Summary

Telling the Truth

Public Disclosures and Code Compliance

Loyalty

Making the Right Choices

Leadership

Ethical Relationships

Questions & Answers

Pride in Our Workplace

Competing Fairly

Public Disclosures

Gateway has a responsibility to communicate effectively with shareholders so that they are provided with full and accurate material information about Gateway’s financial condition and results of operations pursuant to applicable laws and regulations. Accordingly, our reports and documents filed with or submitted to the Securities and Exchange Commission and our other public communications shall include full, fair, accurate, timely and understandable disclosures in accordance with applicable laws and regulations.

Compliance with this Code

All employees, directors and officers are required to comply with all of the provisions of this Code. The Code will be strictly enforced throughout the company and violations will be dealt with immediately. Those who violate the Code will be subject to disciplinary action, up to and including immediate termination. Violations of the Code that involve illegal behavior will be reported to the appropriate authorities. Employees are strongly encouraged to report immediately all evidence of activity by a Gateway employee that may constitute corporate or securities fraud; violations of state or federal law, including federal securities laws; complaints about Gateway's accounting, auditing, internal auditing controls or securities disclosure practices and substantial or specific danger to employee or public health and safety. In reporting such concerns, employees are encouraged to include specific information as possible concerning the events and the basis for your concern. Reports may be made anonymously in writing, on the web or through the Ethics Help Line.

Situations which may involve a violation of ethics, laws, accounting rules or this Code may not always be clear and may require difficult judgment. Employees should report any concerns or questions about potential violations of laws, rules, regulations, accounting, internal accounting controls, internal auditing matters, or this Code to the Ethics Help Line or to the Gateway Law Department. Reports may be made anonymously. An anonymous report should provide enough information about the incident or situation to allow the company (or the Audit Committee of the Board of Directors for matters concerning accounting, internal accounting, or internal auditing matters) to investigate properly.

Gateway encourages all employees to report any suspected violations promptly and will thoroughly investigate such reports. Gateway will not tolerate any kind of retaliation for reports or complaints regarding misconduct that were made in good faith. Open communication of issues and concerns by all employees without fear of retribution or retaliation is vital to the successful implementation of this Code.

Gateway recognizes the need for this Code to be applied equally to everyone it covers. The Gateway Ethics Council, which is chaired by Gateway’s General Counsel, has primary authority and responsibility for the enforcement of this Code. Gateway will devote the necessary resources to enable the Ethics Council to establish such procedures as may be reasonably necessary to create a culture of accountability and facilitate compliance with the Code. Any waivers of the provisions of this Code for Gateway’s executive officers or board members may only be granted by the Board of Directors and will be promptly disclosed to Gateway’s shareholders. Any waivers of this Code for other employees may only be granted by the Ethics Council. Requests for waivers may be directed to the Ethics Help Line.