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Business Ethics We strive to be accountable, straightforward and honest in our dealings with customers, employees, suppliers, shareholders and other stakeholders. Our Code of Conduct , Business Principles a nd other internal policies and procedures are designed to promote a culture of respect that allows every employee to feel safe at work and empowered to speak up if they have concerns about unethical behavior. Code of Conduct Our Code of Conduct highlights the personal responsibility of every employee to operate with the highest standards of integrity, transparency and ethical conduct. It emphasizes the importance of avoiding real and perceived conflicts of interest, protecting confidential information and maintaining a workplace that is free from threats, intimidation and physical harm. All employees must complete Code training shortly after their start date and annually thereafter, and each year employees must affirm their compliance with the Code. In general, consultants, agents and contract or temporary workers are expected to comply with the underlying principles of the Code. An additional Code of Ethics for Financial Professionals applies to the CEO, Chief Financial Officer ("CFO") and other finance, accounting, corporate treasury, tax and investor relations roles. We reinforce these expectations through various channels including Culture of Respect trainings, encouraging our senior leaders to communicate about these issues with employees, through town-hall meetings and by including culture- and conduct-related questions in our employee surveys. Acting with integrity is one criterion used to evaluate employees during their annual reviews. Employees are required to raise concerns about misconduct and report any potential or actual violations of the Code of Conduct, other Firm policies or any applicable law or regulation. Employees, directors, suppliers and customers can report known or suspected violations to our Conduct Hotline via phone, online or mobile device. 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 accessible 24/7 worldwide, with translation services available. The Code of Conduct prohibits intimidation or retaliation against anyone who raises an issue in good faith or assists with an investigation. Reporting obligations to the company do not prevent employees from reporting to the government or regulators conduct that they believe violates the law. It is our Firm's policy to promptly review all potential violations and take action as appropriate. Confidentiality will be maintained to the extent possible consistent with investigations. Ethics and culture are key focus areas of our Board of Directors. The Board’s Compensation & Management Development Committee oversees the governance framework that underpins our Firmwide culture of ethics and receives regular updates from management, including regarding any significant conduct issues should they occur. This committee holds a periodic joint session with the Risk Committee in which directors are briefed by senior management on conduct- related matters. The Audit Committee periodically receives reports on the Code of Conduct program and helps the Board maintain compliance with the Firm’s ethical standards, policies, plans and procedures, laws and regulations. Advancing Principles and Policies for Responsible AI The use of AI and machine learning technologies in financial services is quickly expanding. From optimiz - ing analysis, trading, and enhancing credit under - writing to strengthening customer service and improving fraud detection, the range of potential applications is extensive and can bring benefits for multiple stakeholders. However, these technologies also carry unique risks, such as the potential for unintended bias or new threats to data security and privacy. JPMorgan Chase is committed to upholding and promoting high standards of responsibility and ethics in AI. As part of this effort, we have actively participated in the Business Roundtable AI Initiative, which has published a set of key principles and pol - icy recommendations to guide responsible develop - ment and use of AI. 57 INTRODUCTION ENVIRONMENTAL SOCIAL GOVERNANCE Corporate Governance and ESG Oversight Stakeholder Engagement Risk Management Data Privacy and Cybersecurity Business Ethics Political Engagement and Public Policy ESG REPORT APPENDICES

JPMorgan Chase & Co ESG Report - Page 59 JPMorgan Chase & Co ESG Report Page 58 Page 60

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