Introduction

This Code of Ethics is applicable to any individual designated by the Hewitt Board of Directors as an officer for purposes of compliance with the financial reporting rules under Section 16 of the Securities Exchange Act of 1934 (together, "Senior Leaders") as well as the General Counsel, and each person directly reporting to the Chief Financial Officer (together, "Senior Leaders"). This Code of Ethics supplements the requirements of the Code of Conduct as it applies to Senior Leaders.

While we expect honest and ethical conduct in all aspects of our business from all of our associates, we expect the highest possible conduct from our Senior Leaders. Senior Leaders are examples for other associates and are expected to foster a culture of transparency, integrity and honesty. Compliance with this Code, as well as Hewitt's Code of Conduct, is a condition to the employment of our Senior Leaders, and any violation of either may result in disciplinary action, up to and including termination, of their employment.

Waivers of either Code may be made only by the Board or a Board committee and will be disclosed in accordance with applicable law.

Outside Employment or Activities With a Competitor

Simultaneous employment with or serving as a director of a competitor of Hewitt is strictly prohibited, as is any activity that is intended to or that a Senior Leader should reasonably expect to advance a competitor's interests at the expense of Hewitt's interests. No Senior Leader may market products or services in competition with Hewitt's current or potential business activities. It is a Senior Leader's responsibility to consult with the Chief Executive Officer to determine whether a planned activity will compete with any of Hewitt's business activities before the activity in question is pursued.

Outside Employment With a Supplier

Without the prior written approval of the General Counsel, no Senior Leader may be a supplier or be employed by, serve as a director of, or represent a supplier to Hewitt. Without the prior written approval of the General Counsel, no Senior Leader may accept money or benefits of any kind from a third party as compensation or payment for any advice or services that he or she may provide to a client, supplier or anyone else in connection with its business with Hewitt.

Family Members Working In The Industry

If a Senior Leader's spouse or significant other, children, parents, or in-laws, or someone else with whom the Senior Leader has a familial relationship is a competitor or supplier of Company or is employed by one, the Senior Leader must disclose the situation to the General Counsel so that Hewitt may assess the nature and extent of any concern and how it can be resolved. Each Senior Leader must carefully guard against inadvertently disclosing Company confidential information and being involved in decisions on behalf of Hewitt that involve the other enterprise.

Should any Senior Leader have any doubt as to whether or not conduct would be considered a conflict of interest, please consult with the General Counsel. Any concerns regarding possible conflicts of interest involving the General Counsel should be brought to the attention of the Chief Executive Officer.

Accurate Periodic Reports and Other Public Communications

As each Senior Leader is aware, full, fair, accurate, timely and understandable disclosure in our periodic reports filed with the SEC and in our other public communications is required by SEC rules and is essential to our continued success. Each Senior Leader is expected to exercise the highest standard of care in preparing such materials. We have established the following guidelines in order to ensure the quality of our periodic reports.

• All Company accounting records, as well as reports produced from those records, must be kept and presented in accordance with the laws of each applicable jurisdiction.
• All records must fairly and accurately reflect the transactions or occurrences to which they relate.
• All records must fairly and accurately reflect in reasonable detail Hewitt's assets, liabilities, revenues and expenses.
• Hewitt's accounting records must not contain any false or intentionally misleading entries.
• No transaction may be intentionally misclassified as to accounts, departments or accounting periods or in any other manner.
• All transactions must be supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period.
• No required information may be concealed from the internal auditors or the independent auditors.
• Compliance with Generally Accepted Accounting Principles and Hewitt's system of internal accounting controls is required at all times.

Acknowledgment Form

Each Senior Leader will be required to acknowledge that (i) she or she has received and read the Code of Ethics for Senior Executive and Financial Officers and understood its contents; (ii) agree to comply fully with the standards contained in the Code of Conduct and Hewitt's related policies and procedures; (iii) and report to the General Counsel any suspected violations of the Code of Ethics.