At Hewitt, we always act with high ethical standards. Specifically, we:

• Obey all applicable laws, regulations, and professional standards that govern our business;
• Maintain an environment of honesty, trust, and integrity;
• Safeguard our ethics and never compromise or alter them for any reason; and
• Recognize and value high ethical standards and report any unethical or illegal behavior.

Each of us at Hewitt (which includes Hewitt Inc. and all subsidiaries and affiliates), as well as the members of our Board of Directors, is expected to comply with both the letter and spirit of this Statement and Hewitt’s entire Code of Conduct in all our dealings with clients, service providers, business partners, and fellow associates. This includes all associates and where appropriate, third parties performing services for Hewitt or on behalf of Hewitt in every Hewitt location around the world.

Compliance with our Code of Conduct will help us remain above reproach and allow us to continue to be recognized worldwide -- by our clients, associates, stockholders, business partners, service providers, and the communities in which we work -- for our high ethical standards.

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