21 Code of Ethics and Business Conduct The Wells Fargo Code of Ethics and Business Conduct (PDF) (Code) provides clarity and focus on the ethical behavior we expect of all employees and Board members . The Code reinforces our commitment to always do what’s right by our customers, employees, communities, and stakeholders . And it contains basic principles and guidance that help our employees make decisions that align with these standards and comply with the laws, rules, and regulations that govern our business . To help make sure that the Code is accessible to our diverse workforce, we have made it available in English, French Canadian, and Simplified Chinese . No code of conduct can cover every possible situation, which is why we rely on employees to use good judgment and speak up promptly when they have questions or concerns . Every employee completes Code of Ethics training annually . This training provides interactive activities that guide employees through situations they may encounter . Beyond this training, we extend the learning through our online Wells Fargo Ethics site, Manager Center Ethics site, and Ethics Moments platform, all located on our employee intranet portal, Teamworks . These resources provide employees with information to help them navigate ethical dilemmas and make decisions guided by integrity and ethics . In addition to the Board’s oversight of conduct risk, members of the Board also attest annually that they have read and understand their obligations under the Code . While we consider our Code to be the starting point and not the finish line, it lays out the basic rules for how we conduct business . We encourage employees to read the Code throughout the year so they stay familiar with the following principles: • Anti-bribery and corruption – We do not tolerate bribery and corruption . We don’t 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 aren’t allowed to do ourselves . • Antitrust – We believe in free and open competition . We gain our competitive advantage through superior performance, not through anticompetitive business practices . • Insider trading – Employees must never buy or sell securities when they have material, nonpublic information, nor should they ever “tip” others by providing them with material, nonpublic information . Insider trading restrictions cover Wells Fargo securities, as well as the securities of other companies, including customers and third- party service providers, and they apply to all employees and their immediate families . • Gifts – We generally permit the giving and receiving of reasonable business gifts and entertainment that are neither lavish nor excessive in frequency; that are consistent with accepted, lawful business practices . • Conflict of interest – We work to avoid conflicts of interest in our employees’ personal and business activities in a number of circumstances, including through outside employment or business