Employee Code of Conduct

The BNY Mellon Code of Conduct guides our actions and decisions as individuals and as a company. The Code supports our vision of defining what it means to be the trusted financial institution for the next generation of clients and employees and aligns with our core values: Passion for Excellence, Integrity, Strength in Diversity and Courage to Lead. Our principles for ethical behavior in our day-to-day work are guided by our Integrity, which means we do what is right, always, regardless of the impact on a specific transaction or short-term working relationship.

The Code provides guidance on six key principles that relate to many of the situations you may encounter working at our company: Respecting Others, Avoiding Conflicts, Conducting Business, Working with Governments, Protecting Company Assets and Supporting Our Communities. Topics range from protecting client and employee records, and observing our privacy principles, to responsibly growing our company with our own environmental, social and governance (ESG) practices and conduct, which are further explained in our Enterprise ESG Report.

However, the Code alone cannot address every possible situation. We expect all employees to exercise good judgment, using the Code as a primary resource to better understand our principles of ethical behavior, and to seek help when unsure of the right course of action. Above all, each of us, regardless of level, is obligated to put the interests of our company, clients and shareholders above any personal interest.

While the Code is fundamental, it is not your only resource. Your manager, the Legal, Audit, Compliance and Ethics, Human Resources departments, and our Ethics Office are readily available to answer your questions. When in doubt, I urge you to use these resources and escalate situations if you feel they are not getting the proper attention. You should never be afraid or reluctant to speak up.

Being a BNY Mellon employee means exercising good judgment and conducting yourself in a manner that is above reproach. Please take the time to review the Code of Conduct and keep it in mind to help ensure you always do what is right.