1.	Statement of Policy
	Southwestern Energy Company and its subsidiaries (collectively, the "Company") is committed to providing a workplace conducive to open discussion of its business practices. It is Company policy to comply with all applicable laws that protect employees against unlawful discrimination or retaliation by their employer as a result of their lawfully reporting information regarding, or their participating in, investigations involving corporate fraud or other violations by the Company or its agents of federal or state law. Specifically, Company policy prevents any employee from being subject to disciplinary or retaliatory action by the Company or any of its employees as a result of the employee's:
			disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation or possible violation of federal or state law or regulation; or
			providing information, causing information to be provided, filing, causing to be filed, testifying, participating in a proceeding filed or about to be filed (with any knowledge of the employer), or otherwise assisting in an investigation or proceeding regarding any conduct that the employee reasonably believes involves a violation of:
				federal criminal law relating to securities fraud, mail fraud, bank fraud, or wire, radio and television fraud, or any rule or regulation of the Securities and Exchange Commission, or any provision of federal law relating to fraud against shareholders,
				where, with respect to investigations, such information or assistance is provided to or the investigation is being conducted by a federal regulatory agency, a member of Congress, or a person at the Company with supervisory or similar authority over the employee.
			reporting to his or her supervisor or the Corporate Compliance Offer any conduct or behavior in violation of the Company's Business Conduct Guidelines.
	However, employees who file reports or provide evidence which they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by the above policy statement and may be subject to disciplinary action, including termination of their employment.
	The Company has designated the Corporate Compliance Officer as the person responsible for administering this Policy. The Corporate Compliance Officer is responsible for receiving, collecting, reviewing, processing and resolving concerns and reports by employees and others on the matters described above and other similar matters. Employees are encouraged to discuss issues and concerns of the type covered by this Policy with their supervisor, who is in turn responsible for informing the Corporate Compliance Officer of any concerns raised. If the employee prefers not to discuss these sensitive matters with his or her own supervisor, the employee may instead discuss such matters directly with the Corporate Compliance Officer. Complaints submitted to the Corporate Compliance Officer shall be referred to the Company's Board of Directors or the Audit Committee of the Board, in those instances where the Corporate Compliance Officer determines such referral is appropriate or is required under applicable law or the directives of the Board of Directors or the Audit Committee of the Board.
	The Company's Corporate Compliance Officer is Mark K. Boling, who may be reached at 281-618-4806 or mboling@swn.com.
2.	Notice of Policy Violations
	If any employee believes he or she has been subjected to any action that violates this Policy, he or she may file a complaint with his or her own supervisor, the Corporate Compliance Officer, the Company's Vice President-Human Resources or the Company's Director of Human Resources. If it is determined that an employee has experienced any improper employment action in violation of this Policy, such employee will be entitled to appropriate corrective action.