Business Ethics We strive to be accountable, straightforward and honest in our dealings with cus- Employees are required to raise concerns about misconduct and report any poten- tomers, employees, suppliers, shareholders and other stakeholders. Our Code of tia l or actual violations of the Code of Conduct, other Firm policies or any applicable INTRODUCTION Conduct, Business Principles and other internal policies and procedures are law or regulation. Employees, directors, suppliers and customers can report known designed to promote a culture of respect that allows every employee to feel safe at or suspected violations to our Conduct Hotline via phone, online or mobile device. ENVIRONMENTAL work and empowered to speak up if they have concerns about unethical behavior. The Hotline is anonymous, except in certain non-U.S. jurisdictions where anonymous reporting is prohibited. It is operated by a third-party service provider and is acces- SOCIAL Code of Conduct sible 24/7 worldwide, with translation services available. The Code of Conduct prohibits intimidation or retaliation against anyone who raises GOVERNANCE Our Code of Conduct highlights the personal responsibility of every employee to an issue in good faith or assists with an investigation. Reporting obligations to the operate with the highest standards of integrity, transparency and ethical conduct. It company do not prevent employees from reporting to the government or regulators Corporate Governance & emphasizes the importance of avoiding real and perceived conficts of interest, pro- conduct that they believe violates the law. It is our policy to promptly review all ESG Oversight tecting confdential information and maintaining a workplace that is free from potential violations and take action as appropriate. Under our policy, confdentiality Stakeholder Engagement threats, intimidation, and physical harm. will be maintained to the extent possible consistent with investigations. Political Engagement and Employees must complete Code training shortly after their start date, and each year Ethics and culture are key focus areas of our Board of Directors. The Board’s Com- Public Policy employees must afrm their compliance with the Code. In general, consultants, pensation & Management Development Committee is responsible for overseeing the Managing Environmental and agents and contract or temporary workers are expected to comply with the underly- Social Risks governance framework that underpins our Firmwide culture of ethics and receives Human Rights ing principles of the Code. An additional Code of Ethics for Financial Professionals regular updates from management, including regarding certain material risk and applies to the CEO, CFO and other fnance, accounting, corporate treasury, tax and control issues where misconduct is the root cause. This committee holds a periodic Data Privacy & Cybersecurity investor relations roles. joint session with the Risk Committee, in which directors are briefed by senior man- Business Ethics We reinforce these expectations through various channels, including senior leaders’ agement on conduct-related matters. The Audit Committee periodically receives communications with employees, town-hall meetings and culture- and conduct-re- reports on the Code of Conduct program and assists the Board in providing over- APPENDICES lated questions in our employee surveys. In addition, Acting with Integrity is one cri- sight of compliance with the Firm’s ethical standards, policies, plans and proce- terion used to evaluate employees during their annual reviews. dures, and with laws and regulations. JPMorgan Chase employees are expected to operate with the highest standards of integrity, transparency, and ethical conduct. 59