BNY MELLON ENTERPRISE ESG 67 RESPONSIBLE BUSINESS Investing in Communities In the United States, two BNY Mellon banking entities — BNY Mellon, N.A. and The Bank of New York Mellon — are evaluated in accordance with the Community Reinvestment Act (CRA) of 1977, the federal law intended to encourage banks to help meet the credit needs of the communities in which they operate. BNY Mellon’s banking subsidiaries in the U.S. meet their obligations under the CRA through investing, lending and performing community service in low- and moderate- income communities. Regulators have rated BNY Mellon, N.A. as “Outstanding” and The Bank of New York Mellon as “Satisfactory” during their most recent CRA performance evaluations. Each year, BNY Mellon helps build stronger, more resilient communities by providing financing for affordable housing and investing in small businesses. These efforts are complemented by our corporate giving and community impact activities . These monetary donations, in-kind services and employee involvement in certain qualified activities and organizations are tracked through our internal Community Impact Online portal. In 2021, CRA-qualified giving represented a $13.9 million commitment. FINANCING AFFORDABLE HOUSING One of the most significant ways BNY Mellon’s banking subsidiaries meet their CRA obligations is by providing financing to expand quality, affordable, and where possible, energy-efficient housing. Each year, BNY Mellon provides construction loans, letters of credit and equity in the form of low-income housing tax credits (LIHTC) to clients. By financing affordable housing developments, BNY Mellon helps clients provide quality affordable housing while simultaneously improving the quality of life in low- and moderate-income communities. 2021 K E Y DATA: AFFORDABLE HOUSING INVESTMENTS New LIHTC equity investments: 6 investments totaling $130.5 million Construction, line and letter of credit financing: $371.5 million Units produced (LIHTC investments only): 486 units SMALL BUSINESS INVESTMENT CORPORATION PORTFOLIO Small Business Investment Corporations (SBICs) are CRA-eligible investment vehicles authorized and regulated by the U.S. Small Business Administration. BNY Mellon’s SBIC portfolio consists of investments totaling $150.9 million in 20 funds. Responsible Financing and the Equator Principles The Equator Principles are an internationally recognized framework used by financial institutions to assess the social and environmental risks of their project financing 35 activities. Although BNY Mellon is not and does not plan to become active in project financing and is therefore not an Equator Principles signatory, we adhere to guidelines consistent with the Equator Principles for other lending activities, such as large- scale infrastructure projects. Our periodic lending portfolio evaluations against these guidelines show minimal exposure to environmental and social risk. 35 The E quator Principles uses the Basel Committee on Banking Supervision’s definition of project finance, which is “a method of financing in which the lender looks primarily to the revenues generated by a single Project, both as the source of repayment and as security for the exposure. This type of financing is usually for large, complex and expensive installations that might include, for example, power plants, chemical processing plants, mines, transportation infrastructure, environment, and telecommunications infrastructure.” Basel Committee on Banking Supervision, International Convergence of Capital Measurement and Capital Standards (“Basel II”), November 2005.