ethics & Compliance Program Resources
Issue Resolution Process
Antitrust and Competition Laws
Business Communications
Company Assets
Conflicts of Interest
Employment Practices
Entertainment, Favors, and Gifts
FERC Standards of Conduct
Financial Integrity
Health, Safety, and Environment
Political Activities and Contributions
Safeguarding Important Information
Securities Laws and Insider Trading
Suppliers, Contractors, and Customers
Transacting International Business
Ethical Decision Making Model

Our Core Values
In most situations, our personal values guide us to the right decision. Within our business, we believe that the company's core values should guide our decisions, actions, and conduct. We strive to ensure that every decision we make and action we take demonstrates our values. We believe that putting our values into practice creates lasting benefits for all our associates, shareholders, and the communities in which we live.

We are an exceptional company committed to:

Stewardship
We will serve our fellow employees, our customers, and our shareholders by consistently building long-term value.

Integrity
In all we do, we will be ethical, honest, and forthright.

Safety
Safety is an absolute for employees, for contractors, and for the communities where we operate.

Accountability
We expect to be judged by the successful execution of our commitments.

Excellence
We will prevail by setting and meeting the highest standards.

These core values support and guide our leadership in establishing the strategic direction of the company. El Paso Corporation employees, officers, and directors and the company's business partners are expected to conduct their business in accordance with these ethical principles. We must not simply comply with laws, regulations, and policies; we must work according to our ethical principles and endeavor to conduct ourselves in a manner beyond reproach. El Paso's reputation is based on the personal integrity of each of its employees, officers, and directors and those with whom we do business. Sound judgment must be exercised in the service of our reputation as a global business leader, employer of choice, and good corporate citizen.

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Introduction

El Paso's Commitment
El Paso Corporation is committed to upholding high business standards in our worldwide operations wherever they may be. Our company recognizes the importance of honesty, credibility, integrity, and trust to our success.

Purpose of the Code
Our Code of Business Conduct (the Code) has been adopted by the company's board of directors and establishes our high standards of ethical and legal behavior for all El Paso Corporation employees, officers, and directors. It provides emphasis to our commitment as a corporate family to ethics and compliance with the law. It alerts employees, officers, and directors to critical issues, which require consideration and caution. The Code is also a preventive tool—one designed to equip employees, officers, and directors with the knowledge to prevent violations as well as to detect violations of company policies and procedures and applicable laws and regulations.

The purpose of the Code is to establish general standards:

• To deter wrongdoing.
• To promote compliance with applicable governmental laws, rules, and regulations.
• To encourage honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
• To promote full, fair, accurate, timely, and understandable disclosure in reports and documents that the company files with, or submits to, governmental agencies and in other public communications made by the company.
• To communicate accountability for adherence to the Code.
• To advance the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code.

The Code together with the company's policies and procedures forms El Paso's Ethics & Compliance program. The company believes that the Code exceeds the requirements of the definition of a "Code of Ethics" contained in the regulations of the United States Securities and Exchange Commission issued pursuant to Section 406 of the Sarbanes-Oxley Act of 2002 and the corporate governance rules of the New York Stock Exchange regarding codes of business conduct. In addition, this Code enhances the company's Ethics & Compliance program as one that, under the United States Sentencing Guidelines, is reasonably designed, implemented, and enforced to be generally effective in preventing and detecting criminal conduct. While the Code sets out in general terms our standards of integrity and business conduct, no code can address every situation that individuals may encounter. The omission of a specific act from the Code does not mean that act is acceptable and/or lawful. As a result, this Code is not a substitute for our responsibility and accountability to exercise good judgment and obtain guidance on proper business conduct. We are encouraged to seek additional guidance and support from those designated as responsible for business conduct matters. Ultimately, we must rely on our judgment to determine the right thing to do to maintain our personal and corporate integrity.

Applicability of the Code
This Code of Business Conduct applies to El Paso and its subsidiaries and affiliates, including all business units in all of our offices and locations around the world. All employees, officers, and directors (collectively, El Paso personnel) are expected to be familiar with the Code and to apply it in the daily performance of their work-related responsibilities. The Code is applicable to non-employee directors in their capacities as members of El Paso's board of directors. In addition, El Paso will seek business partners whose policies are consistent with our own.

When any one of us fails to live up to the expectations outlined in our Code, we could collectively suffer the repercussions—not only in the form of fines or other legal penalties, but also in the form of damage to our reputation as well as the loss of customers, profitability, and the loyalty of our employees and the community. Employees, officers, and directors who violate the Code—or who knowingly permit another to do so—are subject to disciplinary action up to and including termination of employment (or board membership if applicable) and other appropriate measures. Disciplinary action for violations will be applied consistently and fairly throughout the company.

It is El Paso's policy to comply with applicable laws and regulations. Some company policies are based on the requirements of applicable laws and regulations, and others are simply good ethics and business sense. Because the company is organized under U.S. law and its securities are publicly traded, the company, including some of El Paso's business outside the United States, is governed primarily by U.S. law. If compliance with this Code or with U.S. law appears to conflict with local customs, norms, laws, or regulations, El Paso personnel should contact the Law department or the Ethics & Compliance Office for assistance in resolving the conflict.

Responsibilities of the Company
The company will provide a work environment in which high standards of ethical behavior are recognized and practiced.

The company will ensure that all El Paso personnel are aware of and understand the Code.

The company will make appropriate training on the Code and company policies and procedures available to El Paso personnel.

The company will provide safe and confidential resources for El Paso personnel to seek advice on business ethics expectations and to raise any concerns or report any violations of the Code, company policies and procedures, or applicable laws and regulations.

The company will not tolerate retaliation toward any El Paso personnel who, in good faith, report, supply information about, or assist in an investigation into a business ethics concern or possible violation of the Code, company policies and procedures, or applicable laws and regulations.

Responsibilities of Employees
Employees will read and understand not only the standards contained in the Code, but also the values on which they are based. Employees also have an obligation to comply with the letter and the spirit of this Code and to encourage others to do the same. Employees are personally responsible for abiding by the Code, all applicable El Paso policies and procedures, and all applicable laws and regulations as well as for behaving in a highly ethical manner as they conduct business.

Employees will be alert to and will promptly raise any concerns or report any violations of El Paso's Code of Business Conduct in accordance with the company's issue resolution process described in the Code.

Employees will regularly review the Code and shall participate in ethics and compliance training that relates to their areas of responsibility to learn about business ethics expectations and applicable laws and regulations.

Employees will cooperate fully and honestly in the company's investigation of alleged illegal or unethical activity when called upon.

Employees shall not knowingly help another person conduct business in a manner contrary to the company's five core values or in violation of the Code, company policies and procedures, or applicable laws and regulations.

Employees shall honestly complete the Certificate of Compliance to the Code.

Responsibilities of Company Leadership
Company leadership will set the "tone at the top" by modeling exemplary ethical business conduct.

Company leadership will make sure that employees understand that nothing is more important than ethical business conduct and compliance with the Code, company policies and procedures, and applicable laws and regulations.

Company leadership will ensure that each employee knows and understands the Code and relevant policies and procedures and how to apply them.

Company leadership will ensure that every new or transferred employee receives a copy of the Code.

Company leadership will communicate the company's high ethical standards to all direct reports through formal and informal communications and will encourage discussion of the ethical and legal implications of business decisions.

Company leadership will monitor and ensure compliance with the Code by employees and others who do business on behalf of the company in their areas of responsibility.

Company leadership will provide appropriate business ethics training for employees. In addition, company leadership will ensure that employees receive the information and/or training necessary to complete their jobs.

Company leadership will avoid hiring or delegating authority to any individual who they have reason to believe or should know has a tendency to engage in unlawful conduct or unethical activities.

Company leadership will be open and available to employees and others who do business on behalf of the company to discuss ethical and legal business conduct concerns and will provide appropriate resources to answer any questions.

Company leadership will encourage employees to seek advice or help without fear of punishment or reprisal.

Company leadership will deal effectively with ethical and legal business conduct concerns that arise in their business units.

Company leadership will prevent retaliation toward any employee who, in good faith, reports, supplies information about, or assists in an investigation into an ethical or legal business conduct concern.

Company leadership will sustain a work environment in which employees and others who do business on behalf of the company know that ethical and legal behavior is expected of them.

Responsibilities of Board Members
Board members will set the "tone at the top" by modeling exemplary ethical business conduct.

Board members will read and understand not only the standards contained in the Code, but also the values on which they are based. Board members also have an obligation to comply with the letter and the spirit of this Code and to encourage others to do the same. Board members are personally responsible for abiding by the Code, all applicable El Paso policies and procedures, and all applicable laws and regulations, as well as for behaving in a highly ethical manner as they conduct business.

Board members will avoid hiring or delegating authority to any individual who they have reason to believe or should know has a tendency to engage in unlawful conduct or unethical activities.

Board members will monitor company leadership to ensure ethical business conduct and compliance with the Code, company policies and procedures, and applicable laws and regulations.

Board members shall honestly complete the Certificate of Compliance to the Code.

Monitoring
The Ethics & Compliance Office has procedures in place to monitor El Paso personnel's compliance with the Code, all applicable El Paso policies and procedures, laws, and regulations. The Corporate Audit department will routinely conduct audits of issues that have regulatory or compliance implications.

Oversight
The Audit committee of the company's board of directors shall have oversight of the administration of the Code and responsibility for the Ethics & Compliance program within the company. Significant or material events related to the company's Ethics & Compliance program shall be reported immediately to the chair of the Audit committee. At least once a year, the chief ethics officer shall report to the Audit committee regarding the company's Ethics & Compliance program activities and of the occurrence of all significant events relating to the Code.

Certificate of Compliance
The Certificate of Compliance is given to all new El Paso personnel and is sent to El Paso personnel annually by the Ethics & Compliance Office on behalf of the Audit committee. The Certificate of Compliance contains an acknowledgment that the signer has read the Code and is in compliance with its requirements. Except where expressly prohibited by written law, completing and returning a signed Certificate of Compliance is a condition of employment.

Waiver
No waiver of a provision of the Code may be made for executive officers and directors except with the prior approval of the board of directors.

Effective Date of the Code of Business Conduct
The Code is effective as of April 2004 and supercedes any prior similar documents, including the Code entitled Ethics in Practice: Our Code of Business Conduct. The Code does not replace any other published policies and procedures of El Paso, including other work rules and personal conduct policies. While the company will continue to release its Code of Business Conduct in hard-copy form at regular intervals, the Code is intended to be a living document that will be reviewed periodically and revised and updated as needed. In addition to the hard-copy version that all El Paso personnel are provided, the Code also appears in the Ethics section of the company's intranet site and the Governance section of the company's Internet site. Although El Paso personnel will not be required to certify they have read and agree to abide by any revisions to the electronic version of the Code, compliance with its provisions is mandatory. We welcome your comments and suggestions.

El Paso Corporation expressly states:

• It reserves the right to unilaterally change at any time the Code or the company's policies and procedures.
• Nothing contained in the Code or the company's policies and procedures shall be construed or applied as binding interpretation or definition of the law or industry practice.
• Nothing contained in the Code or the company's policies and procedures is intended by the company to be, nor shall it be, construed as an employment agreement.
• Any act by El Paso personnel in violation of the Code or the company's policies and procedures, as well as any U.S. or foreign law or regulation, is beyond the scope of such person's authority and is not an act by or on behalf of El Paso.

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Ethics & Compliance Program Resources

Ethics & Compliance Office
The Ethics & Compliance Office is responsible for the company's Ethics & Compliance program. It is available to help all El Paso personnel make appropriate decisions on policy matters or conduct issues. El Paso personnel can contact the Ethics & Compliance Office:

• To ask questions about the Code, company policies and procedures, and laws and regulations.
• To seek advice on business conduct issues.
• To report potential violations of the Code, company policies and procedures, and laws and regulations.

Ethics & Compliance Committee
An Ethics & Compliance committee oversees the Ethics & Compliance Office. This committee reports to the board of directors. The list of committee members can be found in the Ethics section of the company’s intranet site.

Ethics & Compliance Business Unit Liaisons
Business unit liaisons from Human Resources support the Ethics & Compliance program and are available to answer questions about company policies and to give advice on business conduct issues. The list of business unit liaisons can be found in the Ethics section of the company's intranet site.

Ethics & Compliance Office Intranet Site
Detailed information about the Ethics & Compliance program can be accessed in the Ethics section of the company's intranet site by selecting the Ethics icon. The resources available there include:

• This Code of Business Conduct.
• Directions on contacting the Ethics & Compliance Office.
• Ethics & Compliance committee members.
• Ethics & Compliance business unit liaisons.
• Company policies.
• Ethics & Compliance training materials.
• Ethics & Compliance guidelines.

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Issue Resolution Process

Asking Questions and Reporting Concerns
Don't hesitate to ask a question about legal and ethical business conduct. You will not be disciplined, lose your job, or be retaliated against in any way for asking questions or reporting concerns about our legal or ethical obligations, as long as you are acting in good faith. Good faith does not mean that you have to be right—but it does mean that you believe you are providing truthful information. The important thing is that you bring your question or concern to the company's attention through one of the many available channels.

As a first step, talk with your supervisor or manager. If that is uncomfortable or impractical, you may contact a member of the Human Resources department, the Law department, an Ethics & Compliance business unit liaison, a member of the Ethics & Compliance committee, or the Ethics & Compliance Office.

Contacting the Ethics & Compliance Office
The Ethics & Compliance Office can be reached any of the following ways:

Telephone Number
(713) 420-4010

Helpline Number
Toll-free (800) 492-4985
TDD/TTY (800) 410-9934

The Helpline is available 24 hours a day, seven days a week. In addition to English, communication specialists fluent in other languages may be available. When needed, translation services will be offered promptly.

Email Address
ethics@elpaso.com

Electronic Submission
An electronic submission form is available in the Ethics section of the company's intranet site.

Fax Number
(713) 420-2162

Mailing Address
Ethics & Compliance Office
El Paso Corporation
1001 Louisiana Street
P. O. Box 2511
Houston, TX 77252-2511

While the telephone in the Ethics & Compliance Office will be answered only during the company's business hours, a message may be left on voice mail, and your call will be returned if you leave a return telephone number. The toll-free Helpline number, email address, intranet form, fax number, and mailing address may be used 24 hours a day, seven days a week.

Although you are encouraged to identify yourself to assist the company in effectively addressing your concern, you may choose to remain anonymous, and we will respect your choice. The Helpline is not equipped with caller ID, recorders, or other devices that can identify or trace the number from which you are calling. The form available for electronic submission through the Ethics section of the company's intranet site may also be submitted anonymously.

Investigations
The company is committed to investigating promptly all reported concerns to the extent possible. Once a concern is reported, you can expect the following:

• Your report will be taken seriously.
• Your report will be carefully evaluated before it is referred for investigation.
• Your report will be investigated by the appropriate people that may include representatives from the Ethics & Compliance Office, the Law department, Human Resources, Corporate Security, and Corporate Audit.
• Your report will be handled promptly, discreetly, and professionally. Discussions and inquiries will be kept in confidence to the extent appropriate or permitted by law.
• If appropriate, you can obtain certain follow-up information about how the company addressed your report.

The Ethics & Compliance Office will coordinate any investigation and recommend needed corrective action or changes. All El Paso personnel must cooperate fully with investigations of alleged violations.

Disciplinary Action
Employees, officers, and directors who violate the Code—or who knowingly permit another to do so—are subject to disciplinary action up to and including termination of employment (or board membership if applicable) and other appropriate measures. Disciplinary action for violations will be applied consistently and fairly throughout the company.

Non-Retaliation Policy
El Paso will not tolerate any reprisal or retaliation against a person who in good faith reports a known or suspected violation of a law, regulation, company policy, or the Code. El Paso personnel who believe they have been retaliated against should contact Human Resources or the Ethics & Compliance Office immediately. El Paso personnel who retaliate against other El Paso personnel for reporting a problem will themselves be subject to disciplinary action, up to and including termination of employment.

Any El Paso personnel who knowingly report false or misleading information will be subject to disciplinary action.

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Antitrust and Competition Laws

The United States and many other nations in which we do business have antitrust laws as well as other laws and regulations designed to promote free and fair competition. U.S. antitrust laws may apply to El Paso's activities in other countries whenever they have an impact on domestic or foreign commerce. A violation of U.S. and/or foreign laws and regulations may result in serious criminal and civil sanctions for both corporations and individuals.

• We believe in free and open competition, and we fully comply with all applicable policies, laws, and regulations.
• We conduct our business in an open, vigorous, and competitive fashion.
• We make our own decisions on the basis of the best interests of the company, completely independent of and free from any understanding or agreements (including tipping or signaling) with any competitor.
• We set our own prices, unilaterally and at lawful levels.
• We avoid discussing non-public information with competitors regarding pricing, marketing, capacity, production, territorial agreements, or anything else that could be interpreted as limiting competition. We neither discuss nor agree with our competitors to fix prices, control supplies, allocate markets, set production levels, boycott customers or suppliers, or limit the sale of our products and services, nor do we enter into any anticompetitive agreements with our suppliers or customers.
• We do not use our size or historical position to intimidate any person or organization nor to coerce anticompetitive conduct.
• We do not suggest or imply that suppliers to or customers of our company are required to purchase products or services from us.
• We do not make false, misleading, or inaccurate statements about our products and services or those of our competitors.

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Business Communications

• Business records and communications may become known to the public through litigation, government investigations, and the media. Accordingly, in all written and oral business communications, it's important to tell the truth and to avoid exaggeration, inappropriate language, and derogatory remarks or characterizations. This applies to communications of all kinds, including email, voice mail, daily planner notes, and other informal notes or memos. Irrespective of where it is written, what is written may have significant consequences.
• We provide accurate information when promoting our products and services or responding to inquiries from customers, other El Paso personnel, the media, regulatory agencies, or shareholders. We do not make misleading, false, or exaggerated claims concerning our products and services or those of our competitors.
• We state only El Paso's view and not our own when communicating in a forum in which audiences would reasonably expect that we are speaking as representatives of El Paso.
• We strive to communicate with the public in an accurate and consistent manner, so only those who are specifically trained in particular areas and whose job responsibilities include communications with the public or the media will make those communications.
• We encourage free and open discussion.
• We listen and speak with the goal of understanding.
• When we disagree, we do so respectfully, treating each other with dignity.
• We exercise good judgment when using email and the Internet at work.
• We do not use company letterhead, company email, or reference to our business address or title when expressing a personal view in a public forum.
• We retain and destroy records of all kinds, including electronic records, according to our policy on records retention.

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Company Assets

Company assets include, but are not limited to, such things as email, computer systems, documents, equipment, facilities, information, the company's logo and name, materials, and supplies. We will use and maintain these assets with the utmost care and respect, guarding against waste and abuse, to conduct the company's business. Proper use of company assets is the responsibility of all El Paso personnel. Personal use of company resources on an occasional and limited basis is acceptable, provided there are no measurable increased costs to the company. The use of the company's assets and resources for personal financial gain is strictly prohibited.

• We use company assets to fulfill company goals and purposes.
• We use our best efforts to protect all El Paso assets from loss, damage, misuse, or theft and to assist El Paso in its efforts to control costs.
• We are cost-conscious and alert to opportunities for improving performance while reducing costs.
• We protect not only El Paso's assets, but also the assets of others with which we are entrusted. These assets include physical property as well as intellectual property, such as confidential or proprietary information, copyrighted works of authorship, and trademarks.
• We do not make or use any unauthorized copies of software, tapes, books, or other legally protected work.

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Conflicts of Interest

Conflict of interest generally describes any situation in which an individual's own interest may influence the way he or she conducts company business. A conflict of interest can arise when private interests interfere—or appear to interfere—with our company's business. El Paso prohibits such conflicts of interest because they impair our ability to make objective decisions for our company. The divided loyalty caused by a conflict of interest can result in personal harm and could damage our company's reputation. These conflicts usually involve situations from which El Paso personnel (or their family members) can improperly benefit personally as a result of their position with the company.

• We make business decisions in the best interest of the company and our shareholders regardless of our personal interests or those of our business units.
• We deal with our suppliers, contractors, and customers fairly and impartially—free from any conflicting interests.
• We strive to prevent conflicts of interest from arising by avoiding circumstances where El Paso's interests could be compromised. Where potential conflicts are identified, we take the appropriate steps to ensure that the company's interests are properly safeguarded.
• We scrupulously avoid even the appearance of a conflict between improper personal interests and those of the company in matters of importance to the company's business.
• We avoid any investment, interest, association, or activity that may cause others to doubt our or the company's fairness or integrity, or that may interfere with our ability to perform job duties objectively and effectively.
• We refrain from actions that might impair our independent judgment or provide an unfair advantage to a supplier, contractor, or customer.
• We do not take for ourselves or for others outside of the company opportunities that belong to the company.

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Employment Practices

El Paso recognizes that its two most important assets are its employees and its integrity. These assets are inseparable. The company will endeavor to recruit and retain high-caliber employees who reflect the company's core values.

• We are committed to providing employees with a working environment free of discrimination, harassment, intimidation, or coercion relating directly or indirectly to age, race, color, national origin, sexual orientation, gender, pregnancy, disability, religion, or veteran status.
• We hire, evaluate, and promote employees on the basis of their abilities, achievements, experience, and performance regardless of age, race, color, national origin, sexual orientation, gender, pregnancy, disability, religion, or veteran status.
• We take pride in the diversity of our workforce and view it as a competitive advantage to be nurtured and expanded. We aspire to be an employer of choice committed to creating, managing, leveraging, and valuing diversity.
• We encourage a culture of mutual respect in which everyone understands and values the similarities and differences among El Paso personnel, our clients, and others with whom we do business.
• We are committed to building a work environment in which all El Paso personnel, our clients, and others with whom we do business are treated with respect, dignity, fairness, and courtesy.
• We respect individuality and aim to foster an environment in which people can perform to their highest potential.
• We provide a safe and professional working environment.
• We work to provide an atmosphere that encourages positive interaction and creativity among all El Paso personnel.
• We do not tolerate violence, discrimination, harassment, retribution, or retaliation in our workplace.

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Entertainment, Favors, and Gifts

El Paso is committed to the development of durable and long-term relationships with suppliers, contractors, customers, shareholders, and communities with whom the company interacts. Our integrity and good name are fundamental to the creation of such relationships.

• We select products and services on the basis of price, quality, and service. We expect our customers to purchase our products and services on the same basis.
• All business transactions are impartial, objective, and free of outside influence.
• We exchange gifts and social amenities such as business lunches, dinners, or entertainment with others when reasonably related to a clear business purpose and within the bounds of good taste and what is customary in a normal business relationship.
• We do not accept any gifts from third parties that may influence business decisions made on behalf of the company or that would create the appearance of influencing our business decisions.
• We avoid even the appearance of impropriety through participation in entertainment or the exchange of favors or gifts with third parties.

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FERC Standards of Conduct

Federal Energy Regulatory Commission (FERC) regulations restrict the ability of interstate natural gas pipelines and storage companies to give their marketing affiliates undue preferences over non-affiliated customers. These marketing affiliate standards of conduct were originally issued in 1988 in FERC Order No. 497, which has been supplemented and revised since that time. The FERC recently issued an order that extends and expands these regulations so that they apply to a broader category of all "energy affiliates." FERC's overall goal is to prevent interstate natural gas pipeline and storage companies from giving undue preferences to any of their energy affiliates, as defined in the Order, to ensure that services are provided on a non-discriminatory basis. A violation of these regulations could result in sanctions.

• We fully comply with all applicable regulations in this area, including organizational separation requirements, prohibitions against the sharing of information, and posting requirements.
• We treat all customers of interstate pipeline and storage companies, affiliated and non-affiliated, on a not unduly discriminatory basis.

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Financial Integrity

Management, shareholders, creditors, our colleagues, and government entities rely upon the accuracy of the company's financial records. It is therefore imperative that the financial records and reports produced or derived from those records be maintained and presented in accordance with the laws and regulations in each applicable jurisdiction. Those records must accurately and fairly reflect in reasonable detail the assets, liabilities, expenses, and revenues of the company. By demonstrating honesty in our accounting practices, we generate trust with our customers, suppliers, and shareholders and enhance our reputation. When we fail to record financial information accurately, we risk damaging our reputation, losing business, and decreasing customer and shareholder confidence.

• We accurately reflect transactions and events in all financial books, records, and accounts and conform both to generally accepted accounting principles and to the company's system of internal controls.
• We support all transactions with accurate documentation in reasonable detail recorded in the proper account and in the proper accounting period.
• We prepare all business records, accounts, and reports for government agencies and others with care and honesty.
• We do not make entries into any records to hide or disguise intentionally the true nature of the entries.
• We do not make false entries for any reason, nor will we alter documents or sign documents when we lack the proper authority to do so.
• We do not alter or falsify information on any record or document to make a false or exaggerated claim intentionally to anyone, including our competitors, or to mislead customers about our products or those of our competitors.
• We demonstrate financial integrity in preparing and filing travel and expense reports and other financial transactions.
• We retain all of the company's financial books, records, and statements in accordance with the company's policy on records retention and all relevant laws and regulations.
• We recognize that we are all responsible for the integrity and accuracy of business documents, communications, and financial records.

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Health, Safety, and Environment

Safety is one of El Paso's core values. Protecting people and the environment is of critical importance to the company. It plays a role in everything we do and every decision we make. A safe and healthy workplace allows everyone to complete quality work and perform with excellence.

• We are committed to maintaining a safe and secure work environment for El Paso personnel.
• We take precautions to protect ourselves and other El Paso personnel, including immediately reporting accidents, injuries, and unsafe practices or conditions.
• We conduct our business in a manner that avoids harm to people and respects the environment.
• We act in a socially responsible manner demonstrating our commitment to our suppliers, contractors, and customers and to the protection, development, and enhancement of the communities in which we conduct business.
• We observe the safety and health rules and practices that apply to our jobs.
• We work free from the influence of any substance that could prevent us from conducting work activities safely and effectively.
• We do not tolerate workplace violence or threats of any kind. We do not make threatening remarks, cause physical injury to another person, intentionally damage someone else's property, or act aggressively in a manner that causes someone else to fear injury.

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Political Activities and Contributions

The company encourages all El Paso personnel to exercise their individual rights of citizenship by voting, making personal political contributions if they wish to do so with their own funds, and being otherwise politically active in support of candidates or parties of their own personal selection. It should be clearly understood that such political activity by El Paso personnel must be performed strictly in their individual and private capacities as responsible citizens and not on behalf of El Paso. El Paso personnel may not receive any direct or indirect reimbursement or offsetting refund of any nature whatsoever with respect to political contributions made by them in any form.

• We do not make any contributions to political parties, candidates, or public officials on behalf of the company, except as permitted by federal, state, or local laws.
• We are committed to citizenship and community involvement.
• We encourage voluntary involvement with candidates, political parties, and civic organizations.
• We recognize that our personal involvement and participation in civic affairs and the political process must be on an individual basis, on our own time, and at our own expense.
• We express our views as individuals and not as representatives of El Paso when we exercise our right to vote and participate in the political process.
• We do not use company time or resources—including telephones, email, faxes, and photocopying machines—for personal political activities.

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Safeguarding Important Information

Confidential information may include various kinds of information, but it certainly includes internal, confidential, proprietary, or secret information related to the company's business such as trade secrets, proprietary know-how, personnel records, business plans and proposals, capacity and production information, marketing or sales forecasts and strategies, client and customer lists, pricing lists or strategies, construction plans, supplier data, business leads, and research and development information. Most of the company's technology and much of our other know-how and experience are protected as trade secrets. Such trade secrets are valuable assets. Other examples of confidential information include processes, computer passwords and software, and information concerning our operations and vendors. Confidential information may also be received from other companies or individuals in the course of the company's business.

• We carefully protect the company's confidential and proprietary information and act responsibly with the sensitive information of competitors, customers, and other stakeholders.
• We safeguard the confidential and proprietary information of other companies with which we do business with the same care we give to our own company's information.
• We do not obtain information about our competitors through unlawful or unethical means, such as theft, illegal entry, electronic eavesdropping, or surveillance. We will not misrepresent ourselves, our positions, or our circumstances to persuade another to release information, nor will we commission a third party to do so.
• We respect the confidentiality and privacy of our suppliers, our contractors, our customers, El Paso personnel, and others with whom we do business. Unless authorized, we do not use confidential information for personal use, to benefit the company, or to benefit a third party. We disclose confidential information or personal data only when necessary and when appropriate approval to do so has been obtained and/or when we are compelled to do so by legal, regulatory, or professional requirements.
• We are careful not to transfer outside the company confidential email messages or any message intended for internal use only.
• We respect the trade secrets, copyrights, trademarks, and patent rights of others.
• We do not disclose any previous employer's confidential information without written consent of that employer.
• We safeguard our confidential information even if we leave the company.

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Securities Laws and Insider Trading

Company policy, securities exchanges, and applicable laws prohibit the trading of securities by anyone in possession of material, non-public information about the company that issues those securities (insider trading). In addition, applicable securities laws and stock exchanges regulate the manner in which we disclose material, non-public information. Material, non-public information is defined as knowledge of company business that has not been publicly disclosed and which may have an effect on the value of the company's securities (e.g., earnings estimates, significant business investments, mergers, acquisitions, dispositions and other developments, expansion or curtailment of operations, and other activities of significance). Material, non-public information is confidential corporate information that could influence a reasonable person's decision to buy, hold, or sell the company's stock or any other company securities. Because El Paso's stock and other securities are owned and traded by the public, El Paso is obligated by various laws, and is committed to making full, fair, accurate, timely, and understandable public disclosure of material information.

• We comply fully with applicable securities laws and are alert to the laws of other countries when making personal investments. In particular, we comply with those laws and regulations relating to the disclosure of material corporate information and insider trading.
• We do not trade any stock or other securities on the basis of material, non-public information learned about El Paso or a company with which El Paso does or might do business.
• We do not tip others to trade securities of El Paso or other companies on the basis of material information before it is made publicly available through appropriate media.

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Suppliers, Contractors, and Customers

Building strong relationships with suppliers, contractors, and customers is integral to being a world-class company. That means we need to continue treating them as we would like to be treated—with honesty, fairness, and respect. We must keep our commitments of quality, reliability, and service.

• We expect our suppliers, contractors, and customers—and others who do business with us or on our behalf—to conduct their business on behalf of El Paso in compliance with all applicable laws and regulations and to adhere to the same standards of fair and ethical business conduct to which we hold ourselves.
• We are fair in our choice of suppliers and contractors and honest in all business interactions with them. We choose our suppliers and contractors based on appropriate criteria, such as value, quality, price, technical excellence, service, reputation, experience, and capacity.
• We do not make decisions about suppliers or contractors on the basis of personal relationships and friendships or the opportunity for personal financial gain.
• We do not offer bribes to nor do we accept kickbacks from our suppliers, contractors, or customers for any reason.
• We safeguard all information received from our suppliers, contractors, and customers and do not disclose it to anyone outside of the company without the appropriate approval to do so and/or when we are compelled to do so by legal, regulatory, or professional requirements.
• We deal fairly with our suppliers, contractors, and customers and do not take advantage of them through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.
• We do not make false or misleading remarks to suppliers, contractors, or customers about other suppliers, contractors, customers, or company competitors or their products or services.
• We do not suggest or imply that suppliers to or customers of our company are required to purchase products or services from us.

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Transacting International Business

The company operates in many different countries. This dimension of our business adds a certain complexity to our endeavors with regard to the way in which we conduct ourselves and our business. Success in any global business transaction depends on our compliance with country-specific constraints and conditions and sensitivity to local customs. Laws, regulations, and conventions governing business relationships vary from country to country. Of course, our obligation to comply with U.S. laws and regulations does not end when our businesses exit the United States. It is company policy to abide by the national and local laws of the countries where we operate, except to the extent prohibited by U.S. law. This includes, but is not limited to, immigration, customs, and tax or exchange control laws or regulations.

The United States uses trade controls to protect our national security, to strengthen the domestic economy, and to promote foreign policy. These controls are embodied in various laws and regulations that affect international transactions, including the following: (1) the Foreign Corrupt Practices Act (FCPA) and other anti-corruption provisions; (2) controls on exports and re-exports of products, technology, and software; (3) customs and import regulations; (4) anti-boycott laws; and (5) U.S. sanctions and economic embargoes. We comply with the letter and spirit of these laws and regulations, and we share the national security, economic, and foreign policy goals they embody.

• We are familiar with the laws affecting our business activities and assume responsibility for compliance.
• We keep appropriate records concerning our international business dealings, including those records required to be kept under U.S. and host country international trade controls.
• We have great responsibilities in the many countries where we do business. Being a responsible corporate citizen means being sensitive to the people who live in these varied global communities. We comply with the laws of the host countries, except in the case of conflict with applicable U.S. laws.
• We act in a socially responsible manner within the laws, customs, and traditions of the countries in which we operate, and we contribute in a responsible manner to the development of communities.
• We comply with the requirements of the FCPA, international anti-bribery conventions, local anti-corruption and anti-bribery laws, and similar laws in place in the countries where we operate.
• We do not directly or indirectly bribe foreign government officials (including officials of designated public international organizations), political party candidates or officials, or political parties.
• We do business with all of our suppliers, contractors, and customers and with government agencies in a straightforward and transparent manner.
• We make payments on behalf of the company only on the basis of adequate supporting documentation, only for the purpose described by the documents supporting the payment, and in accordance with appropriate corporate accounting procedures.
• We keep the company's books, records, and accounts in reasonable detail to reflect accurately and fairly all transactions and dispositions of assets.
• We comply with U.S. export and re-export restrictions as well as applicable export control laws of all countries where we conduct business.
• We furnish accurate and truthful information and documentation pertaining to all export transactions, including information relevant to their value, destination, end use, and classification.
• We do not conduct business with individuals or entities determined by the U.S. government to be acting on behalf of a country that is subject to a U.S. embargo, or who have been denied export privileges by the U.S. government, or are otherwise listed by the U.S. government as unauthorized to engage in transactions.
• We ensure that a specific export license or applicable exception or exemption covers every export.
• We recognize and investigate "red flags" that may indicate possible export control violations in a transaction.
• We comply with U.S. Customs laws and regulations on all imports and exports. U.S. Customs laws assure that imported products are properly admitted into the United States to safeguard the public and domestic industries and to ensure the proper collection of duties, taxes, and fees on imported products, and to ensure proper compliance with respect to exports. As some subsidiaries engage in imports and exports, those subsidiaries must provide the required information to U.S. Customs about their import and export shipments.
• We do not cooperate in any way with an impermissible foreign boycott.
• We properly report any requests we receive to engage in a boycott.
• We comply with the letter and spirit of U.S. sanctions and embargoes on trade and other commercial dealings with certain countries, regions, individuals, entities, and vessels.
• We do not approve, finance, or otherwise facilitate transactions by others that we may not conduct ourselves because of the prohibitions contained in U.S. sanctions and embargoes.

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Ethical Decision Making Model

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