Supplier Ethics

At BNY Mellon, our reputation for integrity, honesty and accountability is essential to achieve our goal of becoming the best performing financial services company. Our customers and shareholders expect BNY Mellon and all of its employees to conduct business activities in accordance with the highest possible standards of ethical conduct.

Likewise, we maintain all supplier relationships on the highest ethical basis and solely on the merit of quality, innovation, performance and cost effectiveness. These relationships are important for the continued success of BNY Mellon and its subsidiaries and affiliates.

Our policy dictates that employees of BNY Mellon and related subsidiaries and entities may not:

• Solicit or accept anything of value in return for BNY Mellon business, services or confidential information;
• Give cash gifts to, or accept cash gifts from a supplier, customer or person to whom they refer business;
• Accept any gifts or discounts beyond normal business courtesy and of nominal value

To avoid even the appearance of impropriety, any possible conflict of interest, potentially embarrassing situations, jeopardy to our relationship with your company, or jeopardy to the employment of our employees, we ask for your support of this policy and assurance that it has been communicated to the appropriate officers and employees within your company.

The company's 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.

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.