Kinder Morgan : Code of Business Conduct and Ethics

Code of Business Conduct and Ethics

Our Vision:

Delivering energy to improve lives and create a better world.

IntegrityAccountability

Safety

Excellence

Kinder Morgan Code of Business Conduct and Ethics

Dear colleagues,

At Kinder Morgan, we are committed to doing business the right way, every day. To meet this commit- ment, our employees and representatives must act with integrity, honesty and respect for people in fulfilling their responsibilities to Kinder Morgan. Integrity, coupled with Accountability, Safety and Excellence, as well as the other values expressed in our Code, are the foundation of our Company. Remember: people first, safety always.

The Office of The Chairman and the Board of Directors of Kinder Morgan, Inc. (or KMI) adopted and approved Kinder Morgan's Code of Business Conduct and Ethics (or Code). Our Company's Code of Business Conduct and Ethics provides guidance as to how we conduct our business and identifies resources that are available to help you ensure your actions are consistent with our values. The Code also provides information on Kinder Morgan's Ethics Hotline, including how to reach the hotline and the additional steps in the reporting process.

Each of us is required to comply with this Code, Company policies and all applicable laws and regulations. At Kinder Morgan, compliance is not optional - it is every employee's responsibility. We believe acting according to our values is the best way to conduct our business. No one should ever compromise those values to meet financial goals or any other objective.

There may come a time when a situation you face is not covered in the Code, or you have a compliance or ethics question or concern. Our goal is to create a work environment where each employee is comfortable speaking up. We expect and encourage you to ask questions, seek advice, and raise issues and concerns. Our leaders are required to foster this type of environment, but everyone plays a role in making it happen. The Ethics Hotline is available if you are not comfortable speaking up in person, wish to remain anonymous or believe your concern has not been properly addressed. There will be no retaliation against anyone who, in good faith, reports a compliance or ethics concern.

As you continue in your everyday duties, please remember that maintaining our reputation as a good corporate citizen is paramount. We are judged by how we act and what we do. Success can only be attained, and maintained, if each of us is dedicated to upholding our values and the highest possible standards of business conduct.

Sincerely,

Kimberly A. Dang	Richard D. Kinder	Tom Martin
CEO	Executive Chairman	President

Table of Contents

• Our Values and Code

Driven By Our Values	.	6
Purpose of Our Code of Conduct and Ethics	.	7
-	Doing Your Part	.	7
Speaking Up		. 8
Using the Ethics Hotline	.	. 9
Investigating Reports		10
Zero Tolerance for Retaliation	. 11
» Employees and the Workplace
Equal Employment Opportunity		13
-	Harassment-Free Environment		13
Substance Abuse		15
Social Media		16
Protecting and Using our Assets		17
Conflicts of Interest		19
-	Related Party Transactions		20
-	Employment of Family Members		21
-	Gifts		22
-	Outside Employment		23
-	Membership on Outside Boards of Directors		23
-	Personal Investments		24
-	Business Opportunities		24

• Business Integrity

Confidential Information	. 26
-	What is Confidential Information?	. 26
-	Protecting Confidential Information	27
-	Permissible Disclosures	28
Information Governance	. 29
- What is a Record?	29
-	Records Retention and Destruction	30
-	Governmental Inquiries and Investigations	. 30
Accuracy of Records and Reporting	31
Insider Trading	33
Anti-Corruption	. 35
Trade Controls and Sanctions	. 37
Fair Competition and Antitrust Laws	38
Energy Industry Regulatory Compliance	39
Government Contracts	40
» Neighbors and Communities
Operational Excellence	42
- Operations Management System	43
- Environment, Health and Safety	44
External Communications	46
Political and Community Activities	. 47
» Interpretations and Waivers
Interpretations and Waivers	49

Effective: 01/01/2000, Revised: 04/23/2024

OUR VALUES

AND CODE

Driven By Our Values . . . . . . . . . . . . . . . . . . 6 Purpose of Our Code of Conduct and Ethics . . . . . . . 7

- Doing Your Part . . . . . . . . . . . . . . . . . 7 Speaking Up . . . . . . . . . . . . . . . . . . . . . . 8 Using the Ethics Hotline . . . . . . . . . . . . . . . . 9 Investigating Reports . . . . . . . . . . . . . . . . . 10 Zero Tolerance for Retaliation . . . . . . . . . . . . . 11

IntegrityAccountability

SafetyExcellence

Kinder Morgan Ethics Hotline | 866-293-2402

Driven By Our Values

At Kinder Morgan, we expect all of our employees to act with integrity, do the right thing and treat everyone with respect every day. Our core values of Integrity, Accountability, Safety and Excellence, coupled with the other values and principles discussed in this Code, drive every aspect of our business. They are the foundation that helps us achieve sustained success and create lasting benefits for all our stakeholders: investors and other security holders, customers, employees, business partners, regulators and the communities in which we live and work.

We act with Integrity by:

• being honest, trustworthy, ethical, respectful and professional
• honoring commitments, helping others, taking responsibility for our actions
• complying with our Code, Company policies and laws and regulations

We require Accountability by:

• promoting transparency with all of our stakeholders
• engaging in structured reviews of our operations and performance
• creating and rigorously tracking clear goals and detailed budgets

We focus on Safety by:

• integrating safety into all aspects of our operations
• challenging ourselves to beat industry and company incident averages
• driving risk reduction and continuous performance improvements

We strive for Excellence by:

• aspiring to be a best-in-class operator and employer
• working to protect people and the environment
• aligning our interests with the interests of our investors
• fostering teamwork, diversity and pride in our work

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Purpose of Our Code of Conduct and Ethics

This Code refers to KMI as Kinder Morgan or the Company. The Code outlines how our values translate into everyday behavior, establishes high standards of ethical conduct and keeps us working toward a common goal - to be a company driven by its values. The Code also incorporates Company policies and the laws and regulations we must follow. We comply not just because it is required, but because it is the responsible thing to do.

The Code cannot address every issue you will face, but your actions should always be consistent with our Com- pany's values and expectations. This is essential to maintaining Kinder Morgan's reputation and yours as well. You should be generally familiar with the entire Code, even though some sections may be more relevant to your job than others. The Company provides numerous resources to help you determine the appropriate course of action. Always seek guidance when in doubt about compliance or laws and regulations.

In certain sections, you will see a"To Learn More"box with links to additional Company policies on the identified topic. These links are for Kinder Morgan employees and will not work for outside parties.

Doing Your Part

This Code applies to Kinder Morgan, its controlled subsidiaries and each entity that they manage, operate or control from time to time, as well as their directors, officers and employees. We expect our consultants, contractors, suppliers, vendors and business partners to adhere to standards of conduct consistent with our Code when conducting company-related business activities.

You are expected to understand the Code and company policies, and comply with the obligations and responsibilities that apply to you. We are a highly regulated company and your actions in certain instances could expose you to civil and even criminal penalties, including imprisonment. Your compliance efforts can directly affect your performance evaluation and compensation. In addition to the obligation to comply with this Code and promptly report suspected violations, employees may be required to certify periodically that they have read and complied with this Code.

Your Responsibilities:

• Know and comply with our Code and Company policies that apply to your job.
• Conduct yourself in an ethical manner and com- ply fully with all applicable laws and regulations.
• Report any concerns or issues promptly, and seek guidance when you are not sure what to do.

Leaders' Responsibilities:

• Create a workplace where employees feel comfortable asking questions and raising concerns or issues.
• Exemplify ethical conduct in all of your actions and proactively promote a culture of compliance.
• Ensure that no employee is subject to retaliation because of a good faith report of a concern or issue.

Kinder Morgan Ethics Hotline | 866-293-2402	7

Speaking Up

Our values require an environment where every employee feels comfortable seeking guidance and reporting concerns or issues. In this environment, our employees bring questions, issues and concerns to the attention of their supervisors, management and other Company departments on a timely basis. Talk to someone if you need guidance on what to do, or if you have a concern or issue that relates to our business.

• In most instances, the best person to talk to will be your supervisor or your Human Resources representative. However, there may be instances where you will not feel comfortable speaking to your supervisor, or where it makes more sense to go direct- ly
  to another Kinder Morgan resource, for example the Legal Department, Internal Audit or our Ethics Hotline.
• Some Code topics deal with complicated laws or regulations (for example, Insider Trading, Fair Competition, Antitrust, Anti-Corruption, Trade Controls and Sanctions). For these areas, it is especially important that you contact the Legal Department.
• No matter how or to whom you report your concern, it will be evaluated and investi- gated as appropriate.

Supervisors must take steps to appropriately respond to an employee seeking guidance or reporting a concern or issue. Make sure you understand the question, concern or issue and contact the appropriate department to help you respond promptly.

Remember:

It is always better to seek guidance on the appropriate course of action before doing something that could have serious negative repercussions for you as well as for the Company.

When you have a good faith concern or issue, you must raise it as soon as possible and be prepared to disclose everything you know about it. There will be no retaliation for a good faith report of a concern or issue.

Good faith means that the individual providing the information believes that it is true and complete. It does not mean that the individual's understanding of the facts must be

correct.

Q&A

Q: If I see a safety issue, but it is not in my area, should I still report it?

1. Yes, if you have a good faith reason to believe that one or more of the following has occurred or is occurring, then you are required to promptly report:
2. • any violation of this Code, Company policy or any applicable laws and regula- tions
   • any threat to human health, safety or the environment
   • any hazards, potential hazards, incidents or near misses
   • any fraud or any wrongdoing related to our financial books, records, or internal or external reporting

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UsingTitle the Ethics Hotline

If you are not comfortable speaking up in person, wish to remain anonymous, or believe you received an inadequate response, you can ask questions or report your concern or issue using the Kinder Morgan Ethics Hotline (Ethics Hotline).

• The Ethics Hotline is confidential and available 24 hours a day, 7 days a week at [phone], or online through the Ethics Hotlinelinks on the Kinder Morgan websites.
• The Ethics Hotline is maintained by a third party who will report the information you provide to the appro- priate people at Kinder Morgan. Whether you report your concern by calling the hotline or going online, you can remain anonymous and still have your matter submitted for review. If you call the Ethics Hotline, tell the operator you want to remain anonymous and do not provide your name. If you file a report online, choose the anonymous option and do not disclose your name.

Nothing in our Code or our Company's policies restricts you from reporting potential violations of laws or regulations to relevant government authorities.

When you contact the Ethics Hotline:

• File a report, without providing your name if you want to remain anonymous.
• Provide as much information as possible when reporting your concern or issue.
• You will be given a code number that will allow you to check the status of your matter, ask further questions or respond to questions that are asked of you.
• Write your code number down. The code number is important because the Company may need additional

information to properly investigate the claim. Please call or log in from time-to-time to see whether there is new information from the Company or if more information is needed from you.

• Your issue will be communicated to select members of se- nior management or the Board of Directors as appropriate.
• Your issue will be evaluated and timely investigated.
• Your issue will be monitored and formally closed when the investigation is complete.

Q&A

1. If I contact the Ethics Hotline, will they be able to identify me through caller ID, my computer's IP address or any other identifying factor?

1. No, the Company has taken steps to protect your identity.

1. Is there anything else I need to do after I make a report?

1. After you make a report, it is essential that you keep your code number and periodi- cally check back by calling the Ethics Hotline or accessing it online. This is particularly important when you have made an anonymous claim. It is the only way the Company can contact you to get additional information, and it will permit you to check the status of the report.

Kinder Morgan Ethics Hotline | 866-293-2402	9

Investigating Reports

The Company will promptly initiate an appropriate investigation into any reported allegation or suspicion of a violation of this Code, Company policy or a law or regulation. One or more individuals, who are knowledgeable and experienced in investigations, and with no conflicting interests, will be assigned to conduct the investigation.

If the investigation finds a violation, the Company will take appropriate action. Employees who violate our Code, Company policies or any laws and regulations will be subject to discipline, which could result in termination, even for a first offense.

If asked, you must cooperate with a Company investigation. Failure to fully and honestly cooperate with an investigation is grounds for discipline, up to and including termination of employment.

Ethics Hotline: [phone]

Q&A

1. If I think Kinder Morgan is incorrectly reporting certain revenues, but my co-worker disagrees with me, should I report the issue?

1. Yes, if you have a good faith belief that a potential accounting error is occur- ring, you should report it through one of the avenues listed in the Code.

1. If I file a report and the investigation finds a violation, will the Company tell me what discipline is taken against the violators?

1. Generally not. The Company does not usually publicize disciplinary actions.

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