Hewitt's Obligation to Associates
Hewitt encourages all 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, including possible violations of our policies not related to the Code of Conduct. In all situations, Hewitt takes any reported concerns seriously and will promptly investigate them. Hewitt strictly prohibits retaliation against anyone who, in good faith, reports any of these concerns or who participates in an investigation of such reports (whether the investigation is conducted by Hewitt, another private party, or a governmental representative).
Associates' Obligation to Hewitt
If you are aware of any situation that may violate the law, our Code of Conduct, or our policies, you are expected 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. For associates, failure to cooperate will 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
Ask 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.
Ask your HR Business Consultant (HRBC), 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 your HR Business Consultant, your local HR contact, or Workforce Relations. He or she can assist you in finding the right resolution. If you do not know who your HR BC or local HR contact is, you can find out through The Source. Click on the “About the Firm” section. Under “About Hewitt,” click on “HA Resource Directory” and search for “ HRBC.” HR resources are listed by region and market.
In addition, these two resources are available.
- Ethics Mailbox. You can send an email to the Ethics Mailbox. (Type “Ethics Mailbox” in the “to” line when using Hewitt email. If you are sending a note using another email account, you can access the Ethics Mailbox by clicking here). This avenue provides the opportunity for you to submit concerns, ask questions, or seek advice. You should receive an initial response to your email note within 48 hours.
- Call ComplianceLine™. This toll-free service provides a confidential (anonymous) way for you to raise ethical issues and concerns, including confidentially reporting business activities that may be illegal, unethical, or in violation of our Code of Conduct, policies, or guidelines. ComplianceLine is available 24 hours a day, 365 days a year. It is staffed by employees of Compliance Concepts, Inc., an independent, third-party provider of telephone-based compliance-reporting services. A team of experienced professionals, called “Compliance Risk Specialists,” is available to assist you. See below for additional information regarding Hewitt’s ComplianceLine.
In some countries, the process for reporting an issue or concern is limited to reporting to HR (e.g. France). Please consult your local HR policy prior to reporting an issue or concern.
Using ComplianceLine
Step One: To reach ComplianceLine, call toll-free 1-800-455-9058*. A Compliance Risk 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 case number that will permit you to follow up with ComplianceLine 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 with ComplianceLine, as more information may be requested from you. ComplianceLine will provide more information regarding this process during your call.
*To access ComplianceLine 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 this link to determine the code.
Once the access code has been dialed you will hear a tone. Upon hearing the tone, dial the ComplianceLine number, 800-455-9058
You will then be connected to ComplianceLine directly and will not be charged for the call.
Step Two: Once a concern is raised through ComplianceLine, an intake report will be opened. Completed intake reports will be forwarded to either the Hewitt 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 Ethics Manager that require 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 Ethics Manager will determine the appropriate investigator. Cases submitted to the Audit Committee that require 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. If the report was provided anonymously, ComplianceLine will be informed. 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.
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 Ethics Mailbox or ComplianceLine.
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.
