Southwestern and its subsidiaries provide certain goods and services to each other in the ordinary course of business. Because the companies are under common ownership, regulatory agencies, business associates and competitors place these affiliate transactions under higher scrutiny. Therefore, it is important that all transactions between Southwestern affiliates be conducted in a manner that is fair and reasonable to all interested parties, that Southwestern avoid the appearance of unfair or unreasonable transactions between affiliates, and that Southwestern be able to demonstrate the fairness and reasonableness of these transactions if required to do so. To assure that these standards for affiliate transactions are met, Southwestern shall adhere to the following Guidelines, unless applicable federal, state or local laws or regulations impose other requirements:

• All transactions involving interstate pipelines and marketing affiliates will be governed by the Federal Energy Regulatory Commission’s Standards of Conduct for Interstate Pipelines with Marketing Affiliates published in 18 CFR Part 161.