Wells Fargo (WFC)

A. Overview

To preserve and foster the public’s trust and confidence, complete honesty and fairness is required in conducting internal and external business. It’s important that every Wells Fargo team member understands that the honesty, trust, and integrity essential for meeting the highest standards of corporate governance are not just the responsibility of senior management or boards of directors. We all share that responsibility. Corporate ethics is the sum total of the ethical decisions all of us make every day.

To have integrity, one must be consistently honest and trustworthy in everything one does. When you have integrity, people know you will do what you know is right. And that aligns with how we define “culture” at Wells Fargo. It’s knowing what you have to do without someone telling you to do it. It is the core of a person’s — and a company’s — reputation.

A. Overview

Confidentiality has always been an essential part of the financial industry’s business. Wells Fargo’s customers give us private information about themselves and rightfully trust us to keep this information in confidence. Today we have technology that enables us to keep more information about customers than ever before. Recognizing this, Wells Fargo has placed special emphasis on the appropriate collection, storage, and use of customer information. Moreover, Wells Fargo has provided team members with access to computers, electronic mail, the intranet, and the internet. This access is a privilege that carries special responsibilities. This section is about your responsibility to protect confidential and proprietary information from release or misuse.

A. Overview

Team members must avoid conflicts of interest or the appearance of conflicts of interest in their personal and business activities. The appearance of a conflict of interest may be just as damaging to the reputation of Wells Fargo as the existence of an actual conflict of interest. A conflict of interest is a situation in which your personal interest or outside economic interest in a matter:

When presented with a situation involving a potential conflict of interest, you should ask: Would public disclosure of the matter embarrass Wells Fargo or lead an outside observer to believe that a conflict exists? The sections that follow provide rules and guidance for specific situations in which the possibility of a conflict of interest is present. Certain activities must be strictly avoided and others require written approval before they can be undertaken.

If a conflict or potential conflict of interest arises in circumstances not discussed under the rules that follow or if application of a rule to a set of circumstances is unclear, you should consult your supervisor or Code Administrator. In some cases it may be necessary to obtain approval or disclose the possible conflict in writing to your Code Administrator for consideration by the member of the Operating Committee for your business group or the Ethics Committee.