Political Activity

U.S. Only

BNY Mellon is committed to participation in the political process as an integral part of corporate citizenship and representing the company's business interests. This participation can take the form of involvement in industry trade groups, lobbying of elected and appointed officials and, where allowed, political contributions.

BNY Mellon is subject to an extensive system of laws and regulations, and changes to such laws and regulations can have a significant impact on our shareholders, clients, employees and communities. Actively participating in discussions and debate about such changes is critical to ensuring that our interests are appropriately considered. And, where legally permitted, moderate political contributions are used to help elect candidates with views and positions consistent with our company's on important issues.

Political Contributions

BNY Mellon makes political contributions only as permissible by law, including contributions made through our company-established political action committee (PAC). Our PAC is a voluntary, non-profit, bipartisan association that provides financial support to political candidates and committees.

Our PAC makes contributions to U.S. federal candidates, a limited number of state and local candidates, and campaign committees and other PACs. When making specific contribution decisions, the PAC considers a number of factors, including the candidates' positions on issues related to our business, their leadership positions, legislative committees and communities they represent.

Our PAC, which operates solely on the voluntary contributions of its members, is regulated by the Federal Election Commission (FEC) and files regular reports with the FEC and relevant state election commissions on its receipts and disbursements. Reports filed with the FEC are available to the public at www.fec.gov.

Review and Oversight

Our Corporate Affairs department oversees all political activity by or on behalf of BNY Mellon, including the administration of our PAC. It is also responsible for selecting candidates to support and, in conjunction with our Legal department, ensuring that BNY Mellon's political activity complies with applicable legal requirements. The Corporate Social Responsibility Committee of our Board of Directors, which consists entirely of independent directors, provides oversight of BNY Mellon's programs regarding government affairs, including lobbying and political contributions.

BNY Mellon's Code of Conduct requires all employees to receive permission for use of BNY Mellon's name or resources in connection with political events, political candidates and their campaigns, political parties or political committees.