Ethics

The creation of The Bank of New York Mellon (the Company) merges two companies that have long shared similar values and reputations for integrity and excellence in everything that we do. Building on this reputation for honesty, accountability and transparency is essential to achieving our goal of making the Company the trusted global leader in asset management and securities servicing. 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 Bank of New York Mellon Code of Conduct
• The Bank of New York Mellon 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 Ethics Point^®, 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.

Communications with Presiding Director and Anonymous Communications on Questionable Accounting Matters

Interested parties may communicate directly with the Presiding Director, who is independent of management, including anonymously about questionable accounting or auditing matters.

The Bank of New York Mellon
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.