Dear Vendor, Supplier, or Contractor:

National Fuel Gas Company and each of its subsidiaries (“National Fuel”) maintain a Code of Business Conduct and Ethics (the “Code”) that provides guidance to Company stakeholders. We believe that all vendors, suppliers and contractors doing business with National Fuel should be aware of our standards and ethical requirements. We value our business relationships. Please help us preserve these relationships by carefully considering, and complying with, our business ethical standards.

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 vendors, suppliers, or contractors;
• 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 vendors, suppliers or contractors to participate in or support any group, activity, political campaign, or organizations as a requirement of doing business with National Fuel.

National Fuel’s complete Code of Business Conduct and Ethics is available on National Fuel’s website, NationalFuel.com.

Additionally, National Fuel is committed to promoting labor and human rights for our employees, and the communities where we live and operate. That commitment, includes, among other matters, valuing diversity and opposition to all forms of forced labor and child labor as promulgated under the Fair Labor Standards Act. Our approach to these challenges is outlined in the Company’s Labor and Human Rights Guidelines, which can be found on National Fuel’s website, NationalFuel.com. National Fuel expects all vendors, suppliers and contractors 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 (XXX) XXX-XXXX or our Chief Auditor, at (XXX) XXX-XXXX. You may also write to either of us at National Fuel Gas Company, 6363 Main Street, Williamsville, NY 14221. Your traditional vendor relationship with National Fuel should continue to be managed through your normal points of contact.

Sincerely,

Sarah J. Mugel
General Counsel and Secretary