Employee Code of Conduct

Our Code of Conduct guides our actions and decisions as individuals and as a company. I expect each of us to personally commit to doing what is right, regardless of the impact on a specific transaction or short-term working relationship.

The Code provides guidance on six key areas of focus 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.

However, the Code itself 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, are obligated to put the interests of our company, clients and shareholders above any personal interest.

As fundamental as the Code is, it is not your only resource. Your manager, Legal, Audit, Compliance, Human Resources and our Ethics Office are readily available resources if you are having difficulty understanding how our key principles apply to specific situations. When in doubt, I urge you to use these resources and escalate situations if you feel they are not getting the proper attention.

Being a BNY Mellon employee means exercising good judgment and conducting yourself in a manner that is above reproach.