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 our Code of Conduct are subject to disciplinary action, up to and including separation, subject to local laws and existing agreements governing the terms of employment.
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.
Fundamental Obligations
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. To adhere to these accountabilities, you must comply with the following fundamental obligations that drive these behaviors.
Conflicts of Interest
A conflict of interest occurs when your personal interests interfere, or appear to interfere, with the interests of Hewitt as a firm. Conflicts of interest can also arise when you or a member of your family or someone with whom you have a personal relationship have interests that may make it difficult for you to perform your Hewitt duties effectively. Although it’s not possible to list every conceivable conflict, following are examples of some common scenarios that must be reported:
- Improper personal benefits from Hewitt. Conflicts of interest can arise when you or a member of your family or someone with whom you have a personal relationship receive improper personal benefits as a result of your position in Hewitt. You may not accept any personal benefits from Hewitt or others (e.g., service providers) that have not been approved pursuant to Hewitt policy and procedure, including any loans or guarantees of your personal obligations.
- Personal relationships/Conflict of interest. Certain personal relationships (such as a close family or intimate relationship) between associates, between an associate and an employee of a client (that the associate supports), or an associate and a service provider (which the associate has the ability to influence decisions regarding the vendor relationship) may create an actual or perceived conflict of interest. You are responsible for reporting to your manager or HR if you are in any situation that has a potential for a conflict of interest as described above. Your manager or HR will work with you to determine an appropriate resolution.
- Financial or employment interests in other businesses. You may not have an employment or ownership interest in any other enterprise if that interest compromises, or appears to compromise, your loyalty to Hewitt. For example, you may not be employed by or own an interest in a company that competes with Hewitt. Nor should you be employed by or own an interest in any company that does business with Hewitt (e.g., a supplier) where you have any involvement in the decision to retain that business. However, it is not a conflict of interest to invest in clients, competitors, or suppliers indirectly through a mutual fund or a registered investment company that owns publicly listed stock of such entities. Unless directed otherwise by Hewitt (e.g., participating in a Hewitt-sponsored charity), you may not conduct business for another organization during hours you are working for Hewitt nor should you use Hewitt’s facilities, supplies, or other assets in connection with any other business.
- Business arrangements with Hewitt. Without the prior written approval of the General Counsel, you may not participate in a joint venture, partnership, or other business arrangement with Hewitt.
- Using the Hewitt name in connection with activities outside of Hewitt. You are not authorized to use the Hewitt name or that of any associated companies in any activity outside of those involved in the fulfillment of your Hewitt duties, unless authorized in advance by Hewitt in writing.
Corporate Opportunities
If, as a result of your Hewitt employment (such as from a competitor, an actual or potential supplier, or a business associate of Hewitt), you learn of a business or investment opportunity that could reasonably be considered by Hewitt, you must inform your manager of the opportunity and you may not use such information for your personal gain (including sharing such information with potential competitors of Hewitt).
Adherence to Laws, Rules, and Regulations
You are expected to adhere to all applicable laws, regulations, and professional standards that govern our business. This includes not only laws that are applicable to the services we provide our clients, but also laws and regulations regarding the operation of our business, such as securities laws and rules regarding the reporting of financial information.
