The Company's Audit Committee has established procedures for (1) the receipt, retention and treatment of complaints regarding accounting, internal accounting controls, or auditing matters (collectively, the "Accounting Practices") and (2) the confidential, anonymous submission by employees of concerns regarding questionable Accounting Practices. These procedures are designed to facilitate the reporting of concerns or complaints regarding the Company's Accounting Practices. The following is a description of the confidential complaint procedures established by the Audit Committee:
1.	Receipt of Complaints
	A.	Employees and other interested parties with concerns or complaints regarding the Company's Accounting Practices may report their concerns to the Company's Corporate Compliance Officer. Copies of all such concerns or complaints received by the Corporate Compliance Officer shall be provided to the Audit Committee.
	B.	Employees may forward their concerns or complaints to the Corporate Compliance Officer on a confidential, anonymous basis through one of the following two (2) methods:
		1.	The employee may submit his or her concern or complaint in writing and forward the same in a sealed envelope by regular U.S. mail addressed as follows:
			Mark K. Boling Corporate Compliance Officer Southwestern Energy Company 2350 N. Sam Houston Parkway E., Suite 125 Houston, Texas 77032
		2.	The employee may submit his or her concern or complaint in writing and deposit the same in one of the employee drop boxes described below. Each such submittal should be forwarded in a sealed envelope and addressed as follows:
			Mark K. Boling Corporate Compliance Officer Houston Office
Employee drop boxes are available in the following locations:
			Fayetteville:	SWN Break Room
			Houston:	6th Floor Break Room
			Conway:	1st Floor Break Room
			Damascus:	Front Office Break Room
	C.	In addition to the submittal methods described in B. above, employees and other interested parties may forward their concerns or complaints on a confidential basis via one of the following methods: Calling the independent reporting company that Southwestern has engaged for those who want to speak up but prefer to remain anonymous. This service is available at 1-877-516-3496, 24 hours a day, 7 days a week and allows you to voice your concerns without fear of retaliation. This independent company, The Network, also provides a secure, web-based reporting system, that can be accessed through the Corporate and Q-Links pages of SWNet. Leaving a voicemail message on the Company's internal telephone hotline at 1-877-406-2424. Each voicemail message will be transcribed by Company personnel and forwarded to the Corporate Compliance Officer. Since the transcription of the voicemail message will be done by Company personnel, those employees that are concerned about assuring their anonymity should utilize one of the other submittal methods described above.
	D.	Employees and other interested parties are encouraged to provide as much specific information regarding the concern or complaint as is possible, including a description of the action(s), event(s) or transaction(s) giving rise to the concern or complaint, names, dates, places and the employee's perception of why the action(s), event(s) or transaction(s) constitute questionable Accounting Practices.
	E.	An employee may utilize this confidential complaint procedure either to raise new concerns or complaints or if he or she feels that a concern or complaint previously raised with a supervisor or the Corporate Compliance Officer has not been appropriately handled.
2.	Scope of Matters Covered by These Procedures
	A.	These procedures relate to complaints concerning questionable Accounting Practices, including, without limitation, the following:
			fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company;
			fraud or deliberate error in the recording and maintaining of financial records of the Company;
			deficiencies in or noncompliance with the Company's internal accounting controls;
			misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company; or
			deviation from full and fair reporting of the Company's financial condition.
3.	Treatment of Complaints
	A.	Upon receipt of a concern or complaint, the Corporate Compliance Officer shall (i) determine whether the concern or complaint pertains to the Company's Accounting Practices and (ii) when possible, acknowledge receipt of the complaint to the sender.
	B.	All concerns or complaints relating to the Company's Accounting Practices will be reviewed and investigated under Audit Committee direction and oversight by the Corporate Compliance Officer or such other persons as the Audit Committee determines to be appropriate. However, the Audit Committee shall retain the right, in its sole discretion, to take over the review and investigation of any such concern or complaint. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
	C.	Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.
	D.	The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of concerns or complaints regarding questionable Accounting Practices or otherwise as specified in Section 806 of the Sarbanes-Oxley Act of 2002.
4.	Reporting and Retention of Complaints and Investigations
		The Corporate Compliance Officer will maintain a log of all complaints, tracking their receipt, investigation and resolution and shall prepare a periodic summary report thereof for the Audit Committee. Copies of the log and all such complaints will be maintained in accordance with the Company's document retention policy.