Regardless of our growing size, scope, and reach, our common Vision & Values form the fabric that holds us together wherever we are, whatever we do.

Our Vision & Values have helped create a unique culture at Wells Fargo that sets us apart and defines who we are as an organization. We are proud of our culture and its focus on:

Serving our customers

Connecting with our communities and stakeholders

Caring about one another and those we serve

In order to maintain our reputation as a trusted, ethical company, we must do our part to ensure that our values come alive through our actions. Every day when we come to work, we have the opportunity to bring our Vision & Values to life.

Our culture is continually renewed by the choices and actions each of us makes every day. This Code of Ethics and Business Conduct (“Code”) contains basic principles and additional guidance to help us make the best decisions and to comply with the laws, rules and regulations that govern our business. This Code, together with our Vision & Values, Team Member Handbook, other detailed regional and business work rules, and our more comprehensive company policies, are intended to serve as resources when we are faced with ethics or compliance issues or when we have questions about what to do in specific situations.

How to use our Code

No code of conduct can cover every possible situation, which is why we rely on you to use good judgment and to speak up promptly when you have questions or concerns.

In addition to the Code, we also have a number of other resources and corporate and line of business policies for team members. Throughout the Code, we have listed policies that provide more detail on specific topics. Also included is advice on where to go for additional guidance and support.

Wells Fargo operates globally, and if, at any time, this Code or our policies differ with local laws, rules, and regulations, you should comply with the more restrictive policies, laws, rules, or regulations. Whenever the applicability or interpretation is unclear, team members should contact their manager, HR Advisor (for U.S.-based team members), appropriate Human Resources professional (for non U.S.-based team members), or the Office of Global Ethics and Integrity. Directors of Wells Fargo & Company should contact the General Counsel, Corporate Secretary or Chair of the Governance and Nominating Committee of the Board of Directors (the “Board”) of Wells Fargo & Company.

People as a competitive advantage

We’re a relationship company, but our relationships with our customers are only as strong as our relationships with each other.

As team members and representatives of Wells Fargo, we always value and support one another. We believe everyone on our team is important and deserves respect.

Who needs to follow our Code?

Our Code applies to all team members, including officers, as well as directors of Wells Fargo & Company and its subsidiaries, regardless of location or whether the team member is classified as regular, part-time, or flexible.

In addition, we look for third-party service providers that share our commitment to integrity, customer service, ethics, compliance, and behavior that is consistent with our Code. We will take the appropriate actions where we believe they have not met our high standards, their contractual obligations, or have violated any applicable law, rule, or regulation. See the Supplier Code of Conduct for additional guidance.

Ethics

Our ethics are the sum of all the decisions each of us makes every day.

We have a responsibility to always act with honesty and integrity. When we do so, we earn the trust of our customers. We have to earn that trust every day by behaving ethically, rewarding open, honest communication, and holding ourselves accountable for our decisions and actions.

What’s right for customers

We want to be approachable and caring, exceed our customers’ expectations, and invest in relationships that last a lifetime.

Our customers are always our priority. Our customer focus is one of the characteristics that distinguishes us from our competitors. We do what’s right for our customers by:

Closing the loop

Our approach to ethics and business conduct must continually evolve to stay current with new and emerging risk areas. Once you’ve made a decision, ask yourself the following additional question:

Do you believe there are sufficient standards, policies and team member resources in place to address the issue you faced – or should more be done?

If you believe more should be done, contact the Office of Global Ethics and Integrity. Your suggestions will help us improve our ethics and compliance programs.

Diversity and inclusion

We value and promote diversity in every aspect of our business and at every level of our organization.

Collaboration and inclusiveness are central to how we work because the best solutions are often those that draw on our diverse ideas and perspectives.

As team members we have a responsibility to:

Leadership

We want all team members to be able to lead themselves, lead the team, and lead the business.

Every team member is expected to be a leader. This means that each of us must take responsibility for maintaining Wells Fargo’s reputation and for ensuring that we always act with honesty and integrity. Each of us must:

Accountability

We are all accountable for complying with the Code, as well as all company policies and applicable laws, rules, and regulations that apply to us. Likewise, we are all accountable for our decisions and actions, especially managing the risks inherent in our roles and appropriately escalating issues and violations of which we become aware. If mistakes are made, we acknowledge them and act to correct them.

Violation of the provisions of this Code or the referenced policies and guidelines is grounds for corrective action, which may include termination of your employment. Certain actions may also result in legal proceedings, including prosecution for criminal liability.

We do not tolerate retaliation

We do not engage in or tolerate retaliation of any kind against anyone for providing information in good faith about suspected unethical or illegal activities, including possible violations of this Code, violations of laws, rules, or regulations by others, or concerns regarding accounting, internal accounting controls, or auditing matters. If you think that you or someone you know has been retaliated against, contact any of the resources listed in this Code.

To learn more

Where to go for help

We have a responsibility to protect the reputation and integrity of Wells Fargo. If you see or suspect illegal or unethical behavior involving Wells Fargo, including possible violations of this Code, or violations of laws, rules or regulations—whether it relates to you, your manager, a co-worker, a customer or a third-party service provider—or if you have a question or need help making an ethics or compliance decision, you have several options. You can contact any of the following at any time:

We are committed to investigating potential violations and dealing with each report fairly and reasonably.

Our EthicsLine and how it works

Our EthicsLine is a confidential way to report possible violations of the Code or any laws, rules, or regulations. You may contact the EthicsLine 24 hours a day, 7 days a week.

The EthicsLine call center is staffed by third-party interview specialists. Translation services are available. Where allowed by local law, you may choose to remain anonymous.

When you contact the EthicsLine, the interview specialist will listen, ask clarifying questions if necessary, and then write a summary report of the call. The summary will then be provided to Wells Fargo for assessment and further action. The Audit & Examination Committee of the Board oversees the investigation of concerns raised about accounting, internal accounting controls, or auditing matters.

When you contact the EthicsLine, it is important to provide as many details as possible (e.g., who, what, when, where). Because Wells Fargo may need some additional information, you will be assigned a report number and asked to call back at a later date to answer any follow-up questions.

Any information provided to the EthicsLine will be treated as confidential to the extent allowed by local law. In some instances, during the course of investigations, information may be shared on a need to know basis. Under some circumstances, Wells Fargo may be required to report certain types of suspicious activity and other activity that may potentially violate criminal laws.

Keep confidential information safe and secure

Our standard

Each of us has access to confidential information about Wells Fargo, our customers, team members, and our third-party service providers. We are responsible for keeping confidential information safe and secure.

Team member responsibilities

In some business units, there may be additional policies that restrict the flow of confidential information with other business units, including those that are engaged in investment advisory or securities trading activities.

Nothing in this Code prevents you from either discussing or disclosing the terms and conditions of your employment (including your pay) or from reporting any possible violation of law or regulation to the appropriate authority or investigative agency.

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Use our assets wisely

Our standard

We are trusted with and responsible for protecting Wells Fargo’s assets and using them efficiently. Wells Fargo assets include physical and intellectual property.

Always remember

Team member responsibilities

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Maintain accurate and complete records

Our standard

Each of us has an important role to play in recording financial and non-financial information. We must always be accurate and timely when reporting personnel and business transactions.

We are committed to full, fair, accurate, timely, and understandable disclosure in the public reports and documents that Wells Fargo files with, submits, or provides to the U.S. Securities and Exchange Commission, other regulatory authorities, our stockholders, and the public.

Team member responsibilities

To learn more

Be clear and candid in our public communications

Our standard

When we share information with the public, we must do so carefully, consistently, and with one voice. In all of our communications we should be as candid and transparent as possible while keeping in mind our responsibilities to protect confidentiality and privacy. This includes the use of social media as well as more traditional forms of oral and written communication. Only approved Wells Fargo spokespersons may speak on the company’s behalf.

Team member responsibilities

Some business lines may have additional restrictions on electronic communications including prohibitions and preapproval requirements.

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Avoid conflicts of interest

Our standard

We must avoid conflicts of interest in our personal and business activities, in any number of circumstances, including through outside employment or business activities and personal transactions, finances or relationships. Remember that the appearance of a conflict of interest may be just as damaging to Wells Fargo’s reputation as an actual conflict of interest. The following are examples of actual or potential conflicts of interest:

Where conflicts cannot be avoided, we should be transparent about their existence and take proactive steps to manage them.

Always remember

If you are presented with a situation that might involve a conflict of interest or the appearance of a conflict of interest, ask these questions:

When in doubt, discuss the matter with your manager or the Office of Global Ethics and Integrity. Additional rules and procedures are applicable to our directors and executive officers.

Team member responsibilities

Some team members are subject to additional requirements and restrictions, including preclearance, under their line-of-business policies and procedures relating to outside activities and personal investments. This may include team members employed in the brokerage, investment banking, investment research, advisory, trust, and investment management units, as well as senior officers who make or supervise fiduciary investment decisions, as applicable.

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Exchange only appropriate gifts and entertainment

Our standard

We generally permit the giving and receiving of business gifts and entertainment that are reasonable, are neither lavish nor excessive in frequency, are consistent with accepted, lawful business practices, and where no inference can be drawn that the gift or entertainment could influence you in the performance of your duties for Wells Fargo. But if not handled carefully, the giving or receiving of gifts or entertainment can be illegal or may damage Wells Fargo’s reputation, especially if it appears to influence a business decision.

Always remember

Giving and receiving gifts and entertainment are always unacceptable if they are:

Before providing gifts or entertainment to individuals or entities involved in contract negotiations or competitive bidding with Wells Fargo, team members should discuss with their manager and directors should discuss with the General Counsel, with sensitivity to the potential for the appearance of improper influence.

Team member responsibilities

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Exercise sound judgment in incurring business expenses

Our standard

At every level, all of us are responsible for expense management.

Team member responsibilities

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Deal fairly with our customers and others

Our standard

We must be honest and fair in our dealings and communications with our customers, as well as with third-party service providers, competitors and each other. We provide our customers and prospective customers with advice, service, and many products, and we are committed to making financial products and services available to them on a fair, transparent, and consistent basis, and to conducting business in a responsible manner.

Always remember

Team member responsibilities

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Anti-bribery and anti-corruption

Our standard

We do not tolerate bribery and corruption, which, in all forms, go against our Vision & Values and our company policies, and violates the law. We do not offer or accept bribes or any other kind of improper payment, including facilitation payments or anything of value, and we do not do anything through a third party that we are not allowed to do ourselves.

Team member responsibilities

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Competition and antitrust laws

Our standard

We believe in free and open competition. We gain our competitive advantage through superior performance rather than through unethical or illegal business practices.

Competition laws are complex, and compliance requirements can vary based on the jurisdiction and circumstance. If you have any questions, seek appropriate guidance from your line of business compliance team or the Law Department before taking action.

Always remember

All jurisdictions in which we operate have laws against practices that interfere with competition. The following activities should always be avoided and, if they occur, reported to the Law Department or the EthicsLine:

To learn more

Insider trading and other trading restrictions

Our standard

You must never buy or sell securities when you have material, nonpublic information, nor should you ever “tip” others by providing them with material, nonpublic information. Insider trading restrictions cover Wells Fargo securities and the securities of other companies, including customers and third-party service providers, and apply to you and your immediate family. These restrictions also apply to transactions or trades conducted in your personal accounts or any other account over which you have direct or indirect control.

If you commit an insider trading violation, the consequences can be severe, including immediate termination of your employment, civil and criminal penalties for you, anyone you tip, and Wells Fargo as a company, and damage to Wells Fargo’s reputation.

Always remember

Team member responsibilities

Wells Fargo directors, executive officers, and certain other team members expressly identified and notified by our General Counsel or Corporate Secretary may be subject to quarterly blackout trading restrictions and preclearance requirements under the Wells Fargo Personal Trading Policy.

To learn more

Global trade, sanctions, embargos, and anti-boycott laws

Our standard

We are committed to following applicable trade laws, regulations, and sanctions.

Always remember

United States law and our policies prohibit team members from cooperating with unsanctioned boycotts of countries that are friendly to the U.S.

We also have policies, procedures, and controls to comply with U.S., European Union, U.K., and United Nations rules pertaining to transactions and investments that involve certain countries, groups, or individuals, including those associated with terrorism, narcotics trafficking, or nuclear weapons proliferation.

Team member responsibilities

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Anti-money laundering

Our standard

As a global financial institution, we have special responsibilities to help combat money-laundering. Our Global AML Governance Policy and related procedures are designed to comply with all applicable laws and regulations related to money laundering and terrorist financing. Team members are required to comply with these policies, procedures and controls.

Team member responsibilities

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Political activities

Our standard

You have the right to voluntarily participate in the political process, however, you need to always be sure that your personal political opinions and activities are not viewed as those of Wells Fargo.

Always remember

Team member responsibilities

Some team members are subject to additional requirements and restrictions, including preclearance of outside political activities and contributions, under corporate and business line policies and procedures. This may include team members employed in the brokerage, investment banking, investment research, advisory, trust, and investment management units, as well as senior officers who make or supervise fiduciary investment decisions.

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Support our communities

Our standard

We want to be known as a trusted neighbor in the communities where we live and operate.

Team member responsibilities

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Respect human rights

Our standard

Consistent with our Vision & Values, Wells Fargo recognizes that governments have the duty to protect human rights, and our company has a responsibility to respect human rights. To that end, we strive to respect human rights throughout our operations and our products and services, including consistent treatment among people, employee well-being and security, economic and social freedom, and environmental stewardship.

We seek tangible ways to apply these principles through our actions and relationships with our team members, customers, suppliers and communities in which we do business.

Team member responsibilities

Each of us can help support efforts to eliminate modern slavery, exploitation and human trafficking abuses.

To learn more

Protect the environment

Our standard

We are committed to integrating environmental mindfulness into all we do and accelerating environmental sustainability.

We recognize that our environmental impact goes beyond how we operate. We see the business value of taking a leadership position in addressing our own environmental footprint and in finding innovative solutions to help our communities and customers become more resilient. We also know that our impacts extend beyond the walls of our operations to include our supply chain and customers; and are focused on managing environmental risks in our approach to lending and making investments, and across our supply chain. We all do better when we make decisions that care for and improve the environment.

Team member responsibilities

Each of us can help support efforts to advance environmental sustainability in our operations and our communities.

To learn more

Our Code covers many of the ethics and business conduct topics that we are likely to face in our work, but no code can cover every possible situation. That is why it is important to remember that you have other resources in addition to our Code that you can use to help you make good decisions:

Additional Resources

Anything of Value

Any benefit or financial or other advantage, and includes (but is not limited to) money, per diems, property, gifts, meals, entertainment, lodging, travel, contributions, donations, offers of employment, below-market discounts, refunds, rebates, benefit-in-kind, or preferential treatment or access.

Bribe or Bribery

The intentional offer, promise, or giving of anything of value, directly or indirectly, to or from any person to improperly influence that person, as an inducement for that person to act improperly or refrain from acting properly, including in accordance with official or fiduciary duties or contractual or other obligations, or to gain any other improper advantage.

Corruption

Dishonest or fraudulent conduct by those in power, typically involving bribery.

Derivative Transaction

A derivative is a security with a price that is dependent upon or derived from one or more underlying assets. Its value is determined by fluctuations in the underlying asset. For purposes of this Code, a derivative transaction would not include the acquisition or exercise of an employee stock option or other stock right granted as part of a Wells Fargo compensation and benefits program or an investment in or the conversion of Wells Fargo convertible preferred stock.

Facilitation Payments

Payments, typically small in amount, to individuals to secure or expedite the performance of a routine action that the individual has a duty to perform (also known as “grease payments”).

Firewall

Information-sharing restrictions, commonly known as firewalls, help protect the flow of nonpublic information.

Hedging Transaction

A type of transaction in securities that limits investment risk with the use of derivatives, such as options and

futures contracts. Hedging transactions purchase opposite positions in the market in order to ensure a certain amount of gain or loss on a trade.

Material Information

Information is “material” if it could reasonably be expected to affect the market price of a company’s securities, or if it likely would be considered important by an investor when deciding to buy or sell a company’s securities. Both positive and negative information may be material. Some types of information are usually considered to be material and include but are not limited to the following:

Nonpublic Information

Information about a business organization that is not generally available to or known by the public (also called “inside information”).

Proprietary Information

Information that is unique to Wells Fargo and is shared only based on distinct business need to know. Compromise of proprietary information would impact Wells Fargo’s ability to compete. Examples of proprietary information include customer lists, technical data, product costs, and trade secrets.

Securities

Securities include but are not limited to stocks, bonds, notes, debentures, limited partnership units, other equity or debt securities, and derivative instruments (e.g., options, warrants, puts, calls, futures contracts, or other similar instruments).