Dear Supplier:

National Fuel Gas Company and its subsidiaries (“National Fuel” or the “Company”) believe that all suppliers doing business with National Fuel should be aware of the Company’s standards and ethical requirements and should conduct business with integrity. To assist suppliers in accomplishing this goal, the Company maintains a Code of Business Conduct and Ethics (the “Code”) on its website that provides guidance to Company stakeholders:

https://investor.nationalfuelgas.com/governance/code-of–business–conduct–and–ethics/default.aspx

Among other standards, the Code requires that employees of National Fuel may not, under any circumstances:

• Use their position as a National Fuel representative for personal gain through preferential treatment of suppliers;
• Place themselves in a position that compromises their integrity or represents a conflict of their personal interests with National Fuel’s interests, for example, by accepting gifts of such value or given with such frequency that it could influence their business decisions; or
• Require suppliers to participate in or support any group, activity, political campaign, or organizations as a requirement of doing business with National Fuel.

Additionally, the Company expects its suppliers to adhere to National Fuel’s Supplier Code of Conduct Policy, which addresses National Fuel’s standards of conduct related to transacting business, anti-corruption, labor and employment practices, environmental, health and safety, and non-discrimination. The Company values its business relationships and is asking you as one of the Company’s Suppliers to help preserve these relationships by carefully reviewing, and complying with, the Company’s business ethical standards and Supplier Code of Conduct Policy, which can be found on National Fuel’s website:

https://www.nationalfuel.com/corporate/governance–and–ethical–conduct/vendorconduct/

National Fuel is also committed to promoting labor and human rights for its employees, the communities where these employees live, and communities where the Company operates. That commitment includes, among other matters, valuing diversity and inclusion. Our approach is outlined in the Company’s Labor and Human Rights Policy, as well as the Company’s Corporate Responsibility Report published on our website. National Fuel expects its suppliers to adhere to these guidelines.

If, through the course of dealing with National Fuel, you become aware of any situations that may violate the letter or spirit of the Code, please contact me at (716) 857-7313 or Rebecca Hillery, Chief Auditor, at (716) 857-7747. You may also write to either of us at National Fuel Gas Company, 6363 Main Street, Williamsville, New York 14221. Your traditional supplier relationship with National Fuel should continue to be managed through your normal points of contact.

Sincerely,

Michael W. Reville
General Counsel and Corporate Secretary
Chair, Ethics Committee