This excerpt taken from the SWN 8-K filed Aug 4, 2008.
CODE OF ETHICS FOR SECTION 406 OFFICERS
(As Required by Section 406 of the Sarbanes-Oxley Act)
Section 406 of the Sarbanes-Oxley Act of 2002 requires each company registered with the Securities and Exchange Commission to disclose whether or not it has adopted a code of ethics for senior financial officers. In accordance with Section 406, Southwestern Energy Company (the Company) has adopted this Code of Ethics for Section 406 Officers (the Code). The Companys chief executive officer (principal executive officer), chief financial officer (principal financial officer) and chief accounting officer (principal accounting officer) (collectively, the § 406 Officers) are bound by this Code, which sets forth the Companys requirements with respect to ethical conduct, conflicts of interest and compliance with applicable laws. While the Company expects honest and ethical conduct in all aspects of business from all of its employees, it expects the highest possible honest and ethical conduct from the § 406 Officers. The § 406 Officers hold an important and elevated role in corporate governance in that they are uniquely capable and empowered to ensure that all shareholders interests are appropriately balanced, protected and preserved. Compliance with this Code is a condition of employment, and violations of the Code may result in disciplinary action, up to and including termination of employment.