IN THIS SECTION

• A message from Russell Fradin, Chairman and CEO
• Hewitt Statement of Business Ethics
• Associate Accountabilities for Upholding Ethics at Hewitt
• Global Policy Statements
• Reporting an Issue or Concern
• Code of Ethics for Senior Executive Financial Officers
• Global Policy—Corporate Conflict of Interest
• Global Policy—Corporate Conflicts of Interest Involving Serving Two Clients on the Same Transaction
• Global Policy—Hewitt's Ethic Line European Privacy Policy

A message from Russell Fradin, Chairman and CEO

Hewitt has a commitment to associates and clients worldwide to uphold high ethical standards—a commitment that has long been an important part of our history and culture. In today's competitive and rapidly changing business climate, doing the right thing every time has never been more important.

Hewitt's Code of Conduct represents our principles and supporting policies that helps ensure that we abide by legislation in the regions where we operate. It also serves as a consistent guideline for how we work with each other, our clients, and our business partners in our communities. While Hewitt's ethical principles will always remain constant, some of the policies and guidelines within the Code of Conduct change or evolve to keep pace with changes in government regulations or client expectations. That makes it even more important that we refresh our understanding of the Code of Conduct on a regular basis.

We require each and every executive, associate, designated contractor and temporary worker to follow the Code of Conduct so that our ethical approach to business remains consistent and widely understood. Together, we can preserve the high ethical standards that have attributed to our past success and will help lead to our success in the future, and, in the process, make Hewitt a great place to work.

Russell Fradin
Chairman and CEO