Code of Conduct
Published April 2023
Table of contents
Introduction
Code of Conduct – Message from the CEO.............................. 3
Our Code................................................................................................. 4
Our culture............................................................................................. 5
Who we are........................................................................................ 5
Diversity, equity, and inclusion .................................................. 5
Decision making
Questions to ask.................................................................................. 6
Seek guidance when uncertain ...................................................... 6
Speaking up
Resources to report potential misconduct............................... 7
Reporting channels ........................................................................ 7
Duty to cooperate .......................................................................... 7
Reporting concerns that are not misconduct.......................... 7
Nonretaliation commitment .......................................................... 8
Accounting, internal controls, or auditing matters ............... 8
Safety concerns ................................................................................... 8
Required employee self-reporting............................................... 8
Do what is right
Upholding our ethical and legal obligations.............................9
Identify and avoid conflicts of interest................................9
Manage, mitigate, disclose, or pre-clear conflicts...........9
Examples of potential conflicts.....................................10
Fair and honest business dealings ......................................13
Insider trading and other trading restrictions.........13
Anti-bribery and anti-corruption..................................14
Competition and antitrust laws ....................................14
Global compliance.....................................................................15
Financial crimes and money laundering .....................15
Sanctions, embargos, and antiboycott.......................15
Protecting Wells Fargo assets .............................................16
Information security and electronic ................................ .
communications..................................................................16
Intellectual property..........................................................17
Accurate records and disclosures.................................17
Our workplace...................................................................................18
Anti-harassment and anti-discrimination.......................18
Hiring and advancement opportunities.....................18
Workplace safety.......................................................................18
Human rights
Valuing human rights.....................................................................18
Closing thoughts ......................................................................19
Waivers and exceptions ................................................................19
Violations............................................................................................19
2 of 19 Code of Conduct
Code of Conduct – Message from the CEO
As one of the world’s largest financial services institutions,
the work we do at Wells Fargo brings real responsibility. It
requires that we act with the highest standards of trust and
integrity.
Each day we make decisions in how to conduct our business
and serve our customers and communities. This Code of
Conduct, together with our Employee Handbook and other
company policies, guides us in how to do the right thing in
the right way.
Wells Fargo does not tolerate unethical behavior. We are all
responsible for our actions and the decisions we make, and
we must hold each other accountable for the outcomes of
those actions and decisions.
Thank you for your commitment to our Code of Conduct,
and thank you for the work you do to support our success.
Charles W. Scharf
CEO, Wells Fargo & Company
Our Code
Our Code of Conduct (Code) applies to all employees, including executive officers, and in some cases
the Board of Directors of Wells Fargo & Company (collectively referred to in this document as “the
Board”). Employees are expected to adhere to the Code, Employee Handbook, and company policies
and to comply with applicable laws and regulations.
Wells Fargo operates globally, and if, at any time, the Code
1
or our policies differ with local laws and
regulations, the more restrictive guidance applies.
Whenever an expectation is unclear, employees should speak with their manager. If employees are
uncomfortable speaking with their manager they can contact Employee Relations (ER), or the Ethics
Office.
Wells Fargo seeks to engage third parties and contingent resources that share our commitment to
honesty and integrity, and act in a manner consistent with the Code.
Accountability
All employees and the Board have a role in maintaining the trust of our customers and stakeholders
and complying with applicable laws and regulations. Employees are expected to:
• Abide by the Code and seek guidance when uncertain.
• Comply with company policies.
• Represent Wells Fargo accurately and professionally.
• Manage risk in alignment with the company’s Risk Management Framework.
As leaders, managers have an even greater level of responsibility. In addition to their responsibilities
as employees, managers are expected to:
• Lead with integrity, demonstrating and reinforcing the Code.
• Help employees understand the importance of following the Code and policies.
• Hold their employees accountable for adhering to the Code and policies.
• Foster a work environment where employees feel comfortable speaking up without fear of
retaliation.
• Listen to employees and report concerns that may be misconduct as soon as possible, with
appropriate confidentiality.
• Develop high performing teams.
1
The Code is translated into several languages. If there is a conflict or inconsistency between the translations, the English
version prevails, where applicable.
4 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Our culture
Who we are
Wells Fargo is committed to a culture that attracts and retains the best people who help us become a better,
stronger company. Adherence to the Risk Management Framework and effective risk management are key
components of our company’s culture. Our culture is also guided by a customer-centric focus informed by
employee engagement and feedback and reinforced by clear employee expectations. Our employee expectations
are designed to be clear and straightforward, to drive the highest standards of integrity and operational
excellence, and to provide guidance for doing what’s right and doing it well.
These expectations are:
• Embrace candor
• Do what’s right
• Be great at execution
• Learn and grow
• Champion diversity, equity, and inclusion
• Build high-performing teams (for managers)
Diversity, equity, and inclusion
We are committed to creating a culture with broad representation of who we are, how we think, and how we
make decisions. We are focused on increasing diverse representation at all levels of the company through an
inclusive culture and workplace environment; better serving and growing relationships with diverse customers in
each line of business; and supporting our spend with diverse suppliers company-wide.
One of our expectations is to champion diversity, equity, and inclusion. We believe a diverse and inclusive
workforce drives creativity, insight, and innovation in our business, and allows us to respond effectively to the
evolving needs of our customers, colleagues, and communities.
Employees are encouraged to:
• Contribute to a safe, inclusive environment where differences are respected.
• Educate themselves about unconscious bias.
• Solicit diverse ideas that challenge thinking.
5 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Decision making
Wells Fargo’s employees make decisions each day and must evaluate whether those decisions align with the Code.
If the answer to any of these questions is no, do not proceed.
Seek guidance when not sure
While every decision matters, no single document can cover every possible situation or govern every decision
made in the workplace. Employees are expected to use good judgement in applying the Code. If they are
uncertain of the right course of action, they should seek guidance from their manager.
Questions to ask:
1) Is it legal?
2) Does it comply with Wells Fargo’s Code of
Conduct and policies?
3) Is it consistent with our expectations?
4) Does it align with our obligations to our
customers or shareholders?
5) Are we comfortable if our decision is made public?
Yes to all.
Decision is
likely
ethical.
Not sure.
Seek
guidance.
No to any.
Do not
proceed.
TOC Decision making Speak UpIntroduction Do what is right Closing
Related resources include:
• Ethics site on Teamworks
• Policies and procedures
• Employee Relations
• Legal Department
• Control Management or Independent Risk Management contacts
• Ethics Office
6 of 19 Code of Conduct
Speaking up
Employees are responsible for speaking up promptly when becoming aware of potential misconduct, including
potential violations of the Code, even if the employee is not directly involved or affected by the behavior.
Allegations of misconduct are investigated and managed in an objective, thorough, consistent, and timely
manner with the goal of understanding and resolving concerns.
Resources to report potential misconduct
Employees are expected to report potential misconduct to their manager. If employees are uncomfortable
doing so, they can report through the other reporting channels listed below.
Reporting channels
The EthicsLine is a third-party resource
• Employee Relations
available 24 hours a day, 7 days a week. To the
• EthicsLine by phone
extent permitted by local or applicable laws and
− U.S. and Canada (800) 382-7250
regulations, employees may choose to remain
− non-U.S. use link and select country for specific
anonymous.
dialing instructions
• EthicsLine Online Reporting
(https://wellsfargo.ethicspoint.com/)
Nothing prohibits an employee from reporting potential misconduct or potential noncompliance with laws and
regulations by Wells Fargo directly to the applicable regulatory bodies or government agencies or authorities.
Additional information for non-U.S. based employees
Where applicable, follow local grievance resolution or reporting procedures. If there is no specific grievance
resolution or reporting procedure, use a reporting channel listed above.
Duty to cooperate
Wells Fargo employees are expected to fully cooperate in any internal or external investigation that is being
conducted or directed by Wells Fargo.
Employees must not withhold or tamper with information, or in any way attempt to influence others participating
in the investigation.
Reporting concerns that are not misconduct
Concerns unrelated to misconduct such as performance feedback, workplace disputes, inadvertent errors,
business processes, or not following procedures should also be raised. Managers are the starting point to help
resolve these concerns or guide employees to the appropriate reporting channel. Employees should consider the
following reporting channels:
• Employee Relations for performance concerns or workplace disputes.
• Control Management or Independent Risk Management for risks, errors, or business process concerns.
• Wells Fargo Employee Assistance Consulting (U.S.) and Employee Assistance Program (International) for
support in resolving personal and work-related difficulties.
• Loudspeaker for ideas and business process improvements.
• Policy Governance Platform (PGP) for identified policy violations, in accordance with the Policy Management
Procedures.
7 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Nonretaliation commitment
Wells Fargo prohibits retaliation against any employee who reports misconduct or speaks up in good faith
about potential violations of company policies, procedures, this Code, or potential noncompliance with law.
Similarly, Wells Fargo prohibits retaliation against any employee who assists or participates in an
investigation, proceeding, or hearing, or exercises any right protected by law.
Employees must report potential retaliation using methods listed under Resources to report potential
misconduct.
Accounting, internal controls, or auditing matters
If an employee becomes aware of Code violations related to Wells Fargo’s financial reporting, accounting, internal
controls, or audit matters, then they must report such violations using a reporting channel listed under Resources
to report potential misconduct or directly to the Audit Committee of the Board. Information about
communicating with directors or other committees of the Board and the process for reviewing communications
sent to the Board or its members is available on the Leadership and Governance page of wellsfargo.com.
Safety concerns
Acts of violence, threats or perceived threats should be taken seriously. In the event of immediate danger,
employees should contact local law enforcement at 911 or other designated emergency number. Non-emergency
threats can be reported to the Wells Fargo Security Response Center at U.S. (877) 494-9355, non-U.S. call
001‑480‑437‑7599, or to a manager.
Required employee self-reporting
Wells Fargo has processes in place to confirm that each employee is eligible to work and participate in the banking
industry. Wells Fargo offers of employment are contingent upon the candidate successfully passing a criminal
background check. Wells Fargo may also conduct additional background checks during employment. Unless
prohibited by local law, employees must notify Employee Relations if they are convicted of, or enter a plea of
guilty or no contest to, any crime involving dishonesty, breach of trust, money laundering, or the manufacture,
sale, distribution, or trafficking of controlled substances so that Wells Fargo can assess whether the offense
impacts the employee’s employment eligibility.
8 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Upholding our ethical and legal obligations
Identify and avoid conflicts of interest
Wells Fargo is committed to identifying and either preventing or managing conflicts of interest. Employees need
to recognize that certain activities can cause an actual, potential, or perceived conflict of interest, or jeopardize
the company’s integrity or reputation. Employees are
expected to be transparent and to:
• Identify and avoid conflicts where possible.
• Pre-clear or disclose conflicts when required.
• Mitigate or manage conflicts when necessary.
• Conduct personal activities away from work,
outside of scheduled work time, and at their own
expense.
Some employees are subject to additional
requirements and restrictions, including pre-clearance
of personal activities under company business policies
and procedures.
Manage, mitigate, disclose, or pre-
clear conflicts
Employees need to pre-clear any activity that may
give rise to a conflict prior to engaging in the activity.
In addition, certain relationships and activities require
disclosure to mitigate risk. Once the pre-clearance or
disclosure is processed, Compliance provides specific
instructions on how to mitigate or manage any
potential conflict of interest.
Definitions
A personal conflict of interest occurs when an
employee acts, or appears to act, in their personal
interest rather than acting in the interest of Wells
Fargo or its customers.
Examples of personal conflicts:
• An employee receives an improper benefit or
gift because of their position with Wells Fargo.
• An employee uses company property,
information, or position for personal benefit or
to compete or divert business from Wells Fargo.
A business conflict of interest occurs when Wells
Fargo’s interests conflict with those of a customer.
Examples of business conflicts:
• Providing advisory services to a customer on a
transaction while providing financing to another
customer on the same transaction.
• Acting as trustee to investors on a debt security
and acting as a lender to the security issuer.
TOC Decision making Speak UpIntroduction Do what is right Closing
Did you know?
Sometimes a conflict arises after engaging in an
activity. In these situations, the conflict must be
disclosed as soon as possible.
9 of 19 Code of Conduct
10 of 19 Code of Conduct
Examples of potential conflicts
Below are some common situations where conflicts of interest may be present and how employees are expected to avoid the
conflict of interest by not engaging in prohibited activities or obtaining pre-clearance when required. The list of situations is not
meant to be a complete list of every place a conflict can occur.
Outside activities
Employees generally may not:
• Own or operate a business that competes with Wells Fargo.
• Accept secondary employment or perform consulting services with any entity that competes with Wells Fargo,
otherwise conflicts with their Wells Fargo duties, or diverts Wells Fargo business.
• Act as a real estate salesperson, broker, or agent, except for the purchase or sale of their own residence.
• Accept a position with any for-profit business as a director, trustee, officer, general partner, or similar position of
influence without pre-clearance.
• Be compensated directly or indirectly for providing investment or legal advice.
• Engage in activities related to the preparation, audit, or certification of statements or documents that Wells Fargo may
rely on to make lending or other decisions related to any person or entity other than the employee.
• Speak on the company’s behalf in the media without prior approval or publish works related to their role or the
company without prior approval.
Volunteer and charitable activities
Wells Fargo encourages employees to be active volunteers in the community. While many volunteer activities do not
require pre-clearance, to avoid actual, potential, or perceived conflicts, employees must review pre-clearance requirements
and when required obtain approval prior to engaging in certain nonprofit activities, including:
• Managing the finances or investments of the nonprofit.
• Selecting or influencing selection of financial products or services.
• Participating on the Board of an organization that is a Wells Fargo customer for more than deposit services.
• Receiving compensation for service.
Employees may not solicit Wells Fargo customers, employees, or third-party service providers when raising funds for a
nonprofit.
Personal r elationships
Personal relationships in the workplace may
interfere with job responsibilities and decision making. For this reason, all
employees, new hires, or rehires are required to disclose personal relationships (as defined in the Personal and Family
Relationships at Work Policy) with other Wells Fargo employees or contingent resources so the relationship may be
reviewed for potential conflicts.
Additional requireme
nts for the Board, executive officers, and certain
stockholders and their immediate family
members are outlined in the Related Person Transaction Policy and Procedures.
11 of 19 Code of Conduct
Examples of potential conflicts, continued
Gifts and entertainment
Wells Fargo permits giving and receiving business gifts and entertainment provided there is no reasonable inference that
the gift or entertainment could influence the performance or decision making of any employee. The gift or entertainment
with any one individual or entity should occur infrequently and be consistent with accepted, lawful business practices and
customs. Employees should conduct themselves in accordance with the following expectations:
• Refrain from giving and receiving gifts offered in exchange for business referrals or other business advantages.
• Never give or receive gifts that are cash or cash equivalents, cannabis-related, or otherwise do not comply with our
policies.
• Follow requirements to pre-clear the exchange of any gift or entertainment with government officials or government
entities through the Global Preclearance System. Gifts or entertainment provided to government officials or
government entities are controlled by strict laws and regulations.
• Report a payment, loan, gift, entertainment, or anything else of value provided to labor organizations or their
representatives, as these transactions are also subject to strict laws and regulations.
• Consult with a manager before providing gifts or entertainment to individuals or entities involved in contract
negotiations or competitive bidding with Wells Fargo.
Interactions with third parties
When engaging with a third party on behalf of Wells Fargo, employees must confirm that the third party relationship does
not create undue risks, including a conflict of interest, or impair the quality and independence of Wells Fargo’s internal
controls, or the ability of relevant authorities to oversee and supervise compliance with regulatory requirements.
Political activities
Employees have the right to participate in the political process and to support candidates, parties, or initiatives of their
choice. Such participation must be outside the workplace unless pre-cleared. Political activity is strictly regulated under
U.S. lobbying and pay-to-play laws. Employees must:
• Be clear that personal political opinions and activities are not represented as those of Wells Fargo.
• Obtain pre-clearance approval before becoming, agreeing to become, or announcing intention to become a candidate
or appointee to a public office.
• Obtain pre-clearance approval before communicating with U.S. government officials or entities for the purpose of
soliciting new government business.
• Never make political contributions on behalf of the company without prior approval from the Government Relations
and Public Policy team. Company funds are never used for any campaign contributions, candidate campaign
committees, political parties, caucuses, or independent expenditure committees. Wells Fargo supports U.S. candidates
seeking public office only through Wells Fargo-sponsored Political Action Committees.
Covered employees and their family members are subject to additional requirements and restrictions, including approval
of outside political activities, contributions, and fundraising under applicable laws.
12 of 19 Code of Conduct
Examples of potential conflicts, continued
Use of professional designations
Wells Fargo acknowledges employees may maintain specialized, professional designations that may not relate to their
duties with the company. These include but are not limited to legal, medical, notary, accounting, and investment licenses
and certifications. Employees must not misrepresent or use their professional designation if it is not appropriate for their
role or if prohibited by company policy or applicable laws and regulations.
Fiduciary and investment duties
When executing fiduciary duties or responsibilities, acting as a trustee, investment manager, or in any similar capacity in
which the company possesses investment discretion on behalf of another, Wells Fargo acts in the best interest of our
clients. If a conflict arises, the company puts the client’s interests ahead of its own.
Employees may accept appointments as an executor, personal representative, administrator, guardian, trustee, or any
similar fiduciary capacity only for those with whom they have a personal relationship, unless the personal relationship
developed in the context of a Wells Fargo customer relationship.
Personal finances, borrowing, and lending
Wells Fargo expects all employees to handle their personal finances in compliance with laws and regulations. To avoid a
conflict of interest employees must not:
• Process transactions for themselves or anyone with whom they have a personal relationship, except for certain
permitted brokerage transactions.
• Purchase real or personal property that Wells Fargo has repossessed or foreclosed or is marketing at its direction.
• Borrow or lend personal funds to employees, customers, or third parties when it creates an actual, potential, or
perceived conflict of interest.
• Invest in customers or third parties of Wells Fargo beyond permitted circumstances and without obtaining pre-
clearance approval, when required.
The Board, executive officers, and certain other employees expressly identified and notified by our General Counsel, or the
Corporate Secretary, are subject to regulatory provisions related to extension of credit from Wells Fargo and its
subsidiaries.
Fair and honest business dealings
Wells Fargo is committed to engaging in fair and honest business practices and being a responsible provider of
credit in all our markets. Employees and the Board are expected to deal fairly with Wells Fargo’s customers,
suppliers, competitors, and employees, and engage in responsible lending and permissible sales practices.
Wells Fargo’s Treating Consumers Fairly Principles are standards to guide employee interactions with our
customers and help ensure that consumer fairness considerations are central to the decisions we make about
our products and services.
Wells Fargo strictly prohibits:
• Taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair-dealing practice.
• Discriminating on the basis of race, ethnicity, age, gender, or other protected characteristics.
• Engaging in unfair, deceptive, abusive, misleading, or fraudulent practices.
Insider trading and other trading restrictions
Employees must never buy, sell, or otherwise transact in securities when they have material nonpublic
information (MNPI) about the issuer of the securities, nor should they ever “tip” others by disclosing MNPI.
These restrictions apply to transactions or trades conducted in the employee’s personal accounts or any other
account over which the employee has influence or control and continue to apply even after the employee is no
longer employed by Wells Fargo.
Employees must:
• Understand and follow any trading policies, firewall, and other restrictions that apply to them and their
business.
• Report to the Global Compliance Control Group as soon as possible the receipt of any MNPI about
customers or third parties.
• Report to the Global Compliance Control Group any inadvertent disclosure or receipt of MNPI.
Employees and the Board are prohibited from engaging in derivative or hedging transactions involving any
company securities, including Wells Fargo common stock. This hedging prohibition applies to any type of
transaction in securities that limits investment risk through the use of derivatives, such as options, puts, calls,
futures contracts, or other similar instruments.
The Board, executive officers, and certain other employees expressly identified and notified by the Personal
Account Dealing Team in coordination with the Legal Department are subject to quarterly black-out or freeze
periods involving company securities.
Certain transactions that comply with applicable securities laws may be subject to specific exceptions from these
requirements, including transactions under a trading plan that complies with U.S. securities law requirements. In
addition to complying with U.S. securities laws, a trading plan must be preapproved by Wells Fargo’s General
Counsel or Corporate Secretary.
13 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Anti-bribery and anti-corruption
Wells Fargo does not tolerate bribery or corruption in any form. Such conduct is against the law and the company
prohibits it. Further, employees are prohibited from offering, accepting, or utilizing third parties to facilitate
bribes.
Employees must:
• Report suspected bribery or corruption in accordance with the Anti-Bribery and Corruption Policy.
• Comply with all pre-clearance and approval requirements related to transfers of anything of value,
employment offers, and third parties.
Competition and antitrust laws
Free and fair competition benefits Wells Fargo and its customers. Wells Fargo is committed to protecting free
and fair competition by complying with applicable antitrust and competition laws in the jurisdictions in which we
operate.
To comply with antitrust and competition laws, employees must not engage in anticompetitive behavior
including:
• Agreeing with competitors to price fix, rig bids, allocate customers or territories, or restrict supply.
• Exchanging non-public, sensitive information with competitors outside of approved collaborations or
activities.
• Colluding with competitors to boycott certain customers, suppliers, or other third parties.
• Abusing a position of market dominance.
• Agreeing with another company not to hire or solicit each other’s employees or to restrict the terms of
employee compensation.
If a competitor, customer, or third-party attempts to engage an employee in an anticompetitive discussion, that
employee must stop the discussion and promptly escalate the matter according to the Anticompetitive Behavior
Policy.
14 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Global compliance
Wells Fargo is committed to combating financial crimes and complying with applicable financial crimes,
sanctions, trade, and tax laws and regulations.
Financial crimes and money laundering
As a global financial institution, Wells Fargo has important responsibilities to help combat money laundering and
other financial crimes including tax evasion, terrorist financing, identity theft, bribery, corruption, sanctions
evasion, and fraud. We are committed to complying with all applicable global laws and regulations related to
anti-money laundering, sanctions, countering the financing of terrorism, bribery, and corruption, and following
applicable tax rules.
Employees must:
• Complete all financial crimes-related due diligence and know your customer requirements.
• Be alert to—and report—any unusual activity according to applicable procedures.
• Avoid knowingly assisting in any form of tax evasion, including providing advice on how to avoid tax
obligations.
Sanctions, embargos, and antiboycott
Wells Fargo is committed to following applicable sanctions, trade and tax laws, and regulations that prohibit the
company from doing business with certain countries, groups, or individuals, including those associated with
terrorism, narcotics trafficking, or nuclear weapons proliferation. We do this by establishing and maintaining
policies and procedures that are reasonably designed to comply with sanctions, antiboycott laws, and regulatory
guidance in jurisdictions in which we operate. The company does not cooperate with unsanctioned international
boycott requests or actions taken to evade antiboycott laws.
15 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Protecting Wells Fargo assets
Employees are responsible for protecting and appropriately using information, property, and other Wells Fargo
assets under their control. This includes protecting the company’s reputation by identifying and mitigating
potential risks.
Employee responsibilities include:
• Protecting company assets under their control from theft, waste, misuse, loss, and damage.
• Keeping company-owned laptops, mobile devices, and digital storage media safe and secure whether in the
office, working remotely, or traveling.
• Using Wells Fargo assets and the company name, logo, and trademarks only for legitimate Wells Fargo
business purposes. Limited personal use of company-owned phones, computers, electronics, and company
networks is allowed, but good judgment must be used to ensure that personal use does not interfere with
the work environment or in any way violate our policies or security requirements.
• Using their corporate card in a responsible manner and only for business-related expenses.
Employees are not permitted to:
• Allow unauthorized persons to use Wells Fargo equipment or access Wells Fargo facilities.
• Sell, lend, or donate company assets without the appropriate approval.
Information security and electronic communications
Wells Fargo employees and the Board have responsibilities to keep Wells Fargo information safe and secure. This
includes information about Wells Fargo, consumers, customers, employees, our third parties, and legal or
regulatory matters.
Employee responsibilities include:
• Safeguard and protect credentials including user identification numbers, passwords, and personal
identification numbers.
• Secure and maintain the confidentiality of Wells Fargo
information and use only for legitimate business
purposes.
Did you know?
• Protect Personally Identifiable Information and
The concept of Confidential Supervisory
personal data of consumers, customers, and
Information (CSI) is broad and includes both
employees from inappropriate use, access, disclosure,
written and oral supervisory correspondence
or destruction.
and other communications between Wells
• Stay alert and guard against scams and phishing
Fargo and a primary federal banking regulator.
attempts.
CSI is the property of federal banking regulators,
• Protect confidential supervisory information (CSI).
even if the CSI is in the possession of Wells
• Preserve the confidentiality of Wells Fargo attorney-
Fargo.
client privileged or work product protected
information.
• Identify and report possible compromised data
incidents to Compromised Data.
16 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
Intellectual property
Employees must protect and use appropriately intellectual property, including patents, copyright, trademarks,
and trade secrets. All intellectual property that is developed while working for Wells Fargo must be disclosed to
Wells Fargo and it cannot be used externally or published without written permission.
Employee responsibilities include:
Did you know?
• Not using proprietary information acquired while
working at another company, and not pressuring
Employee social media guidelines include:
other employees to do so.
• Avoid posting anything obscene, threatening,
• Not disclosing or using Wells Fargo proprietary
harassing, discriminatory, abusive, or disparaging
information after leaving the company.
to customers or employees.
• Not sharing internal use, confidential, or
restricted information.
• Maintain the confidentiality of Wells Fargo trade
secrets and confidential information.
Accurate records and disclosures
Wells Fargo and its employees must follow applicable accounting standards, policies, procedures, internal
controls, and legal requirements. The company is committed to accurate, timely, and clear disclosures to
regulatory authorities, customers, shareholders, and the public.
Employee responsibilities include:
• Never falsifying data or information.
• Maintaining accurate data or information.
• Accurately recording all payments to, and business transactions with, or conducted by third parties.
• Timely reporting of an error in any of our books or records.
• Obtaining proper authorization or consent for, and never falsifying or improperly altering, legal documents,
company forms, applications, or agreements.
• Never signing a blank or incomplete document or asking a customer or vendor to do so.
• Following records retention guidelines and complying with legal hold notices as appropriate.
• Processing all expenses accurately, timely, and through required channels; reviewing expenses for adherence
to policies; and ensuring approvals are provided by someone with the proper authority.
• Notifying Regulatory Relations as appropriate of any government or regulatory agency requests.
17 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
TOC Decision making Speak UpIntroduction Do what is right Closing Resources
Our workplace
Anti-harassment and anti-discrimination
Wells Fargo is dedicated to providing a workplace free from harassment and discrimination based on an
individual’s race, ethnicity, age, gender, or other protected characteristics. This includes, but is not limited to, on
company property or company communication systems, during remote work or business travel, at company-
sponsored events, or otherwise in connection with company business.
Any such harassment or discrimination is against Wells Fargo policy, may violate the law, and will not be
tolerated. In the event of harassment or discrimination, employees are required to promptly report it using a
reporting channel described in the Resources to report potential misconduct section.
Hiring and advancement opportunities
At Wells Fargo, we strive to provide advancement opportunities for our employees. We recruit, hire, and
promote employees based on their individual ability and experience and in accordance with Affirmative Action
and Equal Employment Opportunity laws and regulations. Wells Fargo is committed to providing all applicants
and employees, regardless of race, gender, culture, sexual orientation, religion, veteran status, ability, and other
dimensions of diversity, with equal consideration for hire, promotion, transfer, wage increases, and training.
Workplace safety
Wells Fargo is dedicated to maintaining a safe work environment.
All employees are required to perform their job duties unimpaired by illegal drugs, alcohol, or by the improper use
of legal substances.
Under no circumstances will the company tolerate physical violence or threats. To support a violence-free
workplace our employees are not permitted to carry, either openly or in a concealed manner, any weapon (such
as a knife or firearm) while on company premises or at company-sponsored events unless they are company-
authorized security personnel.
Any perceived threats of workplace violence and safety concerns should be reported immediately through the
appropriate channel described in the Reporting safety concerns section.
Valuing human rights
At Wells Fargo, we recognize the responsibility — and opportunity — we have to make a positive impact on
society. Wells Fargo is committed to respecting human rights throughout our operations, products, and services.
We encourage our employees to:
• Respect the rights and dignity of everyone with whom we do business. Respect for human dignity begins
with our daily interactions with one another and with our customers. It includes promoting diversity and
accommodating disabilities.
• Support efforts to help prevent human rights abuses including modern slavery and human trafficking.
• Report any suspicion or instance of human rights abuses in our operations or related to any specific
customer, investment activity, or the operations of our suppliers.
18 of 19 Code of Conduct
TOC Decision making Speak UpIntroduction Do what is right Closing
In closing
Wells Fargo is committed to maintaining an environment where employees are encouraged and supported in
doing the right thing in the right way.
We value the trust of our employees, customers, and stakeholders and recognize it’s something we must earn –
every day – by holding ourselves and one another accountable for acting with the utmost integrity in all our
interactions.
Waivers and exceptions
Any waivers or exceptions to the Code for executive officers or the Board may only be made by the Board or
designated Board committee and will be promptly disclosed to our shareholders in accordance with legal and
regulatory requirements.
Violations
Any violation of the provisions of the Code or the referenced policies and guidelines is grounds for corrective
action, which may include termination of employment. Certain violations may also result in legal proceedings,
including prosecution for criminal violations, impacts to the employee’s licensing, and financial industry
employment eligibility.
19 of 19 Code of Conduct
Modified date April 28, 2023
TOC Decision making Speak UpIntroduction Do what is right Closing
