Ethics

At BNY Mellon, our business philosophy is guided by our high ethical standards and practices. "Doing What's Right" is a core focus for our company from the Board of Directors down, and we believe that working together to promote ethical behavior generates positive societal impacts. Building on this reputation for honesty, accountability and transparency is essential to achieving our goal of making the Company the trusted global leader in investment management and investment services. We understand our customers and shareholders expect the Company and its employees to conduct business activities not only in full compliance with all laws and regulations, but also in accordance with the highest possible standards of ethical conduct.

When ethical situations arise in the normal course of doing business, the Company encourages all stakeholders to make decisions that are consistent with our reputation for integrity and offers a number of valuable resources for information and support.

These resources include:

  • A dedicated Ethics Office to assist employees when they need guidance
  • The Company's Code of Conduct
  • The Company's Personal Securities Trading Program
  • Options to report suspected or actual breaches of law, regulations, the Code of Conduct or the Personal Securities Trading Program

The Ethics Office operates an Ethics Help Line, a confidential and anonymous place to ask questions or report concerns concerning conduct that is, or appears to be inconsistent with our Code of Conduct. The Ethics Help Line can be accessed by toll-free phone, via e-mail or through the postal service.

As an alternative, anyone who is uncomfortable contacting the Company directly can report his or her concern confidentially and anonymously directly to the Ethics Hot Line by contacting EthicsPoint, an independent hotline administrator. The Ethics Hot Line can be accessed by toll-free phone, via a secure Internet site or through the postal service.

The Ethics Help Line and the Ethics Hot Line can be used to submit complaints regarding accounting, internal controls or auditing matters, as well as for the confidential and anonymous submission by employees of the Company of concerns regarding questionable accounting or auditing matters. Such submissions can also be made to the Lead Director as provided below.

Communications with Lead Director

Interested parties may communicate directly with the Lead Director, who is independent of management, by writing to the following address:

  • The Bank of New York Mellon Corporation
    Church Street Station
    P.O. Box 2164
    New York, New York 10008-2164
    Attn: Non-Management Director

or via e-mail to non-managementdirector@bnymellon.com.

If your question relates to BNY Mellon Shareowner Services (also known as Mellon Investor Services), please note that this business was sold to Computershare on December 31, 2011. You should direct your question to Computershare at computershare.com/cpusos.