Financial Crimes and Anti-Corruption Fair Lending and Banking Practices Supply Chain and Responsible Sourcing Our Firm has a principle of zero tolerance for bribery and corruption. Our global JPMorgan Chase seeks to treat all individuals fairly and equitably in the conduct of We expect our suppliers to demonstrate high standards of business conduct and Anti-Corruption Policy prohibits ofering or giving anything of value to—and solicit- its lending businesses and in all jurisdictions where it conducts business. This is part integrity. Through our Supplier Code of Conduct, we set out our Business Principles ing or accepting anything of value from—anyone for a corrupt purpose, such as of our mission of providing quality fnancial services to existing and prospective cus- that we expect our suppliers to adhere to, such as operational excellence, fairness, improper payments or benefts to government ofcials or private parties for a busi- tomers in accordance with all applicable laws. In the United States, those fair lend- and environmental and social responsibility. ness advantage. The program includes a governance structure managed by anti-cor- ing laws include the Equal Credit Opportunity Act and the Fair Housing Act, as well Our suppliers respond to annual targeted surveys through which we assess how well ruption professionals with senior management oversight, training and awareness as other state and local laws. These laws require, among other things, the equitable they manage issues such as labor practices, human rights, environmental manage- activities and monitoring and testing for compliance. Employees are required to treatment of all credit applicants without regard to race, sex (including gender, gen- ment, and occupational health and safety. We believe that the efective manage- complete anti-corruption training. der identity and sexual orientation), color, national origin, religion, age, marital sta- ment of these issues, including adherence to applicable laws and regulations, INTRODUCTION tus, disability, familial status, the fact that all or part of the applicant’s income We are also committed to participating in international eforts to combat money reduces potential risk to both JPMorgan Chase and our suppliers. In 2022, we laundering, sanctions evasions and the funding of terrorist activities. We have derives from public assistance programs or to the fact that the applicant has in enhanced our supplier DEI standards and clarifed requirements for suppliers. The ENVIRONMENTAL good faith exercised any right under the Consumer Credit Protection Act. The expec- implemented a risk-based, global Anti-Money Laundering Compliance & Sanctions DEI practices of our suppliers are assessed and monitored. Program designed to comply with anti-money laundering and sanctions laws and tation around fair treatment of our current and potential customers extends to SOCIAL every aspect of a credit transaction, including not only how we review credit We have set up a Supply Network collective comprised of supplier-management regulations in the U.S. and other jurisdictions where we operate. We are also part of stakeholders across the Firm, including vendor management, sourcing and procure- the Wolfsberg Group, an association of banks which seeks to develop frameworks requests, but also our advertising, handling of pre-application inquiries, loan dis- GOVERNANCE bursements, and ongoing servicing of the loan. ment, and fnance and business management, which aims to promote community, and guidance for the management of fnancial crime risks, including the founda- connectivity and collaboration as ways to improve JPMorgan Chase's supply chain. tional Wolfsberg Anti-Money Laundering Principles for Private Banking. Corporate Governance & The Firm leverages its relationships with its key suppliers to promote increased spend- ESG Oversight Responsible Marketing ing with underrepresented businesses and provides them with guidance in building Stakeholder Engagement their own supplier diversity programs; 85% of the suppliers enrolled in the Firm’s sup- We believe it is important to be clear and transparent in our advertising and market- Political Engagement and plier diversity mentorship program launched new supplier diversity programs in 2022. Public Policy ing. The Firm seeks to comply with applicable laws and regulations on responsible and fair marketing practices. Our sales employees are expected to communicate with For more information on our eforts to improve supplier diversity, see page 33. Managing Environmental and Social Risks customers in a clear, truthful and complete manner and to provide them with rele- Human Rights vant information to make an informed decision. Our lines of business are required to Data Privacy & Cybersecurity have an established procedure for reviewing all new and revised marketing materi- als, terms and conditions, disclaimers and other customer communications. Business Ethics APPENDICES 60