Describe the tone, language and structure of the following code of ethics:

Compliance with Laws, Rules, and Regulations Southwest Employees, members of its Board of Directors, and business associates are expected to obey and respect the law, both in letter and in spirit, including compliance with the following: Confidential Information; Insider Trading. All non-public information about Southwest should be considered confidential information; such non-public information is a valuable Company asset. To use non-public information for personal financial benefit or to “tip” others who might make an investment decision on the basis of this information is not only unethical but also illegal. It is the responsibility of all Southwest Airlines Employees, Board members, and business associates to protect the interests and privacy of Southwest’s Customers and Coworkers. You may not inappropriately discuss, solicit, disclose, or use for your personal benefit information in Company records, files, or databases, such as Rapid Rewards Member information, Passenger Name Records (reservations), refund or credit card transactions, Employee/Customer correspondence, personnel files, or work schedules. Page 2 Competition and Fair Dealing. We seek to outperform our competitors fairly and honestly. We seek competitive advantage through low costs, low fares, and superior Customer Service, never through unethical or illegal business practices. Our advertising and other communications with our Customers are simple, direct, and straightforward, as well as compliant with the law. We are required to comply with antitrust laws and similar laws governing competition. As part of our compliance procedures, we make our own decisions concerning pricing, markets, routes, and Customers to be served. It is strictly prohibited to enter into agreements with our competitors or suppliers that have even the appearance of impropriety. Payments to Government Personnel. It is strictly prohibited to make illegal payments to government officials of any country. The promise, offer, or delivery to an official or Employee of the federal, state, or local government of a gift, favor, or other gratuity in violation of applicable law violates Company policy and may also be a criminal offense. Federal law prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. Any questions about the foregoing should be raised promptly with the General Counsel Department.