CODE OF CONDUCT “ Our reputation, our brand, and the trust of our stakeholders are irreplaceable assets we all must protect.” Dear Colleagues, An important part of our job is to read and understand the Code and be familiar with Thank you for taking the time to review our Code resources for our questions or concerns. While our of Conduct. Code may not answer every question, it contains guidance and information about how to learn I am proud to lead this Company, knowing that we more. Speaking up is the Western Union way. I better the lives of our customers around the world encourage anyone with questions or concerns to every day. We operate in more than 200 countries speak up. and territories and our customers rely on us to help them succeed. The key to our growth is working together with integrity and succeeding in the right way. Western Union has a rich and diverse history. We I appreciate all you do to promote our shared have thrived for more than 167 years because values and adhere to our Code. Our Code is the of our determination to meet the needs of our cornerstone of our success. customers and evolve our way of working. Sincerely, Each of us has a responsibility to act ethically and with integrity. We all have a role in making sure our business is conducted in the right way and that we comply with our policies, our Code of Conduct, and the law. Our Code is the foundation for how we work, a statement of our principles, Hikmet Ersek and a guide for navigating issues and getting help. President and Chief Executive Officer Western Union ❘ Our Code Of Conduct i TABLE OF CONTENTS OUR SHARED VALUES 1 HOW WE WORK WITH OUR COMMUNITIES 27 INTRODUCTION 2 We Work with Trusted Agents, Our Responsibilities 4 Suppliers, and Third Parties 28 Manager Responsibilities 5 We Do Not Make or Allow Bribes 30 Asking Questions and Reporting Concerns 5 We Give and Receive Reasonable Gifts and Entertainment 31 The Ethics Helpline 6 Giving Gifts and Entertainment 31 Investigations 6 Receiving Gifts and Entertainment 32 No Retaliation is Allowed 7 We Watch for Signs of Money Laundering and Financing of Terrorism 33 HOW WE TREAT EACH OTHER 8 We Comply with Economic Sanctions We Value Respectful Treatment 9 Rules and Regulations 34 We Do Not Discriminate 10 We Engage in Political We Do Not Harass 11 Activities Appropriately 34 We Respect Each Other’s Privacy 12 We Cooperate with Government Requests 34 We Work Safely 13 We Compete Fairly 35 We Avoid Conflicts of Interest 13 We Value Human Rights 36 We Value the Environment 36 HOW WE TREAT OUR CUSTOMERS 15 The Western Union Foundation 36 We Treat Customers with Integrity 16 We Respect Customer Privacy 17 RESOURCES FOR ASKING QUESTIONS AND OUR USE OF PROPERTY 18 REPORTING CONCERNS 37 We Use Company Property Appropriately 19 We Respect Confidential Information and Intellectual Property 20 We Do Not Engage in Insider Trading and Stock “Tipping” 21 We Keep Appropriate Records 22 We Collect Competitive Information Lawfully 23 Our Communications with the Community 24 We Use Social Media Responsibly 25 We All Have a Role in Data Security 26 Western Union ❘ Our Code Of Conduct ii “Our shared values, to be PURPOSE DRIVEN, GLOBALLY MINDED, TRUSTWORTHY AND RESPECTFUL, are reflected in how we work.“ Western Union ❘ Our Code Of Conduct 1 INTRODUCTION Western Union ❘ Our Code Of Conduct 2 Tower Bridge - London, United Kingdom INTRODUCTION Our shared values are to be Purpose Driven, We always ask ourselves: Globally Minded, and Trustworthy and Respectful. These values are reflected in how we work. Our Does this action harm the Company, Code of Conduct (Code) provides guidance for how our customers, our shareholders, or the we conduct business for our Company and our community? customers. Our Code isn’t just a statement for us to refer to on occasion; it speaks to how we act at all Would we want this action to be known times. by others? Our Company has a long and trusted history Would we be comfortable explaining and plays a key role every day in the lives of our this action to the authorities or to our customers in over 200 countries and territories. No families? matter the situation or difficulty we face, we trust and respect each other, our customers, this Code, and the law. Western Union ❘ Our Code Of Conduct 3 OUR RESPONSIBILITIES Our Code applies to every employee of the Company. We do not grant waivers under any circumstances. This includes all employees of The Western Union Company and its affiliates and subsidiaries (Western Union or the Company). References to “we”, “us”, or “our” in the Code include each of us as employees of the Company. The Code describes how we work, both as individuals and together as an organization. We all follow our Code, our policies, and the law. We follow the highest standards, and in cases where a law or policy is unclear, we ask for help. There are multiple resources available to provide help, including our managers, Human Resources, Gediminas’ Tower - Vilnius, Lithuania the Ethics Office, and the Ethics Helpline. Resources for Asking Questions and Reporting Concerns Complying with our Code is a condition of employment at Western Union. Our Code applies to all Western Union employees, regardless of level or position. Failure to follow the standards of the Code or failure to report a known violation may lead to disciplinary action, up to termination of employment. It is our responsibility to immediately report any information about a violation or a potential “ We are respected and trusted violation of the law to the Ethics Helpline or the around the world. We earn this Litigation group in the General Counsel’s Office.* If there are questions about how the Code applies, trust every day one customer contact the Ethics Office, GeneralCounsel’s Office, at a time.” or the resources section of the Code. * subject to applicable local law Western Union ❘ Our Code Of Conduct 4 “ No business goal or need MANAGER RESPONSIBILITIES should ever come before Our pursuit of business success must support our following our Code.” shared values. Managers set an example for all team members in the way they apply our Code and model our values. No business goal or need should ever come before following our Code, acting professionally, and showing trust and respect to our fellow employees, customers, third parties, and our community. ASKING QUESTIONS AND Managers have specific responsibilities. Following are some examples: REPORTING CONCERNS Managers must always communicate our values Purpose Driven employees ask questions and and promote a culture of trust and respect raise concerns. We speak up if we believe there are possible violations of our policies, our Code, Managers’ conduct must always reflect our or the law. We have several resources including values and commitment to integrity our managers, Human Resources, the Ethics Office, and the Ethics Helpline. Managers must be prepared to advise and train employees on the contents of this Code Resources for Asking Questions and and any policies and procedures that apply to Reporting Concerns employees’ jobs The Company takes employee questions and Managers must create and maintain a culture concerns seriously. The Company is committed to of open discussion where employees feel free answering questions, reviewing reports, and when to ask questions and express their concerns appropriate, conducting investigations. While keeping quiet or looking away from a problem Managers must escalate questions or concerns may seem easier, we must never ignore any issue when appropriate that needs attention. Managers must make sure appropriate actions It is our responsibility to immediately report are taken to address concerns that are raised any information about a violation or a potential violation of the law to the Ethics Helpline or the Managers must support the Company’s Litigation group in the General Counsel’s Office.* prohibition of retaliation Managers must focus on resolving issues and never punish those who raise concerns in good faith * subject to applicable local law Western Union ❘ Our Code Of Conduct 5 THE ETHICS HELPLINE INVESTIGATIONS The Ethics Helpline is a secure and confidential When issues are raised, the Company determines way for us to report issues and concerns or seek whether an investigation is appropriate. The advice about ethics issues. Reports may also be Company makes reasonable efforts to preserve made anonymously from most countries. The the confidentiality of investigations, including the Ethics Helpline is administered by an independent identity of the person who reported the issue.* third-party vendor. Our responsibility as employees during an Concerns reported on the Ethics Helpline are investigation is to cooperate fully and provide forwarded to the Ethics Office for review and truthful and complete information. We may investigation where appropriate. also be required to maintain confidentiality to protect the integrity of the investigation. We Questions or concerns may be submitted online must not interfere with an investigation, attempt at wuethicshelpline.com. To make reports by to influence another person’s participation, or telephone, refer to the international toll-free calling suggest potential consequences for providing instructions available at wuethicshelpline.com. information. Based on the outcome of an investigation, employees who have engaged in improper conduct may face discipline up to employment termination. Joan’s manager asked her to offer products to customers she feels might violate Company policies or the law. Joan hasn’t spoken up because she Q A fears her manager will get upset and she may be subject to retaliation. & What should she do? If Joan fears retaliation, she should contact her manager’s manager, Human Resources, or the Ethics Helpline and report her concerns.