Investment in a Wells Fargo Customer or Vendor
A team member who directly or indirectly holds an investment in or an option to acquire an interest in securities (such as stock, bonds, notes, debentures, interests in limited partnerships, or other equity or debt securities), makes a loan to, or guarantees an obligation of a customer or vendor, may have a conflict of interest when representing Wells Fargo to the customer or vendor. For this reason, team members and any family member residing with them must not invest in a customer or vendor of Wells Fargo unless they do not have material inside information about the customer or vendor and if any one of the following is true:
• The team member has no involvement in the approval or the management of business transactions between the customer or vendor and Wells Fargo.
• The securities of the customer or vendor are publicly traded on a national securities exchange and the team member does not participate in decisions involving credit or other business transactions with Wells Fargo that may be significant to the customer or vendor.
• The investment opportunity is sponsored by Wells Fargo as a part of a team member co-invest program that has been approved by the Ethics Committee.