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Political Engagement

June 2016

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Information on Political Engagement, Public Policy and Lobbying, Trade Associations and Political Contributions at BNY Mellon.

The financial industry globally is subject to an extensive framework of laws and regulations, continuously evolving and affecting the way we do business in the United States and internationally. Opportunities to engage in the policy development and political process can take many forms, including participating in discussions with policy makers and providing thought leadership.

Resources

Corporate Contribution Reports

PAC Contribution Reports

Federal Lobbying Disclosure Reports

Reports can be found here. Total spend is also reported in our annual CSR reports.

Public Policy and Lobbying

Our Office of Public Policy and Regulatory Affairs, working closely with our Government Affairs Office, monitors legislative and regulatory activities in the United States, Europe, and Asia daily and actively analyzes the potential impacts that each relevant proposed law or regulation might have on BNY Mellon, and on the broader financial markets. We contribute to industry policy discussions in a meaningful way that benefits our clients, investors and other stakeholders, and that strengthens our reputation for responsible political engagement.

Priorities are set by the Office of Public Policy and Regulatory Affairs and Government Affairs, reporting up to and engaging with senior management and the specific businesses that may be impacted. We are actively engaged in implementing all changes required by recent regulatory reforms around the world, including those arising from the Dodd-Frank legislation in the U.S. and similar reforms in Europe and Asia, changes to the Basel Accord, updated leverage ratios, and new liquidity standards and similar regulatory issues in Europe and Asia. We devote significant time and effort to educating legislators, regulators and policy makers globally about BNY Mellon. When considering new reforms or regulations, it is important for all policy makers to understand our unique business model, how this model impacts our balance sheet and how we differ from other large financial institutions.

On our own, through our membership in industry and trade organizations, or together with peer banks, we have submitted comment letters, responded to financial industry surveys and participated in meetings with legislators and regulatory agencies in the U.S. and internationally to exchange ideas on the financial industry and regulatory and tax reform. Because our business model differs significantly from those of other large financial institutions, we are often impacted differently by industry regulations and therefore need to engage with policy makers to explain potential unintended consequences.

In addition to lobbying efforts by members of our Government Affairs Office, we have retained lobbying firms to advocate for our legislative interests on the federal and state level. These activities and applicable disclosure reports are regulated pursuant to federal and state laws. Our total annual federal lobbying spend can be found in our annual Corporate Social Responsibility Reports, and our federal lobbying disclosure reports can be found at http://lobbyingdisclosure.house.gov/index.html. Our state and local legislative lobbying efforts are concentrated in New York and Pennsylvania where the company’s main business operations are located. Expenses are of a de minimis nature and are disclosed where required by applicable law.

Trade Associations

BNY Mellon is a member of various trade associations that represent the interests of the financial industry, as well as the business community in general. These groups produce analyses or white papers on topical issues, as well as advocate on public policy issues important to their members. Trade associations also offer opportunities for professional development and networking. While we regularly review our trade association memberships to ensure they align with our priorities, it should be understood that we may not always agree with the positions of the association or its other members or share their priorities.

Principal trade associations to which we belong are American Bankers Association, Investment Company Institute, The Clearing House and SIFMA (Securities Industry and Financial Markets Association). Other trade associations that we belong to include Financial Services Forum, GFMA (Global Financial Markets Association), AFME (Association for Financial Markets in Europe), EFAMA (European Fund and Asset Management Association), The Investment Association, The CityUK, ASIFMA (Asia Securities Industry and Financial Markets Association), New York Bankers Association, Pennsylvania Bankers Association, Insured Retirement Institute and Institute of International Finance.

We request our principal trade organizations to not use our membership dues or fees for funding election-related activity at the federal, state or local level, including contributions and expenditures (including independent expenditures) in support or opposition of any candidate for any office, political party committee or political committee.

Political Contributions

We also engage in the political process through political contributions. BNY Mellon has two political action committees (PACs) funded entirely by voluntary contributions from our employees. Employees are not reimbursed or compensated in any way for political activities or contributions. In accordance with applicable federal, state and local regulations, the PACs have the ability to make contributions to U.S. federal candidates, and/or state and local candidates, political party committees and other political action committees.

Our PACs are regulated by the Federal Election Commission (FEC), and file reports, as required, with the FEC and relevant state election commissions. Reports filed with the FEC are available to the public at www.fec.gov. Our most recent report of our PAC contributions is available here.

It has been our practice to disclose any corporate contributions** that we make. When we do make such contributions, we will disclose that information semi-annually. Our most recent report of corporate contributions is available here.

In addition, BNY Mellon does not use corporate funds for independent political expenditures in support of, or opposition to, any candidate for office.

** A corporate contribution is defined to include a state candidate committee, a 501(c)4, 527 or ballot initiatives.

Compliance and Oversight

Our Government Affairs Office is under the supervision of the company’s General Counsel. The Government Affairs Office is responsible for all political activity by or on behalf of BNY Mellon, including administration of our PACs. When making specific contribution decisions, the PAC officers, in consultation with the Government Affairs staff, consider a number of factors, including the candidates’ views on issues related to our business, their leadership positions and legislative committee memberships, and the communities they represent.

The Corporate Social Responsibility Committee of our Board of Directors, which consists entirely of independent directors, provides oversight of our public policy advocacy, lobbying focus and political contributions.

We encourage our employees to stay informed of political issues and candidates and to take an active interest in political affairs. Employees may participate in the political process by making voluntary contributions on their own behalf to candidates and related political entities, in accordance with applicable federal and state laws and regulations and company policies. In addition, employees must comply with the company’s Code of Conduct and company policy with respect to engaging in personal political activities.

Employees are not reimbursed or compensated in any way for attending political events, engaging in political activities or making political contributions. Employees engaging in political activities must do so on their own time and with their own resources. Our Compliance and Ethics Department reviews all individual employee contributions that may be affected by federal, state or local “pay-to-play” laws. These laws limit the ability of corporations to compete for business if certain employees have made contributions to officials who have the authority to award business.