WTW Code of
Conduct
Transforming tomorrows
with our values

wtwco.com

To our colleagues…

At WTW, our values are more than words; they embody how we work and treat each other. Ourdecisions are guided by our strong client focus, emphasis on teamwork, unwavering integrity,
mutual respect and constant striving for excellence. The WTW values are at the core of our richhistory and are critical to our bold future.
The Code of Conduct, or our “Code” as we refer to it, is important because it incorporates ourvalues and details the ethical behaviors each of us is expected to model—the behaviors thatmake WTW the best company we can be for the benefit of all stakeholders.
Read and reflect on our Code, even if certain sections may not apply to your role. If you havequestions, or if you need to report a Code violation, speak with your people manager or use
one of the other reporting resources listed—they’re available to help you.
By following the provisions of the Code, we demonstrate to our colleagues, clients,
shareholders, communities and suppliers that we take pride in doing business with our values
as the foundation.
Thank you for bringing our vision to life by living our values and following our Code each andevery day.

Carl

WTW Code of Conduct/iOur values
Our values are the core beliefs that guide our culture and behavior:
Client focus

We are driven to help our clients succeed. In every interaction and with every
solution, we act in our clients’ best interests—striving to understand theirneeds, respecting their perspectives and exceeding their expectations.

Teamwork

When you get one of us, you get all of us. We bring innovative solutions andworld-class advice to our clients by working across boundaries of business,
geography and function. We help each other succeed and create more value
by working together.

Integrity

Our clients invest more than their time and money with us; they also invest
their trust. We seek to earn that trust every day through professionalism, doing
what is right and telling the truth. We are accountable to the organizations
and people with which we interact—including clients, shareholders, regulatorsand each other—for our actions and results.

Respect

We listen to and learn from each other. We support and celebrate
differences, foster an inclusive culture and operate with openness,honesty and benefit of the doubt. We manage our relationships, inside thecompany and out, with fairness, decency and good citizenship.

Excellence

We strive to lead and sustain excellence. Most importantly, this means
an unwavering commitment to professional development and personal
growth for our people. Our colleagues take responsibility to develop theirexpertise, competencies and professional stature, while the company
invests in the tools and opportunities that allow for continual development.
In business, we place an unrelenting focus on innovation, quality and risk
management.

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TA B L E O F C O N T E N TS

To our colleagues…

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Our commitment to our communities

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Our valuesii

Avoiding bribery and corruption

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Exchanging gifts and entertainment

22

Complying with sanctions and export controls

23

Anti-money laundering (AML) and counter-terrorist financing (CTF)

24

Participating responsibly in politics

25

Supporting human rights

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Targeting tax evasion

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Our commitment to WTW

28Managing personal conflicts of interest

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Maintaining accurate records and preparing full disclosures

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Protecting confidential and proprietary information

31

Trading securities responsibly

32

Using company assets

33

Communicating responsibly

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Using social media

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Waivers or policy queries

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Our commitment to our Code1

Using our Code2

Speaking up

3Administering our Code

4

Making ethical decisions

5

Our commitment to each other6

Maintaining a respectful workplace

7

Avoiding discrimination and fostering equal employment

8

Supporting inclusion and diversity

9

Providing health, safety and security10

Our commitment to our clients

11

Managing organizational conflicts of interest

12Disclosing compensation

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Supporting fair competition

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Gathering competitive intelligence responsibly

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Understanding legal and regulatory compliance16

Conducting fair sales and marketing

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Securing personal and confidential data and privacy

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Using our Code
The Code is our guide to ethical decision-making. Each section discusses a different topic and includes:
Why it matters
An explanation of why the topic matters and how it relates to our
purpose.

How you do it
A practical guide on how to act in alignment with our values. This section
may include “Ask yourself” scenarios that discuss common situations you
may face in the workplace.
Our Code is meant to complement existing standards, policies andguidelines, not to substitute for them. We apply our Code alongsideapplicable laws and regulations, and where there is a conflict between
our Code and local laws, we follow the higher standard of behavior.
Our Code applies to all WTW colleagues, including directors and officers.
We also expect contractors, temporary workers, Third Parties, suppliers
and agents to comply with the underlying principles of the Code.

What is a Third Party?
A Third Party is an external organization or entity that helps WTW
win and retain business.

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Speaking up
If you observe possible violations of our Code, policies or applicable laws, you must report what you know.
When you make a report, WTW will treat it confidentially to the extent reasonable and practicable.
You may contact any of the following resources with questions, concernsor reports:
1. Your people manager
2. Human Resources
3. Compliance
4. Legal
5. The WTW Hotline
The WTW Hotline is provided by an independent
external party. It is available 24 hours a day, seven daysa week and is free of charge. Anonymous reports are
accepted where local law allows. You may report a
concern via the numbers listed here, online or on yourmobile device via this QR code:

Learn
More

Global Whistleblowing Policy

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Administering our code
WTW reviews and responds to reports of Code violations as appropriate.
Where a violation of our policies or our Code is substantiated, WTW
takes appropriate disciplinary action, up to and including terminationof employment or engagement. WTW may also take other appropriate
measures, including legal action or notifying governmental authorities
and regulators. It is your obligation to cooperate with internal
investigations, provide all information requested by WTW and participate
in any requested interviews.

No retaliation
We are responsible for creating an environment where people feel safeto raise genuine concerns. WTW will not tolerate retaliation against
anyone who, with reasonable belief, reports a violation of our Code,policies or applicable laws. We will take disciplinary action, up to andincluding termination of employment or engagement, against anyone
who retaliates against a colleague for making a report or for participating
in an investigation.

Leading by example
People managers and other business leaders have additional complianceand ethics responsibilities. People managers:
1. Lead by example, modeling ethical behavior for other colleagues
2. Ensure compliance with company policies, practices and trainings
3. Encourage open and honest communication
4. Take immediate action to report ethical issues that are brought totheir attention
5. Support colleagues who raise concerns

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Making ethical decisions
Our Code cannot cover every possible situation you may face at WTW.
When you are faced with a difficult decision, ask yourself these questions.

Is it legal?

Is it consistent with WTW values,
our Code and our policies?

Would I or WTW be embarrassed if it appeared
in a newspaper or internet post?

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Maintaining a respectful workplace
We foster a workplace built on respect and free from harassment.
Why it matters
At WTW, we are able to attract and retain a great team because wemanage all our relationships with fairness and decency.

What does harassment look like?
Harassment is conduct that denigrates or shows hostility or aversion toanother person. It can create an intimidating, hostile or offensive work
environment, hurt a colleague’s work performance or adversely affecttheir employment. It can be:•

Verbal: Offensive nicknames or slurs; offensive jokes or remarks•

Non-verbal: Placing or circulating written or graphic material that
denigrates or shows hostility or bias to another person or group
anywhere on WTW premises or through WTW communication
systems•

Physical: Threatening, intimidating or engaging in hostile acts

Sexual harassment includes unwelcome sexual advances, requests forsexual favors and other verbal or physical conduct of a sexual nature
when:•

Submission to the conduct is a term or condition of employment•

Submission to or rejection of the conduct is used as a basis for
employment decisions•

The conduct unreasonably interferes with an individual’s work
performance•

The conduct creates an intimidating, hostile or offensive work
environment

Bullying includes humiliating, insulting, intimidating or isolating anotherindividual.

How you do it
Be respectful. Always treat others with dignity and respect. Think about
what you say before you say it. Be professional and compassionate andavoid doing anything that others may find offensive.
Never engage in or tolerate harassment relating to gender, gender
identity or expression, race, ethnicity, disability, religion, sexual
orientation, marital status, age, veteran status, ancestry, national origin
or any other characteristic protected by law.
Speak up! Don’t sit on the sidelines if you witness bullying or harassment.
Speak up for each other and report it. It is your job—and everyone’s job—to help the people around you feel safe and welcome.

Learn
More

Respect at Work and Anti-Harassment Policy

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Avoiding discrimination and fostering
equal employment
We make fair employment decisions based on equal opportunity and merit.
Why it matters
At WTW, we believe in an environment that is free from discrimination.
We are proud to offer every candidate and colleague an equal
opportunity to succeed.

How you do it
Treat others fairly. Treat others the way you want to be treated. Focus on
the positive qualities and value that each person brings to your team.
Base employment decisions on merit. When hiring, training, determining
discipline and considering promotions, consider an individual’s merits.
Do not discriminate based on unlawful factors in employment decisions.
Speak up! There are no excuses for discrimination. If you witness or
suspect discriminatory conduct, you should immediately stand up foryour colleagues and report the conduct to your people manager, Human
Resources, Compliance, Legal or the WTW Hotline.

Learn
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Equal Employment Opportunities Policy

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Supporting inclusion and diversity
We are committed to developing a diverse workforce and an inclusive, empowering environment. We support andcelebrate our differences while treating each other with mutual respect.
Why it matters
We want every colleague to feel they can bring their authentic self towork each day in an environment that enables them to develop andcontribute to their fullest potential.

How you do it
Build diverse teams. Try to build teams with diversity in mind; wherepractical, put people with different backgrounds and experiences
together. This can provide more tools, resources and ideas to tackle ourchallenges.
Listen and learn. Listen actively to your colleagues. We should carefully
consider each other’s words and welcome the opportunity to learn fromthose with differing views and perspectives.

Ask yourself
Look around. Does everyone in the room feel included?
Q: My people manager asked me to help plan a team-building meetingat a local sports center. After investigating the available activities
at the facility, I am concerned that some of our team members withdiffering abilities may not be able to participate. What should I do?
A: Consider moving the event to another location and over time plan awide range of events in a variety of locations.

Include. Foster an inclusive environment where everyone feels
welcomed and encouraged to be themselves.
Accommodate differing abilities. Accommodate individuals withdiffering abilities. That may mean speaking with colleagues about theirindividual needs and setting up workspaces to make sure they areaccessible.

Learn
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Psychological Safety
Psychological Safety

Speak up! Raise your concerns if you feel your views or the views ofothers are not being considered or are being disrespected.

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Providing health, safety and security
At WTW, our colleagues are our greatest asset. Keeping them safe is one of our top priorities.
Why it matters
Reducing risks and keeping everyone safe in our workplace keeps thefocus on our work and avoids injuries.

How you do it
Don’t take unnecessary risks. Know and follow health and safety policies
and procedures. Take care of yourself and your colleagues, avoid unsafe
behaviors and know what to do in case of injury or other emergencies.
Report workplace violence. Violence includes threats, intimidation or
attempts to instill fear in others. If you know of or suspect an incident
or threat of violence, immediately report it to your manager, Human
Resources or the WTW Hotline, and, if appropriate based on thecircumstances, contact local authorities.

Drugs and alcohol
For the safety and security of colleagues, while conducting work for
WTW, you must not be under the influence of alcohol or illegal drugs.
Colleagues of legal age who choose to drink alcohol at company
sponsored events where alcohol is permitted are expected to act
professionally.

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Managing organizational conflicts of interest
We consider the competing interests of our clients carefully and properly manage potential conflicts of interest
between WTW and our clients.
Why it matters
For business, ethical and legal reasons, we act in the best interest of ourclients and must avoid even the perception that we are putting WTW’s
interests ahead of our clients’ or putting one client’s interests ahead ofanother’s.

What is a conflict of interest?
A conflict of interest is any situation where different parties havedifferent and potentially competing interests.

How you do it
Know the red flags. Be cautious and always consider potential conflicts,
especially when:•

Initiating a relationship with a new client•

WTW may have a financial incentive to favor the interests of one client
over another•

WTW may have a financial incentive to pursue a particular service,transaction or outcome that may conflict with a client’s interests

Be aware that conflicts can develop over time. Business relationships andopportunities change, and so can the potential for a conflict of interest.
Periodically reevaluate conflicts.
Ask questions and manage potential conflicts. Monitor situations whereconflicts may arise and ask questions of Compliance when you are unsure
how to proceed. Disclose any potential conflict of interest to your manager
and/or Compliance.

Ask yourself
Is it in the client’s best interests?
Q: Can I recommend a WTW fund to our clients without it violating ourconflicts of interest rules?
A: Yes, provided you have determined that the fund is appropriate
for the client via the suitability assessment and procedures andyou have followed any other applicable Compliance procedures.
In addition, marketing material and offering documents should
clearly disclose that it is a WTW fund, and the remuneration ofcolleagues recommending the fund should not depend on volume
of sales of WTW funds.
Q: You are involved in the management of an account for a client. The
client has a claim on a policy under which WTW has the authority
from the insurer to settle claims. Should you get involved in theclaims process?
A: No, as this is a conflict of interest. WTW is acting on behalf of boththe insured and the insurer, and duties should be segregated toensure that colleagues who are responsible for the relationship with
the insurer are not involved with claim settlement decisions.

Learn
More

Conflicts of Interest Policy

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Disclosing compensation
We are open and honest with our clients about the compensation we receive in connection with our services.
Why it matters
We disclose to our clients, directly or upon request, all remuneration we
receive in connection with the services provided to that client. In doing
so, we uphold our clients’ trust and meet our legal obligations.

How you do it
Do not take secret profit. Disclose to a client all income earned inconnection with an insurance placement for a client, as required by local
laws, at the request of a client or where it is market practice to disclose it.
Do not mislead clients. Don’t do anything to mislead a client or themarkets you use. For instance, you must not try to hide a service weprovide to markets for which we also get paid.
Ask your manager. If you have any doubts about how we receive
payment for services, consult with your manager or Compliance.

Market Derived Income (MDI)
MDI includes all revenue received by WTW from insurance
carriers and other insurance firms acting in their capacity as
insurance markets other than regular fees or commission. It
does not include revenue received from insurance carriers
relating to consultancy services.
MDI is an example of compensation we must properly
disclose. We can only accept MDI where we identify andmanage any potential conflict of interest and have obtained
approval via our independent internal mechanisms.
We act in the best interests of our clients and ensure thatproper segregations and controls are in place so as not tosteer business to a particular insurer in service of WTW’s
financial interests, rather than our clients’ best interests.

Learn
More

Market Derived Income Policy

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Supporting fair competition
In the marketplace, we compete fairly and rely on the value of our services and solutions to be successful.
Why it matters
We welcome competition. It encourages us to continually innovateand develop better solutions to meet client needs. It also helps growthe economies of the countries where we operate. We preserve faircompetition by following all competition and antitrust laws.

How you do it
Comply with competition laws. These laws generally forbid entering into
formal or informal agreements with competitors that may restrain trade.
When speaking to competitors, you must avoid discussing:•Price fixing, pricing or any other related competitively sensitive
information•

Bid rigging, bids or any other related competitively sensitive
information•

Specifics of the company’s or the competitor’s agreements with any
client•Dividing or allocating markets, territories or clients•

Wage-fixing or no-poach agreements with competitors in the market
for talent

Ask yourself
Does it limit fair competition?
Q: At a trade association meeting, my colleague and I weretalking to someone who works for a competitor. I was
surprised when my colleague agreed with the competitor’s
employee that we should look to split business in certain
industries. They shook hands, and the competitor’s employee
walked away. I asked my colleague if that was permitted andhe said, “It’s fine, nothing to worry about.” Is that true?
A: No. Agreements like that to divide clients are illegal, and theconsequences are severe. Even informal agreements (likea handshake) could be considered improper. Report any
conduct like this to Legal and/or Compliance.

You must also avoid:•

Agreeing to boycott a client or supplier•

Helping a client enter into any anticompetitive exchange or
agreement

Learn
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Global Competition and Antitrust Policy

Be careful in groups that include competitors. When participating inindustry groups or trade associations, do not discuss the prohibited
topics listed above.
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Gathering competitive intelligence responsibly
We respect our competitors’ confidential information and gather information responsibly.
Why it matters
We gather information about the marketplace, our competitors and theirservices transparently, ethically and without misusing any confidential
information.

How you do it
Be respectful. Respect other companies’ confidential information. Neveruse it without their permission.
Consult with Legal. You may not obtain competitively sensitive
information from a competitor, directly or indirectly, without Legal review
and approval.

Ask yourself
Did we obtain it the right way?
Q: One of my colleagues used to work for acompetitor. When we were brainstorming a newmarketing strategy, they offered some details
about the competitor’s strategy. I asked how theyknew this, and they said they’d learned it when
they were working there. Is this a problem?
A: It could be. If this is confidential information, yourcoworker may not be allowed to share it, even if
they learned it legally when they were employed by
the competitor. Report this to Legal or Compliance.

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Global Competition and Antitrust Policy

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Understanding legal and regulatory compliance
We operate with integrity in everything we do and follow applicable laws and regulations.
Why it matters
As a company, we are committed to operating legally and with integrity
everywhere we work. We do our part as a global citizen by conducting
business in accordance with applicable laws and regulations.

How you do it
Follow the law. You are responsible for knowing and complying with theapplicable laws and regulatory standards of the countries where you
conduct business.
Ask for help. When you are not sure about the legality of a matter or theapplication of a regulatory standard, refer to the Code or other policies
or contact Legal or Compliance.
Provide full disclosure. If your role requires it, you must provide full,accurate, timely and understandable disclosure of WTW business andtransactions in reports and documents.
Maintain professional credentials and licenses. You are responsible fordeveloping your expertise, competencies and professional stature. That
includes keeping up with your required credentials and licenses. Do not
engage in activities you are not licensed to undertake.
Report violations. Speak up when you suspect violations of any
applicable laws or regulations.

Learn
More

Office of the General Counsel Policies and Procedures
Corporate and Personal Professional Licensing Policy

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Conducting fair sales and marketing
Our marketing is grounded in our company strategy. We do not need to use unethical means to sell our solutions.
We protect our reputation when we market honestly.
Why it matters
We must not make statements that might harm our reputation for
integrity and fair dealing. We act in our clients’—and our own—interests
by marketing our services fairly and professionally.

How you do it
Be truthful about WTW services. The information you share with clientsand prospects about WTW solutions and services must be clear, accurate
and not misleading. Do not make deceptive statements to win or maintainbusiness.
Be honest about competitors’ services. Do not make false statements
about a competitor’s services.
Share information responsibly. Do not share or advertise information thatis out of date or incorrect or that you cannot fully validate from a reliable
source.
Be dependable. Provide clear information that clients can understand.

Learn
More

Global Competition and Antitrust Policy
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Securing personal and confidential dataand privacy
We protect our clients and colleagues by securing personal data, following our privacy principles
and complying with confidentiality obligations.
Why it matters
We are subject to data protection and data privacy laws worldwide. Theselaws generally govern the collection, use, processing, disclosure andtransfer of personally identifiable information (PII). We are also subject toother laws regarding confidential information. We earn and keep our clients’and colleagues’ trust by following the law and safeguarding protected
personal and confidential information.

Personally identifiable information (PII)
PII may include an individual’s name, phone number, address, National
Identification Number, Social Security Number and bank account information.

How you do it
Collect and use PII responsibly. Collect and use PII only to meet legal
requirements or facilitate business operations and use it only in the way it
was authorized to be used. Be mindful of privacy considerations when using
or designing new products and services.
Protect PII. Secure any PII you access in the course of your job. Do notshare it with anyone without the relevant individual’s permission, except
in support of business operations, and only use secure and appropriate
communications channels—even when working remotely.

Global Privacy Policy

Learn
More

Global Employee Personal
Information Protection Notice

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Avoiding bribery and corruption
We conduct our business with integrity, honesty, fairness and transparency. We never engage in bribery or corrupt
practices or work with a Third Party who engages in bribery.
Why it matters
We are subject to anti-bribery and anti-corruption laws worldwide, andviolations of those laws could lead to significant fines, reputational
damage, loss of client trust and even criminal charges for the company
and individuals involved.

Ensure payments won’t later be used as bribes. Ensure the Third Parties,
suppliers and markets you use uphold our high standards. Do not pay
anyone if you believe a portion of the payment will be used for corrupt
practices.
Monitor clients and Third Parties. Follow all due diligence, onboarding
and approval procedures and watch for red flags such as:

What is a Third Party?

•

A Third Party is an external organization or entity that helps WTW
win and retain business.

A request to be paid in cash, in another name or to an address inanother country•

A Third Party demanding an unusually high commission for atransaction•

A Third Party who says they are working directly with a government
official to give our company the contract or an advantage (see“Working with government officials”)

How you do it
Do business the right way. Do not:•Offer bribes, gratuities, kickbacks, facilitation payments or inducements
in any form (promises, employment, donations etc.) to anyone to
influence their decisions or behavior (or appear to influence)•Accept bribes, gratuities, kickbacks, payments or inappropriate gifts inany form•

Accept or pay money to facilitate business•Work with a Third Party who you suspect may engage in this type ofactivity independently or on your behalf

Keep accurate records. Maintain accurate records of business
transactions. Failing to do so can be an offense under the law, even if nobribery or corruption occurs.
Speak up! If you suspect corrupt practices or if someone offers youa bribe, contact your people manager and Compliance. You can also
report it to the WTW Hotline.

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Avoiding bribery and corruption (continued)
We conduct our business with integrity, honesty, fairness and transparency. We never engage in bribery or corrupt
practices or work with a Third Party who engages in bribery.

Ask yourself
Would you be comfortable if this appeared on the front
page of a newspaper mentioning your name or WTW?
Q: A client’s risk manager says the client will renew its contract
with WTW if we work with a new Third Party and pay themhalf of our earnings. WTW does not need the Third Party
to provide its services. Furthermore, the Third Party has no
relevant experience and is the cousin of the risk manager.
What should I do?

Working with government officials
We must take special care when interacting with governmentor state-owned entity employees and public officials. Many
countries have enacted laws that specifically prohibit bribing these
individuals. Some of these laws are far-reaching and can apply toactions performed in other countries. As a global company, wemust be diligent in all of the countries in which we operate.
Government officials include any officer or employee of agovernment entity or state-owned business or enterprise, or any
candidate for political office. This category also includes membersof the person’s immediate family.

A: Contact your people manager and Compliance immediately.
It sounds like the risk manager is requesting a bribe, hidden
as a payment to a Third Party.

Anti-Bribery & Corruption Policy

Learn
More

Anti-Bribery & Corruption –Third Party Approval Procedures

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Exchanging gifts and entertainment
We look for ways to strengthen business relationships lawfully. We never exchange gifts or entertainment that could
influence, or appear to influence, business decisions.
Why it matters
An occasional and modest gift or reasonable offer of entertainment is a normalpart of doing business and can be important for building solid relationships.
We must use good judgment, however, when offering or accepting gifts,
events, meals and entertainment to make sure we don’t cross the line.

How you do it
Make sure it is allowed. Gifts may not be excessive, extravagant or seen as ameans to influence our own or another person’s opinion or actions. Refer to the
WTW Gifts, Events/Entertainment & Hospitality Procedures to ensure a particular
gift, event, meal or entertainment event is acceptable. You must also comply
with any policies, rules or procedures applicable to your line of business orgeography. And remember that there are additional considerations that apply togovernment officials, and that any gifts, entertainment or hospitality provided toa government official requires Compliance pre-approval.
Seek approval for anything above the thresholds. Ask Compliance for approval
before accepting any gift, event, entertainment or hospitality above theacceptable thresholds that apply to your business whether the gift is paid for by
WTW, a WTW colleague or another party.

Ask yourself
Is it “quid pro quo” (offered for something in return)?
What would someone else think?
Q: WTW is negotiating the renewal of our contract with a client.
The client has asked WTW to take them to a popular sporting
event valued at $200 per ticket. Should I take the client to thisevent?
A: Check the Gifts, Events/Entertainment & Hospitality Procedures,
including any procedures that apply to the line of businessor geography for the applicable threshold and whether you
need to seek Compliance approval. In this example, the ticket
value is below the event threshold, but the timing with renewal
negotiations means there is a risk that this might be perceived
as a “quid pro quo” or an actual bribe. Even though this is below
the threshold, you should consult Compliance.

Do not offer or accept something that would embarrass you. Consider thegift, meal, event or entertainment you are going to offer to your client or
accept yourself. Now imagine if it was publicly disclosed. Ask yourself—would it
embarrass you, the recipient or WTW? If so, don’t offer or accept it.
Do not give or receive gifts or entertainment that influence objectivity. You
must not give or receive gifts, entertainment or hospitality if it would influence—or appear to influence—your judgment or the judgment of the recipient. And
keep in mind that all gifts must have a legitimate business purpose. This is thecase whether WTW or a colleague personally pays for the gift, entertainment or
hospitality.

Learn
More

Anti-Bribery & Corruption –Gifts, Events/Entertainment& Hospitality Procedures

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Complying with sanctions and export controls
As a global company, we must comply with economic sanctions, export controls and international trade regulations
and restrictions everywhere we operate.
Why it matters
We help clients in 140 countries and markets, but sanctions, trade
restrictions and export controls prohibit us from doing business withcertain countries, industries or individuals. As the consequences of not
following these laws are severe, we must be sure that all our transactions are
permitted by applicable law.

How you do it
Know the law. Make sure you know which countries are subject to sanctions
and export controls before you conduct a business transaction. A breachof one of these regulations can be a criminal offense in some countries andcan expose you and WTW to serious consequences including prosecution,
extradition, imprisonment and fines.
Ask for help. If you are considering conducting business where there is anexport control or sanctions touchpoint, refer the transaction to the Sanctions
Team. They will help you to identify and follow the sanctions and export
controls that apply.

Learn
More

Touchpoints to a Sanctioned Country
Sanctions laws are complex. Consult with the Sanctions Team inCompliance whenever there may be a touchpoint to a Sanctioned
Country.
Examples include:•A national of a Sanctioned Country or an individual located or
resident in a Sanctioned Country•
The government of a Sanctioned Country•
An entity incorporated in a Sanctioned Country•
Entities owned or controlled by any of the above•
Providing technology or consultancy services in respect of a
Sanctioned Country•
Travelling, flying, exporting or shipping in respect of a Sanctioned
Country
Any Sanctioned Country touchpoint must be referred to the Sanctions
Team, even if your country of residence permits activity with that
Sanctioned Country. Sanctions can apply beyond borders. For example,
U.S. sanctions could apply outside the U.S. in numerous situations,
including to:•••Colleagues who are U.S. nationals wherever they are locatedTransactions that involve U.S. dollars or the U.S. banking system
Transactions where one of the parties is a U.S. national, U.S. entity
or non-U.S. subsidiary of a U.S. entity

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Anti-money laundering (AML) andcounter-terrorist financing (CTF)
We take steps to prevent money laundering and terrorist financing.
Why it matters
We comply with applicable AML and CTF laws to avoid severe legal
penalties and reputational risk. Our clients trust us because we follow
these laws, conduct business with integrity and take action to prevent
WTW and our stakeholders from being involved in, or facilitating,money laundering, terrorist financing or any other financial crime.

What is money laundering?
Money laundering is the process of converting the “dirty” proceeds ofcriminal activity into “clean” money, thereby hiding where they camefrom. Terrorist financing involves using funds, which can come fromboth legitimate and illegitimate sources, for the purpose of funding
terrorist organizations, groups or acts.

Some AML and CTF red flags•

Sudden or significant changes in transactions without a reasonable
explanation•

The addition of parties who are unnecessary to the business
relationship or transactions•

An opaque corporate structure, a refusal or unwillingness toprovide KYC details or providing false or outdated information•

Unusual payment routes, payments in cash, overpayments or awillingness to pay penalties or termination fees

How you do it
Conduct due diligence. Conduct due diligence and follow the KnowYour Client (KYC) process for new prospects, clients and Third Parties.
This will help ensure that you know and understand your clients andtheir business while mitigating the risk of WTW becoming involved infinancial crime.

Learn
More

Anti-Money Laundering andCounter-Terrorist Financing Policy

Report suspicious activity. You can find examples of red flags in theAnti-Money Laundering and Counter-Terrorist Financing Procedures.
If you have any knowledge or suspicion of a financial crime, report it toLegal, Compliance, your Money Laundering Reporting Officer or
the WTW Hotline.

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Waivers andpolicy queriesParticipating responsibly in politics
We transform tomorrows for the people around us by being engaged and active in our local communities.
Why it matters
While WTW supports colleague participation in political activities,
WTW cannot be seen to take sides for political candidates nor to takepositions on issues unrelated to our business.

How you do it
Use personal time, not company time. Volunteer and participate inpolitics on your own time and do not work on outside political activities
while at work.
Make sure you do not speak for WTW. Never represent your personal
political opinions as those of WTW.
Do not use WTW funds or resources. Do not contribute company
resources, such as funds, office space, equipment or supplies, to any
political organization or political party, candidate or public official
outside the scope of any regular commercial arrangements we havewith them.
Obey the rules for lobbying. The rules governing lobbying can becomplex and difficult to interpret. Do not engage in any lobbying
without the express permission of Legal.

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Supporting human rights
We believe in the fair treatment of people and support human rights in all aspects of our business.
Why it matters
We provide equitable and safe working conditions to WTW colleagues, andwe support human and workplace rights across our business.

How you do it
Do not tolerate abuse. Never tolerate any forced or involuntary labor,
slavery, human trafficking or child labor.
Support safe and respectful working conditions. Support a collaborative,
safe and respectful work environment for all of WTW’s colleagues, clientsand suppliers.
Speak up! If you see something, say something. Contact Procurement,
Legal, Compliance or the WTW Hotline with any questions or to report any
concerns.

Learn
More

Human Rights Statement
Modern Slavery Act Transparency Statements

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Waivers andpolicy queries

Targeting tax evasion
We are committed to conducting business with honesty and fairness. Our values support our zero-tolerance
approach to tax evasion.
Why it matters
We sustain our communities and follow the law by paying our taxes. Eachof us is responsible for helping detect and prevent tax evasion and thefacilitation of tax evasion by WTW, our colleagues and our associates.

How you do it
Do not engage in tax evasion. All WTW colleagues are prohibited fromseeking to evade tax on behalf of WTW.
Do not facilitate tax evasion. Do not help anyone evade tax (including
clients, suppliers and external parties). This applies to all WTW colleagues,
wherever you are located.
Work with others who share our commitment. Do not work with individuals
or organizations who do not share WTW’s commitment to prevent tax
evasion.
Read our guidelines. Read the Tax Evasion Anti-Facilitation Guidance tofamiliarize yourself with unacceptable behaviors and possible tax evasion.

Ask yourself
Could this behavior possibly enable a client to evade taxes?
Q: One of our long-term clients requested that I send their invoice
to another apparently unrelated company, saying the othercompany would pay for our services. This seems like a strange
request, but I trust this client because we’ve been working withthem for a long time. What should I do?
A: Report this right away. A request to invoice another company
could be a sign that this client is trying to evade taxes. It isgood that you have built a long-standing relationship with thisclient, but if they are starting to engage in illegal behavior,
we will need to address the situation and report it to Legal orCompliance immediately.

Speak up! Report any concerns to business leaders, Legal or Compliance.

Learn
More

Tax Evasion Anti-Facilitation Guidance

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Waivers andpolicy queries

Managing personal conflicts of interest
We disclose and manage situations where our private interests interfere, or could appear to interfere,with our duty to WTW.
Why it matters
Conflicts of interest can make it difficult for us to make business decisions
in the best interest of WTW or our clients and can damage our reputation.

What is a conflict of interest?
A conflict of interest is any situation where different parties havedifferent and potentially competing interests.

How you do it
Be vigilant and learn to spot potential conflicts. Avoid or disclose
situations where:•

You or your family members hold a financial interest in a business,
property or other asset, such as an ownership stake in a competitor,that could affect or even appear to affect your obligations to WTW
and its clients•

You accept another position or opportunity that conflicts or appears
to conflict with your WTW responsibilities, such as a second job orboard membership•

You are involved with a hiring or employment-related decision ofa family member or someone with whom you are in an intimate
relationshipDo not compete with WTW or take for yourself or your family members
business opportunities that you learned about as a result of your position
within the company.
Do not accept an appointment to a directorship/board membership or
any similar role with an outside entity without seeking approval using theOutside Directorships Approval Request Form.

Ask questions and manage potential conflicts. Monitor situations whereconflicts may arise and ask Compliance when you are unsure how toproceed. Disclose any potential conflict of interest to your people manager
or Compliance in accordance with the relevant policy. Having a personal
conflict of interest is not a breach of our Code, but failing to disclose one is.

Ask yourself
Could it interfere with my work for WTW?
Q: My uncle is the owner of a company that is submitting acompetitive bid to become a WTW vendor. Since this is acompetitive bid, do I need to disclose my relationship?
A: Yes. You should disclose any familial relationship that could
potentially conflict with WTW’s business interests. Disclosure does
not necessarily mean a business relationship will be deemed aconflict. Even if WTW deems it a conflict, we may still manage it.

Conflicts of Interest Policy

Learn
More

Conflicts General GuidanceOutside Employment Approval Request Form
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Maintaining accurate records and preparing
full disclosures
We maintain accurate records so we can make responsible business decisions and provide
truthful information about our company.
Why it matters
For ethical, business and legal purposes, we must properly prepare
and manage our books, records and accounts and timely reflect
all transactions. Financial records must be accurate, complete andin accordance with generally accepted accounting principles andestablished finance and accounting policies, and disclosures must becomplete and accurate.

How you do it
Be truthful. Never make false or misleading entries in any books orrecords or to accountants, auditors, government officials or external
parties (e.g., clients, suppliers, creditors or regulators).
Be thorough. Document transactions carefully and completely within
the company’s official books and records. You cannot use “off the books”
accounts to record company transactions.
Be reasonable. Each transaction (e.g., business expense, time charges)
must have a valid business purpose and be supported with appropriate
documentation. You must prepare and submit all client bills inaccordance with applicable client agreements.
Be honest with auditors. You must not take any action to coerce,
manipulate, mislead or fraudulently influence internal and external
auditors.

Provide full disclosure. If your role requires it, you must provide full,accurate, timely and understandable disclosure of WTW business andtransactions in reports, documents and public filings.
Use WTW-approved methods of communication. Avoid using text
messages, WhatsApp, WeChat or similar non-WTW-approved platforms
to communicate about business. If a client, vendor or other commercial
party insists on using such platforms, take steps to re-route or preserve
the communication and related records. See the policy on Use of Instant/
Ephemeral Messaging Platforms for WTW Business for more details.

Records management
To ensure that WTW retains records required by law and necessary to its
business, you must follow our records management policies applicableto your work. In certain circumstances Legal will issue a records
preservation notice, and you must comply with the requirements set out
in it. Any questions about the applicable records management policy or arecords preservation notice should be directed to Legal.

Learn
More

Policy on Use of Instant/Ephemeral
Messaging Platforms for WTW Business
Records Management Policy

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Protecting confidential and proprietary
information
We help WTW succeed by protecting the confidential information that enables our company to function and thrive.

Why it matters

How you do it

Our success depends on our ability to develop services, attract and retain
clients and maintain our competitive advantage. To accomplish theseobjectives, we rely on confidential information, intellectual property(including trade secrets, copyright and process) and knowledge. We
must protect that information so we can continue to solve problems withexpertise and ingenuity.

Be careful about what you disclose. In general, to protect confidential
and proprietary information, you should:•

Not disclose confidential information unless authorized, even after
leaving the company•

Not discuss confidential matters with external parties, including
specifics of the work you perform for clients, and not share WTW’sbusiness information with the media•

Not discuss client matters (even the fact that you are serving aparticular client may be confidential) in public places, including
trains, planes and restaurants, and keep a clean desk•

Be careful when taking or sending confidential information out of theoffice, whether electronically or on paper•

Follow additional safeguards that may apply for certain especiallysensitive projects such as mergers or acquisitions

Intellectual property and copyright
We use a wide variety of products owned by external parties that areprotected by intellectual property laws and licenses. Just as we expect
others to respect our intellectual property rights, we must respect the
intellectual property rights of others. We never:•

Copy, use or display copyrighted work without prior permission•

Distribute copyrighted material internally or externally without
permission. This includes posting material onto the intranet or
network drives.

Material covered by copyright can include web pages, software, tools,
databases, articles, artwork and video footage.

Use confidentiality agreements when disclosure of confidential
information is necessary for conducting business. In some cases, you
may need a client or external party to sign a confidentiality agreement
before disclosing information. Consult Legal or Compliance before
requesting a confidentiality agreement or sharing sensitive information
outside our company.

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Trading securities responsibly
We operate with honesty and integrity, inside the company and out. When we trade in the financial markets (on behalf ofour clients, WTW or on our own account), we do so responsibly and never engage in market abuse or insider trading.
Why it matters
Insider trading is trading securities on the basis of material, non-public
information. It is illegal in many countries where we operate. These laws
apply regardless of the value of the trading transaction.

Examples of inside information
Information related to:•

Mergers and acquisitions•

Senior management changes•

Financial results or guidance•

Expansion plans•

New significant clients or
products•

Significant cyber breaches

How you do it

Ask yourself
Is it non-public information? Can I share it?
Q: A client told me about a big merger they are planning thathas not yet been made public. I mentioned it at a party to myfriends. The next week one of them told me they had bought
the client’s stock in advance of the merger. Does this countas insider trading?
A: Yes. Even if it was unintentional, you “tipped” your friend
about the information and they bought securities in
response. You need to report this to Legal or Complianceright away.

Do not buy or sell securities based on inside information. This applies to
trading in the securities of WTW and other companies, including clients,
suppliers, partners and competitors.
Know what rules you must follow. Certain lines of business haveadditional rules about trading in client securities. Consult with
Compliance for additional information.

Learn
More

Insider Trading Policy

Avoid tipping, directly or indirectly. Insider trading laws also apply to
sharing non-public information with friends, family or anyone else. This iscalled “tipping” and is considered another form of illegal insider trading.
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Using company assets
Safeguarding our assets—both tangible and intangible—is crucial to our success.

Why it matters
We have a duty to use WTW assets responsibly and only for legitimate
purposes. We protect our assets from loss or unauthorized use. Tangible
and intangible assets include facilities, equipment, software, supplies,
information and intellectual property.

How you do it
Use WTW systems and equipment responsibly. Use WTW assets forbusiness reasons. You may use systems and equipment for limited
personal use if it does not conflict with WTW’s business interests oroperations and does not violate any company policies.
Use WTW’s financial assets responsibly. Ensure that costs are reasonable
when you are required to spend company money, follow all travel andexpense and purchasing guidelines and maintain records of all financialtransactions.
Don’t remove company property without permission. This includes
returning all WTW property and material in your possession or under
your control to the company in the event that your employment with thecompany ends. If you remove or keep any company property in violationof WTW policy or the law, you will be disciplined and may be subject tolegal action.

Learn
More

Information and Cyber Security Policy

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Communicating responsibly
We speak with one voice that reflects our values of client focus, teamwork, integrity, respect and excellence whencommunicating to our colleagues, the public, media and government agencies.
Why it matters
To preserve our reputation for integrity, our communication must give an
accurate, honest and consistent picture of our business operations, transactions
and plans. You may not make internal or public statements on behalf of WTW
unless designated as a WTW spokesperson.

How you do it
Refer internal communication inquiries to Internal Communication and ChangeManagement (ICCM). If a leader or colleague has an internal communication
request or need, refer them to ICCM.
Refer financial inquiries to Investor Relations. If an investor, security analyst orother key financial contact requests information from you, refer them to Investor
Relations.
Refer press inquiries to External Communication. If a member of the press
contacts you, refer them to External Communication.
Communicate with government agencies responsibly. You can only
communicate with government or regulatory agencies on behalf of WTWwith specific authority from Legal or Compliance. Never communicate with agovernment agency on a client’s behalf without that client’s approval and Legal’s
approval unless this is authorized as part of the usual responsibilities of your role.
A response to “service of legal process” (subpoenas for documents, deposition
notices or interrogatory requests) on behalf of WTW can only be made after
consultation with Legal. In addition, notify Legal promptly of any regulatory or
governmental investigation, inquiry or audit in which you are asked to respondon behalf of WTW.

Learn
More

Internal Communication
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Waivers andpolicy queries

Using social media
We use social media responsibly by managing our personal use and being careful not to speak on behalf of WTW.
Why it matters
Social media gives us a vast array of opportunities to communicate with our
stakeholders and communities. It includes posts, comments, blogs, social
networking sites, photo/video sharing sites and chat rooms. Our communication
on social media can help or harm our reputation as a company. We must be
careful to use it wisely and responsibly.

How you do it
When using social media, you must never:•Speak on behalf of WTW. Do not give the appearance of speaking or acting
on WTW’s behalf unless you are authorized to do so.

•

On behalf of WTW, post a social media link to a page that takes or solicits
donations unless the charitable program and social media post have been
officially approved by Corporate Responsibility.

•

Reveal confidential information. Be careful not to reveal any confidential
information through social media posts, messages or forums.

Remember that the Code applies online. You must follow the principles laid out
in our Code online just as you do in person.
Follow our Social Media Guidelines. Review and comply with the Social Media
Guidelines and practices that are more restrictive in your business area.
Speak up! Report inappropriate use of WTW technologies or electronic
communication.

Social Media Guidelines

Learn
More

Information and Cyber Security Policy
Policy on Use of Instant/Ephemeral
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Waivers or policy queries
Waivers of or exemptions from the Code are intended to be rare
and will be granted only in exceptional circumstances. You must
submit any request for a waiver or exemption for colleagues to
the General Counsel or the Global Chief Compliance Officer.
Requests for a waiver or exemption for executive officers andWillis Towers Watson plc directors must be submitted to theWillis Towers Watson plc board of directors.
If ambiguity or uncertainty arises as to the meaning of any
requirements in this Code or WTW policies, please refer to theGeneral Counsel or the Global Chief Compliance Officer.

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Statement of policy
This Code is a statement of the fundamental principles and key policies
and procedures that govern the conduct of WTW’s business. It is notintended to and does not create any rights for you, our clients, suppliers,
competitors, shareholders or any other external party. No such party should
construe the adoption of this Code nor any description of its provisions as arepresentation or warranty by WTW regarding any matter covered herein.
About WTWAt WTW (NASDAQ: WTW), we provide data-driven, insight-led solutions in
the areas of people, risk and capital. Leveraging the global view and local
expertise of our colleagues serving 140 countries and markets, we help
you sharpen your strategy, enhance organizational resilience, motivate
your workforce and maximize performance. Working shoulder to shoulder
with you, we uncover opportunities for sustainable success—and provide
perspective that moves you. Learn more at wtwco.com.

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