Dear Vendor, Supplier, or Contractor:

National Fuel Gas Company and each of its subsidiaries (“National Fuel” or the “Company”) 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 and should conduct business with integrity and in accordance with our policies and procedures. Additionally, the Company expects our vendors, suppliers, and contractors to adhere to our Supplier Code of Conduct Policy, which addresses our standards of conduct related to transacting business, anti-corruption, labor, and employment practices, environmental, health and safety, and non-discrimination. The Company values our business relationships. Please help us preserve these relationships by carefully considering, and complying with, our 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/vendor-conduct/.

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

National Fuel’s complete Code of Business Conduct and Ethics is available on National Fuel’s website, https://investor.nationalfuelgas.com/governance/code-of-business-conduct-and-ethics/default.aspx.

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 inclusion. Our approach to these challenges 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 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 (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, NY 14221. Your traditional vendor 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