BNY MELLON ENTERPRISE ESG 4 4 RESPONSIBLE BUSINESS RISK GOVERNANCE BNY Mellon maintains a risk governance structure designed to result in comprehensive risk oversight. The Board of Directors oversees risk management through two key Board committees: the Risk Committee and the Audit Committee. Additionally, the Corporate Governance, Nominating and Social Responsibility Committee (CGNSR) has Board-level oversight of ESG issues, including climate-related risks and opportunities, among other topics. CULTIVATING DIVERSE RISK TALENT We seek to advance diverse talent at all levels of the Risk & Compliance organization through innovative development programs, such as mentoring, cross- training and our Executive Development Program (EDP). Through the EDP specifically, rising high-potential Risk & Compliance leaders receive experiential learning, leadership education and exposure to the BNY Mellon Executive Committee and Board of Directors. In 2021, Risk & Compliance instituted a Diversity, Equity and Inclusion strategy to address the specialized needs of the function. Senior leaders sponsor each of the three strategy workstreams: Talent Attraction and Acquisition to implement inclusive hiring practices and expand recruiting channels; Talent Management and Development to ensure inclusivity across performance management, talent pipelines and succession planning; and Inclusive Culture to overcome barriers to belonging. FINANCIAL RESILIENCY BNY Mellon has a responsibility to demonstrate sound leadership in terms of capital strength, liquidity risk management, and payment, clearing and settlement activities. We are committed to maintaining a strong capital base to meet regulatory requirements, remaining a strong and trusted counterparty to our clients, and withstanding potentially adverse events. Our global resolution plan details how we would maintain critical operations in case of our failure or insolvency. Our 2021 stress test results demonstrated our financial strength and commitment to maintain robust levels of loss-absorbing capital. Compliance and Ethical Behavior BNY Mellon’s Code of Conduct applies to all employees. At the foundation of our Code are our Values: Passion for Excellence, Integrity, Strength in Diversity and Courage to Lead. This Code guides our behaviors in all business activities and helps shape our overall conduct and risk culture. The Code is a unifying document that sets forth the key principles that create a common set of expectations for all employees with regard to: respecting others, avoiding conflicts of interest, conducting business, working with governments, protecting company assets and supporting our communities. Our ongoing measures to reinforce these provisions and standards include annual employee training covering topics such as anti-corruption, protecting assets, business continuity, anti-money laundering and information risk. In 2021, we enhanced our ability to track certain violations of our Code related to employee behavior, such as adhering to our gifts and entertainment requirements, declaring outside activities for evaluation of conflicts of interest, and complying with the Firm’s Personal Securities Trading Policy. We use this to assist managers in addressing violations of company policies and apply disciplinary decisions based upon the company’s Human Resources procedures, as appropriate. These improvements strengthen the company’s oversight of employee compliance violations and consequences, the ability of management to identify violation trends that may need to be addressed, and our efforts to foster a strong risk culture. For all employees, training on topics such as ethics, safety and security in the workplace, unconscious bias, workplace bullying, and harassment are important to maintain an ethical and inclusive culture and are therefore mandatory to meet certain company and regulatory requirements. These trainings, in addition to ongoing risk management communications, help drive employee ownership of risk and compliance outcomes. ESCALATION AND SPEAKING UP We take any breach of rules, laws, regulations, policies or standards of business ethics very seriously. Our corporate culture of “Doing What’s Right” empowers all employees with the necessary knowledge and resources to identify, notify and report issues in a timely manner. We provide several ways to ask questions or make a