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220510-0418
Letter From Stuart 2
O ur members trust USAA because we’re committed to unquestionable ethics and compliance. That
commitment rests with you and me as we live by our core values and The USAA Standard. As we
serve our members and each other, we must always embody service, loyalty, honesty and integrity in
everything we do.
USAA’s Code of Business Ethics and Conduct, our “Code,” is one of the tools guiding our commitment
to these shared values. We’re each expected to know this Code and use it to guide the way we conduct
ourselves. Please keep it close and refer to it often.
If you ever encounter a situation that’s not in line with these shared values, listen to your inner
compass and speak up. If possible, talk with your manager first or contact Enterprise Ethics, Employee
Relations or the Employee Experience team. You can also share concerns anonymously through the
Ethics Matters Helpline.
I know I can count on you to do the right thing and preserve our reputation as one of the world’s most
trusted and respected business institutions.
Thank you for your dedication to USAA.
Respectfully,
Stuart Parker
Chief Executive Officer
I. Introduction: Our Code and USAA . . . . . . . . . . . . . . . . . . . . . 5 IV. Honesty: Our Commitment to Our Stakeholders . . . . . . . . . . 11
ii. Who is Required to Follow the Code . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 ii. Entertainment, Favors and Gifts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
II. Integrity: Our Commitment to Doing the Right Thing . . . . . . . 7 iv. Protecting Company Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
iv. Whistleblower Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ii. Fair Interactions with our Members and Third Party Partners . . . . 16
Table of Contents
Introduction: Our Code and USAA 5
Introduction
6
Introduction
Integrity: Our Commitment to Doing the Right Thing 7
Integrity
8
Ethics Matters Helpline to seek guidance or report concerns without fear of retaliation, secure in the
The Ethics Matters Helpline is your helpline to ask ethics related questions knowledge that you did the right thing in coming forward.
or confidentially raise genuine concerns about a potential violation of If you believe you or someone else has experienced retaliation, you should contact
our Code or other policies. It is available 24 hours a day, seven days a Employee Relations, the Employee Experience Office, or the Office of Ethics
week and is a toll-free call. If necessary, translation services are available. immediately. Anyone engaged in retaliation against an employee for any reason
If you prefer an alternative, you may report your concern through the will be subject to disciplinary action, up to and including termination. For more
Helpline’s web portal at www.usaaethicsmatters.ethicspoint.com. information, see our Open Door Policy.
Although we encourage you to identify yourself to assist us in effectively Investigation of Reports
addressing your concern, you may choose to remain anonymous. To
USAA is committed to taking all reports seriously. All issues are documented and,
ensure your anonymity, the Helpline is operated by a third party and does
if appropriate, investigated. Each of us has a responsibility to cooperate fully with
not have caller ID or any other device that can trace the number from
all USAA investigations. Appropriate action is taken based on the investigation
which you are calling, or the computer from which you are accessing the
findings. If you would like more information, please refer to the Ethics Reporting
portal. You will be given a unique identification code and password to
Process on the Ethics section of Connect.
check back for updates or follow up with an Ethics Advisor, even if you
choose to remain anonymous. Please remember that detailed information Disciplinary Action
will be required to conduct investigations of wrongdoing so we ask you to Anyone who violates our Code – or who knowingly permits another to do so – may
be as specific as possible when making a report. be subject to disciplinary action, up to and including termination.
Whistleblower Procedures
USAA has adopted whistleblower procedures for the receipt, retention # 2 I observed a situation that I suspect violates our
and treatment of complaints received by USAA regarding accounting, Code or policies, but I’m not certain. Should I report
internal controls, or auditing matters related to one or more USAA the matter?
Investment Fund(s). For more information please contact the Chief Yes. You are not only expected, but required to report
Ethics Officer or General Counsel. If you would like to report a concern any known or suspected violations right away. You will not experience
anonymously, please contact the Ethics Matters Helpline. retaliation for making a report in good faith, regardless of whether your
Non-Retaliation report is supported or validated. Reporting in good faith doesn’t mean that
At USAA, we do not tolerate any form of retaliation against anyone you have to be right. It simply means that you are making an honest and
who makes a good faith report of potential misconduct or helps with complete report.
an investigation. Acting in “good faith” means that, to your knowledge,
you are making an honest and complete report. We want you to be free
Integrity
Service: Our Commitment to Each Other 9
Service
10
Service
Honesty: Our Commitment to our Stakeholders 11
Conflicts of Interest • Refrain from actions that might impair your independent judgment
Conflicts of interest occur when our personal interests interfere with or or provide an unfair advantage to a supplier, contractor or member.
influence – or could appear to interfere with or influence – our ability to • Do not accept for yourself a business opportunity in which USAA
act in the best interests of USAA and its members. might be interested or pass it along to another person.
We must strive to conduct ourselves in a manner that avoids conflicts If you face an actual or potential conflict of interest situation, whether
of interest with employees, members and suppliers – real or perceived. due to your actions or those of someone else’s, you have a responsibility
Conflicts can occur when accepting gifts and gratuities from members or to disclose it to the Office of Ethics by filling out a Conflict of Interest
suppliers, obtaining outside employment, or engaging in other external Disclosure Form. For further details on what types of activities should
activities that conflict with your employment at USAA. Be alert to your be avoided, see our Business Ethics and Conflicts of Interest Policy. If
friends’ and relatives’ activities and ensure that they do not create a you have a question about a conflict of interest situation or if there are
conflict of interest between you and USAA. You and your immediate any doubts as to whether a situation involves a conflict, speak to your
relatives may not improperly or personally benefit due to your position manager or contact the Office of Ethics for further guidance.
with USAA.
#5 I want to accept a part-time job as a teller
with a local bank on the weekends. Is this
okay?
Unfortunately, no. While some outside
employment opportunities are acceptable, working for a competitor
is a conflict and must be avoided. Working for a competitor also
poses a reputational risk to both companies.
Honesty
12
Honesty
13
Confidential Information
We must carefully protect USAA’s confidential and proprietary
information and intellectual property, and honor the same of other
companies. This includes internal, non-public or proprietary information
related to USAA’s business. Examples of confidential information include
most of USAA’s technology and much of our other “know-how” and
experience. Confidential information, whether obtained from those with
whom we do business or from other sources within or outside of USAA,
must be safeguarded and never used for personal gain. Information
received should be disclosed only to those who need the information to
serve legitimate business needs and should never be disclosed to anyone
outside USAA other than as specifically authorized.
Remember, you are also responsible for safeguarding confidential USAA
information even after you are no longer employed with USAA. Please see
Protecting USAA Information and Sharing USAA Information policies for
more information.
Protecting Company Assets
Our assets – whether information, physical, financial or technology
assets – are essential to operating our company successfully. You have a
responsibility to use them to perform USAA business and safeguard them
against theft, loss, waste or abuse.
Be sure to exercise good judgment when using electronic resources
at work. Your use should be lawful and ethical, and you should never
download or send any materials that might be considered offensive,
discriminatory, sexually explicit, threatening or otherwise inappropriate.
Do not use USAA email to express a personal view in a public forum.
Each of us has a responsibility to ensure that USAA’s electronic resources
remain secure. Your Eagle ID and password are intended for your use
only. For more details, see our Acceptable Use of Internet and Electronic
Communication Policy.
Honesty
14
Social Media
When using social media, you may share your personal
experiences at work, talk about the USAA culture, share
public content from usaa.com, and link people to job
openings. Should you choose to use social media, use the
same thought, care and consideration as you do when
communicating through traditional channels.
Never post confidential USAA information or speak in a way
that appears you are a representative on behalf of USAA.
Also, this Code, our core values and employment policies
should be considered when using social media. See our
Social Media Policy and Social Media Guidelines for more
information.
The Social Media Policy applies to all USAA employees who
choose to share their experiences about USAA in social
media channels. However, FINRA-associated persons and
those who are USAA’s official representatives have additional
guidance for their use of social media. If you are part of
either group, please speak to your manager about more
#8 I like to talk about my personal life and
specific guidance that may pertain to you.
sometimes my work life on my social media feeds.
Do I need to be concerned with what I discuss?
Yes. While you may use social networks to voluntarily
share your personal experiences about USAA, you need to be careful not
to disclose confidential USAA information. If you ever have a question
about something you are going to post, seek guidance before posting.
We encourage you to review USAA’s Social Media Policy and Social Media
Guidelines for more guidance.
Honesty
Loyalty: Our Commitment to the Marketplace 15
Loyalty
16
Fair Interactions with our Members and Third Party Partners #9 USAA received a sales pitch from one of our
suppliers about a new product they plan to
We conduct business in a way that reflects our core values of Service,
introduce to the market soon. Our supplier
Loyalty, Honesty and Integrity. We continue this tradition of service has not yet released any information about
through our commitment to promoting open and free competition, this new product to the market. While USAA decided that the
quality, reliability and service. Remember, although we are expected to product wouldn’t be useful for our business, I think the new
represent USAA’s interests, we should never do so by violating our Code device could be a breakthrough in several other industries. I’m
willing to take a risk on this and invest in the supplier. May I
or values. If you know or suspect that a supplier or contractor is acting
buy stock in the supplier’s company?
unethically or not in compliance with applicable laws or regulations, you
No. Since you hold material information about the supplier that is
are expected to raise your concerns with your manager and a Global
not yet available to the general public and may have an impact on
Service Delivery representative. the value of the supplier’s securities, you may not buy this stock
until information about the new product is known to the public
Representing USAA and the market has had time to react. You should contact General
Do not represent or give the appearance of representing USAA in outside Counsel if you have additional questions or concerns.
employment or other external activities unless you have authorization to
do so. Anti-Bribery/Anti-Corruption Laws
As a part of a global enterprise, we must abide by the anti-bribery and
Insider Trading anti-corruption laws in the countries in which we operate, including the
Through your work, you may come to know information about publicly Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. In general,
traded companies with whom we conduct business. You must be careful the FCPA prohibits corrupt payments or bribes to all non-U.S. government
officials, political parties or political candidates for the purpose of
to not act upon material non-public information that you learn of during
obtaining or keeping business or improperly influencing government
the course of your employment with USAA. This means you cannot trade action. Included in the anti-bribery prohibition is making a corrupt
in any type of securities or pass along inside information to anyone payment through a third party.
expressly or by recommending the purchase or sale of a security based The FCPA applies to individuals as well as corporations and requires
upon inside information. If you need further guidance, please contact companies to keep and maintain books and records that accurately
USAA General Counsel. reflect the transactions of the corporation. Refer to the Anti-Bribery
Policy for more information.
Loyalty
17
The rules for giving gifts to government officials are very strict. Never offer,
promise or give (either directly or indirectly) anything of value to induce or
influence a government official (including officials of international organizations,
political parties and employees of state-owned or state-controlled enterprises) to
gain an improper advantage or to do something improper. Violations can subject
you and USAA to severe penalties and damage our public reputation. Regardless
of local practice or the practices of other companies, make sure you avoid even
the appearance of doing something improper.
Competition Laws
We respect and comply with competition laws in locations where we
conduct business. Anti-trust and competition laws are designed to
promote a free marketplace. Failure to comply with these laws can have
serious and far-reaching consequences for the individuals involved
and USAA.
Remember, a formal written agreement is not required to violate the law
and the mere exchange of information can be a violation. Please see the
Antitrust Compliance Guide under the USAA Compliance Policy for more
information.
Loyalty
Contact Information 18
Office of Ethics If In Doubt, Use This Ethics Quick Test and Ask Yourself:
The Office of Ethics is responsible for administering the Ethics
Program. To contact the Office of Ethics, you can:
Is it consistent
• Contact a staff member of the Office of Ethics Does it feel like with USAA’s
Is the action Yes it is the right Yes No
legal? Core Values and
• E-mail ethics@usaa.com thing to do? policies?
• Mail a letter to:
USAA Office of Ethics
P.O. BOX 692292 No No
San Antonio, TX 78269-2292
• Contact the Ethics Matters Helpline: Yes
Phone:
Would I feel
- U.S. – 855-208-8583 Would I be Would I feel
3
comfortable with
treating others comfortable family members
- Germany – 0800-225-5288, as I would Yes allowing the Yes or friends
then 855-208-8583 want to situation to reading about it
- United Kingdom: be treated? continue? on the Internet?
- (C&W) 0-500-89-0011, then 855-208-8583
- (British Telecom) 0-800-89-0011, No No No
then 855-208-8583
Web portal: www.usaaethicsmatters.ethicspoint.com No = Seek Help or Refer to the Seeking Advice
and Reporting Concerns Section on page 7
3 = Proceed Accordingly
Go/Ethics