WSFS Financial : Code of Business Conduct and Ethics (the “Code”)

Code of Business Conduct and Ethics (the "Code")

Organizational Functional Area:

Policy For:

EC Approved: Board

Approved: Last

Revision Date:

Department/Individual Responsible for Maintaining/Updating Policy:

WSFS Financial Corporation

Code of Business Conduct and Ethics (the "Code")

September 21, 2023

February 29, 2024

January 26, 2024

Chief Legal Officer - Legal & Chief

Human Resources Officer - Human

Resources-Administration

Table of Contents
Introduction	1
Policy Statement	1
Scope and Basic Principles	2
Reporting of Code Violations, Non-Retaliation, Confidential Submissions	3
Full, Fair, Accurate, Timely and Understandable Public Disclosures	3
Compliance with Laws and Regulations	4
Confidential and Insider Information	5
Electronic Data and Information	6
Conflicts of Interests: Personal and Financial Matters	6
Serving as a Director or Officer for an Organization other than a WSFS Company	10
Other Ethical Matters	11
Anti-Trust Policy	12
Bank Bribery Act - Gifts, Bequests and Gratuities Policy	13
Recordkeeping Requirements	17
Implementation and Administration of the Code	17
Waiver	17
Determination of Violations and Enforcement	18
Amendment	18
Affirmation	18
Terms Used Throughout the Code of Business Conduct and Ethics Policy	20
Code of Business Conduct and Ethics Affirmation Form	23

January 2024

CODE OF BUSINESS CONDUCT AND ETHICS

Introductory Note

The Code of Business Conduct and Ethics (the "Code") applies to all Associates, Directors and Advisory Board Members of WSFS Financial Corporation, Wilmington Savings Fund Society, FSB and the respective subsidiaries and affiliates of WSFS Financial Corporation and Wilmington Savings Fund Society, FSB (collectively "WSFS"). This Code includes our Gifts, Gratuities and Bequests Policy (page 13). The Code must be annually attested to by all Associates, Directors and Advisory Board Members.

When utilizing this Code, be aware that certain terms are capitalized. This means that those terms have been explicitly defined. Please see an alphabetical listing of these terms beginning on page 19 for further explanation.

Policy Statement

Values describe how an organization behaves under all circumstances. Our values are the foundation of our culture. They define us and serve as our moral compass. Our values are rooted in integrity; we do the right thing, unconditionally. We live our values every day, they nourish our culture and practiced, over time, become "the WSFS way." Our values are the fuel that ignites our virtuous cycle: when we do well, our community does well and when our community does well, we do well.

There are three fundamental values that describe our behavior.

• Service: Serving others is fundamental to our "mission" and grounds for our purpose;
• Truth: The truth is non-negotiable. The truth brings clarity to a challenging situation or sensitive matter, it guides us with confidence and conviction; and
• Respect: We value and respect each other and all we serve.

This Code sets forth rules governing the conduct of all Associates, Directors, and Advisory Board Members, and promotes the following objectives:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest;
• Commitment to equal employment opportunity and a workplace free from discrimination, harassment and retaliation, and from bullying
• Full, fair, accurate, timely, and understandable disclosure in internal reports, reports submitted to the Securities and Exchange Commission ("SEC") and to our Federal and State banking regulators, and other public communications by WSFS;
• Compliance with applicable governmental laws, rules, and regulations;
• Prompt internal reporting of Code violations, supported by our policy of requiring that suspected violations be reported and our policy of non-retaliation for those who report suspected violations; and
• Accountability for adherence to the Code including discipline up to and including termination for

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non-compliance.

Scope and Basic Principles of the Code of Business Conduct and Ethics

This Code sets out in broad terms the general principles governing the business conduct of WSFS Associates, Directors, and Advisory Board Members. However, as it is impossible to explicitly delineate every single activity that is inconsistent with WSFS' ethical standards, or to set forth rules covering all conceivable situations in which a conflict of interest may arise, this Code is not intended to be exhaustive. Rather, the Code's provisions serve as a guide for applying WSFS' basic ethical principles to a variety of situations. WSFS Associates, Directors, and Advisory Board Members, by implementing this Code and adhering to its letter and spirit, will accomplish the Code's purpose. It should be noted that this Code is in addition to, and not a replacement for, WSFS policies and procedures that address the specifics of our business, or which may impose stricter or more detailed requirements.

Upon employment with WSFS, appointment to the Board of Directors or to an Advisory Board, and on an annual basis thereafter, each individual will be required to read, acknowledge, and complete the applicable affirmation or disclosure requirements for the Code. Completed affirmations and disclosures will be maintained by the Human Resources Department. In addition to the annual affirmation and disclosure requirements, all Associates are expected to promptly report to the Chief Legal Officer and Human Resources Risk Partners all changes to any relationship or interest for which disclosure is required under the Code. Directors and Advisory Board Members are expected to report such changes to the Corporate Secretary and the Chair of the Corporate Governance and Nominating Committee.

It is WSFS' policy that Associates, Directors, and Advisory Board Members, as well as their Immediate Family Members, should avoid any financial or non-financial interests, positions, payments, and activities which conflict, or reasonably appear to conflict, with the proper performance of the duties and responsibilities of the Associate, Director, or Advisory Board Member to WSFS, or which might affect their independent judgment in transacting with customers, prospective customers, stockholders, vendors/suppliers and others on WSFS' behalf. WSFS Associates, Directors, and Advisory Board Members must be truthful in their dealings with WSFS and conduct themselves with honesty and integrity. The best way to avoid inadvertently violating the Code is to consult with the Ethics Committee, before engaging in an activity which could be deemed a conflict of interest.

When Associates are hired, they must inform WSFS of any non-competition,non-solicitation, confidentiality, or other agreement that they are party to that could restrict the Associate from performing their duties at WSFS. Also, the use at WSFS of any written or electronic proprietary information of a former employer is not permitted.

Reporting of Code Violations; Non-Retaliation; Confidential Submissions

It is the responsibility of all Associates, Directors and Advisory Board Members to report any violations or suspected violations of the Code, as well as any violation or suspected violation of law, statute, or regulation or any suspected misconduct. Associates must report any known or suspected violation to the Human Resource Business Partners, the Chief Legal Officer or the Ethics Committee. All Directors and Advisory Board Members must report any known or suspected violation to the Audit Committee.

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Violations may also be reported into WSFS's Accounting, Auditing, Internal Control, and Ethics Hotline (the "Hotline") via the online portal located at www.reportanissue.com.or calling tool free at 1-800-759-9819. The Hotline is provided by an independent third party and is available 24 hours a day, 7 days a week.

WSFS managers have a particular responsibility to notice and question incidents, circumstances and behaviors that point to a reasonable possibility that a violation of the Code has occurred. A manager's failure to follow up and, as required by the Code, report information suggesting an

actual or potential violation of the Code is, in itself, a violation of WSFS policy. WSFS will neither engage in nor tolerate unlawful or unethical behavior with regard to any of its policies, practices, or operations. All violations by an Executive Officer, Director or Advisory Board Member of any WSFS policy, practice or procedure, including suspected violations of this Code, should be reported to the Chair of the Audit Committee of the Board of Directors or the Ethics Committee, or reported directly into the Hotline. Any violations or suspected violations can also be reported confidentially by mail to WSFS Bank, Chair of the Audit Committee or Chief Legal Officer, 500 Delaware Avenue, Wilmington, DE 19801.

Any reported known or suspected violations of this Code will be investigated by the Ethics Committee or the Audit Committee, as applicable. WSFS prohibits retaliation of any kind against individuals who have made good faith reports of Code of Business Conduct and Ethics violations or other potentially illegal or unethical conduct. Any concerns about retaliation should be reported immediately to the Chief Human Resources Officer or the Chief Legal Officer.

If there is any question as to whether any activity may create an actual, potential, or perceived conflict of interest and/or interfere with an Associate's, Director's, or Advisory Board Member's responsibilities to WSFS, you should contact the Ethics Committee at [e-mail].

Full, Fair, Accurate, Timely and Understandable Public Disclosures

It is WSFS' policy that the information in its public communications, including SEC filings, provide a full, fair, accurate, timely, and understandable disclosure. All Associates and Directors involved in WSFS' disclosure process, particularly the Senior Level Financial Officers, are responsible for adhering to and promoting this policy. Specifically, these individuals must maintain familiarity with the applicable disclosure requirements and are prohibited from knowingly misrepresenting, omitting, or causing others to misrepresent or omit, material facts about WSFS to others, including WSFS insiders, the public, and WSFS' independent registered public accounting firm. In addition, any Director or Associate who has an oversight or supervisory role in WSFS' disclosure processes is obligated to discharge his or her responsibilities diligently.

Compliance with Laws and Regulations

All WSFS entities, through the actions of their Associates, Directors and Advisory Board Members will conduct their business and affairs in compliance with all applicable federal, state, and local laws and regulations; as well as the laws and regulations of any foreign country in which WSFS conducts business.

Confidential and Insider Information

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Confidential Information

Confidentiality is one of the essential elements of our business. All Associates, Directors and Advisory Board Members shall maintain Confidential Information (as defined below in this section) in the strictest of confidence; shall not disclose Confidential Information to any person or Organization outside of WSFS except to WSFS's Agents on a need-to-know basis, or to respond to any subpoena, summons, court or administrative order, or other legal process that requires WSFS's compliance; and shall not use, reproduce, disseminate, or take any other action with respect to Confidential Information, other than for valid business purposes for the provision of services to and/or for the benefit of WSFS. Associates, Directors and Advisory Board Members shall not remove Confidential Information from WSFS premises unless necessary for the performance of their WSFS job duties or services. Further, Associates who have access to Confidential Information as part of their essential job functions are prohibited from disclosing Confidential Information to other Associates, except on a need-to-know basis. Confidential Information should be communicated between WSFS departments/subsidiaries only when there is a legitimate business need to do so. These obligations apply for the duration of the Directors' or Advisory Board Member's term of service and the Associates' employment, and survive in perpetuity.

All Associates, Directors and Advisory Board Members shall cease use of, and return or destroy, all Confidential Information (regardless of form, e.g., hard copy, digital copy, etc.) immediately upon cessation of the Associate's employment, or Director's or Advisory Board Member's term of service, or upon direction from the Associate's supervisor. To be clear, no Confidential Information shall be used for the benefit of any person or Organization other than WSFS.

As used in this Code, the term "Confidential Information" includes, but is not limited to, records, documents, programs, technical data, information technology, policies, files, lists, client and Associate non- public personal information, pricing, costs, strategies, market data, statistics, business partners, customers, customer requirements, prospective customer contacts, referral sources, methods of operation, processes, trade secrets, methods for determining prices, prices or fees, financial condition, profits, sales, net income, and indebtedness, potential mergers or acquisitions, the sale of WSFS assets or subsidiaries, commercial contracts and relationships, litigation (actual and threatened), Board information, and information acquired in connection with WSFS or Advisory Board employment, or Director or Advisory Board service. Information acquired in connection with WSFS employment or Director service includes, without limitation, proprietary or Confidential Information of any third party who discloses such information to WSFS in the course of business, and any other information relating to WSFS that has not been made available to the general public, as the same may exist from time to time. The term "Confidential Information" as used in this Code does not include any information which is, or becomes part of, the public domain through no act or fault of a WSFS Associate, Director or Advisory Board Member.

• Customer, Stockholder, and Vendor/Supplier Information. The relationship between WSFS and its customers, stockholders, and Vendors/Suppliers is based on mutual trust and confidence. Customers, stockholders, and Vendors/Suppliers expect, and regulations sometimes require, WSFS to maintain certain personal and business information in strict confidence. Information concerning a customer's, stockholder's, or Vendor/Supplier's business relationship, loans, accounts, balances, credit ratings, experiences, or any other transaction with WSFS is strictly confidential and must not be discussed with, or divulged to, unauthorized persons (whether inside or outside of WSFS). Specific policies and procedures have been developed for WSFS personnel authorized to release or

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discuss customer, stockholder, and Vendor/Supplier information. Questions and requests to discuss or release such information should be directed to the Ethics Committee.

• Corporate Affairs. Associates, Directors, and Advisory Board Members are prohibited from discussing confidential matters and divulging Confidential Information related to WSFS' affairs outside of WSFS' offices, technology or servers, except to the extent necessary to conduct WSFS business.
• Customer Lists and Other Confidential Information. All documents and records1 (collectively, "records") concerning WSFS business and affairs are the confidential and the exclusive property of WSFS and the right to use such records belongs exclusively to WSFS. WSFS' records include, but are not limited to, its books and records; names, addresses, and telephone numbers; assets and obligations carried in the accounts of WSFS' customers; computer software or hardware used in computer or word processing equipment; training materials; and policy and procedural manuals and bulletins. WSFS' records include the originals and all copies of originals. All WSFS Associates are prohibited from removing WSFS records from its premises in either original or copied form, except for use in business or with specific prior approval from the Ethics Committee.

Insider Information Concerning Investments

An Associate's, Director's or Advisory Board Member's position within WSFS may provide access to Insider Information, the disclosure or use of which can result in civil or criminal penalties for both WSFS and the offending individual under federal securities laws. Associates, Directors and Advisory Board Members must not use or disclose Insider Information in any manner that violates federal or state securities laws, including, without limitation, in connection with effecting or recommending a securities transaction for his/her own account, or effecting or recommending a securities transaction for the account of an Immediate Family Member, WSFS, any WSFS customer, any WSFS stockholder, or any other person or Organization. These obligations are in addition to, and not in lieu of, the obligations of set forth in the WSFS Financial Corporation Insider Trading Policy. Please refer to the Policy and Procedures for Permissible Trading by Insiders for complete details.

Electronic Data and Information

Due to the pervasive use of, and dependency on, various electronic tools, including but not limited to e- mail, facsimile, and the Internet, WSFS Associates must act with caution when utilizing such tools to exchange information. Specifically, when engaging in any type of electronic communications, Associates must adhere to the principles outlined above regarding non-disclosure of confidential customer, stockholder, and Vendor/Supplier information to unauthorized persons or Organizations.

1 Including all information, data, formula, and intangible property or property right preserved in any form including, without limitation, paper, disc, CD, electronic or digital storage mechanism, or any other form currently existing or developed in the future.

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WSFS has established a Social Media Policy as a guide for Associates regarding the personal and business use of social media via the Internet. Associates are expected to adhere to this policy. Please refer to the Social Media Policy for complete details.

Conflicts of Interest: Personal and Financial Matters

• General: Personal investments and finances should be managed in a manner consistent with employment with a banking institution or affiliate. Associates, Directors and Advisory Board Members should exercise prudence in making personal investment and financial decisions and avoid situations which may influence the judgments or advice they give on WSFS' behalf; they are expected to maintain their financial affairs in an ethical manner and to manage their personal finances properly. Associates may not approve or process any transactions for their personal accounts, the accounts of Immediate Family Members, or accounts in which they have a personal financial interest or on which they are an authorized signer.
  WSFS assets are to be used exclusively in the pursuit of WSFS business except for minimal personal use authorized by your manager in accordance with other WSFS policies. WSFS assets include equipment, facilities, supplies, services such as telephones and computer networks, and the time and effort of its Associates. You should not use WSFS assets for personal gain or convenience or make WSFS assets available for the gain or convenience of anyone else, or for any purpose other than conducting corporate business unless you have authorization from the Ethics Committee to do so.
• Investments: Associates, Directors and Advisory Board Members are prohibited from purchasing or selling securities or other investments for his/her account, an Immediate Family Member's account, or any other person's or Organization's account, based on Insider Information. This prohibition includes, but is not limited to, purchases and sales made with knowledge of anticipated or probable changes in WSFS' investment policy, as well as those made with knowledge that WSFS is affecting, or proposing to effect, transactions in a particular security or investment. Associates, Directors and Advisory Board Members must not use their position to obtain leverage to purchase new issues or thinly traded securities for their own account, the account of an Immediate Family Member, or any other person or Organization. Associates who purchase or sell securities for WSFS cannot engage in personal securities transactions with WSFS' securities dealers, or accept gratuities from such dealers, except as provided in the Bank Bribery Act- Gifts, Bequests, and Gratuities Policy (see page 13 below). In addition to the above, Associates and Directors should refer to the Corporation's Insider Trading Policy governing transactions in securities.
• Borrowing: Associates should borrow only from commercial banks, other reputable sources of credit that regularly lend money, or an Immediate Family Member. Associates and their Immediate Family Members are not permitted to borrow from Bank customers or Vendors/Suppliers unless lending is within the customer's or Vendors/Supplier's ordinary course of business. Even in this case, borrowing must be on terms customarily offered to others under similar circumstances and without special concessions on interest rate, term, security, repayment, or other terms. Loans and other extensions of credit between the Bank and its Directors, Executive Officers and applicable Related Interests are governed by the Bank's Regulation O Policy and the standards set forth in the

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Bank's Credit Policy.

Concerning the grant of direct or indirect credit accommodations, Associates, Directors and Advisory Board Members are not permitted to, on WSFS' behalf, make recommendations, represent, or exercise authority, with respect to:

1. Immediate Family Members;

1. Any individual or Organization lending money to, or employing, Immediate Family Members; or

• 1. Any Organization with which they or an Immediate Family Member are associated.
• Transactions with Customers, Borrowers, or Vendors/Suppliers: Except for those transactions properly disclosed in compliance with the Related Party Transaction Policy and Procedures, Associates, Directors and Advisory Board Members are prohibited from engaging in certain transactions with customers, borrowers, and Vendor/Suppliers. This prohibition covers investments in stock or other ownership interests; lending personal funds; and cosigning, endorsing, or otherwise assuming personal liability for borrowed funds of a customer, borrower, or Vendor/Supplier.

Associates are expected to take responsibility for their signatures and are permitted to sign only their own names. Associates must not sign documents on behalf of WSFS, unless they are an Officer of WSFS and must not sign on customers' accounts or otherwise represent customers. This prohibition does not apply, however, to any transactions between an Associate or Director, and

• An Immediate Family Member;
• An organization in which an Immediate Family Member has a majority or controlling interest, either directly or indirectly;
• An organization over which an Immediate Family Member has majority control, whether direct or indirect;
• Any publicly owned entity; or
• Any Organization that serves as a Director's, or an Immediate Family Member's, principal occupation.

Insurance and Sale and Purchase of Property or Purchasing of Corporate and Fiduciary Assets

An Associate shall not acquire real estate, an insurance interest, or other interests from WSFS customers over whose accounts the Associate exercises direct control, and Associates, Directors and Advisory Board Members shall not purchase property on which WSFS is foreclosing or is known to be contemplating foreclosure without prior approval by the Ethics Committee. Except as permitted by applicable federal or state law or regulation, Associates, Directors and Advisory Board Members and their Immediate Family Members may not sell property or services to or buy or invest in property from WSFS. If an Associate wishes to bid on a current WSFS customer's or active prospective customer's property, the following steps must be taken:

• The Associate informs the Ethics Committee of the relevant information and gain approval to bid on the property;

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• The property is offered at public sale by WSFS;
• Seller and seller's representatives are made aware that the Associate is a bidder on the property and the Associate must remove themselves from any involvement (voting, advice, counsel, etc.) regarding all of this customer's banking activity for, at least, a period of one year; and
• The sale is based upon independent appraisals or bids which have been documented in writing and submitted to the Chief Auditor. The Chief Auditor must complete a price/appraisal review of the purchase transaction prior to the closing of the transaction.

If an Executive, Director, or Advisory Board Member wishes to bid on a current WSFS customer's or active prospective customer's property, the above steps must be taken with the applicable information provided and approval received from the Board of Directors.

Senior Level Officers, Directors, and Advisory Board Members or their Immediate Family Members are not permitted to buy property of any type sold by WSFS Wealth Management Division without prior approval of the Board of Directors.

• Related Party Transactions: With the exception of extensions of credit in accordance with the Bank's Regulation O Policy and Credit Policy, Related Party Transactions shall be reviewed and approved by the Corporate Governance and Nominating Committee and approved by the Board of Directors. Refer to Regulation O and Related Party Transaction policies for further details.
• Associate Personal Lending Relationships with Other Financial Institutions: To avoid any conflict of interest and any potential or perceived conflict of interest, when requesting or originating loans (i.e., mortgage loans, personal loans, etc.) from or to lending officers at other financial institutions, Associates must avoid dealing with lending officers at these institutions with whom they have direct or prior business relationships.

Conflicts of Interest: Outside Activities

General: No outside activity of any Associate, Director or Advisory Board Member may interfere or conflict

with WSFS' interests. One must recognize that accepting outside employment or directorships, participating in other Organizations' affairs, and engaging in political activities may potentially result in a conflict of interest with WSFS.

• Outside Business Activities or Employment: Associates must first obtain permission before becoming an employee, officer, consultant, advisor or director of an outside business entity or customer. WSFS discourages outside employment and prohibits Associates from engaging in any business activity or employment which interferes with their duties to WSFS or WSFS' stockholders; divides their loyalty; creates an actual or apparent conflict of interest; or exposes themselves or WSFS to possible criticisms or adverse publicity. Associates are required to disclose all outside employment and, except as set forth below in Community Activities, must obtain prior approval for outside employment, business activities, and directorships from the Ethics Committee.
• Fiduciary Relationships and Activities: All fiduciary activities undertaken by Associates must be in accordance with the best interests of the customer and the requirements of the law. All fiduciary activities must be executed in a fair and equitable manner, with impartiality in the allocation of information, expertise, and the timing of investment executions. In executing its fiduciary

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responsibilities, WSFS will give no preferential treatment to a particular customer based on the size or type of customer relationship with WSFS.

See also the section entitled "Bequests, Devises or Benefits Under Wills and Trusts" on page 17.

• Political Activities: WSFS encourages Associates, Directors and Advisory Board Members to be informed about and participate in the political process and political activities, provided such participation is done in a legal manner on the individual's own time, and does not unduly interfere with their duties, or disparage WSFS's products or services or otherwise create a
  conflict of interest with WSFS. WSFS further encourages Associates, Directors and Advisory Board Members to vote in elections and, if they so choose, to make voluntarycontributions of time and/or money to political and governmental activities. WSFS' Chief Executive Officer and members of the Executive Leadership Team must disclose any monetary or in-kind contributions to political and governmental activities as part of their Code of Business Conduct and Ethics Affirmation and, to the extent necessary, update the Ethics Committee, Chief Legal Officer, and Chief Human Resources Officer throughout the year. Associates are prohibited from consenting to or making political contributions or expenditures of any kind or nature directly or indirectly to any political organizations on behalf of, or in the name of WSFS, unless approved in writing by WSFS, except for WSFS PAC activities.
  Corporate disbursements of money, property, or services to any government official, political party, or candidate are strictly prohibited. This prohibition applies to both domestic and foreign governments and even where such contributions are legally permissible. No offers, promises, or payments are to be made to any foreign government official or Organization to win preferential treatment, secure business, or obtain special concessions for WSFS. Foreign government official is interpreted very broadly, and there is no monetary threshold. This prohibition applies everywhere in the world and includes both direct and indirect offers, promises, and payment. Payments include property and services; and need not be illegal or satisfy any monetary threshold. Additionally, the broad interpretation of "foreign official" includes, but is not limited to, foreign officials, their family members, and their business; state owned businesses and their employees; and any other foreign government representative.
  Associates, Directors and Advisory Board Members must not use the corporate name in connection with any political fund-raising activity, including any printed materials used in such activity. Associates may not use WSFS' logo or stationery for personal purposes. Associates must obtain approval from the Ethics Committee before becoming a candidate for public office, accepting any nomination or appointment to public office, or agreeing to serve as an official (such as a campaign manager, chairperson, or treasurer) in a political campaign.
• Community Activities: We encourage Associates to participate in civic, religious, charitable, and political activities as long as they do not interfere with the performance of your duties at WSFS. Supplies, materials, and other property belonging to WSFS may not be used in more than an incidental way. WSFS should not be identified, nor its name used in community activities without the knowledge of management. Associates are not to act as an official of any organization without prior approval from the Ethics Committee, with the following permitted exceptions: social, religious, charitable, philanthropic, or civic organizations; colleges or schools; neighborhood associations; clubs; trade or professional organizations associated with banking or business.

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