EX-14 6 codeofconductugi2019.htm EXHIBIT 14
POWERED BY INTEGRITY THE UGI CODE OF BUSINESS CONDUCT AND ETHICS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED TABLE OF CONTENTS WE HONOR WE CONDUCT OUR LEGACY BUSINESS RESPONSIBLY A Message From Leadership 4 Competing Fairly 26 Our Mission, Vision, and Values 5 Preventing Bribery and Corruption 28 The UGI Family 6 Contracting With the Government 30 Avoiding Insider Trading 32 WE FOLLOW Being Alert for Money Laundering 34 OUR CODE Conducting Business Beyond Borders 35 A Shared Commitment 8 Our Responsibilities 9 WE PRESERVE 4HRPUN.VVK*OVPJLZ OUR REPUTATION :OHYPUN*VUJLYUZ Maintaining Financial Integrity 37 Protecting: WE UNDERSTAND Physical and Electronic Assets 39 OUR OBLIGATIONS *VUÄKLU[PHS0UMVYTH[PVU TO OTHERS (]VPKPUN*VUÅPJ[ZVM0U[LYLZ[ Knowing the Rules About Gifts 7YVTV[PUN/LHS[OHUK:HML[` and Entertainment 48 Maintaining a Respectful Workplace *VTT\UPJH[PUN(IV\[<.0 +P]LYZP[`HUK,X\HS6WWVY[\UP[` Anti-harassment 20 WE SUPPORT Interacting With: THE COMMUNITY Customers 22 Protecting the Environment 54 Third Parties 23 Honoring Human Rights 55 The Government 24 Volunteering and Contributing Responsibly 56 CLOSING THOUGHTS HELPFUL RESOURCES 2 TABLE OF CONTENTS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE HONOR OUR LEGACY A MESSAGE FROM LEADERSHIP OUR MISSION, VISION, AND VALUES THE UGI FAMILY 3 WE HONOR OUR LEGACY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED A MESSAGE FROM LEADERSHIP At UGI, integrity powers everything we do – and it has done so, every day, since our founding more than 135 years ago. Our Code of Business Conduct and Ethics reinforces our commitment to integrity. It summarizes the standards that apply everywhere we do business and helps us to navigate an increasingly complex world. It also underscores our “Open Door” culture and our support for open communication and sharing of concerns. Please read our Code and refer to it often. You are encouraged – in fact, we rely on you – to reach out to any member of the leadership team or contact the UGI/AmeriGas Integrity Helpline if you have a question or see something that just doesn’t seem right. Together, we will continue to make UGI one of the most respected companies in our industry and beyond. Sincerely, John L. Walsh President and CEO, UGI Corporation WalshJ@ugicorp.com 4 WE HONOR OUR LEGACY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED OUR MISSION, VISION, AND VALUES OUR MISSION UGI’s mission is to be the preeminent energy Responsibility – We are committed to distribution company in our targeted global sustainable business practices and growing markets by providing a superior range of energy the Company in an environmentally products and services to our customers. responsible way. Natural gas and LPG are JSLHUI\YUPUNLɉJPLU[JVZ[LɈLJ[P]L OUR VISION and abundantly available energy sources. ([<.0^LILSPL]L[OH[ZHMLYLSPHISLHUKLɉJPLU[ >LW\YZ\LPUUV]H[P]LHUKLɉJPLU[LULYN` energy is a necessity for our customers and ZVS\[PVUZ[VILULÄ[V\YJ\Z[VTLYZHUK communities. We strive to deliver this fundamental our communities. need through best-in-class safety, operations, products, and services while positively impacting Reliability – We are a reliable service the lives of our employees, customers, and the provider with a long-standing history of active communities we serve. We do this by committing involvement in the community. We recognize to our Values, as described below. that our customers rely on our products and services. In turn, we support the communities OUR VALUES we serve by our investments in critical infrastructure and our team’s commitment Safety – Safety is a way of life for us. We [VWOPSHU[OYVWPJLɈVY[Z take the time to be safe, safeguard one another, and make safety a priority in our Excellence – We are committed to interactions with our colleagues, customers, achieving exceptional performance and communities. through disciplined growth, execution, and continuous improvement. Our goal is to Integrity – We do the right thing and act deliver the best value for investors as a with honesty. We are ethical and trustworthy high-performing investment, for customers in all of our relationships. as a best-in-class service provider, for employees as a great place to work, and Respect – We embrace the diversity and for communities as a valued neighbor. uniqueness of individuals and cultures and the varied perspectives they provide. We recognize that our success depends on the commitment and capability of our employees to create greater value for all. 5 WE HONOR OUR LEGACY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED THE UGI FAMILY UGI is an international energy distribution and services company that provides superior service in KLSP]LYPUNHYHUNLVMLULYN`WYVK\J[Z>LVWLYH[LHZHILZ[PUJSHZZZLY]PJLWYV]PKLYVɈLYPUNH great place to work, serving our communities, and delivering value to investors. We aim to positively impact the lives of our customers, employees, communities, and investors. UGI is a family of high-performing companies that, through its business units: • Supplies and markets natural gas, liquid fuels, electricity, and renewables; • Distributes propane and butane to retail, residential, commercial, industrial, and motor fuel customers throughout the United States and Europe; • Distributes, stores, transports, and markets energy products and related services; and • Provides heating, ventilation, air conditioning, refrigeration, and electrical contracting services. Our success is based on a rich legacy, a clear vision, and the hard work of each of you, our UGI employees, in all locations where we operate. UGI Corporation (NYSE: UGI) is a holding company with the following business units. Whether you’re driving a bobtail, working the loading dock, responding to a customer inquiry, managing a project, overseeing construction or doing one of the hundreds of other jobs at UGI … we are all working toward one goal: to provide comfort in the lives of millions of people, every day, at home, at work, at play, and in the community. 6 WE HONOR OUR LEGACY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE FOLLOW OUR CODE A SHARED COMMITMENT OUR RESPONSIBILITIES MAKING GOOD CHOICES SHARING CONCERNS 7 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED A SHARED COMMITMENT MANY EMPLOYEES. ONE CODE. WHO MUST FOLLOW OUR CODE? Our Code of Business Conduct and Ethics Our Code applies to all employees of UGI (the “Code”) represents a commitment – a Corporation, its business units and functions, commitment to working together across all including consolidated subsidiaries (“UGI”). This of our business units to serve our customers, includes members of our Board of Directors, to bring our Values to life, and to build on our VɉJLYZHUKWHY[[PTLZLHZVUHSÅL_HUK success … for the next 135 years and beyond. temporary employees. We also expect our third- party consultants, contractors, vendors, and 0UV\Y*VKL`V\»SSÄUK! service providers to live up to the expectations outlined in our Code. Information to help you comply with our policies and the law, wherever you operate; WHAT HAPPENS WHEN SOMEONE VIOLATES OUR CODE? Help with everyday ethical situations you might face on the job; and Violations harm our reputation and erode the trust that people place in us. That’s why violations can Resources available to answer any result in disciplinary action, up to and including questions that you may have. termination of employment. Depending on the severity of the act, there can also be civil or 6MJV\YZL`V\^VU»[ÄUK[OLHUZ^LY[VL]LY` criminal consequences imposed on the person question or scenario in the Code – no document involved and/or UGI. could equip you with that. But our Code will give you the tools you need to make the right decision, regardless of the challenge you face. EVERYDAY INTEGRITY Q: I would like to discuss a new law that Our Code lays out UGI’s TPNO[HɈLJ[V\YPUK\Z[Y`>OLYLJHU I go for answers to my questions? expectations and sets A: Contact the Law Department with any the standard for everyday questions or concerns. We encourage decision-making. discussions about laws and regulations because educated employees will lead to better business practices. 8 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED OUR RESPONSIBILITIES FOLLOWING THE LAW WHAT ELSE IS EXPECTED Each of us, regardless of the job we do or the OF EMPLOYEES? location where we do it, has a responsibility In addition to following our Code, our policies, to conduct business legally and ethically. And, and the law, you have an obligation to: having business operating in a highly regulated Be professional, honest, and ethical in every industry, we also have a responsibility to follow action you take on behalf of our Company. any applicable laws, rules, or regulations that apply to our roles or activities at UGI. Never let someone else or the pressure to succeed entice you to do things that you >OH[PM[OLYLPZJVUÅPJ[IL[^LLUV\Y*VKLHUK know are wrong. local laws or practices? The best strategy is to consult with the Law Department for guidance. Attest annually that you have read and will follow our Code. Report promptly anything that you are involved in that may be construed as a JVUÅPJ[VMPU[LYLZ[L]LUPM`V\WYL]PV\ZS` YLWVY[LKP[K\YPUN[OLHUU\HSJLY[PÄJH[PVU process, as required under our policy. Complete all required ethics and compliance training. Speak up if you see or suspect unethical or illegal behavior, report violations (suspected or observed) of Company policies, and cooperate with any investigations into alleged (or suspected) misconduct. 9 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED OUR RESPONSIBILITIES continued WHAT IS EXPECTED OF MANAGERS? When it comes to living our Values and promoting EVERYDAY our Code, leaders have an even greater obligation. INTEGRITY If you are a manager, we are looking to you to: Q: I’m a manager, and I’m not clear what Set a good example and promote a culture my obligations are if someone comes of integrity and respect. to me with an allegation of misconduct – and what if it involves a senior leader? Support your team – help them understand what’s expected of them. A: You are primarily responsible for team members and business partners under Demonstrate an open door approach and your supervision, but if you are aware of attitude so employees feel empowered to misconduct anywhere in the Company, bring concerns to your attention. you are obliged to take action. If, for any 3PZ[LUÄYZ[HUK[OLU[HRLHJ[PVU[VHKKYLZZ reason, you are uncomfortable making a any questions or concerns. As a manager, report to a particular person, you may it is your responsibility to protect UGI, as talk to any member of management, your such, you should report any behavior that is local Human Resources representative, illegal, unethical, or violates our Code, and the UGI Compliance Group, or other our policies. Company resource (see the Sharing Concerns section for available resources). Reach out to others if you are unsure about one of our policies – when in doubt, ask others for guidance. Never retaliate or allow others to retaliate against those who raise concerns in good faith. 10 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAKING GOOD CHOICES ETHICAL DECISION-MAKING Usually, if you let our Values drive your decisions, you’ll make the right choice. But sometimes the right choice may not be clear. In those situations, it can help to ask yourself some key questions. Is it Is it consistent legal? with our Values? Am I doing Does it what’s right for comply with our customers, our Code and investors, and our policies? the communities we serve? Would I feel If you answer “YES,” to all of comfortable these questions, it’s probably OK to proceed. But if you if my actions answer “NO” or “I’m not sure” were made to any question, stop and public? seek guidance. 11 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED SHARING CONCERNS OUR “OPEN DOOR” CULTURE THE HELPLINE If you have a question or are unsure about The UGI/AmeriGas Integrity Helpline is available the correct thing to do, ask someone. If you any time, day or night, and you may call or share see something that doesn’t seem right, say HJVUJLYUVUSPUL;OL/LSWSPULPZZ[HɈLKI`HU something. Do something about it. Open independent third-party company, and you may communication is what our “Open Door” remain anonymous, where permitted by law. culture is all about. Translation services are also available. Start with your manager. He or she may be in When you contact the Helpline, a professional the best position to understand and address interview specialist or customized web form will the issue you’re facing. If you’re uncomfortable capture details of your concern and forward a talking to your manager or have raised a concern report to UGI’s Compliance Group for follow-up. in the past that you feel was not adequately addressed, reach out to any of the following resources for help: THE UGI/AMERIGAS • Any member of management; INTEGRITY HELPLINE • Your local Human Resources 24 HOURS A DAY / 7 DAYS A WEEK representative; • Corporate Human Resources; • Corporate Law Department; SHARE YOUR CONCERN ONLINE: • The UGI Compliance Group; or https://ugiamerigasethicshelpline.tnwreports.com • The UGI/AmeriGas Integrity Helpline. No matter which resource SHARE YOUR CONCERN VIA PHONE: you contact, your concern In the United States, will be handled promptly call toll-free: 866-384-4272 and discreetly. For all other countries, access dialing instructions here: https://ugiamerigasethicshelpline.tnwreports.com/Phone 12 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED SHARING CONCERNS continued AFTER YOU SPEAK UP Regardless of who you contact or what resource What is … you choose, any concern you share will be Good Faith? promptly reviewed and, if necessary, investigated by the team with the appropriate subject matter Sharing a concern in good faith expertise. Information will be shared only with means that you honestly or people who need to know in order to investigate sincerely believe that there may and resolve the issue. be a violation of our Code, our policies, or the law. If we determine that our Code, a policy, or a law has been violated, we will take appropriate corrective action. NO RETALIATION UGI strictly prohibits any form of retaliation against anyone who reports or asks about a suspected wrongful or unlawful activity in good faith. This same protection is provided to employees who participate in an investigation or proceeding related to such activity. If you feel you or a fellow employee has been retaliated against, you should reach out to your manager, the UGI Compliance Group, or someone in the Helpful Resources section. We take these matters very seriously and will not tolerate such behavior. 13 WE FOLLOW OUR CODE

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE UNDERSTAND OUR OBLIGATIONS TO OTHERS PROMOTING HEALTH AND SAFETY MAINTAINING A RESPECTFUL WORKPLACE DIVERSITY AND EQUAL OPPORTUNITY ANTI-HARASSMENT INTERACTING WITH: CUSTOMERS THIRD PARTIES THE GOVERNMENT 14 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED The safety of our employees, customers, PROMOTING HEALTH and communities is our highest priority. AND SAFETY EVERY PERSON, EVERY DAY. A VIOLENCE-FREE UGI No matter where you work or what job you do, Our Company has zero tolerance for threats or you have a responsibility to promote a safe UGI. acts of violence. Except as otherwise provided ;OH[YLZWVUZPIPSP[`L_[LUKZIL`VUKZWLJPÄJ by law, we do not permit any person to possess assigned safety tasks. It includes having an weapons of any kind (licensed or unlicensed) on awareness of what’s going on around you, Company sites. Employees are further prohibited being proactive to address potential hazards, from carrying weapons of any kind while performing and speaking up about any situation that could their duties for UGI or when visiting customer put individuals at risk of illness or injury. sites on behalf of the Company. Examples of threats Never compromise when or acts of violence it comes to safety. include … • Verbal or physical threats; • Bullying (demeaning, BE AT YOUR BEST humiliating behavior); Substance abuse can pose a threat to a safe ^VYRWSHJLHUKULNH[P]LS`HɈLJ[`V\`V\Y • Communicating an coworkers and others at UGI. You may not endorsement of the have, use, or distribute illegal, controlled, inappropriate use of or prohibited substances in the workplace. ðUHDUPVRUZHDSRQV Never perform any of your job duties under • Menacing or intimidating [OLPUÅ\LUJLVMHSJVOVSVYKY\NZPUJS\KPUN behavior; prescription medication, non-prescription medication, or illegal substances that would • Stalking or other form of impair you). If you suspect that a coworker behavior that is likely to is impaired, share your concerns with cause a real or perceived your manager. threat of harm or personal discomfort; and • Intentional destruction of UGI equipment or property. 15 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROMOTING HEALTH AND SAFETY continued WHAT CAN YOU DO? ࠮ Know and comply with all safety and security rules, procedures, and manuals that relate to your role, and complete any required training. ࠮ Speak up immediately about any workplace injuries, illnesses, or unsafe conditions to your manager, any member of management, your local Human Resources representative, the Safety Department, or the UGI Compliance Group. Emergency situations? Immediately contact your local Emergency Services. ࠮ Follow our physical security guidelines. Be alert to and report any security incidents, violent behavior, or unauthorized individuals in our facilities. 16 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROMOTING HEALTH AND SAFETY continued EVERYDAY EVERYDAY INTEGRITY INTEGRITY Q: My manager asked me to dispense Q: I arrived at work at the same time as a propane from a tank. I haven’t been delivery person, who was carrying a big trained to do this, but I’ve seen others do box. After badging in, I held the door it, and I’m sure I can safely perform this for him so he wouldn’t have to wait for task. Should I do as my manager asks? the person at the front desk. I probably shouldn’t have done that, but it just felt A: No. You should never perform any task impolite to leave him standing there with if you have not received proper safety his hands full. Did I do the right thing? training. Let your manager know that you have not received the necessary A: No. This could have been a legitimate safety training to perform this task, delivery person, but it could have been so that they may direct the request to someone who was unauthorized to someone who has. enter the building and was waiting for an opportunity to gain access. The best way to ensure security of our facilities – and Q: My job includes handling heavy everyone in them – would be to apologize machinery. However, I have been taking and let the delivery person know that physician-prescribed medication or other you can’t let anyone in without proper medications that make me a little drowsy. authorization. What should I do? A: Talk with your manager or your local Human Resources representative. UGI doesn’t expect you to inform UGI about common over-the-counter medications (e.g., aspirin), but you should always inform your manager or your local Human Resources representative if you have been prescribed or are taking medications that may keep you from safely performing your job. You do not need to disclose your underlying medical condition. 17 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAINTAINING A Our employees are our most valuable resource. RESPECTFUL WORKPLACE DIVERSITY AND EQUAL OPPORTUNITY CELEBRATE OUR DIVERSITY Each of us – and the diversity of backgrounds, Examples of experiences, and skills we bring to the workplace – “characteristics adds to the growth and success of UGI. Be protected by law” respectful of others and do your part to create may include … an inclusive work environment. • Age; As a company that operates around the world, • Race; we expect you to be professional at all times HUK[VJVUK\J[I\ZPULZZPUH^H`[OH[YLÅLJ[Z • Religion; WVZP[P]LS`VU<.0/VUVY[OLJ\S[\YHSKPɈLYLUJLZ • Gender; of our employees, business partners, and • Marital status; customers. • National origin; EQUAL EMPLOYMENT OPPORTUNITY • Veteran status; We are an equal employment opportunity employer. • Disability; and We comply with all applicable employment- related laws and regulations and do not tolerate • Sexual orientation. discrimination against anyone based on characteristics protected by law. 18 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAINTAINING A RESPECTFUL WORKPLACE DIVERSITY AND EQUAL OPPORTUNITY continued WHAT CAN EVERYDAY YOU DO? INTEGRITY ࠮ Promote diversity and inclusion. Q: I applied for a management position and Be open to – and respectful of – was interviewed, but I didn’t get the job. WVPU[ZVM]PL^[OH[KPɈLYMYVT`V\YZ I believe I was not selected because of T`HNL¶[OLWVZP[PVU^HZVɈLYLK[VH ࠮ Be fair. Base employment decisions person who is much younger than me. (such as hiring, training, promotions, What should I do? and compensation) on Company A: You should contact your local Human needs, job requirements, and Resources representative to discuss PUKP]PK\HSX\HSPÄJH[PVUZUV[VU your concerns. The fact that a younger characteristics protected by law. candidate was selected does not necessarily constitute discrimination – ࠮ Raise your concerns if you feel the other candidate may have been you are a victim of discrimination IL[[LYX\HSPÄLKMVY[OLWVZP[PVU¶I\[ you should feel comfortable inquiring or suspect that someone else is. about the hiring decision. 19 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAINTAINING A We do not tolerate harassment. RESPECTFUL WORKPLACE ANTI-HARASSMENT DIGNITY AND RESPECT Every individual has a right to work free from Examples of harassment (including sexual harassment), harassment may bullying, and abusive conduct. Harassment include … can take many forms and be verbal, physical, or visual – all of which are prohibited at UGI. • Unwelcome hugging, Check our policies to make sure you know how touching, or sexual advances; to recognize, and speak up about, harassing • Verbal or physical intimidation behavior. Remember that managers must or aggressive behavior, such report complaints they receive, conduct they as pushing, shoving, or observe, or alleged activity that is reported to tripping, or cornering/blocking them as potentially violating our policies. Failure to report may be ground for corrective action. someone in; • 2σHQVLYHRUGHURJDWRU\ BE ALERT remarks, jokes, images, Harassment can happen at work, at work- or name-calling; related events, or outside of work. It can • Racial slurs or inappropriate happen between members of the same or opposite sex. It can happen between comments; and employees and business partners. • Display of drawings, cartoons, or pictures of a sexual nature Don’t let it happen. (including pornography). If you see or suspect harassment, say something. If you’re uncomfortable saying something directly, say something to your WHAT CAN local Human Resources representative, YOU DO? the Law Department, any member of management, or the UGI Compliance Group. ࠮ Do your part to promote a positive Alternatively, you may contact the UGI/ workplace. Don’t ignore harassment, AmeriGas Integrity Helpline. abusive conduct, or bullying. ࠮ If you see or suspect harassment, come forward without fear. UGI prohibits retaliation against anyone who raises a concern in good faith. 20 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAINTAINING A RESPECTFUL WORKPLACE ANTI-HARASSMENT continued EVERYDAY EVERYDAY INTEGRITY INTEGRITY Q: In the last few weeks, I’ve been over- Q: My manager frequently makes suggestive hearing sexually suggestive comments comments about my appearance and from one of my coworkers directed at touches me in ways that make me another person. The comments have made uncomfortable. I’ve repeatedly asked me uncomfortable, but I feel like it is none him to stop, but he doesn’t. I’ve thought of my business. The individual who is the about reporting the behavior, but he’ll target of those remarks would speak up if know it was me who said something – it bothered them, right? ^OH[PMZWLHRPUN\WHɈLJ[Z[OLNVVK performance ratings I earn or the job A: Not necessarily. Sometimes individuals assignments he gives me? fear coming forward to report harassing behavior. You can promote a respectful A: You are entitled to do your work free workplace by having a conversation with VMPU[PTPKH[PUNOVZ[PSLVYVɈLUZP]L them and encouraging them to speak up behavior from anyone, including your about the comments. Or you can speak manager, and we consider this behavior directly to the coworker who is making to be harassment. Report the conduct the comments. If you’re uncomfortable to another member of management, your with either approach, you can share your local Human Resources representative, concerns directly with your manager, the UGI Compliance Group or the UGI/ any member of management, your local AmeriGas Integrity Helpline. UGI does Human Resources representative, the UGI not tolerate retaliation, in any form, Compliance Group or the UGI/AmeriGas against anyone who raises a concern Integrity Helpline. in good faith. 21 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We are committed to exceeding INTERACTING WITH customer expectations. CUSTOMERS CUSTOMERS ARE AT THE CORE OF OUR BUSINESS WHAT CAN Our customers are the reason we come to YOU DO? work each day. Strive to provide a customer experience that is not only positive, but also ࠮ Make every customer interaction safe, reliable, and responsive. a positive experience by: - Being professional, polite, Build trust and deal fairly. Taking unfair advantage and friendly; of someone by manipulating, concealing, or misrepresenting facts? That’s just not how we - Following all safety do business. procedures; - Providing unparalleled ADVERTISING AND MARKETING customer service and quality There are laws and regulations that govern products; how we advertise and market our products and services, and we comply with them. - Addressing questions, concerns, and needs in Be true and accurate in any advertising, sales, a timely manner; and and promotional materials. Make sure that - Consulting with your manager PUMVYTH[PVU`V\WYV]PKLHJJ\YH[LS`YLÅLJ[Z[OL if you are unable to adequately quality, features, availability, and price of the answer a customer question. services we provide and the products we sell. Use approved branding guidelines. If you have ࠮ Protect customer data and the any questions on how to advertise and market data of potential customers. responsibly, contact your respective Marketing Don’t use it for marketing purposes Department or the Law Department. unless they have provided consent. If someone no longer wants to be contacted by our Company, honor the request. 22 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED INTERACTING WITH We choose the right third-party partners. THIRD PARTIES MUTUAL TRUST AND RESPECT Positive, productive relationships with third Examples of third parties do more than help us meet our parties include … obligations. They are essential to our growth and success. We value our third-party partners • Suppliers; and are committed to dealing fairly and honestly • Vendors; in our interactions with them. • Contractors; RESPONSIBLE DECISION-MAKING • Consultants; and In selecting a third-party partner, follow our • Agents. policies and base decisions on objective criteria, such as quality, price, and service. Be alert to JVUÅPJ[ZVMPU[LYLZ[ – never let personal relationships and activities interfere with your judgment regarding what’s right WHAT CAN for the Company. YOU DO? Agreements with third parties must be in writing ࠮ Make sure that third parties are and approved by our Law Department or your meeting their obligations under local external counsel appointed by the Law our contracts and that we are Department. Make sure that any third party meeting ours. we engage receives a copy of our Code and understands our requirements before you sign ࠮ Protect the JVUÄKLU[PHS a written agreement with them. information and intellectual property of our third parties in REPUTATIONAL RISK the same way we protect UGI’s. Remember that UGI’s reputation is driven by ࠮ If you see or suspect behavior our own actions, and also by the actions of that violates our Code, our policies, those with whom we do business. One misstep or the law, report it immediately. or poor decision by a third party can have legal consequences for our Company and a negative impact on the reputation that we’ve worked so hard to earn. This is why selecting the right partners – ones who share our high standards – is critical. 23 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We value an open and transparent relationship INTERACTING WITH ^P[O[OLNV]LYUTLU[HUKYLN\SH[VY`VɉJPHSZ THE GOVERNMENT INQUIRIES, AUDITS, AND INVESTIGATIONS We may receive requests for interviews WHAT CAN or information in connection with an audit YOU DO? or investigation. If you are contacted by a NV]LYUTLU[VɉJPHSPTTLKPH[LS`JVU[HJ[[OL ࠮ If you are contacted by a Law Department for assistance. And if you are NV]LYUTLU[VɉJPHSJVU[HJ[[OL responsible for providing the Law Department with Law Department or your local information to respond on behalf of UGI, cooperate external counsel immediately. fully and be truthful, accurate, and complete. ࠮ Uphold our high standards – never interfere with or improperly DAWN RAID PROTOCOL PUÅ\LUJLHUH\KP[VYPU]LZ[PNH[PVU The Dawn Raid protocol is a set of instructions Take all investigations seriously, that are intended to guide your actions in ࠮ along with any request to search the event of an unannounced inspection of a Company facility. You must not our facilities by a competition authority (i.e., obstruct an investigation (even the European Commission or the National an unannounced investigation or Competition Authority). If you are approached inspection), but you may ask for a as part of a Dawn Raid, stay calm and do your valid search warrant or subpoena. part to help the inspection proceed smoothly When in doubt, contact the Law while preserving the rights and interests of Department immediately. the Company. If you have any questions about your role and responsibilities, consult the Law Department. 24 WE UNDERSTAND OUR OBLIGATIONS TO OTHERS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE CONDUCT BUSINESS RESPONSIBLY COMPETING FAIRLY PREVENTING BRIBERY AND CORRUPTION CONTRACTING WITH THE GOVERNMENT AVOIDING INSIDER TRADING BEING ALERT FOR MONEY LAUNDERING CONDUCTING BUSINESS BEYOND BORDERS 25 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We believe in a free and open marketplace COMPETING and in protecting consumers from anti- FAIRLY competitive conduct. ANTITRUST AND FAIR COMPETITION WHAT TO AVOID Most countries have laws designed to keep Always compete lawfully and avoid any agreements the global marketplace thriving, and we’re (either formal or informal) with competitors that committed to complying with them, everywhere could limit free and open competition. we operate. Although these laws can be complex and vary from country to country, it’s Laws in this subject area are complex; when in PTWVY[HU[[V\UKLYZ[HUKOV^[OL`HɈLJ[`V\Y doubt, contact the Law Department for guidance. day-to-day work and avoid conduct that might Examples of anti-competitive behavior may include suggest impropriety. agreements with another party to: Raise, set, hold, not discount, or take any other action regarding pricing Antitrust and competition Divide customer, geographic, or market segments laws also help to keep any one company from unlawfully Restrict production, sales, or output monopolizing an industry. Boycott or refuse to deal with a particular competitor, supplier, or customer Prevent another company from entering the market What is … Tying? 0U[LYMLYL^P[OPUÅ\LUJLVYYPN[OL competitive bidding process It is an anti-competitive practice of selling a product or service :OHYLLTWSV`LLZHSHY`VYILULÄ[PUMVYTH[PVU as a requirement for purchasing with each other or agree not to hire each another product or service, which other’s employees (without a lawful business results in restricting competition purpose) DQGSURYLGHVQREHQHðWIRUWKH customer. It’s also important to take care in what you say about our competitors. Never make false claims about their products and services. 26 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED COMPETING FAIRLY continued WHAT CAN EVERYDAY YOU DO? INTEGRITY ࠮ Compete fairly, vigorously, and Q: May I pretend to be a customer to get lawfully. Always be honest about pricing information from our competitors? who you are and who you work for. A: No. Obtaining information about a ࠮ Be careful in any interaction with competitor by misrepresenting your an actual or potential competitor, identity or by inducing an employee of including at conferences and trade the competitor or a third party to divulge shows. Don’t discuss pricing, costs, customers, terms of sale, JVUÄKLU[PHSUVUW\ISPJPUMVYTH[PVUPZ against our policy. Gathering information or marketing strategies with about our competitors is a legitimate competitors. If a competitor business activity when done lawfully raises one of these topics, stop and ethically. We certainly do not search the conversation immediately, through our competitors’ trash or allow inform the competitor that you others to do so for us. However, it would cannot discuss these topics, be acceptable to review industry analyst and report the incident to the Law Department. YLWVY[ZUVUJVUÄKLU[PHSJ\Z[VTLYVY supplier intelligence or other public ࠮ Gather information about our information about our competitors. competitors through public sources, such as news stories and trade journal articles, never through deception, misrepresentation, theft, or any other unethical means. ࠮ Be aware: The penalties for violations of antitrust and competition laws can be severe for both you and UGI, including criminal penalties and jail sentences. If you’re ever unclear about your responsibilities, seek help from the Law Department. 27 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We conduct business with integrity – we don’t PREVENTING BRIBERY VɈLYIYPILZHJJLW[IYPILZVYHZRZVTLVUL[V AND CORRUPTION bribe for us. ZERO TOLERANCE Bribery and corruption can harm our customers, What is … harm our communities, and harm the global a Facilitating marketplace, so we strictly comply with laws Payment? designed to prevent it, everywhere we operate. +VUV[VɈLYNP]LWYVTPZLVYHJJLW[HU`[OPUN A small payment, sometimes of value – either directly or indirectly – in order referred to as a “grease” payment to get business, keep business, or gain an made to low-level, government unfair advantage. RτFLDOVWRVSHHGXSURXWLQH government actions such as: DEFINING A BRIBE • Processing permits, A bribe can be something other than cash, licenses, visas, and including: work orders; Gifts that are excessive or lavish • Obtaining customs clearance; Charitable or political contributions • Providing phone service, 1VIVɈLYZ power, and water supply; and Stocks or investments • Loading and unloading Loans or favors cargo. 0UNLULYHSHU`[OPUNVM]HS\L[OH[PZVɈLYLK Although they may be legal [VPUÅ\LUJLHKLJPZPVUJV\SKILJVUZPKLYLK in some countries, facilitating a bribe. So, regardless of local practice payments are prohibited by UGI. or the practices of other companies, make sure you avoid even the appearance of improper activity. GOVERNMENT OFFICIALS Bribery laws vary from country to country, and some countries impose more severe penalties for bribing NV]LYUTLU[VɉJPHSZI\[V\YWVSPJ`PZZPTWSL!+VU»[IYPILHU`VULH[HU`SL]LSH[HU`VYNHUPaH[PVU5L]LY use your governmental contacts or any connections with persons in authority to obtain undue favors or WYLMLYLU[PHS[YLH[TLU[PUYL[\YUMVYWH`TLU[¶[OPZPZRUV^UHZPUÅ\LUJLWLKKSPUNHUK]PVSH[LZV\YWVSPJPLZ and the law. 28 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PREVENTING BRIBERY AND CORRUPTION continued WHAT CAN EVERYDAY YOU DO? INTEGRITY ࠮ Choose third parties wiselyy. Q: My team wants to give a local police We may be responsible for the VɉJLYHNPM[HZH[VRLUVM[OHURZ actions of third parties doing This would be for regularly patrolling business on our behalf, so set while we do service inspections. clear expectations and actively Is this appropriate? monitor the work of those who do business with us. Never direct a A: No. You should not give the police third party to do something that VɉJLYHNPM[VUILOHSMVM[OL*VTWHU` you’re not legally permitted to This could be viewed as a bribe for do yourself. favored treatment. ࠮ Be able to recognize a bribe when `V\ZLLVUL)LMVYL`V\VɈLYVY Q: My manager has asked me to submit a accept anything of value, check WH`TLU[[VHNV]LYUTLU[VɉJPHS;OPZPZ our policies and ask for guidance to help facilitate the process of getting if you’re not sure of what to do. permits and licensing for our Company to do business in another country. May I ࠮ 0MHUVɈLYPZWLYTP[[LKI`V\Y provide this payment? policies, be accurate and complete in recording payments A: In some countries, these types of payments and expenses in our books are allowed by law, but they are prohibited and records. by UGI. Contact the Law Department for guidance on how to proceed. 29 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We work to be a responsible partner CONTRACTING WITH and meet our contractual obligations. THE GOVERNMENT OUR COMMITMENT Contracting with the government is complex and heavily regulated to ensure that public policy objectives are met and taxpayers receive the best value for goods and services. We understand that, and we understand the responsibility we have to comply with the terms of our contracts and the laws, including regulations. PROCUREMENT INTEGRITY If UGI is bidding on or preparing a proposal for a government contract, follow the applicable rules (for example, any request for proposal guidelines, as applicable). Compete fairly and ethically and abide by both the letter and the spirit of laws designed to promote full and open competition. Transparency, accountability, and openness are the key to not only winning, but also retaining, our government business. GIFTS AND BUSINESS COURTESIES The laws governing what we can give to our government partners are very strict. Don’t give anything of value, including gifts, entertainment, VYHTLHS[VHNV]LYUTLU[VɉJPHS^P[OV\[ receiving approval in advance from the Law Department. “Anything of value” means anything – even low-priced promotional items can pose a problem. 30 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED CONTRACTING WITH THE GOVERNMENT continued WHAT CAN Be alert for … YOU DO? Bribery – this can take the form ࠮ If your job involves contracting of requests from a government with the government or RτFLDOIRUH[DPSOHWKDW\RX participating in government get them a job at UGI, make a audits or investigations, work to political contribution, or use a be a good, responsible partner. particular vendor in exchange for a contract; ࠮ Protect any government property VYJSHZZPÄLKPUMVYTH[PVU¶PM *VUÅPJ[ZVMPU[LYLZ[ – if you you have a security clearance, have a personal relationship remember that a special with an employee of a obligation has been placed government agency, you must on you. disclose it; and Anti-competitive conduct – discussing prices or agreeing ZLWKDFRPSHWLWRURURτFLDORQ who will win (a practice known as “bid rigging”) is both unfair and illegal. 31 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We don’t trade – or tip others so they may trade – AVOIDING INSIDER on material, nonpublic (“inside”) information. TRADING WHAT IS INSIDER TRADING? As an employee of UGI, you may be exposed Examples of inside to information about our Company – or information include companies with which we do business – that nonpublic information is not available to the public and would be about … JVUZPKLYLK¸TH[LYPHS¹PU[LYTZVMPUÅ\LUJPUN an investor to buy, sell, or hold stock or other • 2XUðQDQFHVLQFOXGLQJ securities in that company. Trading based on earnings and revenues; that information is called “insider trading,” and • Sales volumes, margins, it’s illegal. and forecasts; Passing along a “tip” to someone else that they • Potential mergers, then use to trade is also a form of insider trading. acquisitions, or joint ventures; • New products or services; DON’T TRADE, DON’T TIP. • Changes in executive Know the kinds of information considered leadership; “inside information” and follow our policies to make sure the information is protected • The gain or loss of from illegal use or disclosure. customers or suppliers; and • Potential legislation that would impact our business. WHAT CAN YOU DO? ࠮ Don’t take chances. If you’re not sure if information is inside information, treat it as though it is and seek help from the Law Department before trading on it or tipping others to trade. ࠮ Be aware that you’re prohibited from trading on inside information even if you leave UGI. 32 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED AVOIDING INSIDER TRADING continued EVERYDAY INTEGRITY Q: One of our suppliers with whom I work is a publicly traded company. I’d like to buy some of their stock because I think it is a good value. However, because of my business interactions with them, I’ve learned that their Board of Directors just approved a large project to expand their operations. That information makes me even more eager to buy … but I haven’t seen anything about it in the news. Can I purchase this stock? A: No, you may not purchase their stock. The information you received is considered “material, nonpublic information” (i.e., information that is important to the investing public, but is not yet publicly known). Until that information is publicly announced by the supplier, it is illegal for you to buy that company’s stock and any such purchase would be considered to be “insider trading.” Also remember that it is illegal for you to share this sensitive information with anyone else. 33 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We know our customers and raise concerns BEING ALERT FOR when we suspect illegal activity. MONEY LAUNDERING WHAT IS MONEY LAUNDERING? RED FLAGS Money laundering is a process where funds Know the warning signs of money laundering generated through criminal activity – such as and monitor transactions and activities in your [LYYVYPZTKY\NKLHSPUNO\THU[YHɉJRPUN work that may be more susceptible to acts of and fraud – are moved through legitimate money laundering. businesses in order to hide their criminal origin. We comply with anti-money laundering and anti-terrorism laws in the countries where we operate. WHAT CAN YOU DO? ࠮ Take the time to know our Examples of money business partners and their SH\UKLYPUNYLKÅHNZ reputation for lawful business include … practices. • Large cash payments; ࠮ Take the time to know our • Unusual fund transfers to or customers and their use of from foreign countries; and our products and services. Familiarity with customer habits • A customer or and practices can make it easier supplier who provides to spot something irregular or incomplete information suspicious. or avoids recordkeeping requirements. ࠮ Report any unusual activity to your manager or the Law Department. 34 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We serve customers, engage with business partners, CONDUCTING BUSINESS and comply with trade laws all over the world. BEYOND BORDERS IMPORTS AND EXPORTS We comply with all applicable laws, regulations, WHAT CAN and restrictions in the import or export of our YOU DO? products, services, information, or technology in every geographical location where we operate. ࠮ Make sure that anything we You are responsible for understanding and import or export is properly following the laws in the country (or countries) JSHZZPÄLKPUHK]HUJLIHZLK where you work as well as any additional laws on the country of origin, the that may pertain to your import and export destination, the end use, and operations. the end user. Also make sure that all required documentation We also expect those in our supply chain to know (including labeling, licensing, and understand the requirements that apply to permits, and approvals) is their products, services, and technologies. completed. ࠮ If you receive a request to comply with a boycott (or Be aware that the laws of more requests to supply boycott- than one country may apply in related information), contact the Law Department. cross-border transactions. ECONOMIC SANCTIONS AND EMBARGOES As a U.S.-based company, we don’t conduct business with countries, companies, or individuals that are subject to United States or other applicable trade embargoes or economic sanctions, and we don’t participate in boycotts where doing so would violate applicable U.S. law. 35 WE CONDUCT BUSINESS RESPONSIBLY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE PRESERVE OUR REPUTATION MAINTAINING FINANCIAL INTEGRITY PROTECTING: PHYSICAL AND ELECTRONIC ASSETS CONFIDENTIAL INFORMATION AVOIDING CONFLICTS OF INTEREST KNOWING THE RULES ABOUT GIFTS AND ENTERTAINMENT COMMUNICATING ABOUT UGI 36 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED Accurate and complete “records” help MAINTAINING FINANCIAL UGI make important business decisions. INTEGRITY A SHARED RESPONSIBILITY RECORDS MANAGEMENT Accuracy in recordkeeping is not just for our The responsible creation, storage, maintenance, accountants and auditors, but for all of us. and disposal of records is another important aspect VMTHPU[HPUPUNÄUHUJPHSPU[LNYP[`*VTWS`^P[O`V\Y Every business action we business unit’s policies take – the timesheets we “Good business records as they relate to proper complete, the expense drive good business records management. reports we submit, the decisions – good sales orders we process, business decisions There may be occasions and the deliveries we inspire trust.” when UGI needs to hold accept – involves some Ted J. Jastrzebski data for legal, audit, or *OPLM-PUHUJPHS6ɉJLY aspect of reporting or UGI Corporation investigative reasons. recording. Make sure that If you receive a “legal ^OH[`V\YLWVY[YLÅLJ[Z[OL[Y\LUH[\YLVM[OL OVSK¹UV[PÄJH[PVUMYVT[OL3H^+LWHY[TLU[KV transaction. Follow our internal controls, be not destroy or dispose of information that might accurate and complete, and provide supporting be needed – even if it is within the disposal period documentation when required. of your business unit’s record retention and disposition policy. Follow the directions outlined FINANCIAL REPORTING PU[OLUV[PÄJH[PVUHUKRLLW[OLYLX\LZ[LKKH[H As a publicly traded company, we have intact and secure. obligations to both current and prospective investors. If you are responsible for disclosing information to regulatory authorities, JVTWS`^P[OHWWSPJHISLÄUHUJPHSYLWVY[PUN Be alert for … requirements and make sure the information you provide is complete, accurate, and timely. • Misrepresenting or omitting information; We cooperate with requests for information • Stealing, embezzling, or from government and regulatory agencies. If misusing funds; you are contacted directly by a government agency, notify the Law Department for • False entries or improper information on how you should respond, and payments; if you are asked by UGI to participate in a • 8QGLVFORVHGRURσWKH government audit or investigation, cooperate record accounts; and fully. For more information, see the Interacting With the Government section. • Fraud. 37 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED MAINTAINING FINANCIAL INTEGRITY continued WHAT CAN EVERYDAY YOU DO? INTEGRITY ࠮ Always provide data that is Q: At quarter-end, my manager asked me to complete, accurate, and timely. record some additional expenses, even though we haven’t received the invoices ࠮ Never misrepresent facts or allow from the supplier, and the work has not yet your judgment to be compromised. started. I’m sure the work will be completed ࠮ Remember, no one has the in the next quarter, so I did as I was asked. authority to force you to do Now I wonder if I did the right thing. something illegal. Do not alter, compromise, or circumvent our A: No, you didn’t. Costs should be recorded systems or controls, even if your in the period in which they are incurred. manager, or someone with more Misrepresenting the facts in this way seniority, asks you to do so. distorted the true chain of events and, depending on the circumstances, could ࠮ If you have questions or concerns amount to fraud. Report the incident to about the Company’s records or any member of management, the UGI public disclosures, raise them. Compliance Group or the UGI/AmeriGas Integrity Helpline. 38 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED Safeguarding Company assets helps us do our jobs, PROTECTING PHYSICAL serve our customers, and build an even better UGI. AND ELECTRONIC ASSETS UGI DEPENDS ON YOU Every day at work, you use or access WHAT CAN Company assets, and you are responsible for YOU DO? their proper care. This means protecting them from loss, theft, abuse, and unauthorized use. Use UGI assets for UGI business only. Never borrow, lend, sell, or give them away unless you’re authorized to do so. If you have a Company What are … credit card or purchasing card, Company Assets? you should only use it for business-related charges. Everything we need to carry out ࠮ Be aware that personal use of UGI’s business, including: UGI-issued cell phones and Physical assets, such computers is OK as long as as the facilities where your use is limited, occasional, we work, the Company and never interferes with the vehicles we drive, and time, talent, and energy you the equipment, tools, bring to your job and does and supplies we use; not violate our policies. However, you should have no expectation Technology assets, such of privacy when using our systems as cell phones, and – information you create, share, mobile devices, computer or download onto UGI systems hardware, software, data, belongs to UGI, and we reserve networks, and internet the right to monitor your use at access; and any time, to the extent permitted by law. Financial assets, such as cash, Company credit cards, purchasing cards, and inventory. 39 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROTECTING PHYSICAL AND ELECTRONIC ASSETS continued EVERYDAY INTEGRITY Q: I am working on a personal project at my home over the weekend and would like to borrow some Company-owned tools. Would this be allowed? A: No, using Company-owned equipment for personal use is not permitted. Q: I have to run to a quick meeting with my manager. Can I leave my computer unlocked and unattended if it is only for a few minutes? A: No, if you have to walk away from your computer, you may leave it on. However, lock the screen to prevent unauthorized WHAT CAN HJJLZZ[V`V\YÄSLZ YOU DO? ࠮ Observe good security habits. Follow our policies to prevent unauthorized access not only to our buildings and vehicles, but also to our networks and systems. Keep keys, ID cards, access cards, and passwords protected. ࠮ Observe good cybersecurity to avoid phishing, malware, ransomware, and other forms of attack that could put our operations at risk. 40 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED Information drives everything we do – that’s why PROTECTING CONFIDENTIAL each of us has a responsibility to collect it, use it, INFORMATION and handle it responsibly. INFORMATION ABOUT PEOPLE Protecting the personal information of our What is … coworkers, customers, and third parties is Personal Information? another way for us to do the right thing. It is yet another way we show respect for 7KHGHðQLWLRQFDQYDU\JUHDWO\ those who rely on us. depending on your location, but generally includes any data that As a company, UGI abides by all applicable could – directly or indirectly – data privacy laws and regulations and is identify someone, such as a committed to handling information the right person’s: way. As an employee, you are responsible • Name; for protecting the privacy of the individuals who have provided you with their personal • Address; information, as well as helping reduce the risk of a data loss or breach, by following • Email; your business unit policies as they relate to: • Phone number; Collecting personal information • Bank or credit card information; Classifying personal information • ,GHQWLðFDWLRQQXPEHU Using and sharing personal information • Birth date; Storing and disposing of personal • %HQHðWVSD\RU information performance information; or • IP address, geolocation, account passwords, biometric information, and household information. 41 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROTECTING CONFIDENTIAL INFORMATION continued INFORMATION ABOUT UGI Depending on your job, you may have access What is … [VJVUÄKLU[PHS*VTWHU`PUMVYTH[PVUPUJS\KPUN Intellectual Property? customer data, business and marketing plans, pricing policies and practices, nonpublic Inventions, discoveries, or written ÄUHUJPHSPUMVYTH[PVUI\KNL[ZHUKMVYLJHZ[Z materials that are unique to acquisition and strategic plans, and operating UGI and make us who we are, policies and practices. including: • Trade secrets; When you protect this information, as well as UGI’s intellectual property, you help us to be • Copyrights; successful and maintain a leadership position in the marketplace. Discoveries, inventions, • Trademarks; concepts, written materials, and trade secrets • Designs; that are created using Company time, resources, or materials are also the property • Logos; and of UGI. • 2WKHU&RPSDQ\VSHFLðF INFORMATION ABOUT THIRD PARTIES proprietary information. What about information that’s not ours? We OH]LHYLZWVUZPIPSP[`[VYLZWLJ[[OLJVUÄKLU[PHS business information and intellectual property of our customers, vendors, partners, and other third parties, too. If you have access to their information, handle it with the same level of care you apply to UGI’s information and intellectual property. /VUVYHSSJVUÄKLU[PHSP[`HUKUVUKPZJSVZ\YL agreements, and do your part to protect the privacy of third parties and their information from loss or unauthorized disclosure. 42 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROTECTING CONFIDENTIAL INFORMATION continued WHAT CAN WHAT CAN YOU DO? YOU DO? ࠮ Respect the privacy of all ࠮ Immediately report all suspected individuals and be committed data breaches or the theft or loss to taking appropriate measures VMWLYZVUHSHUKVYJVUÄKLU[PHS to protect personal information information (or devices with against unauthorized access. WLYZVUHSHUKVYJVUÄKLU[PHS information on them) to your ࠮ *VSSLJ[JVUÄKLU[PHSHUKWLYZVUHS manager and the IT Department. information by lawful and fair means and, use, process, and ࠮ If you should leave UGI, return keep it only for legitimate business all proprietary information in your purposes. Access only the possession and do not share information you need to complete V\YJVUÄKLU[PHSPUMVYTH[PVU^P[O your work, and retain it (or your new employer. Remember, dispose of it) in accordance with your obligation to protect our your business unit’s data retention JVUÄKLU[PHSPUMVYTH[PVUPZMVYL]LY and destruction procedures. ࠮ 0U[OLL]LU[JVUÄKLU[PHSHUK ࠮ :OHYLJVUÄKLU[PHSPUMVYTH[PVU personal information is eligible only on a need-to-know basis, for destruction, follow applicable limiting access to those – inside or procedures for disposal of this outside of UGI – who require the information, complying with any information to do their jobs. Make legal requirements associated with Z\YL[OLYLPZHJVUÄKLU[PHSP[`VY the type of information (paper or nondisclosure agreement in place electronic). before you share information with anyone outside of UGI. If you have any questions relating to data privacy, please contact UGI’s +H[H7YV[LJ[PVU6ɉJLY+76H[ Privacy@ugicorp.com. 43 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED PROTECTING CONFIDENTIAL INFORMATION continued EVERYDAY EVERYDAY INTEGRITY INTEGRITY Q: I believe that I may have clicked on an Q: My Company-issued cell phone was external link asking for my professional stolen. What should I do? login and password. What should I do? A: Immediately report any lost or stolen A: Immediately contact your respective IT equipment or printed materials that contain Department and make them aware of JVUÄKLU[PHS*VTWHU`PUMVYTH[PVUVY the issue. You may also contact the the personal information of coworkers, Integrity Helpline. customers, or third parties to your respective IT Department. Q: 0RLLWTHU`WHWLYÄSLZ[OH[OH]L customer information on them. Is it Q: 0TPZ[HRLUS`ZLU[HÄSLJVU[HPUPUNH OK for me to leave these papers in customer’s personal data to another my Company vehicle? customer. What should I do? A: Take responsible precautions to protect A: Immediately contact your manager and this information. If you must carry paper the IT Department to report the incident. ÄSLZ[OH[OH]LJVUÄKLU[PHSKH[HZ[VYL[OL Resolving incidents that result in the loss, papers in a place not visible from outside disappearance, or misuse of personal the vehicle and lock all vehicle doors. information as soon as possible helps to reduce the possible impact to the Q: A coworker accidentally sent me an individual(s) concerned, as well as UGI. email containing personal information about some of our customers. I am not authorized to have the information she sent. What should I do? A: You should report the issue right away, and in the meantime, do not read the information or distribute it further. Sending our customers’ personal information to someone not authorized to have it could cause harm to those customers and to UGI’s reputation. 44 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We act in the best interest of UGI and avoid the kinds AVOIDING CONFLICTS VMZP[\H[PVUZ^OLYLJVUÅPJ[ZVMPU[LYLZ[TH`OHWWLU OF INTEREST WHAT’S A CONFLICT OF INTEREST? (JVUÅPJ[VMPU[LYLZ[VJJ\YZ^OLU`V\Y (S[OV\NOP[»ZUV[WVZZPISL[VSPZ[L]LY`JVUÅPJ[ personal interests interfere – or may be of interest scenario, there are certain situations perceived by others to interfere – with the where they frequently happen. Being alert to decisions you make as an employee of UGI. these types of situations can help you to *VUÅPJ[ZVMPU[LYLZ[JHUOH]LHOHYTM\SLɈLJ[ avoid them: on the trust people place in you and in our Using UGI’s assets or your position for Company, so it’s important to recognize a personal gain JVUÅPJ[^OLU`V\ZLLVUL Taking for yourself a business deal or opportunity that you discover through your work at UGI Accepting a second job[OH[JVUÅPJ[Z with the job you do at UGI Leveraging your position at UGI to hire, promote, or supervise family or close friends 4HRPUNHSHYNLÄUHUJPHSPU]LZ[TLU[ in major UGI suppliers, contractors, or customers Working for a competitor or a company that does (or wants to do) business with UGI Accepting a role as a board or committee member that interferes with your obligations to UGI 6ɈLYPUNVYHJJLW[PUNNPM[Z meals or entertainment that could be perceived as frequent, excessive or lavish and create a quid pro quo expectation for UGI 45 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED AVOIDING CONFLICTS OF INTEREST continued DISCLOSING A CONFLICT 0M`V\Z\ZWLJ[`V\TH`OH]LHJVUÅPJ[ EVERYDAY disclose the situation to the UGI Compliance INTEGRITY .YV\WVY[OL3H^+LWHY[TLU[4HU`JVUÅPJ[Z can be avoided or managed if they are Q: My wife applied for a job at one of UGI’s disclosed promptly. I\ZPULZZ\UP[Z:OLPZ]LY`X\HSPÄLKMVY the position. Can I tell the hiring manager about her credentials? WHAT CAN A: Yes, you may recommend a family YOU DO? member or close friend for a position – UGI always appreciates the referral of ࠮ Take the time to review our OPNOS`X\HSPÄLKPUKP]PK\HSZ¶I\[`V\TH` JVUÅPJ[ZVMPU[LYLZ[WVSPJ`HUKIL not be involved in the hiring process or aware that our policy, depending supervise a family member. You must upon the situation, may extend also ensure that your wife discloses her to the activities of your close relationship with you when applying for personal friends and family the position. members, too. ࠮ If you’re still not sure if a situation Q: My employee owns a side business that JV\SKWVZLHJVUÅPJ[VMPU[LYLZ[ performs a variety of services (including ask yourself: VɉJLJSLHUPUNSH^UTV^PUNHUKZUV^ - *V\SK[OPZHɈLJ[T`HIPSP[`to removal). Am I allowed to have this make an objective decision on employee also work as a contractor behalf of UGI? for our location? - Would my actions make A: You should seek guidance from your others – inside or outside of respective Human Resources Department, UGI – question my motives the Law Department or the UGI Compliance or my loyalty to UGI? Group regarding this situation, as decisions are made on a case-by-case basis. ࠮ If the right course of action is still not clear, discuss the situation with the UGI Compliance Group or the Law Department. 46 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED AVOIDING CONFLICTS OF INTEREST continued EVERYDAY EVERYDAY INTEGRITY INTEGRITY Q: I am considering an outside business Q: My brothers and I own a business and we venture, selling nutritional supplements. are planning to bid on a project for UGI. Can I use Company bulletin boards What should I do? or email to advertise my products to coworkers? A: You should seek guidance from your manager or the UGI Compliance Group A: No. You may not promote your products regarding required disclosures before or services during Company hours or on you or your brothers submit a bid on Company property, and you may not use the project. UGI’s facilities, resources, or name to support your personal business activity. Q: My manager and I have a great relationship – we work well together and share a lot of the same interests. Would it be against Company policy to ask him out on a date? A: Yes. Dating your manager could pose HJVUÅPJ[VMPU[LYLZ[VYH[SLHZ[NP]L[OL appearance of one since decisions he makes (about the kinds of assignments or working conditions or promotions you’re given) could be viewed by others as preferential or unfair treatment. If you have questions about a potential JVUÅPJ[VMPU[LYLZ[ZLLRN\PKHUJL from the UGI Compliance Group or from Human Resources. See the Maintaining a Respectful Workplace: Anti-harassment section for more information. 47 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We have rules in place that govern gifts and KNOWING THE RULES ABOUT entertainment to avoid even the perception GIFTS AND ENTERTAINMENT of anything improper. BUSINESS COURTESY OR BRIBE? An inexpensive thank-you gift, an informal What is … KPUULYHM[LYHTLL[PUNHUVɈLY[VH[[LUK a Gift? a local sports event – these are normal and customary ways to build and maintain Typically a tangible item, such as: I\ZPULZZYLSH[PVUZOPWZ)\[^OLUHNPM[VYVɈLY • A modestly priced bottle NVLZ[VVMHYVYPZVɈLYLK[VVMYLX\LU[S`P[JHU of wine; JYLH[LHJVUÅPJ[VMPU[LYLZ[;OH[»Z^O`<.0 has guidelines in place to help you determine • A box of candy; what is appropriate … and what isn’t. • $ERXTXHWRIñRZHUVRU By following these guidelines and asking • A promotional t-shirt. questions anytime you are unsure, you maintain your objectivity and foster good, ethical business relationships. DECLINING A GIFT OR OFFER What is … 0M`V\HYLVɈLYLKHNPM[[OH[KVLZU»[JVUMVYT[V Entertainment? our guidelines, respectfully and politely return the gift and explain UGI’s policy. Typically, an event during which a business discussion takes place, If you are concerned that declining the gift such as: would be seen as disrespectful (due to • A meal at a restaurant; cultural reasons, for example), accept the gift on behalf of the Company and contact your • A sporting event; or manager and the UGI Compliance Group so • A cultural event. that we can determine its proper disposition. Often, these gifts may be donated to a charity on behalf of the Company. (NPM[VYVɈLYVMLU[LY[HPUTLU[[OH[WSHJLZ`V\\UKLY ZVTLVISPNH[PVUVYPUÅ\LUJLZ`V\YKLJPZPVUTHRPUN is always inappropriate. 48 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED KNOWING THE RULES ABOUT GIFTS AND ENTERTAINMENT continued WHAT CAN WHAT CAN YOU DO? YOU DO? ࠮ Make sure you know - Entertainment is not what’s acceptable. acceptable if it is: - Gifts must be lawful, nominal » A specialty ticket to a in value, and aligned with our sporting event like the standards and policies; and Super Bowl or World Cup; - Entertainment must be » An “adult” form of non-lavish, reasonable, and entertainment (e.g., infrequent. Both the business strip clubs); or partner and the UGI employee » responsible for the business (X\PKWYVX\VVɈLY relationship must attend the - The rules for what you may event together (you may NP]L[VHNV]LYUTLU[VɉJPHSHYL UV[WHZZVɈ[PJRL[Z[VHU employee who has no direct L_[YLTLS`Z[YPJ[¶KVUV[VɈLY or provide anything of value HɉSPH[PVU^P[O[OLI\ZPULZZ (either directly or indirectly) to partner or attend the event without the business partner). HNV]LYUTLU[VɉJPHS^P[OV\[ obtaining approval in advance from the UGI Compliance Make sure you know ࠮ Group or the Law Department what’s not acceptable. (see the Preventing Bribery - Gifts are never acceptable and Corruption and if they are: Contracting With the Government sections of the » Lavish or frequent; Code for more information). » Cash or cash equivalents (e.g., gift cards); » Legally prohibited; or » A quid pro quo (i.e., you give me this, and I will NP]L`V\[OH[VɈLY 49 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED KNOWING THE RULES ABOUT GIFTS AND ENTERTAINMENT continued EVERYDAY EVERYDAY INTEGRITY INTEGRITY Q: An employee I supervise wished to Q: I was invited to an industry conference congratulate me on a promotion. She gave sponsored and paid for by one of our me a $200 gift card. Is this an acceptable suppliers. It will be held at a resort gift to accept from my direct report? and the supplier will pay all expenses including travel and lodging. The purpose A: No, you should not accept this gift. First, of the conference is to demonstrate the gift cards are considered cash equivalents supplier’s new line of software. May I and are not permitted by our guidelines. attend this conference? Second, the amount of $200 is considered SH]PZO(UKÄUHSS`[OLMHJ[[OH[P[^HZNP]LU A: 0M[OLYLPZHI\ZPULZZW\YWVZLHUKHILULÄ[ after a promotion may lead others to view to our Company, attendance may be this as a bribe. permitted; however, our Company should pay all expenses. You must avoid the Q: A supplier invited me to a local sporting HWWLHYHUJLVMHU`JVUÅPJ[VMPU[LYLZ[HUK never put yourself in a position of being event and provided me with a free ticket. obligated to any certain vendor. Check with May I attend the game? your manager or with the UGI Compliance Group for guidance. A: Yes, provided that the supplier will be joining you for the game and the other facts surrounding this invitation, such as the frequency of such tickets being provided to you, do not create the appearance of a JVUÅPJ[VMPU[LYLZ[VYPTWYVWLYPUÅ\LUJL Also, please note the importance of it being a regular season game (as opposed to the World Series or World Cup). 50 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We rely on Company spokespersons to provide COMMUNICATING information about UGI to ensure consistency ABOUT UGI and accuracy. OUTSIDE INQUIRIES As a publicly traded company, UGI’s public statements must be carefully managed to ensure accuracy and compliance with legal requirements. Unless you are a designated spokesperson, don’t speak on behalf of UGI or give the impression that your views represent those of the Company. If you are contacted by the media, investors, or market analysts and asked to discuss Company business, advise the individual that you’re not authorized to respond and refer them to the proper resource. For questions from external parties, contact the UGI Investor Relations team at Investors@ugicorp.com. 51 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED COMMUNICATING ABOUT UGI continued SOCIAL MEDIA :VJPHSTLKPHVɈLYZH]HS\HISLWSH[MVYTMVYZOHYPUN WHAT CAN information and maintaining personal and business YOU DO? relationships. But use good judgment. Remember, you are responsible for what you post – make sure Don’t speak on behalf of UGI your use doesn’t violate our Code, our policies, or unless you’re authorized to do so – the law, and make it clear that any opinions you refer all inquiries to the appropriate express about our Company are your own, not resource. those of UGI. ࠮ Take care in your social media use to: If you see posts on social media that you believe are inaccurate or unfairly represent UGI, don’t - Never disclose proprietary attempt to correct the misinformation, but VYJVUÄKLU[PHSI\ZPULZZ instead contact your respective Communications information about UGI, our Department so they may address it. customers, or our business partners; - Avoid posting anything that could be discriminatory or constitute harassment; and - Think before you hit “send” – remember that what you WVZ[VUSPULYLÅLJ[ZVU`V\ personally and, possibly, as an employee and that online communications live forever. 52 WE PRESERVE OUR REPUTATION

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED WE SUPPORT THE COMMUNITY PROTECTING THE ENVIRONMENT HONORING HUMAN RIGHTS VOLUNTEERING AND CONTRIBUTING RESPONSIBLY 53 WE SUPPORT THE COMMUNITY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We sustain and protect the environment where PROTECTING THE we live and work. ENVIRONMENT A GOOD STEWARD Our Value of Responsibility speaks to the commitment UGI makes to promoting sustainability and the responsible use of the Earth’s natural resources. We comply with all applicable environmental laws and regulations in the locations where we operate. But we look for opportunities beyond what’s legally mandated to be environmentally responsible in the operation of our facilities, to invest in alternative energy sources, to provide consumers with energy- saving tips, and to forge partnerships with others on environmentally friendly projects. WHAT CAN YOU DO? Follow all safety rules for handling, transporting, and disposing of hazardous waste. ࠮ Promptly report any environmental concerns, including leaks, spills, dumping, or discharging. ࠮ Reduce your environmental footprint – practice recycling where available and reduce your personal consumption of water, energy, and other resources. 54 WE SUPPORT THE COMMUNITY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We are committed to treating all people HONORING HUMAN RIGHTS with respect and dignity. STAY ALERT We conduct our business in a manner that WHAT CAN respects the human rights and dignity of all, YOU DO? HUK^LZ\WWVY[PU[LYUH[PVUHSLɈVY[Z[VWYVTV[L and protect human rights, including an absolute ࠮ Report any suspicion or evidence VWWVZP[PVU[VZSH]LY`HUKO\THU[YHɉJRPUNJOPSK of human rights abuses in our labor, and forced labor. operations or in the operations of our suppliers. We never knowingly do business with any ࠮ Remember that respect for human individual or company that violates employment dignity begins with our daily laws or engages in human rights abuses. We interactions with one another also expect our suppliers to source responsibly, and with our suppliers and monitor their suppliers and, where needed, customers. It includes promoting require corrective action. diversity, making reasonable accommodations for disabilities, and doing our part to protect the rights and dignity of everyone with whom we do business. 55 WE SUPPORT THE COMMUNITY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED We are making a positive impact on communities VOLUNTEERING AND around the corner and across the globe. CONTRIBUTING RESPONSIBLY CHARITABLE ACTIVITIES POLITICAL ACTIVITIES We celebrate employees who are making a UGI encourages you to exercise your civic duty. WVZP[P]LKPɈLYLUJLPU[OLJVTT\UP[PLZ^OLYL they live, work, and play. Personal political activities should be undertaken on your own time, using your own funds and We encourage your personal involvement in resources. Make it clear that your views and charitable organizations and causes. Just make HJ[PVUZKVU»[YLÅLJ[[OVZLVM<.0HUKKVU»[ sure that your activities are undertaken without solicit support – for political candidates, parties, pressuring coworkers or business partners to or committee organizations – from others you support them and that your participation is in work with. If you plan to seek or accept a public accordance with any local policies. VɉJLUV[PM``V\YTHUHNLYPUHK]HUJL@V\^PSS need to discuss with your manager and the UGI UGI sponsors many initiatives designed to *VTWSPHUJL.YV\W^OL[OLY`V\YVɉJPHSK\[PLZ support communities, too. You are invited (but TPNO[HɈLJ[`V\Y^VYRMVY[OL*VTWHU` not required) to dedicate time and talents to advancing education, community development, UGI’s political action committee (UGI/PAC) disaster response, and the environment. allows eligible employees to voluntarily donate personal funds to collectively support political When UGI sponsors an event or makes a candidates who understand issues important to contribution, it must be done under appropriate UGI and our industry in the United States. But local approval. If you have any questions or there are strict rules and reporting requirements concerns, please contact the Law Department. associated with these contributions. For more information, contact the Law Department. 56 WE SUPPORT THE COMMUNITY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED VOLUNTEERING AND CONTRIBUTING RESPONSIBLY continued WHAT CAN EVERYDAY YOU DO? INTEGRITY ࠮ Take care to not let your personal Q: 4H`0\ZL[OLVɉJLWYPU[LY[VJYLH[L interests interfere with your Å`LYZMVYHWVSP[PJHSL]LU[&0HTOVZ[PUN professional interests. Avoid it at my local community center. JVUÅPJ[ZVMPU[LYLZ[. Your charitable and/or political activities A: No. Although UGI encourages your should never adversely impact the involvement with candidates and causes time or energy you bring to your that are important to you, you may not job at UGI. use Company resources to advance your personal interests, unless you ࠮ Seek approval from your have received approval in advance from manager when volunteering or Company management to do so. participating in charity events during working hours. ࠮ Be aware that neither UGI (nor the PAC) will reimburse you for any personal charitable or political contributions you make. ࠮ Obtain permission from the Law Department before engaging in lobbying. 57 WE SUPPORT THE COMMUNITY

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED CLOSING THOUGHTS Thank you for reading our Code and making a commitment to doing the right thing. Working together, we’ll maintain the reputation we’ve earned for exceeding the expectations of our customers, being a great place to build a career for our employees, and returning value to our communities and investors. Remember, our success is not only a function of the energy products and services we deliver. It is also a function of the everyday ways in which we deliver them – it is how we do what we do. That is what makes us a great company. As you go about your daily responsibilities as a UGI employee, use the Code as a resource for answers to questions, access to people who can help you, and resources for speaking up about misconduct. I look to each and every member of the UGI family – through lawful and ethical conduct – to build upon the Company’s legacy and to lay the groundwork for serving future generations of customers. Monica M. Gaudiosi *OPLM*VTWSPHUJL6ɉJLY UGI Corporation gaudiosim@ugicorp.com 58 CLOSING THOUGHTS

TABLE OF HELPLINE LAST PAGE CONTENTS VIEWED Need help? Talk to your manager, any member HELPFUL RESOURCES of management, or your local Human Resources representative. Contact information for other key resources is listed below. CONTACT CONTACT INFORMATION Corporate Human Resources HumanResources@ugicorp.com Corporate Internal Audit Department InternalAudit@ugicorp.com Corporate Investor Relations Investors@ugicorp.com Corporate Law Department LawDepartment@ugicorp.com <.0»Z+H[H7YV[LJ[PVU6ɉJLY Privacy@ugicorp.com The UGI Compliance Group Compliance@ugicorp.com The UGI/AmeriGas Integrity Helpline Share your concern online: https://ugiamerigasethicshelpline.tnwreports.com Share your concern via phone: In the United States, call toll-free: 866-384-4272 For all other countries, access dialing instructions here: https://ugiamerigasethicshelpline.tnwreports.com/Phone WAIVERS :DLYHUVRIRUH[FHSWLRQVWRWKH&RGHUHTXLUHVSHFLðFSULRU 5HJDUGLQJ86HPSOR\HHVRQO\QRWKLQJLQWKLV&RGHRULQ written DSSURYDORIWKH&KLHI([HFXWLYH2τFHUWKH&KLHI DQ\RIRXUSROLFLHVLVLQWHQGHGWROLPLWRULQWHUIHUHZLWKWKH &RPSOLDQFH2τFHUWKH&RPSDQ\âV%RDUGRI'LUHFWRUVRU ULJKWWRHQJDJHLQDFWLYLWLHVSURWHFWHGXQGHU6HFWLRQRI D%RDUGFRPPLWWHHSULRUWRXQGHUWDNLQJDQ\DFWLRQRU WKH861DWLRQDO/DERU5HODWLRQV$FWVXFKDVGLVFXVVLRQV DFWLYLW\WKDWZRXOGRWKHUZLVHEHGHHPHGD&RGHYLRODWLRQ UHODWHGWRZDJHVKRXUVZRUNLQJFRQGLWLRQVKHDOWKKD]DUGV $Q\ZDLYHUVJUDQWHGZLOOEHSXEOLFO\GLVFORVHGDVUHTXLUHG DQGVDIHW\LVVXHV 59 HELPFUL RESOURCES

THE UGI CODE OF BUSINESS CONDUCT AND ETHICS 2019