Southwestern Energy
$4.37  -0.18
03.22.18 4:02 ET
Delayed 20 minutes
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The Company has established procedures for (1) the receipt, retention and treatment of complaints regarding unethical, illegal or unsafe activities (collectively, "Misconduct") and (2) the confidential, anonymous submission by employees or other interested parties of concerns regarding questionable activities. These procedures are designed to facilitate the reporting of concerns or complaints. The following is a description of the confidential complaint procedure established by the Company:
1.   Receipt of Complaints
  a.   Employees and other interested parties may report their concerns or complaints via the following two methods:
  • Report their concerns or complaints to the Corporate Compliance Officer on a confidential, anonymous basis by submitting their concern or complaint in writing and forward it in a sealed envelope by regular U.S. mail addressed as follows:

    Southwestern Energy Company
    Attn: John Ale, Corporate Compliance Officer
    PO Box 12359
    Spring, Texas 77391-2359

  • Report their concerns or complaints on a confidential basis by calling the independent reporting company that Southwestern has engaged for those who want to speak up. 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, which can be accessed through the Corporate Services and Quick Links on SWNet,
b.   In addition, employees may also report their concern or complaint in writing and deposit it in one of the following drop boxes:
  • Houston: Spring Campus, Tower 2 – Café Entrance
  • Conway: 2nd Floor Kitchen
  • Tunkhannock: Cafe Entrance
  • Jane Lew: Building 3 Kitchen
c.   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 activity.
d. An employee may utilize this confidential complaint procedure if they feel that a concern or complaint previously raised with a supervisor or the Corporate Compliance Officer was not appropriately handled.
2.   Scope of Matters Covered by This Procedure
This procedure relates to complaints concerning questionable misconduct, some common examples or unethical, illegal or unsafe activities include, but not limited to:
  • Accounting or auditing irregularities (as specified in Sarbanes-Oxley Act of 2002)
  • Conflicts of interest
  • Improper dealings with customers or vendors
  • Theft and fraud
  • Misuse of assets
  • Creating or ignoring safety hazards
3.   Treatment of Complaints
a.   Upon receipt of a concern or complaint, the Company shall perform a review. All reports will be handled promptly and discreetly.
b.   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.
4.   Reporting and Retention of Complaints and Investigations
The Company 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.