A conflict of interest arises when your private interests have the potential of interfering, or appearing to interfere, with the interests of Hewitt as a company. Conflicts of interest can also arise when you or a member of your family or someone with whom you have a personal relationship has 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 receives 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 subject to adherence to procedural requirements as determined by the laws and regulations of the countries in which Hewitt operates. Your manager or HR will work with you to determine an appropriate resolution, if necessary and subject to adherence to procedural requirements as determined by the laws and regulations of the countries in which Hewitt operates.
• 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).