Code of Ethics & Business Conduct

Introduction
Wells Fargo’s Code of Ethics and Business Conduct is the guiding principle for the actions of every Wells Fargo team
member. All new team members are required to sign the Team Member Acknowledgment to indicate that they will read
and conduct themselves in accordance with the provisions of the Code. In addition, team members are required to
complete annual Code of Ethics compliance training and certify, upon completion of that training, that they have read and
will comply with the Code.
Important: You’re responsible for complying with the provisions of the Code and reporting any conflicts of interest or
other violations of the Code to the appropriate person. Violations of the Code or refusal to complete the Team Member
Acknowledgment are grounds for corrective action, which may include termination of your employment.

Wells Fargo's Approach
Wells Fargo* expects its team members to adhere to the highest possible standards of ethics and business conduct with
customers, team members, vendors, stockholders, other investors, and the communities it serves and to comply with all
applicable laws, rules, and regulations that govern our businesses. This Code of Ethics and Business Conduct (the “Code”)
explains Wells Fargo’s policy and standards concerning ethical conduct for all team members. Our aim is to promote an
atmosphere in which ethical behavior is well recognized as a priority and practiced every day. Team members have a
special responsibility to follow these standards because our everyday actions influence what people think about our
company. That's called our reputation. A reputation is earned over years of consistently focusing on what is best for our
customers and communities and following the rules that govern our business in the spirit of our Vision & Values.
The policy and standards are grouped under section headings that emphasize the fundamental and overriding principles
that should guide our behavior: We should act in a manner that will serve the best interests of Wells Fargo, that is honest
and trustworthy, that will preserve confidential information, and that will avoid conflicts of interest or the appearance of
conflicts of interest.
This Code cannot provide rules to cover every circumstance. Answers to questions involving ethical considerations are
often neither easy nor clear-cut. You should understand and abide by both the spirit and the letter of the policies and
standards in the Code and remember that you may not do indirectly what you cannot do directly under the Code.
Individuals employed in brokerage, investment, or other similar positions governed by licensing requirements are subject
to additional requirements that may be more restrictive due to law, regulation, or the Code; discuss these requirements
with your supervisor or your Code Administrator. If you violate any provision of the Code or fail to cooperate fully with any
inquiries or investigations, you will be subject to corrective action, which may include termination of your employment. A
process for resolving issues that arise under the Code is more fully outlined in the Code Administration section.
If you have concerns about conduct that you believe may violate the Code, laws, rules, or regulations or about accounting,
auditing, or internal accounting control matters, you should contact EthicsLine as described in the EthicsLine section. No
retaliation may be taken against a team member for providing information in good faith about possible Code violations;
violations of laws, rules, or regulations by others; or accounting, auditing, or internal accounting control matters.
*Wells Fargo, as used throughout this Code, means Wells Fargo & Company and each of its subsidiaries.