Safe, Reliable, and Resilient

F O R O U R C U S T O M E R S , C O M M U N I T I E S , A N D E M P L O Y E E S

ATMOS ENERGY CORPOR ATION

2020 Corporate Responsibility and Sustainability Report

During these challenging times, Atmos Energy remains focused on our vision to be the safest provider of natural gas services. This year, reliable and affordable energy is more essential than ever.

Above: Jacqueline, Service Technician 1 in Dallas, provides safe and courteous service as we continue to "Make Our Safe System Safer" during our pipeline replacement projects.

Cover: Prior to March 2020, Phillip, a Service Technician 2 from Dallas, explains his findings after completing a safety check during the service restoration process.

To that end, we must operate exceptionally well, invest in our employees and infrastructure, enhance our culture,

and continue to make a difference in the communities we serve.

Corporate Governance

Safety

We're fostering strong governance

We're investing in technologies of

to achieve our vision.

the future to improve safety today.

Communities

Employees

We're fueling safe and thriving

We're supporting our people,

communities every day.

the heart and soul of our company.

Environment

We're doing our part to protect and

preserve our environment today and for generations to come.

ATMOS ENERGY CORPOR ATION

2020 Corporate Responsibility and Sustainability Report

A M E S S A G E F R O M L E A D E R S H I P

Letter to Our Stakeholders

Fiscal 2020 Corporate Responsibility and Sustainability Highlights

ENVIRO N MENTAL

  • Continued to reduce methane emissions by replacing 845 miles of pipe
  • Delivered 5.1 Bcf of RNG and CNG; equivalent to removing 58,000 cars from the road annually
  • Joined Our Nation's Energy Future Coalition (ONE Future)

SO CIAL

  • Kicked off our rebranding efforts for Fueling Safe and Thriving Communities
  • Provided over 226,000 training hours to our employees; approximately 40 percent were delivered virtually
  • Contributed $14 million to charitable organizations

G OVERN A N CE

  • Transitioned 95 percent of our employees to a digital working environment
  • Launched a Corporate Responsibility section on our website to provide greater transparency around our ESG practices
  • Formalized our corporate communications strategy to further improve engagement with all stakeholders

Atmos Energy is rooted in the belief that safety is at the center of everything we do, and it is our enduring vision to be the safest provider of

natural gas services. To be sure, fiscal 2020 brought challenges; however, our steadfast commitment to safety paired with the guiding principles of our culture, AtmoSpirit, enabled us to emerge stronger and demonstrate the resiliency and reliability of natural gas.

As the public health crisis escalated in the 1,400 communities we serve, the safety of our employees, our customers, and our communities remained our focus. Therefore, we implemented employee and customer safety practices and protocols to ensure continued safe and reliable delivery of natural gas service. Doing our part to help slow the spread, more than 95 percent of our 4,700 employees safely transitioned to remote work and continued to perform at the highest level. We were able to accomplish this because our culture of teamwork and inclusion means we can move fast and adapt quickly.

We took the early step to voluntarily suspend natural gas disconnections and announced a $1.5 million donation to stock the shelves at local food banks around the country to support those in need. Additionally, we donated $1 million to energy assistance agencies in our service territories to support our friends and neighbors in need. We also helped arrange over $11 million in financial assistance through LIHEAP, our Sharing the Warmth program, and other assistance programs to help struggling customers manage past-due balances.

As part of our safety practices and protocols and to ensure the continued safe operation of our gas systems, employees wear face coverings and practice social distancing guidelines. We also implemented screening precautions to protect our customers and employees. Those actions provided us the ability to continue our system modernization work.

Over the next five years, we plan to spend $11 billion to $12 billion to make our safe system even safer by replacing 5,000 to 6,000 miles of pipe. Despite the pandemic, we have a reasonable plan to complete the replacement of the remaining cast iron in our system by December 2021. Additionally, we remain on target to reduce methane emissions across our natural gas distribution system by 50 percent from 2017 to 2035. You can read more about our focus on safety and long-term sustainability on our website in the Corporate Responsibility section.

I want to thank all of our Atmos Energy employees, as they continue to provide our customers safe and reliable natural gas service. I am extremely proud of their dedication and commitment to keeping our 3.1 million customers, our 1,400 communities, themselves, and their families healthy and safe. At Atmos Energy, we take immense pride in fueling safe and thriving communities every day, and we pledge to continue that outreach as part of our ongoing commitment to deliver safe, reliable, affordable, and efficient natural gas.

Thank you for your support of Atmos Energy.

Executive Chairman of the Board

J. Kevin Akers

President and Chief Executive Officer

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S A F E T Y

We're investing in technologies of the future to improve safety today.

Our commitment to safety guides every decision we make because the safety of our employees, customers, and communities is essential. Because safety is our number one priority, we continually innovate and advance employee training, communicate safety messaging to our customers and communities,

and invest in the modernization of our system.

Anthony is a Senior Construction Operator in Louisiana and is a

Safety Team Lead at his local service center.

S A F E T Y

Remaining Resilient During Uncertain Times

During this year of uncertainty, our culture provided the foundation for Atmos Energy to be resilient and focused on our vision to be the safest provider of natural gas services.

Workforce

  • At the end of our fiscal year, 95 percent of our employees were working in a digital working environment and continue to perform at the highest level.
  • Employees have been trained and are following social distancing and other safety measures recommended by the CDC.
  • Field operations personnel receive electronic work orders and report directly to the jobsite.
  • Employees continue to receive high-quality technical training through virtual classrooms.
  • Atmos Energy Wellness Workshops help support emotional, physical, and work-lifewell-being for employees during COVID-19.

Atmos Energy employees showed their appreciation for our health care heroes with a drive-by truck parade and dropped off lunch at Texas Health Harris Methodist in Cleburne, Texas.

S A F E T Y

Saluting Our Health Care Heroes

Nurses, doctors, paramedics, hospital administrators, and laboratory technicians have been working tirelessly throughout the pandemic. Many were unable to take a quick break or grab a sandwich at the hospital cafeteria, and some were even forced to live apart from loved ones in order to limit exposure and keep their own families healthy. During National Hospital Week in May, we saluted health care workers' heroic efforts by delivering more than 12,000 meals to health care heroes in the eight states we serve. Our team members safely coordinated with local health care professionals caring for coronavirus patients to deliver hearty meals full of hometown flavor from local restaurants that offer expanded takeout and delivery services during the coronavirus pandemic.

Safety

  • Safety remains our top priority; safety meetings are held virtually or on jobsites with employees maintaining social distancing.
  • Employees are following the Occupational Health & Safety Administration (OSHA)'s Guidance on Preparing Workplaces for COVID-19.
  • Employees are provided sanitizing products for themselves as well as for equipment and vehicle cleaning.
  • New safety signage was placed to remind employees to follow social distancing and equipment cleaning protocols.
  • A new mobile and desktop application for employees was developed to complete a daily wellness check-in.

Community

  • Customer service agents use screening protocols to ensure customers and employees remain healthy and safe.
  • We temporarily suspended disconnections for nonpayment, and temporarily waived late payment and reconnect fees during these challenging times.
  • We communicated with customers who may be facing financial hardship that payment assistance is available through LIHEAP and our Sharing the Warmth program. We also provided payment flexibility by offering installment plans and accepting partial payments.
  • Employees use updated safety signage on jobsites to remind the community of the protocols we are following to keep them safe.

Feeding Students and Families in Times of Need

Millions of U.S. workers filed for unemployment benefits in the wake of the economic shutdown, and many of those were parents with children who rely on school food programs for breakfast and lunch every day.

$1.5M

Atmos Energy donated $1.5 million to quickly stock the

shelves at local food banks.

D O N A T I O N

By directing $1.5 million from the Atmos Energy/Robert W. Best Charitable Giving fund to numerous local food banks around the country that serve students and families most in need, organizations like the North Texas Food Bank (NTFB) were able to make a direct and immediate impact on the communities we serve. Every dollar donated to the NTFB provided access to three healthy meals, and 94 percent of every dollar goes directly to hunger relief programs in the 13 counties it serves.

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S A F E T Y

Ambassador Program Boosts Damage Prevention Efforts

Because third-party damage represents one of the greatest threats to distribution systems, Atmos Energy administers a Damage Prevention Ambassador Program that empowers team members to identify and prevent potential digging accidents in the field. In fiscal 2020, ambassadors inspected more than 28,000 excavation sites, helping to prevent many potentially dangerous and costly accidents.

For example, in our West Texas Division, where new home growth is flourishing, Damage Prevention Ambassadors in cities like Midland, Odessa, Big Spring, and Lubbock are always on the lookout for opportunities to raise awareness and strengthen relationships with contractors, homeowners, municipal utilities, and the public.

Pictured is Darsey, a Crew Leader who takes part in the Damage Prevention Ambassador Program in the West Texas Division.

S A F E T Y

Safety Training Helps Save Lives

Training is an essential element of safety, empowering our employees to perform their jobs safely while also keeping our customers and the public safe. Drawing on their preparation and experience, several team members recently demonstrated compassion, skill, and selflessness that was beyond compare and ultimately helped save lives.

While reading meters in a residential neighborhood, Service Technician Desmond witnessed a man fall off his roof. Desmond and a neighbor rushed to where the injured man lay on the ground, and Desmond coached the neighbor to assist the injured man according to his first aid and first responder training. When the paramedics arrived, Desmond was told by the ambulance attendant that his medical training was invaluable in keeping the man safe until help could arrive.

"I was grateful the first aid and first responder training that I received allowed me to help in this situation until the ambulance arrived."

- Desmond

The program encourages personnel driving a company vehicle to visit active excavator sites and ask if the workers called 811 before digging. If not, employees are empowered to stop work, distribute 811 literature and take photos of the excavation site for documentation in a mobile app.

"We use the app to be proactive in engaging contractors before they can possibly damage us, to make sure they have called 811 and are digging safely around Atmos Energy underground facilities," said the West Texas Compliance Manager. The West Texas Division has inspected more than 3,600 excavation sites to help ensure safe digging practices.

Calling 811 to locate and mark utility lines is crucial for safe digging. Clem, a Crew Leader, marks a natural gas line with temporary paint in Louisiana.

In another instance, Senior Construction Operators Jacob and Kolby, and Crew Foreman Marcus, had just finished lunch when they came upon a woman holding a baby who was struggling to breathe. They quickly leaped into action, applying their CPR training to help the infant while simultaneously flagging down a passing ambulance. The paramedics stopped and quickly transported mother and baby to the hospital, and the team discovered later that day that the baby was fine. The employees credit their company safety training in helping to save the infant's life.

Pictured from left to right: Senior Construction Operators Kolby and Jacob, and Crew Foreman Marcus

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E M P L O Y E E S

We're supporting our people, the heart and soul of our company.

Our employees are our greatest asset and our most important investment. We recruit and hire individuals with a variety of skills, talents, backgrounds, and experiences. We value our culture that respects and appreciates inclusion and diversity as it reflects the unique communities that we serve.

Sheila is a Damage Prevention Technician in Mississippi and is passionate about the safety of our employees and protecting the integrity of our distribution system. She is an enterprise leader in the company's Damage Prevention Ambassador Program.

E M P L O Y E E S

Making a Difference for New Employees

E M P L O Y E E S

Culture of Leadership

For years, all new employees have traveled to the Charles K. Vaughan Center to participate in a three-day,in-person workshop to learn about our AtmoSpirit culture and the role each employee plays in making Atmos Energy the safest provider of natural gas services. When we pivoted to a digital work environment this year, members of our Workforce Development team introduced Virtual Atmos Energy Essentials, which is designed to remotely onboard 10 new employees per session from any location. Two groups of new employees "virtually meet" throughout a single week - one group from 9 a.m. to 1 p.m. and another group from 1 p.m. to 3 p.m. each weekday.

"We adjusted our existing AtmoSpirit content to function as a virtual curriculum after running a pilot workshop with a diverse cross-section of employees from across the enterprise," said AtmoSpirit Facilitator Jack, who co-created the virtual orientation.

This partial-day format allows participants to learn and apply AtmoSpirit principles in their work and home life, and Microsoft Teams provides the technology to foster a true connection between the participants.

Our culture of leadership begins before an applicant is offered a job and continues through performance planning, personal development, and succession planning.

Workforce performance enhances our leadership pipeline. Each year, employees participate in goal setting, regular check-ins with supervisors, and year-end reviews to capture what they will do to live AtmoSpirit, help achieve our vision, adapt to change, and continuously improve. One of the most important components of our AtmoSpirit culture is personal development.

In 2019, 64 percent of the participants in our five developing leaders learning tracks were minorities/ women. Currently, 25 percent of our leaders are women and more than 20 percent are minorities.

Our leadership development efforts and succession planning for all employees is reflected in the increase in leadership diversity over the last five years, including a 10 percent increase for women and an overall 34 percent increase for minorities.

L E A D E R S

B Y G E N D E R

L E A D E R S B Y

R A C E / E T H N I C I T Y

  • 75% Men
  • 25% Women
  • 4% Asian
  • 6% Black or African American
  • 10% Hispanic or Latino
  • <1% Native American or Alaska Native
  • 1% Two or more races
  • 79% White

Growth and Diversity

Our company is a place where people with diverse backgrounds strive to create a great future - together. Investing in our people has allowed us to expand our workforce and reflect the changing demographics in the communities where we live, work, and play. We partner with local colleges and universities to identify and recruit qualified applicants in each of the cities and towns we serve, and we target jobs fairs including those focused on minority, veteran, and women candidates.

Over the last five years, of the approximately 2,000 employees hired, 31 percent are women and 44 percent are minority.

R E C E N T H I R E S

B Y G E N D E R

within 5 years

R E C E N T H I R E S B Y R A C E / E T H N I C I T Y within 5 years

  • 69% Men
  • 31% Women
  • 2% Asian
  • 17% Black or African American
  • 19% Hispanic or Latino
  • 1% Native American or Alaska Native
  • 5% Two or more races
  • 56% White

Diana, a Measurement and Engineering Analyst in Dallas, is passionate about giving back and has volunteered with Susan G. Komen since 2001.

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E M P L O Y E E S

Innovative Virtual Training Enhances Employee Skills and Development

When we temporarily suspended in-person training at the Charles K. Vaughan (CKV) Center to maintain the safety of our workforce, our technical training team was prepared to transition technical training classes to a virtual environment to ensure our employees continued to have access to the training they need to realize our vision of being the safest provider of natural gas services. Core functions such as meter reading and service & construction were delivered via Microsoft Teams with self-paced courses and hands-on practice. New materials were also developed to support virtual learning, including a class syllabus, new online courses, video demonstrations, and field assignments.

This new style of digital learning enhances our job skills training and supports our business modernization efforts.

E M P L O Y E E S

Virtual Reality Lab at the Charles K. Vaughan Center in early 2020.

Our Workforce Development team launched a successful pilot of our Virtual Reality (VR) Emergency Response Situation module with 50 students who provided overwhelmingly positive feedback.

These pioneering solutions enhance our existing curriculum and perfectly complement the coaching that employees receive at our state-of-the-art CKV facility. Ongoing innovations in learning and development will continue to add value across our existing technical and job skills training as well as new employee development.

Continuous Training Leads to Safety Improvements

Because employee safety is paramount, our daily focus is to continuously improve on our safety training and protocols so that our essential workforce is always prepared to deliver safe, reliable natural gas.

The virtual training process features smaller class sizes and more one-on-one time for the instructors to spend with students through phone calls, video meetings, and online chat. The revised training schedule has also provided the opportunity to offer more classes and enables students to absorb training without traveling from other states to the DFW metroplex. Experienced employees have also been able to take advantage of virtual refresher training opportunities that reinforce their existing skills. This new style of digital learning enhances our job skills training and supports our business modernization efforts.

Training kits and props, such as this meter, were delivered to students in order to mimic the hands-on portion of training that would ordinarily be completed at the CKV training center.

OSHA

Recordable Injury Rate

(per 200,000 hours worked)

DART

Days Away/Restricted Duty/ Transfer Injury Rate

(per 200,000 hours worked)

RMVC

Reportable Motor Vehicle Collision Rate (per 1,000,000 miles driven)

2014

2019

2.80

2.85

2.90

2.95

3.0

2014

2019

1.66

1.67

1.68

1.69

1.70

1.71

1.72

2014

2019

5.0

5.1

5.2

5.3

5.4

5.5

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E N V I R O N M E N T

We're doing our part to protect

and preserve our environment today

and for generations to come.

We provide clean, efficient, and innovative energy solutions for our customers and communities, and continue to invest in system modernization that reduces our environmental impact. Our goal of reducing methane emissions by 50 percent from 2017 to 2035 is essential to our environmental commitment.

Atmos Energy, Texas Trees Foundation, Texas 811, and local officials celebrate 811 Day by safely planting 500 trees in 25 cities across Texas.

E N V I R O N M E N T

Innovative Natural Gas Technologies Provide Clean and Efficient Energy

We partner with customers and suppliers to apply innovative technologies that deliver sustainable solutions for a clean energy future, providing yet another pathway to protect and preserve our environment today and for generations to come.

E N V I R O N M E N T

Combined Heat and Power Delivers Low-Carbon, Affordable Energy Solutions

Combined heat and power (CHP) is an efficient and clean approach to generating electric power and useful thermal energy from a single fuel source, typically natural gas. The heat created from producing electricity, which is typically wasted, is captured and turned into steam or hot water that can be used for space heating, cooling, domestic hot water, and industrial processes. A 2016 Department of Energy study cited CHP as a clean energy solution that has a number of benefits, including reducing greenhouse gas emissions and energy operating costs,

Valued Partnerships Deliver Renewable Energy

The transportation of landfill gas is an important element of our strategy to responsibly reduce methane emissions. According to the EPA, municipal solid waste (MSW) landfills are the third-largest source of human-related methane emissions in the United States, and methane has a global warming potential more than 25 times greater than CO2. Reducing methane emissions can achieve significant near-term benefits in mitigating global climate change, so MSW facilities represent a unique opportunity to capture, convert, and use landfill gas as a renewable energy resource. Landfill gas producers need transmission companies like Atmos Energy to transport their renewable natural gas (RNG) to market.

RENEWABLE ENERGY PROCESS

5.1 Bcf

Of renewable natural gas transported

58,000

Equates to removing almost 58,000 passenger vehicles from our roads every year

in addition to increasing energy efficiency up to 75 percent when compared to electricity from the grid.

CHP is utilized in a variety of industrial facilities and commercial buildings to simultaneously supply electricity and provide thermal loads. CHP can also be integrated into district energy systems utilized by colleges, hospitals, downtown areas, and other campus-type facilities. A district energy system is a centralized facility that generates steam and hot and cold water that is piped through an underground network to buildings for space heating, air conditioning, and other energy needs.

Water

Heat Recovery

Steam or

Cooling/

Unit

Hot Water

Heating

Hot Exhaust Gases

Natural Gas

Engine/Turbine

Building, Facility,

or Grid

Electricity

Biogas is methane captured from

Biogas-derived methane is

Renewable natural gas is injected

Renewable natural gas is used to

landfills, agricultural and food

conditioned, processed, and refined

into utility-owned pipelines

fuel homes, businesses, industries,

waste, and wastewater

into pipeline-quality gas

and vehicles

Our relationship with River Birch landfill demonstrates how we are helping companies transport their RNG to market. The River Birch landfill is a 920-acre facility outside New Orleans that processes MSW emissions into approximately 4,500 Mcf of RNG every day. Since 2010 we have collaborated with River Birch on quality specifications and, during non-peak demand periods, to blend pipeline-quality natural gas with RNG from the landfill and then sell the gas to a power generator and local distribution company. Following a planned expansion that will connect it to the nearby Jefferson Parish landfill, River Birch will soon be the largest facility in the country producing pipeline-quality gas.

We also work with partners like HAMM Waste Services, a landfill gas manufacturing facility in Lawrence, Kansas, that produces 1.5 million Mcf of RNG from 130 "wells" on capped areas of the landfill. After passing through a series of filters and separation processes, additional scrubbing is done by a thermal oxidizer using natural gas provided by Atmos Energy. The "cleaned" natural gas meets Southern Star Pipeline standards and is marketed to fuel compressed natural gas (CNG) vehicles in California, helping to offset nearly 5 million gallons of gasoline in that state.

Natural Gas Fuels Microgrid to Provide Responsible Energy for Student Housing

Atmos Energy and Mississippi State University (MSU) teamed up with developer Greystar and Blue Sky Power to build College View Apartments. This innovative 130-unit student housing complex utilizes CHP technology to generate clean electricity that's powered by an onsite natural gas generator to provide electricity, hot water, and heating to all units.

This clean energy infrastructure, known as the MSU Clean Energy Microgrid, will generate reliable and resilient energy with the ability to operate fully independent of the city's electric grid. It also significantly reduces operating expenses by relying on a centralized electric and thermal energy system fueled by affordable natural gas. MSU will save approximately $116,000 every year in electric utility costs and will reduce CO2 emissions by more than 827 tons annually - the equivalent emissions of 162 passenger vehicles. This CHP project is the first in Mississippi for use in apartments, and MSU is already planning the next phase of this development.

$116,000

In electric costs saved annually

827

Tons of CO2 emissions avoided annually

162

Equates to removing the emissions of 162 passenger vehicles

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E N V I R O N M E N T

Helping Customers Save Money, Conserve Energy, Reduce Carbon Footprint

Efficiency is one of the main reasons why our customers choose natural gas as an essential energy source for their homes and businesses. To help our customers achieve energy savings and lower their environmental impact, we offer financial incentives for purchasing high-efficiency natural gas appliances and smart thermostats, plus installing weatherization materials in our Mississippi, Colorado, and Mid-Tex divisions.

45,000

1.2M

7,100

Residential and commercial

Therms of natural gas

Tons of CO2 emissions

customers participated in

conserved

avoided annually

energy efficiency programs

E N V I R O N M E N T

Atmos Energy Joins ONE Future

Our target to reduce methane emissions in our natural gas distribution system by 50 percent from 2017 to 2035

is an essential component of our environmental sustainability strategy. In January, Atmos Energy joined Our Nation's Energy Future Coalition (ONE Future), a voluntary alliance of leading companies across the natural gas supply chain focused on technology and policy solutions to drive continual improvement in the reduction of methane emissions.

Joining ONE Future includes a commitment to measuring, reporting, and tracking key emissions metrics in accordance with ONE Future protocols, reflecting our continued commitment to responsible, sustainable practices in our natural gas distribution businesses and pipeline and storage operations.

Natural Gas Provides Energy

Efficiency, Lower Environmental

Impact in New Home Construction

A 2019 National Association of Home Builders survey found that buyers are looking for energy-efficient homes that also have whole-house green certifications which are affordably and comfortably achieved with natural gas. We partnered with two Dallas-area builders, Hoffmann Homes and Urban Edge Developers, to provide marketing assistance and coordinate the infrastructure and installation of high-efficiency natural gas equipment so these builders could achieve Green Built Texas and Platinum LEED certified homes in Dallas.

In the Mississippi and Mid-Tex divisions, builders can take advantage of rebates on high-efficiency appliances like furnaces and water heaters, in addition to smart thermostats. These financial incentives have encouraged 36 builders to install higher efficiency models that avoid close to 600 tons of CO2 emissions annually.

Gerson, a Senior Utility Technician in Kansas, locates and marks underground natural gas pipelines with yellow temporary paint to ensure safe digging.

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C O M M U N I T I E S

We're fueling safe and thriving communities every day.

Community service is woven into the fabric of Atmos Energy's culture, and our employees take pride in fueling safe and thriving communities every day. We are committed to helping our children have a bright and healthy future by fighting childhood hunger and focusing on reading on level by third grade, showing appreciation to our hometown heroes, and providing assistance to our neighbors in need. Being a good neighbor also means providing helpful solutions for customers to pay their bills, and doing our part to support local economies so they can grow and flourish. Taking care of our communities is more essential now than ever.

Frank is a Colorado native who enjoys spending time with his family outdoors and volunteering at the Guadalupe Center in Greeley.

C O M M U N I T I E S

Fueling Safe and Thriving Communities Is Woven into Our Culture

C O M M U N I T I E S

Fueling Hope for Our Neighbors in Need

Compassion to give back to communities we serve flows through the heart and soul of Atmos Energy's 4,700 employees. Whether it is reading to students, working with local food banks, or showing appreciation to our hometown heroes, our employees have always invested in the communities we call home. In 2020, we formally rebranded what we have been doing for years - we call it Fueling Safe and Thriving Communities.

Fueling Bright Minds and Healthy Futures for Our Kids

Through our Fueling Safe and Thriving Communities program, we donated $2 million across the eight states we serve to provide resources that help students read on level by the third grade. Third grade marks the shift from "learning to read" to "reading to learn," which means deficient readers are at greater risk of falling behind. According to the National Conference of State Legislatures, research shows that students struggling to read at the end of third grade are four times less likely to finish high school.

Sharing a similar passion to open doors, broaden horizons, and position kids for success, we proudly committed $1 million of the donation to United Way of Metropolitan Dallas to bring life-changing resources to our youngest learners and their families.

Our average residential bill is one of the most affordable utility bills in the house, representing approximately 1 percent of the median household income in the eight states we serve. However, we recognize there are times when our customers need financial assistance with their bill. That is why we always stand ready to offer critical relief to families and businesses. In addition to our annual Sharing the Warmth contribution, we donated an additional $1 million directly to energy assistance agencies to help customers stay warm this winter. These funds are distributed in partnership with more than 100 energy assistance agencies and nonprofit organizations across the eight states we serve.

Beginning in March, we temporarily suspended natural gas disconnections for non-payment, in addition to offering additional flexible payment plans and raising awareness about financial help that is available to qualified households. To make sure homes and businesses have reliable and affordable natural gas, Atmos Energy continues to work with our customers and local assistance agencies to offer customers year-round relief and financial solutions including Atmos Energy's Sharing the Warmth program and the federal Low-Income Home Energy Assistance Program (LIHEAP).

Atmos Energy continues to work with our customers and local assistance agencies to make sure homes and businesses have reliable and affordable natural gas when they need it the most.

$9,518,903

Customer assistance received through LIHEAP and other assistance programs

$1,877,127

Financial assistance provided through our Sharing the Warmth program

37,424

Households assisted through energy assistance programs

An estimated 18 million children face hunger nationwide, so we also donated $2 million to join forces with hundreds of local school districts, food banks, and other essential organizations to give the breakfasts, lunches, snacks, and healthy meals that all children need to grow, develop, and succeed.

Fueling safe and thriving communities means we are committed to enhancing childhood literacy and reducing food insecurity, and these donations will fuel bright minds and healthy futures for the kids in our communities.

Fueling Honor and Appreciation for Our Hometown Heroes

Firefighters, police, medical professionals, teachers, and other community role models are America's everyday heroes, and we proudly support their continued dedication to the communities we serve. In September, Atmos Energy donated $105,000 to Colorado and Kansas fire departments that are essential in protecting public health, safety, and community well-being.

David, Colorado Operations Supervisor, shares his appreciation with the Greeley Fire Department Rescue team.

Atmos Energy employees Kurtis, David, and Frank donate backpacks, lunch boxes, and water bottles to a school in Greeley, CO. In attendance is Greeley-Evans Weld County School District 6 Superintendent, Dr. Deirdre Pilch, and Centennial Elementary Principal, Dr. Angie McDowell.

America's firefighters respond to health and safety emergencies every day, while fire departments also offer safety classes to educate the public about topics including the proper use of fire extinguishers, the importance of fire alarms, and sound evacuation procedures. As part of our commitment to fueling safe and thriving communities, we partner with thousands of firefighter personnel each year to provide natural gas safety training, promote home safety guidance to residents, and support victims of natural disasters.

Atmos Energy's donation helped to provide equipment and personal protective gear, raise awareness for community safety, support professional development, and expand volunteer fire departments.

"We are extremely grateful to Atmos Energy for their generosity and for their dedication to community safety, helping us prepare to deal with the vast array of emergencies we face," said Chief Dale Lyman of the Greeley (Colo.) Fire Department.

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C O M M U N I T I E S

Employees Pledge $875,000 During Week of Giving

Our employees take enormous pride in their commitment to fuel safe and thriving communities. During our annual Week of Giving campaign, employees across the enterprise pledged more than $875,000 in donations to benefit United Way, No Kid Hungry, and The Salvation Army. Further amplifying the impact of this tremendous financial support, the company matched all employee donations to double the vital resources crucial organizations use to enrich childhood literacy, provide nutritious meals, and offer a helping hand to our most vulnerable neighbors.

During Week of Giving, employees across the enterprise participated in various activities to give back to communities where they work and live. Some employees participated in an online Back to School Drive that amassed school supplies for students at Mi Escuelita, a preschool network that develops English language vocabulary skills at 11 locations in the Dallas area. Other employees wrote thank you notes to health care heroes to express gratitude for their service and offer words of encouragement. These are just a couple of examples of how our employees support their communities.

Employees participated in a logo design contest for Week of Giving. This is the winning logo by Bethany, Revenue Management Coordinator in Dallas, Texas.

C O M M U N I T I E S

Jack, Senior Service Technician, and Tyler, Senior Construction Operator, work with local Mississippi contractors to provide natural gas service to new customers in the Starkville area.

Natural Gas Is Fundamental for Growing Economies and Communities

Since 2018, we have partnered with the Mississippi Public Service Commission to implement a service expansion program benefiting rural communities that would otherwise lack access to affordable and reliable natural gas. Atmos Energy has completed 54 projects in 28 communities since the program's inception, with the most recent service extension occurring at the Mississippi Horse Park in Starkville as well as 50 current residences and another 200 planned homes in the area.

This is a prime example of how public and private entities can work together to expand access to reliable, affordable, and environmentally responsible natural gas.

2 6

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2 7

C O R P O R A T E G O V E R N A N C E

We're fostering strong governance to achieve our vision.

At Atmos Energy, strong corporate governance is core to our culture and our values. It supports our vision to be the safest provider of natural gas services, it mitigates risk, and is the foundation of our long-term corporate sustainability effort. We expect everyone to take responsibility for doing what is right for all stakeholders. Leading with integrity is essential for conducting our business ethically, instilling accountability in our employees and working with business partners who share our high standards and principles. We are committed to continuous improvement by providing an anonymous Compliance Helpline for employees, contractors, and the public to give feedback or make recommendations for improvements to safety, risk identification, prevention, and mitigation.

To access the Compliance Helpline, call

1-866-543-4065or visit our compliance website.

Doug, Operations Supervisor in the Golden Triangle area of Mississippi, has trained countless employees in his 40-year tenure with the company.

C O R P O R A T E G O V E R N A N C E

Corporate Governance Highlights

Atmos Energy has adopted a number of practices to promote strong corporate governance to ensure the long-term sustainability of the Company.

Board Practices

  • Independent lead director
  • Separation of board chair and CEO
  • 11 of 14 directors are independent
  • Annual election of all directors
  • Regular executive sessions of independent directors
  • Comprehensive and strategic risk oversight
  • Annual board and committee evaluations

Other Governance Practices

  • Executive and director stock ownership guidelines
  • Clawback policy
  • Prohibition on hedging or pledging stock

Shareholder Matters

  • Robust shareholder engagement
  • Annual say-on-pay voting
  • Majority voting for director elections
  • No poison pill defense

Board Committees

  • Audit Committee
  • Corporate Responsibility, Sustainability, & Safety Committee
  • Executive Committee
  • Human Resources Committee
  • Nominating and Corporate Governance Committee

Board of Directors

Our Board's leadership structure is designed to ensure independent oversight of corporate management and key issues related to strategy and risk. Our lead director is independent. All standing Board committees are chaired by independent directors. Additionally, independent directors regularly hold executive sessions outside the presence of the executive chairman, the president and CEO, or any other company employee. Directors serve one-year terms upon election and are reelected to subsequent one-year terms by a shareholder vote at the annual shareholders meeting. The Board has a mandatory retirement age of 75, with members serving through the annual meeting following their 75th birthday.

Board members are nominated annually based on their diversity of skills, background, financial literacy, availability, independence, and other relevant leadership qualities. We believe our Board has the right balance of tenure, with 50 percent of the Board members with 10-plus years of experience on the Board, providing consistency and historical perspective, and 43 percent with less than five years

of experience bringing new ideas and a fresh perspective.

28.6%

42.9%

B O A R D T E N U R E

21.4%

7.1%

< 5 years

10-15 years

5-9 years

> 15 years

3 0 ATMOS EN ERGY CO RP O R ATI O N

C O R P O R A T E G O V E R N A N C E

Leadership

Our Management Committee is comprised of five senior leaders responsible for the execution of company strategy as approved by the Board. The Management Committee meets regularly to actively monitor operations and financial performance; ensure compliance with policies, procedures, and ethical business practices; and implement strategy to achieve sustainable, long-term performance.

20%

32%

56%

Women and minorities on

Women and minorities

Women and minorities

Management Committee

as officers

recently appointed to

leadership

C O R P O R A T E G O V E R N A N C E

Leading with Integrity

Atmos Energy's Code of Conduct begins with our deep commitment to fairness, mutual respect, and participation. We are committed to abide by the letter and spirit of all laws and regulations that apply to our business. These guidelines apply to all of us, and remind us that what we do every day and how we do it are critically important to help us achieve our vision of being the safest provider of natural gas services. In 2020, 100 percent of active employees completed our annual Code of Conduct training. Our Code of Conduct training reinforces how to identify and deal with ethical issues such as conflicts of interest, gifts and entertainment, use of confidential information, fair dealing, protection of corporate assets, compliance with rules and regulations, and safety.

100%

In 2020, 100 percent of active employees completed our

annual Code of Conduct training.

If you have suggestions, recommendations, questions, or have witnessed a potential violation of the Code of Conduct, you may contact Atmos Energy's Compliance Helpline. All submissions to the Compliance Helpline are treated confidentially and we will not tolerate retaliation against anyone for submitting a concern or recommendation. In addition to our Code of Conduct, our Board has adopted several policies and guidelines that demonstrate our commitment to strong corporate governance and diversity.

Employee safety meetings, like this one in Mississippi, were conducted monthly in service centers prior to March 2020.

Succession Planning

Succession planning is an extensive annual process at Atmos Energy. It begins with our Board and goes down through all levels of the organization to ensure that we are building a strong bench of talent. Not only is talent identified, but potential paths of development are discussed to ensure that employees have an opportunity to build their skills and are well prepared for future roles. We have a long history of promoting our senior leadership from within the organization. Over the past five years women and minorities have accounted for 56 percent of the officer appointments, including the promotion of two women to division president.

In addition to Learning from Leaders, Atmos Energy provides numerous professional development courses ranging from "Is Supervision for Me?" to "OQ Evaluator Training."

Leaders Learning from Leaders

Just like our vision of being the safest provider of natural gas services, learning how to lead is a continuous, never-ending journey. We support this journey in a way that is aligned with our vision and our AtmoSpirit principles.

We have a proven approach for growing leaders that is guided by our belief that you learn it by doing it, by getting opportunities, receiving coaching and feedback, and through self-reflection. Leadership training and a well-equipped Learning from Leaders Toolkit support our organic, learn by doing approach to growing leaders. Our leader-led development goes beyond just communicating with and coaching direct reports. Our leaders collaborate and share information about how they are connecting with their employees and other leaders across the enterprise.

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3 3

Matthew, Senior Utility Technician, checks for continuity to ensure company assets are isolated to maximize protection of our system.

Appendix

a. Sustainability Accounting Standards Board (SASB) Index

b. Global Reporting Initiative (GRI) Index

c. Methane Emissions Report

d. DOT Report

A P P E N D I X

Sustainability Accounting Standards Board (SASB) Index

SASB

Question

SASB Title

Disclosure Title

Response

Code

Average retail gas

rate for (1) residential,

Historical information is available in the Atmos Energy

IF-GU-

Energy

(2) commercial, (3)

1

Corporation Statistical Summary, which is available on the

240a.1.

Affordability

industrial customers,

Atmos Energy Website.

and (4) transportation

services only

Typical monthly gas

For residential customers using 50 MMBtu per year the average

bill for residential

bill is $47.18.

IF-GU-

2

Energy

customers for (1)

240a.2.

Affordability

50 MMBtu and (2)

For residential customers using 100 MMBtu per year the average

100 MMBtu of gas

bill is $74.05.

delivered per year

Number of residential

This is a metric that we do not publicly disclose. However, we

proactively work with customers to provide them with solutions

customer gas

should they experience financial hardship. We are able to

disconnections

IF-GU-

Energy

provide our customers with financial assistance should the need

3

for non-payment,

240a.3.

Affordability

arise through programs like Sharing the Warmth and LIHEAP.

percentage

Beginning in March 2020 we temporarily suspended gas

reconnected within

disconnections for non-payment to help those customers who

30 days

were impacted by the economic effects of COVID-19.

Discussion of impact

Our customers' natural gas bills are some of the lowest in the

of external factors on

home and make up approximately 1% of the median income in the

IF-GU-

4

Energy

customer affordability

jurisdictions where we operate. We provide a comparison of our

240a.4.

Affordability

of gas, including the

monthly gas bill in our monthly investor report along with providing

economic conditions

a detailed chart of our bills' historical growth and factors that

of the service territory

impact customer bills.

In our distribution segment, we have weather normalization

Percentage of gas

(WNA) mechanisms in all states, except for Colorado. This

substantially mitigates the adverse effects of warmer-than-normal

utility revenues from

weather for meters in those service areas. We have one formal

rate structures that

IF-GU-

End-Use

lost revenue adjustment mechanism called the DSM in Colorado.

5

(1) are decoupled

420a.1.

Efficiency

We also have formula rate mechanisms in place in four states

or (2) contain a lost

that provide for an annual rate review and adjustment to rates.

revenue adjustment

In our pipeline and storage segment, approximately 80% of this

mechanism (LRAM)

segment's revenues are earned from delivery services to local

distribution companies (including our MidTex Division).

A P P E N D I X

SASB

Question

SASB Title

Disclosure Title

Response

Code

Gas savings efficiency measures are only permissible in jurisdictions

where it is allowed by our regulators. Currently we have four energy

efficiency programs in our service areas.

Colorado (Tariff Sheet 8a)

Gas Demand-Side Management Cost Adjustment (G-DSMCA)

All sales rate schedules for natural gas service are subject to a Gas

Demand-Side Management Adjustment ("G-DSMCA") designed

to prospectively recover prudently incurred costs of Demand-Side

Management Programs ("DSM Programs") in accordance with

Gas Demand-Side Management Rules 4750 through 4760 of the

Commission's Rules Regulating Gas Utilities and Pipeline Operators,

4 Code of Colorado Regulations 723- 4 ("Gas DSM Rules"). The

G-DSMCA Factor shall be separately calculated and applied to the

Company's base rates schedules for residential, small commercial,

and commercial customers. The Company shall recover the annual

expenditures projected for that year over a one-year period with the

G-DSMCA Factor.

Kentucky (Tariff Sheet 30)

Applicable to Rate G-1 Sales Service, residential class only. Purpose:

The Company offers a low-income weatherization program in order

to improve efficiency and household safety for eligible customers.

The program does not rehabilitate homes and does not include

home additions, paint, carpet, or lead-based paint and asbestos

abatements. The program may include, but not be limited to, the

replacement of doors and windows, caulking, window stripping,

IF-GU-

End-Use

Customer gas savings

installation of insulation, and/or the maintenance/replacement of

natural gas appliances.

6

from efficiency

420a.2.

Efficiency

measures by market

Mississippi (Energy Efficiency Rider Tariff)

The purpose of the Energy Efficiency Cost Recovery (EECR) Rider is

to establish the EECR Rate(s) by which the Company will recover its

energy efficiency Quick Start Plan program costs approved by the

Mississippi Public Service Commission ("Commission"), including

(1) the incremental energy efficiency program costs ("Incremental

Program Costs") and (2) lost contribution to fixed cost ("LCFC")

(collectively, the "Recoverable Costs"), all as described in Rule 29,

"Conservation and Energy Efficiency Programs," of the Commission's

Rules and Regulations Governing Public Utility Service, and as

approved by the Commission in Docket 2010-AD-2 on July 11, 2013.

Recovery of Incremental Program Costs is limited to the incremental

costs which represent the direct program costs that are not already

included in the then-current rates of the Company.

Mid-Tex (Conservation and Energy Efficiency Rider)

Atmos Energy Corporation's Mid-Tex Division provides a

Conservation and Energy Efficiency program which offers assistance

to residential and commercial customers to encourage reductions in

energy consumption and lower energy utility bills. The proposal is

one where Atmos Energy shareholders will fund half the allowable

expenses incurred annually, with a customer rate component

providing the remainder of the funding. The programs offered under

Rate Schedule CEE will be consistent with similar conservation and

energy efficiency programs offered by other gas utilities and may

include, but not be limited to, residential and commercial customer

rebates for high-efficiency appliances and equipment, as well as a

low-income customer weatherization assistance program.

Number of (1)

reportable pipeline

IF-GU-

7

Integrity of

incidents, (2)

Reportable Pipeline Orders - 6

Gas Delivery

Corrective Action

Corrective Action Orders - 0

540a.1.

Infrastructure

Orders (CAO), and (3)

Notices or Probable Violation (NOPV) - 0

Notices of Probable

Violation (NOPV)

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

SASB

Question

SASB Title

Disclosure Title

Response

Code

Percentage of

We publish this information in our annual DOT Report Filings.

IF-GU-

Integrity of

distribution pipeline

Additionally, the data is made available on our website, in our

8

that is (1) cast

annual Corporate Responsibility and Sustainability Report, and in

Gas Delivery

540a.2.

and/or wrought

our monthly Investor Updates. As of September 30, 2020, we had

Infrastructure

iron and (2)

356 miles of cast iron and 4,998 miles of unprotected steel which

unprotected steel

represents approximately 7.6% of our distribution pipeline.

In fiscal year 2020 we inspected approximately 18% or 1,035 miles

of the 5,684 total transmission miles.

IF-GU-

Integrity of

Percentage of gas

Atmos Energy surveys the approximately 75,000 miles of our

(1) transmission

9

Gas Delivery

distribution and transmission pipelines at rates and frequencies that

540a.3.

and (2) distribution

Infrastructure

meet and often exceed state and federal guidelines. Monitoring

pipelines inspected

frequency of pipelines is determined by federal and state pipeline

safety codes, accepted industry standards, and internal Atmos

Energy practices and procedures.

Atmos Energy is committed to being the safest provider of natural gas.

That's why we invest approximately $2 billion a year to modernize our

pipeline infrastructure.

Our system includes more than 75,000 miles of distribution and

transmission pipelines, as well as smaller "service" pipelines that

connect directly to homes and businesses. We bury much of our

pipe underground, where it is away from weather and activities that

commonly cause damage and leaks. Atmos Energy has always

had processes and procedures in place to ensure the safety of our

distribution and transmission network. During fiscal 2019, we adopted

a Pipeline Safety Management System (PSMS), which formally

documents our processes and procedures under a systematic and

structured framework that builds on our established pipeline safety

programs. PSMS was developed by the American Petroleum Institute

and is a recommended practice for the pipeline industry. All Atmos

Description of

Energy employees play a role in our PSMS through identification,

prevention, and remediation of operational safety risks.

efforts to manage

IF-GU-

Integrity of

the integrity of

Additionally, because third-party damage represents one of the greatest

10

gas delivery

threats to distribution systems, Atmos Energy administers a Damage

Gas Delivery

540a.4.

infrastructure,

Prevention Ambassador Program that empowers team members to

Infrastructure

including risks

identify and prevent potential digging accidents in the field. In fiscal

related to safety

2020, ambassadors inspected more than 28,000 excavation sites,

and emissions

helping to prevent many potentially dangerous and costly accidents.

Additionally, we operate an emergency hotline 24 hours a day, seven

days a week to respond to and investigate reports of natural gas leaks.

Atmos Energy is committed to practices that reduce methane emissions

from our transmission and distribution systems, including infrastructure

renewal programs to replace aging steel and cast iron distribution

pipelines. Atmos Energy utilizes a number of practices in its day-to-

day operations to prevent or reduce methane emissions. Some of the

practices include but are not limited to the following:

• Drawing down transmission line pressure when repairing or working

on the pipelines to reduce natural gas released to the atmosphere.

• Rerouting gas to minimize or prevent venting or blowdowns.

• Installing pipeline stopples and bypasses as necessary to maintain

operations and minimize extent of blowdown.

• Utilizing flares to combust methane instead of releasing methane to

the atmosphere.

A P P E N D I X

SASB

Question

SASB Title

Disclosure Title

Response

Code

Number of: (1)

IF-GU-

11

Activity

residential, (2)

Historical information is available in the Atmos Energy Corporation

commercial, and

000.A

Metric

Statistical Summary, which is available on the Atmos Energy Website.

(3) industrial

customers served

Amount of natural

gas delivered

to: (1) residential

IF-GU-

12

Activity

customers, (2)

Historical information is available in the Atmos Energy Corporation

commercial

000.B

Metric

Statistical Summary, which is available on the Atmos Energy Website.

customers, (3)

industrial customers,

and (4) transferred

to a third party

Length of gas (1)

At September 30, 2020, in our distribution segment, we owned

IF-GU-

an aggregate of 71,558 miles of underground distribution and

13

Activity

transmission and

transmission mains throughout our distribution systems. Through our

000.C

Metric

(2) distribution

pipeline and storage segment we also owned 5,684 miles of gas

pipelines

transmission lines.

This index is designed to provide information from the Sustainability Accounting Standards Board (SASB) reporting framework. It identifies where we make certain disclosures and provides unaudited information for the Gas Utilities & Distributors industry section within the infrastructure sector.

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Global Reporting Initiative (GRI) Index

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

102-1

General disclosures

Name of the organization

Atmos Energy Corporation

• Atmos Energy 2020 10-K

102-2

General disclosures

Activities, brands, products, and services

• Part I Item 1. Business

• Atmos Energy 2020 Proxy Statement

Atmos Energy Corporation

102-3

General disclosures

Location of headquarters

5430 LBJ Freeway

Suite 1800

Dallas, Texas 75240

102-4

General disclosures

Location of operations

United States

102-5

General disclosures

Ownership and legal form

• Atmos Energy 2020 10-K

• Part I Item 1. Business

102-6

General disclosures

Markets served

• Atmos Energy 2020 10-K

• Part I Item 1. Business

102-7

General disclosures

Scale of the organization

• Atmos Energy 2020 10-K

• Part I Item 1. Business

• Atmos Energy 2020 10-K

• Part I Item 1. Business

Information on employees and other

• Atmos Energy 2020 Corporate Responsibility

102-8

General disclosures

and Sustainability Report: Employees

workers

• Atmos Energy Website

• Corporate Responsibility: Employees

• Careers: Working at Atmos Energy

The Supply Chain Management Group is part

of the Atmos Energy shared services division.

Supply Chain: A description of the

The mission is to provide best-value supply chain

solutions through innovative insights with a strong

organization's supply chain, including

focus on customer service and our company's

102-9

General disclosures

its main elements as they relate to the

culture. Our core supply chain services include new

organization's activities, primary brands,

product approvals, contract review and corporate

products, and services

and operational sourcing, fleet and equipment

management, procurement and management of

our small businesses and supplier relationships.

Supply Chain: Significant changes to the

organization and its supply chain: changes

in the location of, or changes in, operations,

including facility openings, closings, and

expansions; changes in the share capital

There were no significant changes to Atmos Energy

102-10

General disclosures

structure and other capital formation,

Supply Chain in the past year.

maintenance, and alteration operations (for

private-sector organizations); changes in

the location of suppliers, the structure of the

supply chain, or relationships with suppliers,

including selection and termination

A P P E N D I X

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

• Atmos Energy 2020 10-K

• Part I Item 1A. Risk Factors

Precautionary

• Atmos Energy 2020 Corporate Responsibility and Sustainability

102-11

General disclosures

Report: Environment

principle or approach

• Board Committee Charters:

• Audit Committee

• Nominating and Corporate Governance Committee

102-12

General disclosures

External initiatives

Atmos Energy 2020 Corporate Responsibility and Sustainability

Report: Environment

• American Gas Association

• Belzoni Humphreys Development Foundation

• Building Owners and Managers Association

• Chamber of Commerce

• Common Ground Alliance

• Daughters of the American Revolution

• Economic Development Council

• Gas Technology Institute

• Home Builders Association

• Iberia Industrial Development Foundation

• Kentucky Association of Manufacturers

• Kentucky Gas Association

• Louisiana Association of Business

• Louisiana Chemical Industry Alliance

• Louisiana Gas Association

Membership of

• Louisiana Restaurant Association

102-13

General disclosures

• Middle Tennessee Industrial

associations

• Mississippi Hospitality and Restaurant

• Mississippi Manufacturers Association Membership

• Mississippi Partnership for Economic Development Inc.

• National Energy and Utility Affordability Coalition

• Northeast Tennessee Regional Economic Partnership

• Operations Technology Development Co.

• Our Nation's Energy Future (ONE Future)

• Pipeline Association for Public Awareness

• Prowers Economic Prosperity

• Rotary Club

• Southern Gas Association

• Society for Information

• Tarrant Regional Transportation Coalition

• Tennessee Economic Development Council

• Tennessee Gas Association

• Women's Energy Network

102-14

General disclosures

Statement from senior

Atmos Energy 2020 Corporate Responsibility and Sustainability

decision-maker

Report: Letter to Our Stakeholders

Atmos Energy 2020 10-K

102-15

General disclosures

Key impacts, risks,

• Part I Item 1A. Risk Factors

and opportunities

• Part II Item 7. Management's Discussion and Analysis

of Financial Condition and Results of Operations

Our vision is for Atmos Energy to be the safest provider of natural gas

services. We will be recognized for exceptional customer service, for

Values, principles,

being a great employer, and for achieving superior financial results.

• Atmos Energy 2020 Corporate Responsibility and Sustainability

102-16

General disclosures

standards, and norms

of behavior

Report:

• Employees

• Corporate Governance

• Atmos Energy Website: Careers; Diversity & Culture

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Atmos Energy Code of Conduct

We are committed to continuous improvement as we work

to achieve our vision of being the safest provider of natural

Mechanisms for advice and

gas. We provide an anonymous Compliance Helpline for

102-17

General disclosures

employees, contractors, and the public to give feedback

concerns about ethics

or make recommendations for improvements in safety, risk

identification, prevention, and mitigation at:

1.866.543.4065 or www.compliancehelpline.com/

welcomeAtmosEnergy.jsp.

• Atmos Energy 2020 Corporate Responsibility and

Sustainability Report: Corporate Governance

102-18

General disclosures

Governance structure

• Atmos Energy Website

• Corporate Responsibility: Corporate Governance

• Atmos Energy Governance Documents

• Atmos Energy About - Board of Directors

• Atmos Energy's Corporate Governance Guidelines

generally speak to the delegation of authority to

management.

102-19

General disclosures

Delegating authority

• Atmos Energy's Corporate Responsibility, Sustainability,

and Safety Committee Charter does not specifically state

that the authority is delegated, but refers to the Committee

overseeing company policies on these items, which

presumably management is responsible for.

Executive-level responsibility

• Atmos Energy 2020 Corporate Responsibility and

102-20

General disclosures

for economic, environmental,

Sustainability Report: Corporate Governance

and social topics

• Atmos Energy Website: About - Leadership

• Atmos Energy 2020 Corporate Responsibility and

Consulting stakeholders on

Sustainability Report:

102-21

General disclosures

economic, environmental,

• Letter to Our Stakeholders

and social topics

• Fiscal 2020 Corporate Responsibility and

Sustainability Highlights

Composition of the highest

102-22

General disclosures

governance body and its

Atmos Energy 2020 Proxy Statement

committees

102-23

General disclosures

Chair of the highest

Kim R. Cocklin

governance body

• Atmos Energy 2020 Proxy Statement

102-24

General disclosures

Nominating and selecting the

• Atmos Energy 2020 Corporate Responsibility and

highest governance body

Sustainability Report: Corporate Governance

• Atmos Energy Corporate Governance documents

• Atmos Energy 2020 Proxy Statement

• Atmos Energy Corporate Governance Guidelines

102-25

General disclosures

Conflicts of interest

• Atmos Energy Code of Conduct

• Atmos Energy Corporate Responsibility Website:

Governance

Role of highest governance

Atmos Energy Corporate Responsibility Website:

102-26

General disclosures

body in setting purpose,

• Corporate Governance

values, and strategy

• Atmos Energy Governance Documents

A P P E N D I X

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Measures taken to develop and enhance the highest

governance body's collective knowledge include regular

updates by senior management on financial, social, and

environmental issues that impact Atmos Energy and the

Collective knowledge of highest

natural gas industry. Ad-hoc updates include operational

102-27

General disclosures

reports, published articles, academic white papers,

governance body

and research reports on the defined topics, and peer

company publications. These updates are in addition to

the Company's quarterly Board and committee meetings

where members of senior management provide and review

educational materials on these topics.

Evaluating the highest

102-28

General disclosures

governance body's

Atmos Energy 2020 Proxy Statement

performance

• Atmos Energy 2020 10-K

• Item 1A. Risk Factors

• Item 7. Management's Discussion and Analysis of

Identifying and managing

Financial Condition and Results of Operations

• Atmos Energy 2020 Corporate Responsibility and

102-29

General disclosures

economic, environmental,

Sustainability Report: Corporate Governance

and social impacts

• Board Committee Charters:

• Corporate Responsibility, Sustainability,

& Safety Committee

• Audit Committee

• Atmos Energy 2020 10-K

• Item 1A. Risk Factors

Effectiveness of risk

• Item 7. Management's Discussion and Analysis of

102-30

General disclosures

Financial Condition and Results of Operations

management processes

• Board Committee Charters: Audit Committee

• Risk Management and Compliance Committee Charter

• Atmos Energy 2020 Proxy Statement

Board Committee Charters:

102-31

General disclosures

Review of economic,

• Corporate Responsibility, Sustainability, & Safety

environmental, and social topics

Committee

• Audit Committee

102-32

General disclosures

Highest governance body's role

Corporate Responsibility, Sustainability, & Safety

in sustainability reporting

Committee of the Board of Directors

Atmos Energy 2020 Proxy Statement

• P.O. Box 650205, Dallas, Texas 75265-0205

102-33

General disclosures

Communicating critical concerns

• Company's Compliance Helpline at 1-866-543-4065

https://www.compliance-helpline.com/

welcomeAtmosEnergy.jsp

102-34

General disclosures

Nature and total number of

There were no critical concerns reported to the Board

critical concerns

of Directors.

Atmos Energy 2020 Proxy Statement:

102-35

General disclosures

Remuneration policies

• Executive Compensation Program Objectives

and Strategy

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Process for determining

Atmos Energy 2020 Proxy Statement:

102-36

General disclosures

• Executive Compensation Program Objectives

remuneration

and Strategy

102-37

General disclosures

Stakeholders' involvement in

Atmos Energy 2020 Proxy Statement

remuneration

102-38

General disclosures

Annual total compensation

Atmos Energy 2020 Proxy Statement

ratio

102-39

General disclosures

Percentage increase in annual

Atmos Energy 2020 Proxy Statement

total compensation ratio

• Government and Regulatory Entities

• Governors Office, State Public Utility Commissions, and

City Councils

• Customers and Communities

• Customer advocacy groups, economic development

groups, NGOs, local news, engineering/consulting

102-40

General disclosures

List of stakeholder groups

firms, commercial and industrial customers

• Peer Utilities and Associations

• Employees

• Investors

• Suppliers

• Midstream gas, RNG suppliers, contractors, materials

suppliers, technology suppliers

102-41

General disclosures

Collective bargaining

Atmos Energy does not have collective bargaining

agreements

agreements in place.

Stakeholders are identified through their direct engagement

with Atmos Energy (Employees, Customers, Investors,

102-42

General disclosures

Identifying and selecting

Suppliers, Regulators) and through the identification of

stakeholders

stakeholders that have a unique and/or a vested interest

in our organization (community partners, environmental

agencies, customer advocacy groups, industry associations).

Atmos Energy engages with our stakeholders through

multiple channels. The engagement is tailored to address

the stakeholder audience and the information being

communicated. For direct communications with stakeholders

we engage using email, phone calls, and in-person or

virtual meetings. For indirect engagement we utilize our

102-43

General disclosures

Approach to stakeholder

website, social media platforms, surveys, printed mailings,

engagement

and marketing campaigns. In addition to these methods we

engage with investors through quarterly and annual earnings

calls, through 1 x 1 meetings in conferences, virtual meetings,

or upon request. We also engage with employees through

satisfaction surveys and our annual review process. None

of this engagement was undertaken in connection with the

preparation of this report.

A P P E N D I X

General Disclosures

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Throughout the year we engage with stakeholder groups in a

variety of ways to gather feedback related to Atmos Energy's

operations, policies, procedures, and industry-specific

issues. This engagement allows us to proactively address

topics and potential concerns raised by different stakeholder

Key topics and concerns raised

groups. Key topics include:

102-44

General disclosures

• The role of natural gas in the domestic energy portfolio of

(stakeholder engagement)

the future

• Methane emissions and environmental impact

• Establishing goals and targets and setting a timeline for

each action

• Renewable natural gas

• Customer advocacy

Entities included in the

Atmos Energy 2020 10-K

102-45

General disclosures

consolidated financial

• Part I Item 1. Business

statements

Defining report content and

We are following the Global Report Indicator (GRI)

102-46

General disclosures

Standards "Core" reporting methodology as the basis

topic boundaries (materiality)

of our disclosures.

102-48

General disclosures

Restatements of information

No restatement of information

102-49

General disclosures

Changes in reporting

No changes in reporting

102-50

General disclosures

Reporting period

Fiscal Year 2020 (October 1, 2019 - September 30, 2020)

102-51

General disclosures

Date of most recent report

The Atmos Energy's Corporate Responsibility and

Sustainability Report, published in November 2020

102-52

General disclosures

Reporting cycle

It is Atmos Energy's intent to publish a Corporate

Responsibility and Sustainability Report annually

102-53

General disclosures

Contact point for questions

investorrelations@atmosenergy.com

regarding the report

Claims of reporting in

102-54

General disclosures

accordance with the GRI

This report references the 2016 GRI Reporting Standards

Standards

102-55

General disclosures

GRI content index

This index

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Economic Performance

GRI #

GRI Standard Title

Disclosure Title

Response/Location

201-1

Economic performance

Direct economic value

Atmos Energy 2020 10-K

generated and distributed

• Part II

Financial implications and

Atmos Energy 2020 10-K

• Part I Item 1A. Risk Factors

201-2

Economic performance

other risks and opportunities

• Part II Item 7. Management's Discussion and Analysis of

due to climate change

Financial Condition and Results of Operations

Defined benefit plan

Atmos Energy 2020 10-K

201-3

Economic performance

obligations and other

• Part II Item 8. Financial Statements and Supplementary Data

retirement plans

201-4

Economic performance

Financial assistance

Atmos Energy received no government assistance in Fiscal

received from government

Year 2020.

Proportion of senior

202-2

Economic performance

management hired from the

100% of senior management is hired from the local community.

local community

The infrastructure investments made by Atmos Energy support

local economies and stakeholders. Through infrastructure

Infrastructure investments

investments we promote local economies by providing jobs in

203-1

Economic performance

the communities where we operate and as customers to local

and services supported

business and suppliers. These investments allow us to provide

a clean and reliable fuel source to our customers and operate

safely which is to the benefit of all stakeholders.

Atmos Energy 2020 Corporate Responsibility and

Sustainability Report:

• Communities

Significant indirect

• Environment

203-2

Economic performance

Atmos Energy Website

economic impacts

• Fueling Safe and Thriving Communities

• Corporate Responsibility

• Communities

• Environment

A P P E N D I X

Economic Performance

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Atmos Energy partners with a variety of groups to ensure the

safe delivery of natural gas. We are committed to enterprise

decision making and a proactive approach in identifying

opportunities through our suppliers, employees, and

customers. We encourage our suppliers to build relationships

204-1

Economic performance

Proportion of spending on

with Atmos Energy employees, as the better they understand

local suppliers

our needs the better product support they can provide. We

also support local hiring initiatives to ensure local suppliers

and contractors have the opportunity to work with us. At least

28% of our budget has been spent with small and diverse

businesses each of the last three years, and 99% of our

vendors are headquartered in the United States.

Atmos Energy Corporate Governance Documents:

Operations assessed for risks

• Corporate Governance Guidelines

205-1

Economic performance

• Director Independence

related to corruption

• Code of Conduct

• Political Activities Policy

Communication and training

• Atmos Energy Code of Conduct

• 100% of Atmos Energy active employees completed our

205-2

Economic performance

about anti- corruption

annual Code of Conduct training.

policies and procedures

• Atmos Energy political activities policy

205-3

Economic performance

Confirmed incidents of

Atmos Energy has had no confirmed incidents of corruption or

corruption and actions taken

actions taken.

Legal actions for anti-

Atmos Energy 2020 10-K

206-1

Economic performance

competitive behavior, anti-

• Part I Item 3. Legal Proceedings

trust and monopoly practices

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Economic Performance

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Direct (Scope 1) GHG

Atmos Energy Corporate Responsibility Website:

305-1

Emissions

Environment - AGA voluntary reporting tool

emissions

• EPA filing subpart NN and W

Energy indirect (Scope 2)

Atmos Energy Corporate Responsibility Website:

305-2

Emissions

Environment - AGA voluntary reporting tool

GHG emissions

• EPA filing subpart NN and W

305-4

Emissions

GHG emissions intensity

Atmos Energy Corporate Responsibility Website:

Environment - AGA voluntary reporting tool

305-5

Emissions

Reduction of GHG emissions

Atmos Energy Corporate Responsibility Website:

Environment - AGA voluntary reporting tool

305-6

Emissions

Emissions of ozone-depleting

Atmos Energy does not release ozone-depleting substances.

substances (ODS)

Nitrogen oxides (NOX),

Atmos Energy Corporate Responsibility Website:

305-7

Emissions

sulfur oxides (SOX), and other

Environment - AGA voluntary reporting tool

significant air emissions

306-4

Effluents and waste

Transport of hazardous waste

Atmos Energy does not transport hazardous waste.

Environmental

Non-compliance with

Atmos Energy has had no material fine for non-compliance

307-1

environmental laws and

compliance

with environmental laws and regulations.

regulations

A P P E N D I X

Social Indicators

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Atmos Energy 2020 Corporate Responsibility and Sustainability

Report: Employees

401-1

Employment

New hires and employee

Over the last five years, of the approximately 2,000 employees hired,

turnover

31% are women and 44% are minority.

Total employee turnover, including retirements, for calendar year

2019 was 7%, including 4% voluntary turnover.

Benefits provided to full-

Atmos Energy does not provide health or life insurance benefits to

time employees that are

401-2

Employment

temporary or part-time employees. Additionally, part-time employees

not provided to temporary

receive a reduced allocation of time-off benefits.

or part-time employees

Workers representation in

403-1

Occupational health

formal joint management-

100% of Atmos Energy employees are represented in formal joint

and safety

worker health and safety

management-worker health and safety committees.

committees

Types of injury and rates

• Atmos Energy 2020 Methane Emissions Report

• Atmos Energy 2020 Corporate Responsibility and

of injury, occupational

Occupational health

Sustainability Report:

403-2

diseases, lost days,

and safety

• Employees

absenteeism, and number

• Atmos Energy Corporate Responsibility Website:

of work-related fatalities

• Employees

Workers with high

Atmos Energy has not identified a high incidence or risk of work-related

Occupational health

incidence or high risk of

403-3

diseases. In March 2020 we moved to a virtual work environment out

and safety

diseases related to their

of an abundance of caution due to the COVID-19 pandemic.

occupation

In fiscal year 2020 we completed 226,235 training hours, which

equals approximately 48 average training hours per employee.

Our internal training programs focus primarily on Operations, Safety,

Customer Service, and our foundational employee & leadership

development programs. Of the employees who participate in these

trainings, the average hours of training is:

404-1

Training and education

Average hours of training

per year per employee

Average Hours

Technical Training

51.6

Employee Development

9.7

Client Service Organization

85.5

Safety Training

18.1

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Social Indicators

GRI #

GRI Standard Title

Disclosure Title

Response/Location

We provide our employees with the training, tools, and

opportunities to grow and develop, which is vital to our long-

Programs for upgrading

term sustainability. Additionally, we want our employees to

404-2

Training and education

employee skills and transition

take their education as far as they desire. We provide support

assistance programs

through the Robert W. Best Education Assistance program,

which provides support for employees to work toward

advanced technical training or a college degree.

Percentage of employees

Substantially all of Atmos Energy's full-time employees receive

404-3

Training and education

receiving regular performance

annual performance and career development reviews.

and career development reviews

• Atmos Energy 2020 Proxy Statement

• Atmos Energy 2020 Corporate Responsibility and

Sustainability Report:

405-1

Diversity and equal

Diversity of governance bodies

• Employees

opportunity

and employees

• Corporate Governance

• Atmos Energy Corporate Responsibility Website:

• Employees

• Corporate Governance

Freedom of association

Operations and suppliers in which

the right to freedom of association

407-1

and collective

There is no significant risk.

and collective bargaining may

bargaining

be at risk

411-1

Rights of indigenous

Incidents of violations involving

Atmos Energy has had no known incidents of violations

peoples

rights of indigenous peoples

involving rights of indigenous peoples.

Human rights

Employee training on human

Atmos Energy Code of Conduct

412-2

100% of Atmos Energy active employees completed our

assessment

rights policies or procedures

annual Code of Conduct training.

• Atmos Energy 2020 Corporate Responsibility and

Sustainability Report:

• Communities

Operations with local community

• Environment

413-1

Local communities

engagement, impact assessments,

• Atmos Energy Website

and development programs

• Fueling Safe and Thriving Communities

• Corporate Responsibility

• Communities

• Environment

Operations with significant actual

Atmos Energy Website

• Pipeline Replacement Projects

413-2

Local communities

and potential negative impacts on

• Corporate Responsibility

local communities

• Environment

A P P E N D I X

Social Indicators

GRI #

GRI Standard Title

Disclosure Title

Response/Location

Atmos Energy's Political Activities Policy provides guidelines

on company lobbying and political spending activities as

415-1

Public policy

Political contributions

well as engagement by our employees in the overall political

process.

Atmos Energy Corporate Governance Documents:

• Political Activities Policy

Requirements for product and

Atmos Energy complies with all state and federal requirements

417-1

Marketing and labeling

related to identification and labeling as it applies to our

service information and labeling

natural gas distribution and transmission business.

Incidents of non-compliance

Atmos Energy has not had any non-compliance concerning

417-2

Marketing and labeling

concerning product and service

product and service information and labeling.

information and labeling

Incidents of non-compliance

Atmos Energy has not had any non-compliance concerning

417-3

Marketing and labeling

concerning marketing

marketing communications.

communications

Substantiated complaints

Atmos Energy has received no substantiated complaints

concerning breaches of

418-1

Customer privacy

concerning breaches of customer privacy and losses of

customer privacy and losses of

customer data.

customer data

Socioeconomic

Non-compliance with laws and

Atmos Energy has had no material fines for non-compliance

419-1

regulations in the social and

compliance

with laws and regulations.

economic area

This index is designed to provide information from the Global Reporting Initiative's (GRI) Sustainability Reporting Standards. It identifies where we make certain disclosures and provides unaudited information related to the reporting standards.

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

2020 Methane Emissions Report

Atmos Energy is committed to practices that reduce methane emissions from our transmission and distribution systems, including infrastructure renewal programs to replace aging steel and cast iron distribution pipelines.

As part of Atmos Energy's efforts to reduce methane emissions, we joined the Environmental Protection Agency's (EPA) Natural Gas Methane Challenge Program as a founding partner in March 2016. As part of the Natural Gas Methane Challenge Program, a voluntary partnership that encourages oil and natural gas companies to improve efficiency and reduce methane emissions, Atmos Energy set a goal to replace cast iron and unprotected steel mains at an annual rate of 1.5 percent. We have performed, and expect to continue to perform, above our stated goal. In 2020 Atmos Energy joined ONE Future, which is a coalition of natural gas companies working together to voluntarily reduce methane emissions across the natural gas value chain. In addition, Atmos Energy has a goal to reduce methane emissions by 50 percent from 2017 to 2035 in its natural gas distribution system.* The Corporate Responsibility, Sustainability & Safety Committee of the Board of Directors oversees these goals as well as the Company's other sustainability and environmental practices. The Committee's charter can be found on atmosenergy.com.

New Technologies Keep Everyone Safer

We are working with industry and technology partners to develop and evaluate new technologies to enhance safety. For years we have partnered with the Gas Technology Institute, which develops technology-based solutions for the natural gas industry. We were among the early participants in our industry to evaluate technologies that had the potential to be adapted to our business. This partnership has produced tools we are incorporating into our daily processes, such as mobile technology that captures critical infrastructure data during construction and operations.

A P P E N D I X

OSHA

3.00

2.88

Recordable Injury Rate

(per 200,000

hours worked)

2014

2019

DART

1.72

1.69

Days Away/Restricted

Duty/Transfer Injury Rate

(per 200,000

2014

2019

hours worked)

RMVC

5.46

5.25

Reportable Motor

Vehicle Collision Rate

(per 1,000,000

2014

2019

miles driven)

Investing in Technology to Improve Safety

Modernizing Infrastructure

Atmos Energy utilizes state-of-the-art instrumentation for leak detection, monitoring, and leak grading to enhance safety for the public, our customers and employees, and to protect the environment. Atmos Energy reviews advances in technology as they are brought to market and incorporates them as deemed appropriate for our leak detection and monitoring efforts. This includes advanced mobile leak detection technology, including cavity ring-down spectroscopy (CRDS) for surveying our distribution system that is 1,000 times more sensitive than legacy technologies. As of December 31, 2019, Atmos Energy had 13 advanced mobile leak detection technology units mounted and operating in vehicles.

Leak Detection Technologies we use:

  • Remote methane leak detection (RMLD)
  • Flame ionization detector (FID)
  • Combustible gas detector (CGI)
  • Optical methane detector (OMD)
  • Forward-lookinginfrared camera (FLIR)

Distribution Miles Replacement Rate

1,000

Miles

800

600

400

200

0

2013

2014

2015

2016

2017

2018

2019

2020

21-25E

Bare Steel, Cast Iron, Vintage Plastics

Other Risk-Based Materials

Reduces Carbon Footprint

Replacing pipelines reduces leaks and methane emissions. We track and report greenhouse gas emissions in accordance with the Environmental Protection Agency's (EPA) Greenhouse Gas Reporting Rule, which requires reporting of greenhouse gas data and other relevant information from large sources and suppliers in the United States. In addition, all of our operating divisions report to various state agencies that have environmental jurisdiction over our activities.

To monitor compressors and storage fields, we use FLIR cameras as well as RMLD, FID, and CGI equipment. RMLD, CGI, CRDS, and OMD equipment is used to conduct inspections and surveys of buried natural gas distribution and transmission pipelines. The equipment utilized to perform leak surveys is dependent on several different criteria, including but not limited to safety, weather, instrument capabilities, location, application, and operating experience.

*Based on 2017 DOT inventory, projected 2035 inventory, and calculated using 40 CFR 98, Subpart W Natural Gas Distribution Emission Factors. The 2017 baseline is 35,386 MT CH4.

Transmission Miles Replacement Rate

200

180

160

140

Miles

120

100

80

60

40

2013

2014

2015

2016

2017

2018

2019

2020

21-25E

Since 2012, we've replaced over 4,400 miles of pipe. Over the next five years, we plan to replace between 5,000 and 6,000 miles of distribution and transmission pipes. Included in this total is the replacement of all remaining cast iron main by the end of 2021. To determine the schedule for non-cast iron pipeline replacements, we use a risk-based prioritization model that considers factors like the pipe's age, location, material, leak history, environmental factors, and more.

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Leak Detection

Atmos Energy surveys the approximately 75,000 miles of our distribution and transmission pipelines at rates and frequencies that meet and often exceed state and federal guidelines. Monitoring frequency of pipelines is determined by federal and state pipeline safety codes, accepted industry standards, and internal Atmos Energy practices and procedures. The technology used to complete a pipeline leak survey may vary, depending on the conditions at the time of survey. It is our practice to use the instrument that is best suited for the existing conditions to complete pipeline surveys. Here is a brief summary of the frequency of leak surveys of our transmission and distribution systems:

Transmission Pipelines

Distribution Pipelines

A P P E N D I X

  • In many of our more densely populated areas, transmission pipelines are visually surveyed twice per month and incorporate the use of aircraft, where appropriate, to look for oxygen-starved vegetation, right-of-way encroachment, erosion, landslides, and possible security threats.
  • Our Mississippi and West Texas divisions use aircraft to leak survey annually. Our Atmos Pipeline - Texas and Mid-Tex divisions use aircraft to leak survey twice per year.
  • Technicians leak survey all pipeline road crossings quarterly using the appropriate leak survey equipment.
  • Atmos Energy also completes annual visual vegetation/leak surveys on all transmission pipelines using highly trained technicians performing patrols.

Distribution mains located outside of business districts

are surveyed at least as often as prescribed by federal

and state regulations (with the maximum being five

years) using the various technologies discussed on the

previous left-hand page of this appendix under

Investing in Technology to Improve Safety.

For distribution pipelines located within business

districts, a survey is required and completed at

least annually.

Our Texas jurisdictions, Mid-Tex and West Texas,

contain over 95 percent of our unprotected steel

distribution pipe inventory and Mid-Tex contains 100

percent of our remaining cast iron pipe inventory. In

these jurisdictions, we leak survey at intervals that are

more frequent than the federal requirements. For

coated steel pipe, we survey at least once every three

years, bare steel we survey at least once every two

years, and cast iron at least once every 12 months.

We are committed to replacing all remaining cast iron

main by 2021.

In Texas, distribution main segments that are identified

as high relative risk are scheduled for replacement or

they are leak surveyed within 12 months.

In Kansas, coated steel pipe and plastic pipe are

surveyed at least once every three years, and bare

steel is surveyed at least annually.

For our other jurisdictions, we leak survey at least

as often as state regulations prescribe. However, we

evaluate performing leak surveys in accordance

Grading a Leak

Leaks identified on the Atmos Energy transmission and distribution systems are investigated and graded in accordance with our procedures, which meet or exceed the requirements of state or federal regulation. As required by regulation, these procedures categorize leaks in three grades:

1

2

3

Grade 1

Leaks which represent an immediate hazard to persons and/or property. These leaks are addressed and repaired immediately.

Grade 2

Leaks recognized as being non-hazardous at the time of detection but having the potential to become a future hazard. In general, these leaks must be scheduled for repair or eliminated within one year. Our Kansas, Mid-Tex, and West Texas distribution systems collectively make up

60 percent of our total distribution system. Grade 2 leaks on these systems are repaired within six months.

Grade 3

Leaks that are non-hazardous at the time of detection and can be expected to remain non-hazardous. Grade 3 leaks on our Kansas, Mid-Tex, and West Texas distributions systems are repaired within three years and some within two and a half years. In jurisdictions that do not prescribe a repair interval for Grade 3 leaks, we target these to be repaired within 36 months.

with the more stringent regulations of other states in

our footprint.

At Atmos Energy compressor stations subject to New Source Performance Standard Subpart OOOOa, leak surveys are conducted quarterly using a FLIR camera. Any detected leaks are tagged. Leaks are repaired within 30 days of detection or as soon as repair parts can be obtained. Any component found to be leaking is checked using a soap and water test within 30 days after it has been repaired. Annual reports summarizing the results of all leak surveys are submitted to state regulatory authorities.

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Frequency of Monitoring

The frequency of monitoring conditions along our transmission right-of-ways (ROWs) is based on criteria documented in our O&M Manual that have been established to meet or exceed federal and state regulations. Inspections and maintenance work are performed regularly and pipeline segments are replaced when deemed necessary to maintain the safe delivery of natural gas to Atmos Energy customers.

The Atmos Energy Federal Pipeline Integrity Management (PIM) program provides for enhanced preventive and mitigative measures already in place to maintain the safe and reliable operation of our transmission pipeline system. The PIM program includes risk modeling that takes into account both the risks posed to our pipeline systems and the potential impacts of those risks. High consequence areas (HCAs) along the pipeline are typically densely populated areas or rural areas containing identified sites adjacent to the pipeline that pose considerably more risk to human life. Identified sites may be churches, schools, hospitals, daycare centers, assisted-living facilities, campgrounds, or other buildings and outside areas where people congregate. Additional inspections of pipelines within HCAs, as well as certain pipelines outside of HCAs, are conducted in accordance with the Atmos Energy federal and state PIM programs.

The frequency of monitoring the conditions of our distribution pipelines is based on our O&M Manual and our Distribution Integrity Management (DIM) program, both of which have been established in conjunction with federal and state regulations. Distribution pipeline segments are regularly subjected to inspection and maintenance work, such as leak surveys and corrosion control, and are replaced as necessary. Our DIM program includes risk modeling that takes into account both the risks posed to our distribution pipeline systems and the potential consequences of those risks.

Commitment to Safety and Protecting Our Environment

We are committed to replacing all remaining cast iron main by the end of 2021.

In addition, Atmos Energy utilizes a number of practices in its day-to-day operations to prevent or reduce methane emissions. Some of the practices include, but are not limited to, the following:

  • Drawing down transmission line pressure when repairing or working on the pipelines to reduce natural gas released to the atmosphere.
  • Rerouting gas to minimize or prevent venting or blowdowns.
  • Installing pipeline stopples and bypasses as necessary to maintain operations and minimize extent of blowdown.
  • Utilizing flares to combust methane instead of releasing methane to the atmosphere.

Finally, the Company's methane emissions intensity rates for 2019 are as follows:

  • Atmos Energy - 0.40 percent based on the amount of natural gas received at city gate stations (34,134 MT CH4 total emitted in 2019).
  • The emission intensity is calculated using EPA-reported fugitive emissions data and Company data of natural gas distribution system volumetric throughput. The EPA-reported emissions data is based on a combination of EPA emission factors and data calculated using the leak testing described above.

You may find more information on our commitment to pipeline safety on our website at atmosenergy.com.

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

2019 DOT Report

Distribution

Miles of Main

TN

VA

CO

KS

KY

LA

MS

MTX

WTX

Total

Steel - Coated (Un)

0

0

0

0

0

0

0

4,086

0

4,086

Steel - Coated (Pr)

824

311

1,162

237

2,217

4,983

3,715

4,407

4,644

22,501

Steel - Bare (Un)

0

0

31

0

85

0

0

2,767

241

3,124

Steel - Bare (Pr)

0

0

38

1,381

25

218

43

169

0

1,874

Cast Iron

0

0

0

0

0

0

0

356

0

356

Plastic PVC

0

0

280

42

0

43

0

0

135

500

Plastic PE

2,821

400

1,702

2,461

1,740

3,469

2,842

19,558

2,761

37,754

Plastic ABS

0

0

0

0

0

0

0

0

85

85

Plastic Other

0

0

0

0

0

0

0

273

0

273

Other

0

0

0

0

14

0

0

0

0

14

Total

3,645

712

3,214

4,120

4,081

8,713

6,601

31,615

7,866

70,566

A P P E N D I X

Distribution

Vintage

TN

VA

CO

KS

KY

LA

MS

MTX

WTX

Total

Pre-40s

0

1

0

15

4

28

306

363

470

1,187

40s

0

0

112

0

67

32

493

357

302

1,363

50s

106

1

238

4

328

676

789

1,171

2,232

5,543

60s

366

216

445

11

741

356

768

1,771

1,257

5,931

70s

270

55

461

25

366

2,297

926

3,262

788

8,450

80s

776

146

457

48

402

2,106

844

4,256

547

9,582

90s

987

140

458

66

583

1,535

892

4,193

643

9,497

00s

608

81

818

223

282

757

1,054

3,253

471

7,547

10s

518

58

225

411

529

920

529

4,195

1,158

8,545

Unknown

15

14

0

3,316

780

4

0

8,795

0

12,924

Total

3,644

712

3,214

4,120

4,081

8,713

6,601

31,616

7,868

70,568

Services

Steel Services

14,839

1,758

29,548

33,980

73,882

234,329

113,013

106,543

204,008

811,900

Copper

0

0

0

0

0

0

171

0

0

171

Other

0

0

0

0

0

0

0

377,870

0

377,870

Plastic

146,254

21,928

75,948

118,509

107,556

178,895

191,136

1,273,100

197,016

2,310,342

Total

161,093

23,686

105,496

152,489

181,438

413,224

304,320

1,757,513

401,024

3,500,283

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Transmission

Miles of Transmission Pipelines

Vintage

TN/VA

KY/AEH

MS

MTX

CO/KS

LA/TLA/

WTX

APT

Total

Pine

Pre 40s

0

0

17

0

0

2

28

164

211

40s

0

0

1

23

1

0

6

428

459

50s

0

30

69

81

0

1

36

660

878

60s

5

29

90

25

1

0

15

1,132

1,297

70s

0

81

4

54

0

21

3

959

1,123

80s

9

8

24

39

3

50

4

229

367

90s

47

35

67

54

3

1

7

653

868

00s

4

0

22

9

0

0

2

360

397

10s

1

0

0

24

0

5

19

1,095

1,145

Unknown

0

8

0

0

0

0

0

3

11

Total

65

190

296

310

9

81

121

5,684

6,756

Diameter

< 6"

0

21

28

0

3

4

11

846

914

6" thru 10"

39

104

259

86

4

30

64

2,003

2,588

> 10" thru 20"

26

65

9

209

1

24

46

1,494

1,875

> 20" thru 28"

0

0

0

6

0

24

0

421

451

> 28"

0

0

0

8

0

0

0

919

928

Total

65

190

296

310

9

81

121

5,684

6,756

A P P E N D I X

Transmission

Miles of Transmission Pipelines

Class Location

TN/VA

KY/AEH MS

MTX

CO/KS

LA/TLA/

WTX

APT

Total

Pine

Class 1 HCA

0

0

2

1

0

0

1

12

16

Class 1 Non-HCA

12

134

198

74

9

34

78

4,676

5,215

Class 2 HCA

0

0

1

1

0

0

0

13

15

Class 2 Non-HCA

27

23

70

45

0

12

13

532

722

Class 3 HCA

8

1

29

97

0

13

4

191

344

Class 3 Non-HCA

18

27

0

85

0

22

25

256

433

Class 4 HCA

0

0

0

6

0

0

0

3

9

Class 4 Non-HCA

0

0

0

0

0

0

0

0

1

Total

65

185

301

310

9

81

121

5,684

6,756

Pipe Material

Coated Steel (Un)

0

0

0

0

0

0

0

0

0

Coated Steel (Pr)

66

190

296

308

8

80

121

5,367

6,435

Bare Steel (Un)

0

0

0

0

0

0

0

0

0

Bare Steel (Pr)

0

0

0

1

1

0

0

175

177

Cast Iron

0

0

0

0

0

0

0

0

0

Wrought Iron

0

0

0

0

0

0

0

0

0

Plastic

0

0

0

0

0

2

0

143

144

Composite

0

0

0

0

0

0

0

0

0

Other

0

0

0

0

0

0

0

0

0

Total

66

190

296

310

9

81

121

5,684

6,757

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Leaks

Cause of Leak

Corrosion

CO

KS

KY

LA

MS

MTX

TN

VA

WTX

Total

Hazardous Main

13

25

4

21

14

263

3

1

67

411

Non-Hazardous Main

46

128

42

264

63

1,288

13

7

296

2,147

Total Main

59

153

46

285

77

1,551

16

8

363

2,558

Hazardous Service

12

100

22

76

22

317

7

6

51

613

Non-Hazardous Service

36

100

91

469

38

487

21

6

164

1,412

Total Service

48

200

113

545

60

804

28

12

215

2,025

Total Corrosion

107

353

159

830

137

2,355

44

20

578

4,583

Equipment

Hazardous Main

2

5

2

13

21

206

2

0

22

273

Non-Hazardous Main

17

22

33

152

158

1,027

35

17

119

1,580

Total Main

19

27

35

165

179

1,233

37

17

141

1,853

Hazardous Service

9

25

21

86

125

1,180

30

12

56

1,544

Non-Hazardous Service

124

349

393

1,055

1,106

5,267

523

830

2,086

11,733

Total Service

133

374

414

1,141

1,231

6,447

553

842

2,142

13,277

Total Equipment

152

401

449

1,306

1,410

7,680

590

859

2,283

15,130

A P P E N D I X

Leaks

Cause of Leak

Excavation Damage

CO

KS

KY

LA

MS

MTX

TN

VA

WTX

Total

Hazardous Main

29

65

62

143

89

895

78

13

159

1,533

Non-Hazardous Main

1

0

1

8

5

24

1

0

1

41

Total Main

30

65

63

151

94

919

79

13

160

1,574

Hazardous Service

86

105

181

471

321

2,859

315

33

146

4,517

Non-Hazardous Service

1

4

15

33

25

71

2

0

10

161

Total Service

87

109

196

504

346

2,930

317

33

156

4,678

Total Excavation Damage

117

174

259

655

440

3,849

396

46

316

6,252

Incorrect Operations

Hazardous Main

1

2

1

5

5

1

0

1

7

23

Non-Hazardous Main

7

11

1

24

28

8

0

1

11

91

Total Main

8

13

2

29

33

9

0

2

18

114

Hazardous Service

3

5

4

8

23

8

1

2

17

71

Non-Hazardous Service

23

38

44

30

160

24

13

5

70

407

Total Service

26

43

48

38

183

32

14

7

87

478

Total Incorrect Operations 34

56

50

67

216

41

14

9

105

592

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Leaks

Cause of Leak

Material or Welds

CO

KS

KY

LA

MS

MTX

TN

VA

WTX

Total

Hazardous Main

0

5

1

8

1

126

4

0

5

150

Non-Hazardous Main

3

14

2

101

17

707

6

0

12

862

Total Main

3

19

3

109

18

833

10

0

17

1,012

Hazardous Service

1

8

4

8

5

184

8

0

8

226

Non-Hazardous Service

9

32

17

65

29

255

79

1

15

502

Total Service

10

40

21

73

34

439

87

1

23

728

Total Material or Welds

13

59

24

182

52

1,272

97

1

40

1,740

Natural Forces

Hazardous Main

1

6

0

3

11

24

1

2

8

56

Non-Hazardous Main

0

24

8

0

13

47

5

3

35

135

Total Main

1

30

8

3

24

71

6

5

43

191

Hazardous Service

20

29

7

8

78

59

0

8

12

221

Non-Hazardous Service

5

90

17

4

195

89

12

26

33

471

Total Service

25

119

24

12

273

148

12

34

45

692

Total Natural Forces

26

149

32

15

297

219

18

39

88

883

A P P E N D I X

Leaks

Cause of Leak

Other

CO

KS

KY

LA

MS

MTX

TN

VA

WTX

Total

Hazardous Main

0

1

0

4

0

12

0

0

3

20

Non-Hazardous Main

7

6

1

341

14

47

0

1

26

443

Total Main

7

7

1

345

14

59

0

1

29

463

Hazardous Service

6

17

3

20

7

32

1

1

7

94

Non-Hazardous Service

9

58

24

225

71

69

13

0

45

514

Total Service

15

75

27

245

78

101

14

1

52

608

Total Other

22

82

28

590

92

160

14

2

81

1,071

Other Outside

Force Damage

Hazardous Main

0

3

1

7

7

24

0

0

9

51

Non-Hazardous Main

0

2

1

2

2

36

0

0

7

50

Total Main

0

5

2

9

9

60

0

0

16

101

Hazardous Service

30

87

57

218

56

120

21

7

649

1,245

Non-Hazardous Service

3

29

8

32

21

133

1

0

346

573

Total Service

33

116

65

250

77

253

22

7

995

1,818

Total Other Outside

33

121

67

259

86

313

22

7

1,011

1,919

Force Damage

ATMOS EN ERGY CO RP O R ATI O N

ATMOS EN ERGY CO RP O R ATI O N

A P P E N D I X

Leaks

Summary of All Causes

CO

KS

KY

LA

MS

MTX

TN

VA

WTX

Total

Hazardous Main

46

112

71

204

148

1,551

88

17

280

2,517

Non-Hazardous Main

81

207

89

892

300

3,184

60

29

507

5,349

Total Main

127

319

160

1,096

448

4,735

148

46

787

7,866

Hazardous Service

167

376

299

895

637

4,759

383

69

946

8,531

Non-Hazardous Service

210

700

609

1,913

1,645

6,395

664

868

2,769

15,773

Total Service

377

1,076

908

2,808

2,282

11,154

1,047

937

3,715

24,304

Total Leaks

504

1,395

1,068

3,904

2,730

15,889 1,195

983

4,502

32,170

Leaks Scheduled

454

474

107

1,310

830

11,293

8

4

4,682

19,162

for Repair

CAUTIONARY STATEMENT

This material includes forward-looking statements. These statements can be identified because they use words such as "anticipate," "believe," "estimate," "may," "could," "expect," "forecast," "target," "goal," "intend," "objective," "plan," "projection," "seek," "strategy," or similar words. Similarly, statements that describe future plans or strategies and future emissions reductions are forward-looking statements. Such forward-looking statements are subject to risks and uncertainties that could cause actual results to differ materially from those expressed or implied in the statements. These risks and uncertainties include the following: federal, state, and local regulatory and political trends and decisions; increased federal regulatory oversight and potential penalties; possible increased federal, state, and local regulation of the safety of our operations; the impact of climate change; the impact of greenhouse gas emissions or other legislation or regulations intended to address climate change; possible significant costs and liabilities resulting from pipeline integrity and other similar programs and related repairs; increased dependence on technology that may hinder the Company's business if such technologies fail; our ability to continue to access the credit and capital markets to execute our business strategy; the impact of adverse economic conditions on our customers; and other risk factors discussed under Part I, Item 1A, Risk Factors, and Part II, Item 7, Management's Discussion and Analysis of Financial Condition and Results of Operations, Cautionary Statement for the Purposes of the Safe Harbor under the Private Securities Litigation Reform Act of 1995 in our Annual Report on Form 10-K for the fiscal year ended September 30, 2020, which should be read in conjunction with the forward-looking statements in this report. Atmos Energy undertakes no obligation to update or revise any of our forward-looking statements whether as a result of new information, future events, or otherwise.

ATMOS EN ERGY CO RP O R ATI O N

ATMOS ENERGY CORPOR ATION

1800 Three Lincoln Centre  |  5430 LBJ Freeway  |  Dallas, Texas 75240

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AEC - Atmos Energy Corporation published this content on 04 December 2020 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 04 December 2020 22:42:02 UTC