BNY MELLON ENTERPRISE ESG 98 APPENDIX Aspect: Anti-corruption Standard Disclosure Our Response GRI 205: Anti- corruption 2016 20 5 -1 Operations assessed for risks related to corruption BNY Mellon Enterprise ESG Report 2021, Compliance and Ethical Behavior, p.44-45 BNY Mellon Employee Code of Conduct 205-2 Communications and training about anti-corruption policies and procedures BNY Mellon Enterprise ESG Report 2021, Compliance and Ethical Behavior, p.44-45 BNY Mellon’s anti-corruption policies and procedures have been communicated to the general public via BNY Mellon’s website, and communicated to all employees and the Board of Directors. BNY Mellon Employee Code of Conduct 205-3 Confirmed incidents of corruption and actions taken BNY Mellon Annual Report 2021 , Legal Proceedings, p.183-186 Aspect: Anti-competitive behavior Standard Disclosure Our Response GRI 206: Anti- competitive behavior 2016 20 6 -1 Legal actions for anti- competitive behavior, anti-trust, and monopoly practices BNY Mellon Annual Report 2021 , Legal Proceedings, p.183-186