Page 7 - Code of Business Conduct and Ethics

Employees are required to read and understand the Code and, if necessary, ask questions for
clarification and to determine what would be the best course of action in a particular situation. If
it doesn’t feel right, then it probably isn’t right. Use good business judgment and think about
how you would respond to the following questions:

• Does this action feel right to you?
• Is it legal and ethical?
• Is it consistent with the Company’s values and commitment to compliance?
• How would you feel explaining this action to your coworkers, management, customers,

your family, or the public?
• How would this action be perceived by the public if it was reported in the media?

An employee or Director aware of any situation that he or she believes may violate or lead to a
violation of this Code must report the situation to supervisors, managers, Human Resources
(“HR”), the Ethics and Compliance Hotline, or the Company’s Compliance Officer (collectively
known as “Internal Resources”). Periodic training will be provided to assist employees with
understanding their responsibility to comply with the Code and the duty to report in good faith any
known or suspected violations. Anyone reporting such violations in good faith will not be subject
to retaliation. See “Code Compliance Reporting Procedures” listed below.

COMPLIANCE
This Code is the Company’s “Code of Ethics” as defined in Item 406 of Regulation S-K of the U.S.
Code of Federal Regulations, Title 17, Chapter II, Securities Exchange Commission. The Code
can be found on the Company’s InfoNet site and at www.swgas.com.

This Code covers a wide range of business practices and procedures. It does not cover every
issue that may arise, but it sets out basic principles to guide all employees and Directors of the
Company. Corporate policies and procedures provide additional guidance to employees, but such
policies and procedures are not incorporated into this Code. Although there can be no better
course of action than to apply common sense and sound judgment, do not hesitate to use the
resources available whenever it is necessary to seek clarification.

Employees are responsible for knowing and complying with current laws, regulations, standards,
policies, and procedures for their respective job duties. Any employee who violates the provisions
of this Code will be subject to disciplinary action, up to and including termination. Willful disregard
of criminal statutes may subject the employee to criminal prosecution or civil action.

This Code, along with Company policies and procedures, may change from time to time at the
Company’s discretion.

This document is not an employment contract between the Company and its employees, nor does
it modify their employment relationship with the Company.

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