This Code applies to all directors of Northern Trust Corporation, all directors of
subsidiaries of Northern Trust Corporation and all officers and employees of Northern Trust worldwide. More detailed Northern Trust policies and procedures that apply to all employees or certain groups are set forth in other documents. While these other policies and procedures are not part of this Code, everyone is expected to conduct himself or herself consistently with this Code and all other policies that address specific legal requirements imposed by laws and regulations in countries in which Northern Trust does business and other corporate standards. We expect everyone covered by this Code to adhere to our overriding commitment to the highest standards of integrity, ethics, honesty and respect for all persons with whom we deal, within and outside Northern Trust. This Code helps us enhance our relationships with our clients, each other, and all of the people that contribute to Northern Trust’s success. Compliance with the Code, other Northern Trust policies, procedures and standards, and the laws and regulations referred to in those documents is a vital part of that commitment.
Frederick H. Waddell
Chairman and Chief Executive Officer