Whistleblowing, complaints, and non-retaliation.

SEI is committed to conducting its business activities with integrity. We believe that personal accountability is the foundation of ethical conduct and encourage Employees to speak up about any potential wrongdoing. Employees who observe, learn of, or in good faith, suspect a violation of the Code should immediately report the matter using a method outlined below. A reportable concern could also relate to a breach of rules, policies and procedures, or harmful behavior. As described below, SEI strictly prohibits retaliation of any kind against Employees who speak up about any suspected or potential violation or wrongdoing. Employees should immediately report any suspected acts of retaliation.

Raising concerns and speaking up.

An Employee may escalate concerns to their manager, any member of senior management, a member of the Legal and Compliance teams, or Workforce Development (Human Resources). Other reporting options include:

• The Head of Internal Audit at SEI for accounting, internal accounting controls, or auditing matters
• The General Counsel of SEI Investments Company
• By email to SEIEthicsCommittee@seic.com

SEI has also contracted a third-party vendor to provide confidential reporting available in multiple languages, 24 hours a day, and seven days a week with the option to remain anonymous. Phone calls are not recorded. 

Procedure for reporting code violations.

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

• By telephone
  • U.S. and Canada: 1-877-705-2579
  • Hong Kong: 800-906-553
  • India: 022-5097-2653
  • Ireland: 1800-443-388
  • Luxembourg: 800-24-997
  • South Africa: 087-195-1003
  • Switzerland: 0800-121-155
  • United Kingdom and Northern Ireland: 0800-066-8826
• Online at www.SEIC.EthicsPoint.com
• By email to SEIEthicsCommittee@seic.com

When making a report, Employees should provide as much specific information as possible, including names, dates, places, events, witnesses, and an explanation of why they believe the incident is a potential violation. If using our third-party vendor to make a report, the report will be provided to the relevant SEI personnel, who will coordinate investigations into alleged violations and will elevate allegations as necessary. All reports and related investigations are treated as confidentially as possible, consistent with the need to investigate and address the matter, and subject to applicable laws and regulations. However, Employees should understand that if they do choose to remain anonymous, SEI may be unable to obtain additional information needed to investigate or address their concern. 

Treatment of reports.

Any accounting, internal accounting controls, or auditing matters will be forwarded to the Head of Internal Audit and the Audit Committee for review. Other reports, depending on the matter’s nature, will be forwarded to appropriate SEI personnel, in accordance with SEI policies and procedures. Suspected violations or wrongdoings that 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. Violations or other wrongdoings may result in disciplinary action up to and including termination of employment. The General Counsel may report certain concerns to SEI’s Board of Directors, including those involving executive officers of SEI or which otherwise may be material to SEI. The General Counsel shall maintain, or instruct appropriate personnel to maintain, records relating to concerns received pursuant to these procedures and related investigatory records consistent with applicable record retention requirements. Such records may be kept electronically.

Non-retaliation.

SEI prohibits any form of retaliation against Employees who, for lawful purposes, report a concern regarding a suspected violation or wrongdoing. SEI also prohibits any form of retaliation against Employees who provide information, cause information to be provided, or assist in an investigation conducted by SEI or any governmental body, regarding a possible violation of any law, regulation, or policy relating to fraud 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, regulation, or policy. 

All managers are responsible for promoting adherence to this Code. In addition, each manager is responsible for supporting programs and practices designed to develop understanding of, commitment to, and compliance with this Code. In the event that any manager believes that a violation of this Code has occurred or receives a report of a violation, they must immediately contact the Head of Workforce Development, the General Counsel, the Chief Financial Officer, or the Chief Executive Officer. 

If an Employee believes that they have been retaliated against (including threatened or harassed) in violation of this Code, the Employee should immediately report it to the Head of Workforce Development, the Director of Internal Audit, the General Counsel, the Chief Financial Officer, or the Chief Executive Officer, or online or by phone. Once an Employee reports suspected retaliation, SEI will promptly investigate the matter. The investigation will be handled as discreetly as reasonably possible. Appropriate corrective action will be taken whenever a violation of this Code 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, provides information in an investigation that the individual knows to be untrue or inaccurate, or fails to report concerns or share material information will be subject to disciplinary action, up to and including termination of employment. 

SEI maintains a list of the related supplemental policies included in the appendix. Employees should feel free to direct questions concerning this Code to any member of the Legal and Compliance team.