USAA Code of Business
Ethics and Conduct
Inspiring Trust
220510-0715
Letter From Stuart
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
Letter From Stuart
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Our Core Values of Service, Loyalty,
Honesty, and Integrity reflect the
values of the military and
our membership and form
the foundation on
which we perform
our work
and conduct
ourselves.
Table of Contents
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I. Introduction: Our Code and USAA . . . . . . . . . . . . . . . . . . . . . 5
IV. Honesty: Our Commitment to Our Stakeholders . . . . . . . . . . 11
i. Why We Have a Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
i. Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
ii. Who is Required to Follow the Code . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
ii. Entertainment, Favors and Gifts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
iii.Additional Responsibilities for Managers . . . . . . . . . . . . . . . . . . . . . . 6
iii.Confidential Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
II. Integrity: Our Commitment to Doing the Right Thing . . . . . . . 7
iv. Protecting Company Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
i. Seeking Advice and Reporting Concerns . . . . . . . . . . . . . . . . . . . . . . 7
v. Social Media . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
ii. Office of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
V. Loyalty: Our Commitment to the Marketplace . . . . . . . . . . . . 15
iii.Ethics Matters Helpline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
i. Financial Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
iv. Whistleblower Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
ii. Fair Interactions with our Members and Third Party Partners . . . . 16
v. Non-Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
iii.Representing USAA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
vi.Investigation of Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
iv. Insider Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
vii.Disciplinary Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
v. Anti-Bribery/Anti-Corruption Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
III.Service: Our Commitment to Each Other . . . . . . . . . . . . . . . . 9
vi.Competition Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
i. Discrimination and Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
VI.Go/Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
ii. Building Strong Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
i. Office of Ethics: Contact Information . . . . . . . . . . . . . . . . . . . . . . . . 18
iii.Charitable and Volunteer Activities . . . . . . . . . . . . . . . . . . . . . . . . . . 10
ii. Ethics Quick Test . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Table of Contents
Introduction: Our Code and USAA
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A
t USAA, we are dedicated to the financial well-being of our members
and their families. We do this by upholding the highest standards and
ensuring that our corporate business activities and individual employee
conduct reflects good judgment, common sense, and is consistent with
our core values of Service, Loyalty, Honesty and Integrity. In doing this,
we continue to foster a culture of trust with our members, coworkers,
and community.
Why We Have a Code
Our Code and our values provide a foundation for protecting USAA’s
reputation, which is built on a legacy of unwavering commitment to
ethical behavior and serving the needs of our members. However, our
reputation and the privilege of serving our members can be easily lost.
Our Code guides employees in adhering to the highest standards of
ethics and professional conduct in day-to-day
business operations, as well as in interactions
with our stakeholders, including members,
employees, and the communities, governments
and businesses with which we are
affiliated.
While our Code provides general
guidance, it does not cover
every circumstance you may
encounter. If you are ever unsure
of the proper course of action, seek
guidance before acting. To do so,
contact your manager or any of
the resources listed on page 7 of
this Code.
Introduction
Who is Required to Follow the Code
As USAA employees, we each have a responsibility to:
• Honor our core values and act with honesty and integrity.
• Comply with all applicable laws and regulations in performing
our duties.
• Be familiar with the Code, follow it and seek help when you
have a question.
• Report ethics violations and misconduct in accordance
with USAA’s core values and cooperate fully with USAA
investigations.
• Encourage other employees to comply with this Code by your
words and actions.
• Complete an annual certification of compliance to our Code.
In addition, we expect our suppliers and contractors – and others who do
business on our behalf – to conduct USAA-related business activities in
compliance with the standards set forth in our Code, as well as any other
applicable laws and regulations.
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Additional Responsibilities for Managers
As a USAA Manager, Director, or member of Executive Management,
you are expected to:
• Model ethical conduct and encourage other employees to
comply with this Code by your words and actions.
• Ensure employees understand the behavior expected of them,
and that they comply with our Code, policies, procedures, and
applicable laws and regulations.
• Promote an environment where employees feel comfortable
asking questions, seeking advice and reporting concerns.
• Refer matters you are unable to resolve to the appropriate
resource.
• Ensure either you or the employee reports violations of our
Code to the Office of Ethics or another resource listed on page
7 of this Code.
# 1 Yesterday, my supervisor asked me to do something that
violates our Code. I’m not sure what to do.
This is a difficult situation for any employee. You have a
responsibility to comply with our Code, even if your supervisor
asks you to do otherwise. No one – not even your supervisor – has the authority to
tell you to do something illegal or unethical. Talk to someone else in management
or contact your Employee Relations Representative, the Ethics Office or report your
concern anonymously thorough the Ethics Matters Helpline.
Introduction
Integrity: Our Commitment to Doing the Right Thing
Seeking Advice and Reporting Concerns
Office of Ethics
We understand that sometimes the choices we face are difficult, and
many decisions seem to fall into gray areas. If you face an ethical
dilemma, ask yourself the following questions:
• Is the action legal?
• Does it feel like it is the right thing to do?
• Is it consistent with USAA’s core values and policies?
• Would I feel comfortable with family members or friends reading
about it on the Internet?
• Would I feel comfortable allowing the situation to continue?
• Would I be treating others as I would want to be treated?
The Office of Ethics is responsible for administering the Ethics Program.
To contact the Office of Ethics, you can:
If you answer “No” to any of these questions or you’re not sure, seek
guidance from your manager, the Office of Ethics, a member of the
Employee Relations team, an Ethics Facilitator, or anonymously through
the Ethics Matters Helpline.
Speak up. Ask Questions. Then do the right thing.
USAA only hires the best employees and we trust
your judgment. If something doesn’t feel
or seem right, your intuition is probably
telling you to talk with your manager. They
are often in the best position to understand
the situation you face. If your manager is
unable to help or if you are uncomfortable
discussing your concern with them, you
have several resources available to you. To
ask a question or share a concern, contact
any of the following: the Office of Ethics, a
member of the Employee Relations team, an
Ethics Facilitator, or anonymously through
the Ethics Matters Helpline.
Integrity
• Contact a staff member of the Office of Ethics
• E-mail ethics@usaa.com
• Mail a letter to:
USAA Office of Ethics
P.O. BOX 692292
San Antonio, TX 78269-2292
• Contact the Ethics Matters Helpline:
Phone
- U.S. – 855-208-8583
- Germany – 0800-225-5288, then 855-208-8583
- United Kingdom:
- (C&W) 0-500-89-0011, then 855-208-8583
- (British Telecom) 0-800-89-0011, then 855-208-8583
Web portal: www.usaaethicsmatters.ethicspoint.com
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Ethics Matters Helpline
The Ethics Matters Helpline is your helpline to ask ethics related questions
or confidentially raise genuine concerns about a potential violation of
our Code or other policies. It is available 24 hours a day, seven days a
week and is a toll-free call. If necessary, translation services are available.
If you prefer an alternative, you may report your concern through the
Helpline’s web portal at www.usaaethicsmatters.ethicspoint.com.
Although we encourage you to identify yourself to assist us in effectively
addressing your concern, you may choose to remain anonymous. To
ensure your anonymity, the Helpline is operated by a third party and does
not have caller ID or any other device that can trace the number from
which you are calling, or the computer from which you are accessing the
portal. You will be given a unique identification code and password to
check back for updates or follow up with an Ethics Advisor, even if you
choose to remain anonymous. Please remember that detailed information
will be required to conduct investigations of wrongdoing so we ask you to
be as specific as possible when making a report.
to seek guidance or report concerns without fear of retaliation, secure in the
knowledge that you did the right thing in coming forward.
If you believe you or someone else has experienced retaliation, you should contact
Employee Relations, the Employee Experience Office, or the Office of Ethics
immediately. Anyone engaged in retaliation against an employee for any reason
will be subject to disciplinary action, up to and including termination. For more
information, see our Open Door Policy.
Investigation of Reports
USAA is committed to taking all reports seriously. All issues are documented and,
if appropriate, investigated. Each of us has a responsibility to cooperate fully with
all USAA investigations. Appropriate action is taken based on the investigation
findings. If you would like more information, please refer to the Ethics Reporting
Process on the Ethics section of Connect.
Disciplinary Action
Anyone who violates our Code – or who knowingly permits another to do so – may
be subject to disciplinary action, up to and including termination.
Whistleblower Procedures
USAA has adopted whistleblower procedures for the receipt, retention
and treatment of complaints received by USAA regarding accounting,
internal controls, or auditing matters related to one or more USAA
Investment Fund(s). For more information please contact the Chief
Ethics Officer or General Counsel. If you would like to report a concern
anonymously, please contact the Ethics Matters Helpline.
Non-Retaliation
At USAA, we do not tolerate any form of retaliation against anyone
who makes a good faith report of potential misconduct or helps with
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
# 2 I observed a situation that I suspect violates our
Code or policies, but I’m not certain. Should I report
the matter?
Yes. You are not only expected, but required to report
any known or suspected violations right away. You will not experience
retaliation for making a report in good faith, regardless of whether your
report is supported or validated. Reporting in good faith doesn’t mean that
you have to be right. It simply means that you are making an honest and
complete report.
Service: Our Commitment to Each Other
W
e build trusting relationships through our commitment to treating
our fellow employees, members, suppliers, contractors and business
partners with dignity and respect. We strive to avoid engaging in any
activity or conduct – on or off the job – that could harm USAA or distract
us from serving the needs of our members or the company.
Discrimination and Harassment
We are committed to providing employees with a work environment
free of discrimination and harassment. If you are subject to or observe
harassment or discrimination, you are obligated to report the issue to
your manager, Employee Relations, Diversity, the Office of Ethics, the
Employee Experience Office, or the Ethics Matters Helpline. Please see
our Equal Employment Opportunity, Affirmative Action, and Harassment
Prevention Policy for more information.
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#3 How do I know if I’m being harassed?
At USAA, we prohibit harassment, including jokes,
gestures, visual displays, or other inappropriate
comments or actions based on legally protected
characteristics. Non-USAA workers, vendors, members, and anyone
else conducting business with USAA are also prohibited from
engaging in such behavior. If you feel that you may have experienced
or witnessed harassment, you should immediately bring your concern
to one or more resources that are available to you, including your
manager, Employee Relations, Diversity, the Employee Experience
Office, or the Office of Ethics. If you are concerned about making
a report, you may make an anonymous report through the Ethics
Matters Helpline either by phone or online. Keep in mind you will be
protected from retaliation for making a good faith report.
#4 My co-worker sometimes forwards emails
containing offensive material to a few
people on our team. Is this ok, since only a
few people receive the messages and we’re
all friends?
No. Even though the emails are only sent to a small group, any
email containing offensive content is inappropriate and will not be
tolerated at USAA. Such emails also violate USAA’s Acceptable Use of
Internet and Electronic Communication Policy and may be considered
harassment. If you receive such an email, you should immediately
report the matter to your manager or any of the resources listed on
page 7 of this Code.
Service
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Building Strong Communities
Charitable and Volunteer Activities
USAA and its employees are dedicated to serving our members as well as
our communities. Together we give back in ways that provide essential
services for families in need, help students succeed, and serve military
and veterans groups. By doing so, we help change lives for the better.
USAA encourages you to get involved and make a difference in your local
community. You may participate in community activities as a private citizen,
using your own time and money for causes you care about (such as your church,
your children’s school, or the non-profit agency of your choice). Make sure your
involvement in community activities is not prohibited by other USAA policies
or suggestive of anything improper. Do not use, without specific authorization,
USAA funds or resources to help promote any charitable cause, political party or
candidate. Please remember that all volunteer activities take place on your own
personal time.
You may also participate in USAA volunteer programs that promote team-building
and a significant community impact. In addition, USAA provides opportunities for
employees to come together and contribute financially to help address needs
within our local communities through events such as the Bowlathon, the United Way
Campaign, and Season of Sharing.
Service
Honesty: Our Commitment to our Stakeholders
Conflicts of Interest
Conflicts of interest occur when our personal interests interfere with or
influence – or could appear to interfere with or influence – our ability to
act in the best interests of USAA and its members.
We must strive to conduct ourselves in a manner that avoids conflicts
of interest with employees, members and suppliers – real or perceived.
Conflicts can occur when accepting gifts and gratuities from members or
suppliers, obtaining outside employment, or engaging in other external
activities that conflict with your employment at USAA. Be alert to your
friends’ and relatives’ activities and ensure that they do not create a
conflict of interest between you and USAA. You and your immediate
relatives may not improperly or personally benefit due to your position
with USAA.
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• Refrain from actions that might impair your independent judgment
or provide an unfair advantage to a supplier, contractor or member.
• Do not accept for yourself a business opportunity in which USAA
might be interested or pass it along to another person.
If you face an actual or potential conflict of interest situation, whether
due to your actions or those of someone else’s, you have a responsibility
to disclose it to the Office of Ethics by filling out a Conflict of Interest
Disclosure Form. For further details on what types of activities should
be avoided, see our Business Ethics and Conflicts of Interest Policy. If
you have a question about a conflict of interest situation or if there are
any doubts as to whether a situation involves a conflict, speak to your
manager or contact the Office of Ethics for further guidance.
#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.
To avoid conflicts of interest, ensure that you:
• Make business decisions in the best interest of USAA and our
members, regardless of your personal interests.
• Interact with our suppliers, contractors and members fairly and
impartially.
• Avoid any investment, interest, association or activity that may
cause others to doubt USAA’s fairness or integrity, or that may
interfere with your ability to perform your job duties objectively
and effectively.
Honesty
#6 My spouse was offered a job with one of our
suppliers. Is this a problem?
Maybe. If you are in a position to influence
decisions related to purchases made from
the supplier (your spouse’s employer) there could be a problem.
You should disclose the matter to your manager immediately and
complete a Conflict of Interest Disclosure Form.
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Entertainment, Favors and Gifts
We recognize accepting and giving modest gifts and entertainment
could be a part of normal business courtesy and are not always
prohibited. Gifts may be a part of building and maintaining
relationships with prospective members, suppliers, affinity
associations, and sponsors in supporting USAA’s mission. Your
business transactions with these parties must however, always
be impartial, objective and free of outside influence. Further, we
should always use good judgment and discretion to avoid even the
appearance of impropriety or obligation. Please see our Business
Ethics and Conflicts of Interest Policy for more information.
What is a “Gift”?
A gift is anything of value. It includes tangible items such as
jewelry, art, or wine, but also intangible items such as discounts,
services, loans, favors, special privileges, advantages, benefits and
rights that are not available to the general public. A “gift” also
includes vacations, lavish meals, spa packages, use of vacation
homes, tickets to sporting or music events, golf outings, vendor
familiarization trips and use of recreational facilities. Under no
circumstance should you
ever solicit a gift from
any person or
company that is
doing – or seeks
to do – business
with USAA.
Gifts may be acceptable if they are:
• Related to a clear business purpose.
• Customary in a normal business
relationship.
• Not given in an attempt to influence any
transaction affecting USAA.
• Not of excessive value ($100 or less).
• Not in the form of cash, gift cards or
alcohol.
• Not exchanged during active contract
negotiations.
• Infrequent.
Procurement, P&C Claims Services, and FINRA
(Financial Industry Regulatory Authority)associated employees have additional gift/
entertainment related guidance which may be
more restrictive. Please speak to your manager
for more details.
#7 A supplier has invited me to play a round of
golf and I believe it’s a great opportunity to
solidify our relationship and discuss future
projects between USAA and the supplier.
They offered to pay my costs (green fees, cart, lunch, etc) but
they are a bit more than $100. Can I participate?
Maybe. This request should be discussed with your manager and
the Office of Ethics. If it is determined that there is a business need
and the golf outing supports USAA’s mission, USAA will need to pay
your costs.
Honesty
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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
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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
specific guidance that may pertain to you.
#8 I like to talk about my personal life and
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
USAA is built on a relationship of trust
with our members and the public. As a
responsible company in the financial
services and insurance industries, we
are committed to business practices that
meet the highest standards of ethics and
integrity, including the management of
our financial records, company assets,
and adherence to trading, corruption and
competition laws.
Financial Integrity
Many groups – including our members, our
creditors and government entities – rely on
the accuracy of USAA’s financial records.
You have a responsibility to be accurate,
complete and honest in what you report and
record to meet regulatory requirements, as
well as in all USAA documents. This includes,
but is not limited to, accounting records,
time entry, expense reports, payroll records,
and performance evaluations.
Those of us involved in the creation of USAA
financial records may not allow anyone to:
• Make false entries or intentionally hide or disguise the nature of the entries.
• Alter or sign documents when they lack the proper authority to do so.
• Alter or falsify information with the intent to make a false or exaggerated claim in our financial records.
Any situation involving fraud or possible fraud should be reported. Please see our Enterprise Fraud Compliance Program Overview for more information.
Loyalty
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Fair Interactions with our Members and Third Party Partners
We conduct business in a way that reflects our core values of Service,
Loyalty, Honesty and Integrity. We continue this tradition of service
through our commitment to promoting open and free competition,
quality, reliability and service. Remember, although we are expected to
represent USAA’s interests, we should never do so by violating our Code
or values. If you know or suspect that a supplier or contractor is acting
unethically or not in compliance with applicable laws or regulations, you
are expected to raise your concerns with your manager and a Global
Service Delivery representative.
Representing USAA
Do not represent or give the appearance of representing USAA in outside
employment or other external activities unless you have authorization to
do so.
Insider Trading
Through your work, you may come to know information about publicly
traded companies with whom we conduct business. You must be careful
to not act upon material non-public information that you learn of during
the course of your employment with USAA. This means you cannot trade
in any type of securities or pass along inside information to anyone
expressly or by recommending the purchase or sale of a security based
upon inside information. If you need further guidance, please contact
USAA General Counsel.
Loyalty
#9
USAA received a sales pitch from one of our
suppliers about a new product they plan to
introduce to the market soon. Our supplier
has not yet released any information about
this new product to the market. While USAA decided that the
product wouldn’t be useful for our business, I think the new
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
buy stock in the supplier’s company?
No. Since you hold material information about the supplier that is
not yet available to the general public and may have an impact on
the value of the supplier’s securities, you may not buy this stock
until information about the new product is known to the public
and the market has had time to react. You should contact General
Counsel if you have additional questions or concerns.
Anti-Bribery/Anti-Corruption Laws
As a part of a global enterprise, we must abide by the anti-bribery and
anti-corruption laws in the countries in which we operate, including the
Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. In general,
the FCPA prohibits corrupt payments or bribes to all non-U.S. government
officials, political parties or political candidates for the purpose of
obtaining or keeping business or improperly influencing government
action. Included in the anti-bribery prohibition is making a corrupt
payment through a third party.
The FCPA applies to individuals as well as corporations and requires
companies to keep and maintain books and records that accurately
reflect the transactions of the corporation. Refer to the Anti-Bribery
Policy for more information.
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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
Office of Ethics
The Office of Ethics is responsible for administering the Ethics
Program. To contact the Office of Ethics, you can:
•Contact a staff member of the Office of Ethics
•E-mail ethics@usaa.com
•Mail a letter to:
USAA Office of Ethics
P.O. BOX 692292
San Antonio, TX 78269-2292
•Contact the Ethics Matters Helpline:
Phone:
- U.S. – 855-208-8583
- Germany – 0800-225-5288,
then 855-208-8583
- United Kingdom:
- (C&W) 0-500-89-0011, then 855-208-8583
- (British Telecom) 0-800-89-0011,
then 855-208-8583
Web portal: www.usaaethicsmatters.ethicspoint.com
18
If In Doubt, Use This Ethics Quick Test and Ask Yourself:
Is the action
legal?
Yes
Does it feel like
it is the right
thing to do?
No
Yes
Is it consistent
with USAA’s
Core Values and
policies?
No
Yes
3
Would I be
treating others
as I would
want to
be treated?
Yes
Would I feel
comfortable
allowing the
situation to
continue?
Would I feel
comfortable with
family members
Yes
or friends
reading about it
on the Internet?
No
No
No
No = Seek Help or Refer to the Seeking Advice
and Reporting Concerns Section on page 7
3
= Proceed Accordingly
Go/Ethics
No