Many of Hewitt's policies are a part of the Code of Conduct and provide more context for understanding associate accountabilities. Global policy statements have been developed for policies having global application. These statements do not fully reflect the specific policy details and guidelines by country. You are expected to refer to your local database or check with your HR Business Consultant or HR contact for policies specific to your location. Following is a description of our global policy statements.

Serving Our Clients

Agreements With Clients, Vendors/Suppliers, and Third Parties

We are committed to building and maintaining high-quality business relationships with our clients, vendors, and third parties. All associates who have contact with clients, vendors/suppliers, and third parties—including those who have decision-making and approval authority—must not engage in any activity that might affect the integrity and effectiveness of these relationships. We expect our associates to understand and comply with this principle and abide by Hewitt’s regional policies, local business practices, country-specific customs, and applicable legislation. All agreements with clients, vendors/suppliers, and third parties—including purchasing requests, business letters of intent, and confidentiality agreements—must be reviewed and approved by legal counsel.

Preventing Legal Liability and Financial Loss for Hewitt and Our Clients

Every associate has an obligation to take reasonable steps to minimize the risk that our services could cause legal liability or financial loss to Hewitt or our clients. This includes delivering high-quality work, ensuring that our actions and client discussions are documented, managing client information with third parties, and acting with the highest level of honesty and professionalism in all we do. We are careful about accepting assignments that can bring risk to Hewitt or our clients. If you have any concerns about accepting an assignment, you should discuss it with your manager.

Gifts, Entertainment and Other Gratuities

At Hewitt, we are committed to building and maintaining sound business relationships with our clients, suppliers and other business partners. Accepting gifts can cloud our objectivity and create undue expectations in our business relationships. For this reason we purposely avoid any situation that could damage the integrity of these relationships such as accepting gifts, entertainment or other forms of gratuity. All associates are responsible for abiding by their local policy regarding gifts.

Working With Each Other

Harassment and Discrimination

We are committed to an environment of mutual appreciation and respect. Our position on harassment and discrimination is clear and explicit in that we do not tolerate any behavior that degrades, harasses, or discriminates against any other associate, client, vendor/supplier, contractor, or employee of a third-party provider. All associates are expected to learn how harassment and discrimination are defined in their local market and understand the process and policies in place to protect and enhance a culture of mutual appreciation and respect.

Substance Abuse in the Workplace

We are committed to providing a safe, healthy, and professional work environment that is not impacted by the risks of associates working while under the influence of alcohol, illegal drugs, or the abuse of legally prescribed or legally available drugs. To fulfill this commitment, we have established a principle that prohibits the possession, use, manufacture, sale, or distribution of illegal drugs within a Hewitt-owned facility or vehicle or within the scope of your employment while off premises. Hewitt facilities can include Hewitt-owned or leased buildings, parking lots, garages, grounds, and vehicles located there.

Maintaining a Nonviolent Workplace

We are committed to the goal of providing a safe work environment without violence or weapons. Our position is clear in that we do not tolerate acts of violence and abusive or threatening behavior, including verbal, written, or other nonverbal threats, or physical attacks. This includes behavior at Hewitt-sponsored events, as well as at client sites where the associate performs work. Weapons are prohibited in the workplace, as well as in any personal motor vehicle brought to the premises. We expect associates not to encourage, initiate, or engage in workplace violence. This also applies to behaviors with clients, vendors/suppliers, and contractors. The purpose of our position is to stop potentially violent, abusive, or threatening situations before they start or escalate.

Consulting With the Media and Investor Community

Communicating With the Media, Industry Analysts, and the Investor Community

Media and Industry Analyst Relations

Our relationships with the global business media and industry analysts are important ones. We work with both audiences to build awareness of Hewitt’s business, services, and expertise in HR outsourcing and consulting. Our policy is that all media and industry analyst communications must be managed and approved by Public Relations or Investor Relations. It is imperative that all associates adhere to this policy. Interactions with a reporter or industry analyst should not occur without the involvement of a regional Public Relations representative. Interactions with an industry analyst should not occur without the involvement of Investor Relations. If you should receive an inquiry from a reporter or industry analyst about Hewitt Associates, you must contact your regional Public Relations representative or Investor Relations immediately. If you become aware of a situation that has the potential to impact the firm’s reputation, please contact a member of the Public Relations team as soon as possible so that the most appropriate course of action can be determined.

Investor Communications

As a publicly held company, Hewitt has certain obligations with respect to our communications with the investment community at large, the financial analyst community, and our stockholders. In addition, Hewitt must comply with applicable laws and regulations of the Securities and Exchange Commission (“SEC”), the New York Stock Exchange, and any other regulatory bodies governing the nature and timing of our communications with such constituencies, including communications subject to the SEC’s Regulation FD. Therefore, communications to the investment community that are made by and on behalf of the firm are only to be made by Hewitt’s Chief Executive Officer, Chief Financial Officer, Group Presidents, Senior Vice President of Law and Strategy, Investor Relations Manager, or Public Relations officials, or persons designated by these officials (collectively, “Authorized Spokespersons”). Our policy is that no other person shall issue or participate in any such communication on behalf of Hewitt without the express prior consent of an Authorized Spokesperson.

Using Hewitt Resources and Company Assets

Personal Use of Internal Resources

Our work requires the use of Hewitt resources, such as office supplies, and equipment (use of technology resources is discussed in the Appropriate Use of Technology policy statement) to meet everyday business needs. The purpose of these resources is to serve the direct needs of our clients and internal business functions. We recognize that you may have an occasional need to use the company’s resources for personal reasons. We expect all associates to follow applicable guidelines on the personal use of internal resources.

Appropriate Use of Technology

Technology is essential in serving the needs of our clients. Because of this, we are committed to researching new technologies and adopting them as appropriate to meet our business needs. At Hewitt, "technologies" are defined as any electronic tools or products designed to support the company’s efforts to serve our clients; to improve communications between associates and clients, vendors, or other business-related contacts; and to help associates work more efficiently and effectively. Examples of technologies included in the scope of this Statement are the Internet; email; Lotus Notes® databases; PCs and laptops; personal digital assistants (PDAs); phone systems; shared technologies such as copiers, printers, and fax machines; and computer software.

Every associate is responsible for using existing and new technologies in an appropriate business manner. We recognize that associate roles differ, technology is always changing, and it’s a challenge to define all acceptable and discouraged behaviors related to the use of technology. We also recognize that you may have an occasional need to use the company’s resources for personal reasons. However, we expect all associates to abide by the company’s goals and values and understand that Hewitt technology is intended primarily for business use. It is never acceptable to use the company’s resources to conduct illegal activities. Use of technology must comply with local laws related to issues such as copyright, trademark, data protection, privacy, insider trading, harassment, and discrimination. Associates are expected to use our technologies in a manner consistent with such laws and our internal policies.

It is never acceptable to view, share, or keep pornographic or violent material using Hewitt technologies. Hewitt’s professional image and reputation must be maintained with clients, prospective clients, vendors, associates, and others in the business community while using our technologies.

Protecting the Security and Privacy of Information

Confidentiality Agreements

We recognize that some information, often referred to as “trade secrets” or “privacy protected,” could be detrimental to Hewitt or our clients if confidentiality is violated. We expect all associates to be aware of, and agree to, locally approved confidentiality guidelines and agreements. Our position is to protect our associates and clients from harm through the misuse of information that could have a negative impact on the firm, our clients, or our prospective clients. When an associate leaves Hewitt, that associate’s Hewitt work products remain the property of the firm.

Privacy

Hewitt strives to be a market leader in ensuring the confidentiality and security of the data it processes. This means that associates are expected to be sensitive to the way they treat personal information.

All associates must protect the confidentiality of personal information—of our clients, our clients' employees, and associates at Hewitt. 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. If your role involves working with personal data, you are required to:

• Seek and disclose personal data only when it is needed to perform a business-related service to client employees or to other Hewitt associates;
• Disclose the minimum information needed to perform Hewitt's services;
• Follow Hewitt's policies, guidelines, and procedures related to security and confidentiality;
• Limit your and others' access to personal data so that it is used at the right time for the right reasons.

Information Security

Hewitt places a high importance on securing the information we collect and process on behalf of our clients and associates. Hewitt's information security policy and supporting procedures are intended to preserve the integrity of our client relationships, protect client and associate data, and maintain legal compliance. Our objective is to maintain business continuity and avoid business damage by preventing and minimizing the impact of information security incidents.

This policy outlines the requirements for the protection of corporate information and technology resources and applies to:

• All Hewitt entities;
• All computer applications (developed internally or by a third party);
• All of Hewitt's computer system platforms and operating systems; and
• All users of Hewitt's computing resources. (Users are defined as associates, contractors, temporary staff, and clients.)

Insider Trading

"Inside information" is information about a public company that is not yet available to the public and that a reasonable investor would consider important in making a decision about whether to buy, sell, or continue to hold the stock of that company. For this purpose, buying or selling Hewitt stock includes buying or selling any derivatives based on Hewitt stock, such as a put or call. Directors and executive officers may not enter into any transactions involving derivatives of Hewitt stock.

No associate shall buy or sell Hewitt stock while in possession of inside information or engage in any other action or conduct to financially gain, directly or indirectly, from inside information or pass it on to others. If you have inside information about Hewitt, you may not buy or sell Hewitt stock. Put another way, if the inside information leads you to want to buy or sell stock—don't. The odds are that other people would feel the same way and thus you could be breaking the law. In addition, it's critical that you not communicate inside information to anyone other than fellow associates or others who need to know the information in order to do Hewitt work.

This policy also applies to inside information concerning any other company you come in contact with in the course of your employment or association with Hewitt. To prevent any appearance of conflict of interest, neither you nor your immediate family members should own any stock or have any other financial interest in any client for whom you perform services.

Recording and Reporting Financial Information

Expense Reimbursement

Expense reports are an important responsibility for associates who travel on business or have other approved business expenses. We expect all associates to only submit legitimate business expenses and complete expense reports in a timely and accurate manner since these reports impact our client billing and financial reporting. Localized reimbursement guidelines and processes must be used.

Time Recording

For some of our products and services, we invoice our clients based upon the amount of time required by our associates to perform the work. We are committed to ensuring that all billings are fair and accurate. We expect all associates to accurately record the amount of time worked to the correct billing or client number. It is unacceptable to falsify or misrepresent your time on timecards, invoices, or other time-recording systems.

Records Retention and Disposal

We maintain and support a comprehensive worldwide records management program to properly maintain, protect, and dispose of records, as appropriate, on a local basis in the normal course of our business.

Hewitt records are maintained in accordance with established retention schedules, which are approved by General Counsel and the appropriate line of business, region, or country. Approved records retention schedules are found in the HA Records Management Reference database, which is the official location for the firm’s schedules.

Hewitt records are created and maintained in a manner that ensures integrity and accuracy of information. Records that are relevant to pending or ongoing litigation, investigation, or audit shall not be destroyed. Also, Hewitt records are the property of Hewitt Associates and shall not be used for non-business-related or personal purposes.