Upholding Hewitt's Code of Conduct

Each and every associate at Hewitt has the responsibility to uphold Hewitt’s high ethical standards. We have countless opportunities to demonstrate our ethical actions through our daily work and activities. To help us make ethical business decisions, all of us must follow Hewitt’s Code of Conduct, including the Statement of Business Ethics and the associate accountabilities described here. These accountabilities reinforce our commitment to each other, our stockholders, our clients, our service providers, and the communities in which we do business.

Associates who fail to comply with these requirements may face disciplinary action, up to and including separation, subject to adherence to procedural requirements as determined by the laws and regulations of the countries in which Hewitt operates.

While it communicates clear standards for ethical behavior, it’s important for associates to understand that the Code of Conduct does not change the fundamental nature of the employment relationship between Hewitt and our associates, or create new or additional contractual rights between Hewitt, its associates or any third party. Except as explicitly restricted by applicable law or contract, each associates’ employment relationship with Hewitt is “at will”. This means that Hewitt or the associate may terminate the relationship at any time for any reason, with or without cause or prior notice.

The accountabilities outlined below apply to all associates at Hewitt in accordance with Hewitt’s Code of Conduct. By continuing to follow these accountabilities, we will continue to be recognized worldwide by our clients, investors, associates, and suppliers for upholding our high ethical standards.

Serving Our Clients

• We are honest and trustworthy with our clients and their data.
• We represent our products and services accurately.
• We provide solutions that are in our clients’ best interests and deliver what we promise.
• We do not compromise our ethics on behalf of, or at the request of, our clients.
• We maximize the value of our services for our clients and for Hewitt.

Working With Service Providers/Suppliers

• We select service providers by balancing cost, quality of service, diversity, and the needs of the business in order to provide the most value to our clients and the firm.
• We act fairly and honestly with each service provider.
• We do not accept any gifts that influence or obligate us or the firm in any way.

Dealing With Competitors

• We focus our comments on our abilities and refrain from broad criticism. We use facts and accurate information when comparing ourselves with our competitors.
• When a competitor is also a client, we treat each relationship as distinct so as not to compromise either.

Partnering With Outside Organizations

• We are honest and trustworthy in all dealings and communicate openly with our business partners.
• We treat all potential partners fairly throughout the process and negotiate in good faith.

Working With Each Other

• We treat each other with respect and honesty.
• We hold each other accountable for upholding Hewitt’s ethics, values, and policies.
• We value each other’s differences and experience.

Communicating With the Media and Investor Community

• We always direct any media or investor inquiries to Public Relations or Investor Relations as appropriate.
• We are truthful and forthcoming with information to the media and our investors.

Recording and Reporting Financial Information

• We accurately record financial and operating information (including revenue, expenses, billings, time and attendance) fairly, accurately, ethically and in a timely manner.
• We timely and accurately publicly report our revenues and expenses.

Using Hewitt Resources and Company Assets

• We use resources, technology, and supplies for serving our external and internal clients.
• We use business assets appropriately and prudently.
• We protect Hewitt’s assets and trade secrets.

Protecting the Security and Privacy of Information

• We protect the security of our data and treat client, participant, and associate information as private and confidential.
• We ensure that Hewitt’s trade secrets are protected as private and confidential.

Hewitt’s Code of Conduct can’t possibly address every ethical dilemma an associate may face. Regardless of the situation, you must always consider how your actions reflect on the integrity and credibility of the firm and how your decisions drive business results without compromising Hewitt’s long-standing history of high ethical standards.

The above accountabilities apply to all contexts in which we interact with others in our day-to-day work—our clients, each other, our suppliers, our competitors, other organizations, the media, and our investors.