Hewitt strongly encourages associates to promptly report any situation they believe raises ethical, financial, or legal concerns regarding our behavior, whether the concerns are with the business, an individual, or a group of associates. The concerns may arise from a possible violation of our Code of Conduct or from related legal or financial issues. In all situations, Hewitt takes any reported concerns seriously and will promptly investigate. Hewitt strictly prohibits retaliation against anyone who, in good faith, reports a concern or who participates in an investigation of such reports (whether the investigation is conducted by Hewitt, another private party, or a governmental representative).

If you are aware of any situation that may violate the law, our Code of Conduct, or our policies, you are strongly encouraged to report it by one of the means noted below. Associates and service providers are required to cooperate with any investigation of an allegation of improper behavior unless otherwise dictated by local law or regulations. For associates, failure to cooperate may result in disciplinary action up to and including separation, subject to adherence to procedural requirements as determined by the laws and rules of the countries in which we operate.

Reporting an Issue if You Are an Associate

• Discuss with your manager or your manager's manager. If you have an ethical issue or concern, the first step should be to discuss the issue with your manager (or your manager's manager). Your manager is responsible for upholding Hewitt's ethics and should be your primary resource.
• Discuss with HR Connect (North America and India), your local HR contact, or Workforce Relations. If you are not comfortable approaching your manager (or your manager's manager) about an ethical dilemma, you can contact HR Connect, your local HR contact, or Workforce Relations. S/he can assist you in finding the right resolution.

In addition, two other resources are available for reporting an issue or concern. Please note: In Europe, reporting through these resources is limited to complying with legal requirements related to the financial arena such as exposing unlawful transactions. They should not be used for reporting other Code of Conduct issues.

• Hewitt Ethics Line Web Portal. Go to www.Hewitt.com/EthicsLine to access the web portal. To file a new report, access the "click here" link on the main page. After submitting a report, you will be issued a Report Key. Please write it down and keep it in a safe place. You should then use the Report Key and a password of your choosing to return to Hewitt's Ethics Line in 2-3 days to check on the status of your report.
• Hewitt Ethics Line Call Center. This toll-free service provides a confidential (anonymous) way for you to raise ethical issues and concerns, including reporting business activities that may be illegal, unethical, or in violation of our Code of Conduct, policies, or guidelines. The Hewitt Ethics Line is available 24 hours a day, 365 days a year. It is staffed by employees of Ethics Point, an independent, third-party provider of telephone-based compliance-reporting services. A team of experienced professionals are available to assist you. See below for additional information regarding Hewitt's Ethics Line.

Using Hewitt Ethic Line Call Center

Step One: To reach the Hewitt Ethics Line Call Center, call toll-free 1-800-455-9058*. A Contact Center Specialist will walk you through a series of questions to gather information on the issue you are reporting. On average, telephone reports take 10–15 minutes to complete. You will receive a report key that will permit you to follow up on your report regarding any requests for additional information. You will be given the option of providing your name or reporting the information anonymously. Please note, if you choose to remain anonymous, it will be incumbent upon you to check back periodically, as more information may be requested from you. The Contact Center Specialist will provide more information regarding this process during your call.

*To access Hewitt Ethics Line Call Center outside North America, please use the following process:

Determine the AT&T access code for your country. If you do not know the access code, use the AT&T Dialing Guides & Access Codes information to determine the code.

Once the access code has been dialed you will hear a tone. Upon hearing the tone, dial the Hewitt Ethics Line number, 800-455-9058

You will then be connected to Hewitt's Ethics Line Call Center directly and will not be charged for the call.

Step Two: Once a concern is raised through Hewitt Ethics Line, an intake report will be opened. Completed intake reports will be forwarded to either Hewitt's Global Ethics Manager or Hewitt's Internal Audit function. Reports sent to Internal Audit will be processed according to procedures established by the Audit Committee of Hewitt's Board of Directors. The Audit Committee is responsible for looking into allegations related to financial impropriety (such as the use of improper accounting procedures, fraudulent financial reporting, etc.). Each report will be handled promptly.

Step Three: Reports submitted to the Global Ethics Manager that requires further investigation will be given to an internal investigation team. The team may consist of members from Human Resources, General Counsel, Security, and other functions, as appropriate. Circumstances of each report submitted to the Global Ethics Manager will determine the appropriate investigator. Cases submitted to the Audit Committee that requires further investigation will be handled through the Audit Committee and Internal Audit.

Step Four: Once an investigation is completed, the reporting individual will be informed that the investigation is completed. Actual disclosure of specific actions taken by Hewitt or the Audit Committee will vary to ensure compliance with applicable law. All reports will be kept on file as required under applicable law.

Reporting an Issue If You Are Not an Associate

Contact your primary Hewitt contact or that person's manager (if known). If you have an ethical issue or concern, the first step should be to discuss the issue with your immediate Hewitt contact. If your issue or concern involves that person, we ask that you consider raising your issue or concern with his or her manager. In addition, you may use the Hewitt Ethics Line. Please see above for information on how to use these resources. Note: in Europe, if you are not an associate, please access Hewitt.com.

Recommending a Change to the Code of Conduct

If you have any suggestions for changes to Hewitt's Code of Conduct, you may submit your recommendation to the Ethics Mailbox. Please include in your note the reason for your recommendation.