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1. Policy Regarding Reporting of Suspected Code Violations or Accounting Concerns.

Employees who observe, learn of, or, in good faith, suspect a violation of the Code of Conduct of the Company ("Suspected Code Violations") should immediately report the violation in accordance with the following procedures. Similarly, any employee or other person who has good faith complaints or concerns regarding accounting, internal accounting controls or auditing matters ("Accounting Concerns") should communicate those complaints or concerns in accordance with the following procedures. As described below, employees who report Suspected Code Violations or Accounting Concerns in good faith will not be subject to retaliation of any kind.

2. Procedure for Reporting Code Violations.

Any person who has knowledge of a suspected Code Violation should file a complaint by contacting:

  • Any Compliance Officer designated on SEI's Corporate Website at www.seic.com; or
  • The SEI Ethics Alertline by calling Alertline at 1-877-705-2579 (international callers call collect at 704-943-1126), or
  • By email to SEIEthicsCommittee@seic.com.

Complaints to the Ethics Alertline may be made on a confidential or anonymous basis. When making a complaint, the employee should provide as much specific information as possible, including names, dates, places, events, and an explanation of why the employee believes the incident is a Code Violation.

3. Procedure for Reporting Accounting Concerns.

Any person that has knowledge of an Accounting Concern should file a complaint by contacting:

  • The Director of Internal Audit of SEI, or
  • The General Counsel of SEI; or
  • The SEI Ethics Alertline by calling Alertline at 1-877-705-2579 (international callers call collect at 704-943-1126), or
  • By email to SEIEthicsCommittee@seic.com.

Accounting Concerns directed by employees to Ethics Alertline may be made on a confidential or anonymous basis. When voicing a concern, the reporting person should be as clear as possible concerning the exact nature of the concern and should provide as much specific information as possible, including names, dates, places, events, and an explanation of why the employee believes the matter is an Accounting Concern.

Accounting Concerns which should be reported in accordance with these procedures include, without limitation, the following:

  • fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company
  • fraud or deliberate error in the recording and maintaining of financial records of the Company;
  • deficiencies in or noncompliance with the Company's internal accounting controls;
  • misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of the Company;
    • deviation from full and fair reporting of the Company's financial condition; or
    • any violation of SEI's Code of Ethics for Senior Financial Officers by the persons subject to that Code of Ethics.
    4. Treatment of Reports Concerning Suspected Code Violations and Accounting Concerns.
    The General Counsel shall cause to be maintained a log of all reports of Suspected Code Violations and Accounting Concerns, tracking their receipt investigation and resolution.
  • Accounting Concerns. All reports regarding Accounting Concerns shall be forwarded for review to the Director of Internal Audit. Reports relating to Accounting Concerns will be reviewed under Audit Committee direction and oversight by the Director of Internal Audit, the General Counsel or such other persons as the Audit Committee determines to be appropriate. At each meeting of the Audit Committee, the Director of Internal Audit will review with the Committee a summary of the current status of reported Accounting Concerns. Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee, which corrective action may include disciplinary action, up to and including discharge.
  • Suspected Code Violations. All reports regarding Suspected Code Violations shall be reviewed by the Compliance Officers, who may refer the matter to an ethics committee comprised of SEI employees for consideration and investigation as appropriate. The resolution of any Suspected Code Violation may involve corrective action and disciplinary action, up to and including discharge. The General Counsel will periodically review with the Board of Directors a summary of the current status of reported Suspected Code Violations which involve executive officers of the Company or which are otherwise material to the Company.

Suspected Code Violations and Accounting Concerns which are reported pursuant to these procedures will be investigated and addressed promptly and will be treated confidentially to the extent possible, consistent with the need to conduct an adequate review. Records relating to complaints received pursuant to these procedures and related investigatory records will generally be retained for a period of five years following the conclusion of the investigation. Such records may be kept electronically.

5. Non-Retaliation Policy

SEI prohibits any form of retaliation against employees who, for lawful purposes, makes a complaint regarding a Suspected Ethics Violation. SEI also prohibits any form of retaliation against employees who provide information, cause information to be provided, or assist in an investigation conducted by the Company or any governmental body, regarding a possible violation of any law or regulation relating to fraud or any rule or regulation of the United States Securities and Exchange Commission, or who file, cause to be filed, or assist, participate or give testimony in any proceeding relating to an alleged violation of any such law, rule or regulation.

All managers are responsible for ensuring adherence to this non-retaliation policy. In addition, each manager is responsible for communicating this policy to employees under his or her supervision and for supporting programs and practices designed to develop understanding of, commitment to and compliance with this policy. In the event that any supervisor or manager believes that a violation of this policy has occurred or receives a report of a violation, he or she must immediately contact the Director of Human Resources, the General Counsel, the Chief Financial Officer, or the Chief Executive Officer.

If an employee believes that he or she has been retaliated against (including threatened or harassed) in violation of this policy, he or she should immediately report it to the Director of Human Resources, the Director of Internal Audit, the General Counsel, the Chief Financial Officer or the Chief Executive Officer or the Ethics Hotline. Once an employee reports retaliation prohibited by this policy, SEI will promptly investigate the matter. The investigation will be handled as discreetly as reasonably possible, allowing for a fair investigation and any necessary corrective action. Appropriate corrective action will be taken whenever a violation of this policy is determined to have occurred. Depending on the nature of the violation, the offending individual may be subject to disciplinary action up to and including termination. In addition, anyone who interferes with an investigation, or provides information in an investigation that the individual knows to be untrue or inaccurate, will be subject to disciplinary action, up to and including termination of employment. Retaliation against employees who in good faith file a complaint or participate in an investigation is strictly prohibited.

Rev. Date: 4/16/04