Information Security & Data Privacy

The following email was sent to Wells Fargo Policy Works (policyworks@wellsfargo.com) in 2007:

"Currently, Wells Fargo has approximately 363 inventoried yet unencrypted laptop computers on 44 LAN servers. Is this is a critical security vulnerability?"

Wells Fargo "addressed" this potential breach of information security and consumer data privacy with the following dismissive response:

"Please keep in mind that we know that there are unencrypted laptops / desktops out there, for a variety of reasons."

I am sure Wells Fargo customers will be relieved to know their confidential data (including social security numbers, Wells Fargo account numbers, addresses, income, and other information) may be stored on hundreds of unencrypted laptop computers and over 4,000 unencrypted desktop computers.

Potential Conflict of Interest or Violation of Code of Ethics?

The following email was sent to policyworks@wellsfargo.com. Wells Fargo also did not deem this issue worthy of a reply:

I assume Wells Fargo pre-approved Mr. Kovacevich's nomination and election to the Cisco board of directors in January 2005, as required by the Wells Fargo Code of Ethics. However, this same code stipulates all team members , "must avoid conflicts of interests or the appearance of conflicts in your personal and business activities. In many cases, the appearance of a conflict may be just as damaging to Wells Fargo and its reputation as an actual conflict of interest."

Based on publicly available information, there appear to be several conflicts of interest between Mr. Kovacevich's personal business pursuits and the corporate financial objectives and reputation of the Wells Fargo Enterprise. To wit:

1.) Mr. Richard Kovacevich was elected a director at Cisco in January 2005 and he now currently holds 30,629 common stock shares valued at $798,804.31. SEC Form 4 dated 11-17-06 also indicates Mr. Kovacevich has an option to buy 15,000 Cisco common stock shares at $26.60. Unfortunately, the public at large does not know whether these shares and options have trade restrictions or whether Mr. Kovacevich is prohibited from buying or selling Cisco stock during his tenure as a Cisco director. This appearance of a conflict of interest may have already directly or indirectly damaged the Wells Fargo Enterprise and its shareholders.

2.) As a recent prospectus indicates, Cisco and Wells Fargo & Company share financial interests: Wells Fargo Securities LLC acts as an underwriter and co-manager for notes issued by Cisco (these notes are valued at $142,498,000) and Cisco may pay fees to Wells Fargo for commercial banking services. A recent Cisco prospectus quite correctly acknowledges Mr. Kovacevich is both a Cisco director and the Chairman and Chief Executive Officer of Wells Fargo & Company. However, I have been unable to uncover any Wells Fargo communications or publications that identify and properly address the financial conflict of interest that appears to exist between the Enterprise, one of its business partners or customers (Cisco), and a Wells Fargo team member and company officer who has been personally and amply compensated for his services as a Cisco director.

3.) A document (StrategicPartnerUpdateCISCO_PEAP.doc) published on the Wells Fargo intranet stresses Cisco's relevance as a "strategic partner" and "leading vendor" of the Enterprise. Once again, I have been unable to uncover any documents that properly disclose this potential conflict of interest caused by an Enterprise officer who can influence or approve purchasing decisions and who at the same time, has personally profited from a relationship with one of the Enterprises' leading vendors.

As a Wells Fargo shareholder and Team Member, I look forward to a detailed response to these concerns.

Does Wells Fargo CEO and Wife Conduct Personal Business on Company Premises? Potential Conflict of Interest?

Alarmed the Chairman, President and CEO of Wells Fargo and his wife (who is not an employee of the firm) may be habitually violating company policies by conducting their personal business on company premises, I sent the following email to policyworks@wellsfargo.com in early 2007. Wells Fargo did not deem my concerns worthy of a reply:

Over the years, Mr. Richard Marco Kovacevich, Wells Fargo Chairman, President & CEO and his wife Mrs. Mary Jo Kovacevich, have made a number of individual contributions to state and national political campaigns and committees as reported to the Federal Election Commission. No one can dispute or deny these private citizens have the right to join the democratic process by making these donations. However, a conflict of interest appears to exist because these individual contributors have reported their mailing address to be the same as that of Wells Fargo's Corporate Headquarters (420 Montgomery St., Floor 12, San Francisco, CA 94104).

Outside observers may accordingly arrive at one or more of the following conclusions:

1.) Mr. & Mrs. Kovacevich have established a personal residence on the 12th floor at 420 Montgomery St.

2.) Wells Fargo condones and permits all of its Team Members and their immediate family members to use a Wells Fargo property address for their own personal and non-work related activities. This is in clear violation of company policies as detailed in the Team Member handbook at http://teamworks.wellsfargo.com/handbook/HB_Online.pdf.

3.) The Wells Fargo enterprise, Mr. Kovacevich and Mrs. Kovacevich all actively and publicly support the very same political candidates and committees. This is the most serious assumption the public might make because as you know, corporations are not legally permitted to make political contributions.

To address any concerns the public and Wells Fargo Team Members may have regarding this potential conflict of interest, I suggest Mr. & Mrs. Kovacevich ensure that amended forms indicating their proper mailing address are submitted to the FEC posthaste. If the couple understandably is concerned about keeping their home address private, they might consider renting a post-office mailbox.

Wells Fargo's Image

E-mail received on March 9, 2008:

Wells Fargo does not care for the little guy !!! I give up on them!!!!! :(

As always, your comments are welcome and appreciated.