bank of america code of ethics and values

8/6/2019 Bank of America Code of Ethics and Values

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Bank o America Corporation

Code of Ethics


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The Bank of America Core Values

We are Bank o America teammates serving customers, clients, communities and

shareholders through all o our businesses around the world.

Together we:

Deliver for our customers, clients and shareholders

We share a passion or winning and serving the fnancial needs o individuals, corporate clients

and institutional investors. We believe that disciplined execution will lead to sustainable and

long-term perormance.

Trust in our team

We work together around the globe to deliver the entire ranchise to all our constituents.

We strive to be consistent and straightorward in our interactions.

Embrace the power of our people

We value our dierences in thought, style, cultures, ethnicity, and experience understanding

that diversity and inclusion are good or business and make our company stronger.

Act responsibly

We are aware that our decisions and actions aect peoples lives every day. We hold ourselves

accountable or the disciplined management o risk and or doing the right thing.Promote opportunity

We are committed to helping each other achieve our potential in order to build a better uture

or ourselves and the customers, clients, communities and shareholders we serve.

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Code of Ethics: Our foundation for success

To my Bank o America teammates:

We are proud o all we do as an engine o growth and success or millions o individuals,

households, amilies and businesses o every size. With the trust our customers and clients

give us comes a responsibility or ethical behavior in everything we do. The Bank o America

Code o Ethics applies to everyone who is employed by our company all employees

and directors.

The Code, which spells out our shared commitment to the highest standards o conduct, is

based on our companys Core Values. Consider our Code o Ethics as our Core Values in action.

The language we use to describe our values is brie and aspirational it represents the spirit o

our culture. The Code o Ethics provides the detailed guidance we need to translate our values

into action as we compete in the marketplace and engage with customers, clients, shareholders,

vendors and each other.

Trust is at the heart o what we do. Our customers and clients want to know they are doing

business with a fnancial services company that they can trust; that all our associates will treat

them airly, communicate orthrightly, and make clear, honest and ethical decisions. Trust is

crucial to the value we provide our customers. Trust is at the heart o our Core Values and

Code o Ethics.

The Code o Ethics has been designed this year with new eatures, illustrations and examples

to help us apply the ideas in the Code to everyday situations. The Code also contains new

inormation this year relating to corporate social responsibility, discrimination and harassment,

diversity, responding to the media, the new risk ramework, workplace saety and special

obligations o managers to lead by example. The Code is posted on Bank o Americas public

website, and may be used to respond to questions rom customers, vendors or members o

the public. Each o us is required to acknowledge our responsibility or reading, understanding

and complying with the guidelines in this document. I you have any questions, please talk

with your manager.

I thank you or working hard to set opportunity in motion or all those we serve. As we work

together to achieve our goals, it is equally important that we commit to one another that we will

always do business and grow the right way with the honesty, integrity and air dealing that our

Code o Ethics and our Core Values require.

This commitment is the oundation on which our company stands, and on which we will build

a successul uture or our customers, clients, shareholders, communities and one another.

Thank you or your personal commitment to upholding our values and ethical standards

every day.

Brian T. Moynihan


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Table of Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

We Honor Our Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Making good decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Fair dealing and responsibilities to customers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Reporting certain conduct; Code complaints and possible violations . . . . . . . . . . . . . . . . . . 2Non-retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Observing the Code o Ethics and annual training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Code waivers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

We Act Ethically . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Conicts o interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Gits and entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Inormation disclosure and dissemination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Outside activities and relationships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Political contributions and activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Service providers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Anti-bribery/anti-corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Interactions with government employees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

We Manage Risk Effectively. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

We Are Fair and Honest in Our Communications . . . . . . . . . . . . . . . . . . . . . . . . . . 7Responding to media inquiries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Duty to cooperate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

We Safeguard Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Customer inormation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Bank o America inormation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Associate inormation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Supplier inormation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

We Protect Bank of America Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Corporate opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

We Conduct Our Financial Affairs Responsibly . . . . . . . . . . . . . . . . . . . . . . . . . . 10Borrowing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Business expenses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Personal ees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

We Care About One Another. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Diversity & Inclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Discrimination and harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Workplace saety and business continuity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Special obligations o managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

We Respect Laws and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Anti-money laundering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Books and records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

We Will Not Misuse Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Restrictions on trading in Bank o America securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Restrictions on trading in other securities or fnancial instruments . . . . . . . . . . . . . . . . . . 13

We Value Our Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Corporate social responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

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1 The terms Bank o America, corporation and company reer to Bank o America Corporation and its direct andindirect subsidiaries. For convenience, we use these terms because various companies within Bank o America use thisbooklet. The use o these terms here or in other publications does not mean you are an employee o Bank o AmericaCorporation. The use o these terms or issuance o this booklet does not change your existing at-will employee status.

2 The term associate, teammate or you reers to any Bank o America director, ofcer or employee.

3 The 2011 Code o Ethics supersedes and replaces any prior communications, policies, rules, practices, standards and/orguidelines that are less restrictive or to the contrary, whether written or oral. To the extent there are any conicts with theAssociate Handbook, the language o this Code controls.

4 I any provision o this Code conicts with your local law, the provisions o your local law apply.

1 Back to Table of Contents

Introduction

Bank o America Corporation1 is committed to the highest standards o ethical and proessional

conduct. The Bank o America Code o Ethics (the Code o Ethics or the Code) provides

basic guidelines o business practice, and proessional and personal conduct, that we are

expected to adopt and uphold as Bank o America associates.2

The public judges Bank o America by our actions as associates. This Code is intended toguide our conduct to instill public trust and confdence as we demonstrate our commitment

to our Core Values.

The Code o Ethics contains the ollowing key themes consistent with our Core Values:

We honor our Code.

We act ethically.

We manage risk eectively.

We are air and honest in our communications.

We saeguard inormation.

We protect Bank o America assets.

We conduct our fnancial aairs responsibly.

We care about one another.

We respect laws and regulations. We will not misuse inormation.

We value our communities.

Your manager or compliance ofcer will provide you with any manuals, policies and procedures

related to your specifc job. You should visit the internal website or your line o business to

determine all policies applicable to you and reer to the Associate Handbook or additional

inormation on associate conduct.3

The corporation may publish additional policies as deemed necessary or appropriate.

You are expected to ollow the inormation in this Code, other policies reerred to in this

document, additional policies that apply to your specifc job, and the spirit and letter o all laws

and regulations.4 Violation o the Code o Ethics or these other policies, laws and regulations

constitutes grounds or disciplinary action, including termination o employment and possible

legal action.
http://flagscape.bankofamerica.com/portal/site/flagscape/menuitem.131ba41c63d0e18f211649ede3cc5cba/?vgnextoid=307067f0de156210VgnVCM10000038ccc5abRCRD&mname=relatedlinks_AssociateHandbookhttp://flagscape.bankofamerica.com/portal/site/flagscape/menuitem.131ba41c63d0e18f211649ede3cc5cba/?vgnextoid=307067f0de156210VgnVCM10000038ccc5abRCRD&mname=relatedlinks_AssociateHandbook


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We Honor Our Code

Making good decisions

Countless decisions are made every day at Bank o America. Every decision we make as an

institution and as associates impacts not only the corporation and our teammates, but our

shareholders and communities as well. We all strive to make good decisions and to do the

right thing. However, making decisions is not always easy. While in certain situations the rightresult is obvious and the decision can be made easily, in many situations the right result is less

clear-cut or you may be acing time or other business pressures. Regardless o the nature o a

particular decision, keep the ollowing in mind to help you make inormed, thoughtul decisions:

Make sure you have the relevant acts.

Identiy potential options and their consequences.

Take into account relevant laws, standards and policies.

Consider competing interests.

Uphold our Bank o America Core Values.

Fair dealing and responsibilities to customers

At Bank o America, we are expected to deal airly with our customers, competitors, suppliers

and teammates.

You should not take unair advantage o anyone through manipulation, concealment, abuse

o privileged inormation, misrepresentation o acts or any other unair-dealing practice.

You must not give or accept bribes, kickbacks, promises or preerential extensions o credit.

You must approve or award orders, contracts and commitments based on objective business

standards to avoid avoritism or perceived avoritism.

You must not conspire or collude in any way with competitors.

Reporting certain conduct; Code complaints and possible violations

Bank o America can be held criminally liable i one o its associates or agents commits certain

crimes. You must promptly report any knowledge or inormation about unethical conduct by

another associate or agent o the corporation that you reasonably believe to be:

A crime A violation o law or regulation

A dishonest act, including misappropriation o unds or anything o value rom Bank o America,

or the improper recording o corporations assets or liabilities

A breach o trust

You also must report any other circumstances or activities that may conict with the

Code o Ethics.


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Bank of America takes claims

of retaliation seriously. We

will investigate allegations of

retaliation, and anyone found

responsible for retaliating

against an associate who

reported to the Ethics and

Compliance Hotline is subject

to disciplinary action, up to

and including termination of

employment and possible

legal action.

I you have any questions or concerns regarding the Code o Ethics:

Consult your manager or compliance ofcer.

To report complaints or possible violations regarding ethical issues, call the Ethics and

Compliance Hotline:

Associates in the U.S., Canada, Puerto Rico and U.S. Virgin Islands call toll-ree

1.888.411.1744 or email at www.reportlineweb.com/bankoamerica.

For other international associates, toll-ree dialing instructions will vary by location.

Please see the Ethics and Compliance Hotline International Dialing Instructions

or details. International associates may email at

www.reportlineweb.com/bankoamericainternational.

Complaints or possible violations can be submitted anonymously and in complete

confdence. However, because o strict data privacy laws, particularly in the European Union,

associates working outside the U.S. may be subject to certain limitations on reporting to

the Ethics and Compliance Hotline. I you are outside the U.S., consult your local policies

and procedures on reporting, or contact your local human resources or compliancedepartment, and they will be able to advise on the rules applicable to you and appropriate

local reporting channels. Bank of America will not retaliate, and prohibits all associates

from retaliating, against any associate who in good faith reports suspected unethical

conduct, violations of laws, regulations or company policies.

Special consideration for EMEA associates


The Ethics Oversight Committee resolves issues regarding the Code o Ethics, including

potential violations and certain exceptions, and reviews inormation rom the Ethics and

Compliance Hotline. The committee includes the corporations general auditor, general counsel,

global compliance risk executive and global human resources executive.

Non-retaliation

Bank o America values clear and open communications, and respects the contributions o

all associates. You will not be retaliated against or reporting inormation in good aith and in

accordance with this Code.

We will not terminate employment, demote, transer to an undesirable assignment or otherwise

discriminate against an associate or calling attention to suspected unethical acts, including

providing inormation related to an investigation.

Observing the Code of Ethics and annual training

As a Bank o America associate, you are required to agree to observe the Code o Ethics

and take Code o Ethics training, which includes an acknowledgment, on an annual basis.

Code waivers

The board o directors must approve any waiver o the Code o Ethics or the principal executive

ofcer, the principal fnancial ofcer, the principal accounting ofcer and any executive ofcer or

director. The corporation will promptly disclose any such waiver on its website or through a press

release or other public fling as required by law, regulation or applicable stock exchange rule.


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Q: I would like to work

part-time on the weekends

at a local department

store to make extra money

for the holidays. Is thisa conict?

A: Before starting a second

job, you must inform your

manager and obtain his or

her approval. The second

job must not interfere

in any way with your job

performance at the bank.

5 For purposes o this Code, amily member includes spouse or domestic par tner, child, parent, grandparent, grandchild,sibling or parent-in-law.


We Act Ethically

Conicts of interest

You must avoid conicts or even the appearance o conicts between personal interests and

the interests o Bank o America, its shareholders or customers.

It is impossible to defne every action that could be reasonably interpreted as a conict o

interest. This section defnes several potential conicts o interest as examples that you must

be aware o:

Gits and entertainment

Inormation disclosure and dissemination

Outside activities and relationships

Political contributions

Service providers

What is a conict of interest?

Conicts o interest may occur when:

Personal interests or activities compete or interere or even appear to compete or

interere with your obligations to the corporation, its shareholders or customers. The interests o two or more o the corporations customers conict, potentially giving

rise to a material risk o damage to the interest o one or both o the customers.

The corporation places its interests over the interests o its customers, without

legitimate reason.

Such situations might interere with your judgment or ability to properly ulfll your

Bank o America duties.

Conicts o interest also arise when you or your amily members5 receive improper personal

benefts, products or services as a result o your position in the corporation.

Some general considerations or identiying potential conicts o interest:

Perception: Could the activity or transaction be perceived as a potential conict by others?

I all the related acts were made public, would you be embarrassed?

Intent: Is the activity or transaction being oered in an attempt to inuence the recipients

judgment?

Impact: Will the corporation, its shareholders or its customers be disadvantaged without

legitimate reason i you participate in the activity or transaction?

Objectivity: Will participation in the activity or transaction aect your ability to be objective

with regard to any decision made in the legitimate exercise o your job responsibilities?

Time considerations: Will the time required to participate in an outside activity interere

with your ability to eectively carry out your job responsibilities?

Steps to take if you think a conict of interest may exist:

Seek counsel through your manager, your primary compliance or risk ofcer, or your

designated Conicts Ofcer. Conicts Ofcer inormation can be accessed through the

Conicts Management and Anti-Corruption website. Associates in the U.S., Canada, Puerto Rico and U.S. Virgin Islands also may call toll-ree

1.888.411.1744 or email at www.reportlineweb.com/bankoamerica. For other international

associates, toll-ree dialing instructions will vary by location. International associates may

email at www.reportlineweb.com/bankoamericainternational. Please see the Ethics and

Compliance Hotline International Dialing Instructions and Reporting Certain Conduct; Code

Complaints and Possible Violations section o this Code or details.
http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0002e8ca2a97b210VgnVCM10000038ccc5abRCRD&mname=complianceriskmanagement_35a258d5342f9210VgnVCM10000038ccc5abRCRD_1569816115http://www.reportlineweb.com/bankofamericahttp://www.reportlineweb.com/bankofamericainternationalhttp://discoveryll.il.nbgfn.com/Discovery/livelink/64807221/Ethics_&_Compliance_Hotline_Dialing_Instructions.doc?func=doc.Fetch&nodeid=64807221&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/64807221/Ethics_&_Compliance_Hotline_Dialing_Instructions.doc?func=doc.Fetch&nodeid=64807221&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/64807221/Ethics_&_Compliance_Hotline_Dialing_Instructions.doc?func=doc.Fetch&nodeid=64807221&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/64807221/Ethics_&_Compliance_Hotline_Dialing_Instructions.doc?func=doc.Fetch&nodeid=64807221&viewType=1http://www.reportlineweb.com/bankofamericainternationalhttp://www.reportlineweb.com/bankofamericahttp://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0002e8ca2a97b210VgnVCM10000038ccc5abRCRD&mname=complianceriskmanagement_35a258d5342f9210VgnVCM10000038ccc5abRCRD_1569816115


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6 The service o the corporations outside directors on the boards o or-proft organizations is covered byBank o Americas Corporate Governance Guidelines.

You are expected to be

aware of and comply with

Bank of Americas Enterprise

Gifts & Entertainment Policy,

and all other policies and

procedures on gifts and

entertainment that relate to

your area of responsibility.

To learn more about

Bank of Americas gift and

entertainment guidelines and

restrictions, please visit the

Gifts and Entertainmentwebsite.

Q: I am interested in running

for a local ofce. Because

I am not sure if I will win,

can I wait until after the

election to get my

managers approval to

serve in that position?

A: No. You must inform and

obtain the approval of yourmanager before running for

or accepting appointment

to any political ofce.


Gifts and entertainment

Providing gits, including promotional items and entertainment, is oten customary in the

fnancial services industry; however, many jurisdictions have rules that regulate these activities.

You must adhere to such rules to avoid impropriety or the appearance o impropriety that

could expose Bank o America to civil or criminal liability or threaten the publics trust inBank o America.

A conict o interest may arise when you provide or receive gits or entertainment. Such

activities must be legal, and should not be requent or extravagant. You must not accept or

provide entertainment to or rom current or prospective customers or suppliers unless it is or a

valid business purpose, providing an opportunity or a meaningul business conversation. You

should not participate in any activity that could embarrass or reect poorly on Bank o America.

Beore entertaining or giving any item to a government employee, you must contact your

manager and consult with your compliance ofcer.

You must not give or receive gits o cash or cash equivalent instruments to or rom current

or prospective customers or suppliers, unless given as part o an approved Bank o America

customer satisaction program, in which case, such git(s) must comply with all program

restrictions.

These restrictions are not intended to apply to gits or entertainment based on amily

relationships where the circumstances make it clear that it is the relationship rather than

Bank o Americas business that is the motivating actor or giving the git.

Information disclosure and dissemination

A conict o interest may arise i you make public certain types o inormation.

You must not inappropriately share or disclose to the public proprietary inormation concerning

Bank o America, including such inormation about clients, associates, suppliers, market

conditions or business events. Even i you inadvertently or accidentally share or disclose such

inormation, a conict o interest may arise.

Outside activities and relationships

A conict o interest may arise rom activities, employment or other relationships outside

Bank o America.

You must not act on behal o or appear to represent the corporation in any transaction outside

your role and responsibilities with Bank o America. Inorm your manager and obtain all required

approvals beore you:

Pursue additional employment outside Bank o America

Engage in an independent business venture

Perorm services or another business organization

Run or or accept appointment to any political ofce

You must not pursue such outside activities and relationships using Bank o America

resources (including but not limited to physical space, supplies, communications methods,

or time) or allow any outside business, civic or charitable activities to interere with your job

perormance. Bank o America generally discourages associates other than the corporations

outside directors6 rom serving on a board o a or-proft organization in a personal capacity,

particularly the board o a public company, and other approvals are required.

For more inormation, please visit the Outside Directorships website.
http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0f5df377c8f7b210VgnVCM2000003cccc5abRCRD&mname=complianceriskmanagement_0002e8ca2a97b210VgnVCM10000038ccc5abRCRD_1146019627http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0f5df377c8f7b210VgnVCM2000003cccc5abRCRD&mname=complianceriskmanagement_0002e8ca2a97b210VgnVCM10000038ccc5abRCRD_1146019627http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1


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Political contributions and activities

In general, you may make personal political contributions, either directly or through

corporation-sponsored or other political action committees, as legally permitted. Because o

industry regulations and state or other local laws, associates o particular lines o business or

associates with certain coverage responsibilities may be restricted rom making some politicalcontributions or engaging in certain political activities. You must confrm with your compliance

ofcer i you are subject to such limitations prior to making or soliciting others to make political

contributions or engaging in political activities.

Under no circumstance may you coerce or pressure other associates to make political

contributions. Associate campaign contributions are not reimbursable by Bank o America,

and campaign undraising or solicitation activities on Bank o America premises or with the

use o Bank o America resources are prohibited.

Service providers

A conict o interest may arise rom relationships with suppliers or other service providers.

I you are authorized to approve or award orders, contracts or commitments to suppliers o

goods or services, you must do so based on objective business standards to avoid any realor perceived avoritism.

Anti-bribery/anti-corruption

You are expected to comply with the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act

as well as all other anti-bribery and anti-corruption laws. You may not give, promise or oer

anything o value to any customer, government employee or any other person or the purpose o

improperly inuencing a decision, securing an advantage, avoiding a disadvantage or obtaining

or retaining business. I you engage in such behavior, you expose yoursel and the corporation

to civil and/or criminal liability and signifcant reputational harm, and undermine the trust o our

customers, shareholders and communities.

For more inormation, visit the Conicts Management and Anti-Corruption website.

Interactions with government employees

Interactions with government entities and their employees may expose the corporation and its

associates to a myriad o public policy, legal or compliance concerns. Prior to these contacts,

you must confrm with your compliance ofcer i there are any limitations or requirements that

apply to your contact (e.g., limits on gits and entertainment, requirement to register as a

lobbyist, responding to a subpoena).

You are expected to be particularly vigilant when interacting with government employees and

must not engage in behavior that could be seen as being intended to improperly inuence a

Bank o America business relationship.

You must not oer, give or promise to give money or anything o value to any executive,

ofcial or employee o any government, agency, state-owned or controlled enterprise, political

party or candidate or political ofce i it could be seen as being intended to inuence aBank o America business relationship. You must be sensitive to those situations or

circumstances that could create an appearance o impropriety or potential conict o interest,

or raise bribery or corruption concerns.
http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0002e8ca2a97b210VgnVCM10000038ccc5abRCRD&mname=complianceriskmanagement_35a258d5342f9210VgnVCM10000038ccc5abRCRD_1569816115http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.679c7f0c918b4486f9f9c21155a71bba/?vgnextoid=0002e8ca2a97b210VgnVCM10000038ccc5abRCRD&mname=complianceriskmanagement_35a258d5342f9210VgnVCM10000038ccc5abRCRD_1569816115http://discovery.bankofamerica.com/discovery/livelink/63227923/Identifying_Government_Officials.docx?func=doc.Fetch&nodeid=63227923&viewType=1


11/19

We are all accountable

Think independently.

Take a stand.

Actively escalate issues.

Assume personal

accountability.

Take action.

Resources

Companys

Risk Appetite Statement

Risk Framework

Document

How We Manage Risk

website

Risk Framework training


We Manage Risk Effectively

Bank o America is in the business o taking risk. You are responsible or understanding what

risks impact the company, managing those risks and ensuring an appropriate risk/reward

balance.

Individual accountability is at the heart o our risk culture this means that each associate is

responsible or using his or her individual judgment to manage risk. We are all accountable ordebating risk-related issues, escalating concerns, taking a stand and making sound judgments

about the risk/reward trade-os o business decisions.

You should take an open, candid and act-based approach to discussing risk issues, making all

relevant acts and inormation available so the company can consider all possible options and

make decisions. You also are responsible or promptly communicating and escalating matters

to management that may cause risk or potential harm to the company, such as operational

problems, inappropriate conduct, policy violations, illegal activities or other risks. Always act to

protect the company and the interests o shareholders.

To defne how we manage risk, the company has developed a comprehensive Risk Framework,

which defnes a consistent risk management process and clearly illustrates the independence

o the risk management unction. A key part o this ramework is a ormal Risk Appetite

Statement that the board o directors approves each year. The risk appetite defnes both howmuch and what types o risk we are willing to take to achieve our long-term fnancial goals.

Each associate is responsible or operating within our companys established risk appetite.

All risk-taking activities must align to this corporate Risk Appetite Statement.

We Are Fair and Honest In Our Communications

Responding to media inquiries

We work to both advance and protect the Bank o America brand through engagement with

the news media as part o our larger marketing, communications, public policy and corporate

aairs activities. I you are contacted or approached by a reporter or member o the media, you

should direct them to Bank o America Media Relations. Associates who anticipate speaking

or otherwise communicating with the media must obtain prior approval rom a member o the

Media Relations sta. You need to be aware o and comply with any other applicable line o

business specifc policies and procedures regarding media, public relations or communication

requirements.

Duty to cooperate

You must ully cooperate with any internal or external investigation or audit, or any regulatory

examination or request or inormation. You need to be aware o and comply with any applicable

line o business specifc policies and procedures regarding contact with regulators, which

among other things, may require you to report such contact to either your manager

and/or compliance ofcer. Additionally, you must immediately inorm your manager i you are

the subject o an external investigation or contribute/participate in an external investigation

unless laws, regulations or the investigating authority prohibit you rom doing so.


12/19

Every year, you are required to take Inormation Protection and Privacy training.

This training highlights:

Proper methods to protect confdential and proprietary inormation or Bank o America,

its customers and associates

Appropriate use o electronic communications

Consumer Privacy Notices

Appropriate use and sharing o customer inormation

For more inormation on privacy, visit the Privacy website. The Enterprise Inormation

Management website contains helpul inormation about confdentiality and inormation

security at Bank o America. The We Will Not Misuse Information section o this Code o

Ethics explain the prohibitions on misuse o material, nonpublic inormation in the

Inormation Wall Policy, as well as relevant line o business specifc policies.

Remember, any assets you

create for Bank of America or

while using Bank of America

resources are the corporations

property, and remain its

property even if you leave

Bank of America.

Bank of America has

guidelines with which you

should be familiar to ensure

the protection of intellectual

property, records and other

information. Please visit

the following websites:

Intellectual Capital

& Property

Global Records

Management

Secure Destruction Services


We Safeguard Information

We must keep the ollowing inormation confdential and secure:

Customer information

You must not access customer inormation or use customer inormation except or appropriate

business purposes and must protect the confdentiality and security o customer inormation.

You should be amiliar and handle customer inormation in accordance with Bank o Americas

privacy notices, which detail our commitment to privacy and inormation protection, and internal

privacy and inormation security policies and standards. You should also be amiliar with the

need to know policy or material, nonpublic inormation and certain other confdential

inormation related to our corporate clients. For more inormation, please visit the Enterprise

Inormation Management website, the Privacy website and see the Inormation Wall Policy.

Bank of America information

You must keep confdential and secure any nonpublic inormation about Bank o America. Such

inormation should only be shared within the corporation with other associates who need to

know the inormation to perorm their duties. Consult your manager i you have questions about

sharing inormation about Bank o America on a need to know basis.

Associate information

You must keep confdential and secure any inormation we have about other Bank o America

associates. The Associate Privacy Policies outline responsibilities or associates, managers and

service providers when requesting, using, transmitting and disposing o associate inormation.

Supplier information

We must keep confdential and secure any inormation you have about the corporations purchase

o products or services. Sharing this inormation with the wrong source could provide an improper

advantage to the supplier or its competitors and violate agreements Bank o America has with

suppliers. In some instances, it also might violate the need to know policy or material,

nonpublic inormation. For more inormation, please visit the Supply Chain Management website.
http://flagscape.bankofamerica.com/portal/site/lob05110003/?authenticated=1295449839909http://flagscape.bankofamerica.com/portal/site/lob05110003/?authenticated=1295449839909http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.0f2459b099329986f9f9c21155a71bba/?vgnextoid=819234bbde1a4010VgnVCM100000597ab1abRCRD&mname=complianceriskmanagement_8967e84733d94010VgnVCM100000597ab1abRCRD_1538420401http://flagscape.bankofamerica.com/portal/site/pmt08040002/?ch=5e05e703f655b110VgnVCM10000038ccc5abRCRD&pol=91c187911165b110VgnVCM10000038ccc5abRCRDhttp://flagscape.bankofamerica.com/portal/site/scmleader/menuitem.78fa1b23423e0bca3dc5f16f55a71bba/?vgnextoid=c5d1e599853f4010VgnVCM100000597ab1abRCRD&mname=scmleader_641f23a6b42ba010VgnVCM200000597ab1abRCRD_1538420401http://flagscape.bankofamerica.com/portal/site/scmleader/menuitem.78fa1b23423e0bca3dc5f16f55a71bba/?vgnextoid=c5d1e599853f4010VgnVCM100000597ab1abRCRD&mname=scmleader_641f23a6b42ba010VgnVCM200000597ab1abRCRD_1538420401http://flagscape.bankofamerica.com/portal/site/pmt08040002/?ch=5e05e703f655b110VgnVCM10000038ccc5abRCRD&pol=91c187911165b110VgnVCM10000038ccc5abRCRDhttp://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.0f2459b099329986f9f9c21155a71bba/?vgnextoid=819234bbde1a4010VgnVCM100000597ab1abRCRD&mname=complianceriskmanagement_8967e84733d94010VgnVCM100000597ab1abRCRD_1538420401http://flagscape.bankofamerica.com/portal/site/lob05110003/?authenticated=1295449839909http://flagscape.bankofamerica.com/portal/site/lob05110003/?authenticated=1295449839909


13/19

Bank of America assets include, but are not limited to, items such as:

Computer sotware Innovations

Customer lists or inormation Intellectual property

Data processing systems Money and unds

Databases Records

Equipment Reerence materials

Furnishings Reports

Files Supplies

Ideas Technology

Inormation about corporate or customertransactions

The corporations private computer systems,including your email and your internet access


We Protect Bank of America Assets

We must properly care or and protect Bank o America property and assets, which should be

used or legitimate business purposes only.

You must not:

Steal, embezzle or misappropriate money, unds or anything o value rom Bank o America.

Doing so subjects you to potential disciplinary action, according to the law andBank o America policy.

Use Bank o America assets or personal gain or advantage.

Remove Bank o America assets rom the acilities unless you have your managers approval.

Use ofcial Bank o America stationery, the corporate brand, documents or the

Bank o America name or nonofcial purposes, since such use implies endorsement

by the corporation.

Misuse your internet, phone or email privileges. The corporations private computer and

phone systems are primarily or business purposes and subject to review, monitoring and

recording at any time without notice or permission, to the extent permitted by law. More

inormation on these and other policies is available in the Working at Bank of America section

o the Associate Handbook.

Corporate opportunities

You must not deprive the corporation o an opportunity by:

Competing with the corporation or using corporate property, inormation or your position or

personal gain

Taking or yoursel an opportunity that belongs to the corporation or helping others do so ithey are in a position to divert a corporate opportunity or their own beneft
http://flagscape.bankofamerica.com/portal/site/flagscape/menuitem.131ba41c63d0e18f211649ede3cc5cba/?vgnextoid=307067f0de156210VgnVCM10000038ccc5abRCRD&mname=relatedlinks_AssociateHandbookhttp://flagscape.bankofamerica.com/portal/site/flagscape/menuitem.131ba41c63d0e18f211649ede3cc5cba/?vgnextoid=307067f0de156210VgnVCM10000038ccc5abRCRD&mname=relatedlinks_AssociateHandbook


14/19

10

At Bank of America, we giveeveryone a fair opportunity

to be part of our team and to

excel, and we base decisions

and rewards on facts and

results. To help associates

excel on the job and reach

their full potential, we provide

professional development

strategies, tools and processes

across the company.

Back to Table of Contents

We Conduct Our Financial Affairs Responsibly

You should conduct your personal fnancial aairs responsibly and keep your business

expenses in order.

You are responsible or your fnancial activities in the ollowing areas:

Borrowing

You may not personally borrow money rom or lend it to suppliers, customers or other

associates unless the loan is:

To or rom a amily member

From an institution normally in the business o lending

There is no conict o interest

An occasional loan o nominal value (such as or lunch) to another associate or acquaintance

is acceptable, as long as no interest is charged.

Business expenses

You must report your business expenses accurately and in a timely manner. You also must not

use business credit cards or any purpose other than appropriate business expenses.More inormation on appropriate business expenses is available in the Corporate Expense

Policies and the Excessive or Luxury Expenditures Policy.

Personal fees

You may not accept personal ees or commissions or any transaction on behal o

Bank o America unless you are specifcally authorized to do so.

We Care About One Another

Diversity & InclusionAt Bank o America, we respect and value not only dierences related to race, religion, gender,

gender identity, ethnicity, disability and sexual orientation, but also diversity o viewpoints,

experiences, talents and ideas. We strive to empower all associates to excel on the job and reach

their ull potential, and reward and recognize associates based on perormance and results.

In addition to being the right thing to do, encouraging a diverse, inclusive workplace gives us the

business advantage o understanding and meeting the needs o our diverse customers, clients

and shareholders. Our diversity also provides resh ideas and perspectives, which promote

ingenuity.

Bank o America is proud to be a leader in supporting diversity and has been widely recognized

or its progressive workplace practices and initiatives to promote inclusion.
http://digitalasset.bankofamerica.com/BOA_DAL/dalibrary.do?name=00-08-6083NSB.pdfhttp://digitalasset.bankofamerica.com/BOA_DAL/dalibrary.do?name=00-08-6083NSB.pdfhttp://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9MTUxNjN8Q2hpbGRJRD0tMXxUeXBlPTM=&t=1http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9MTUxNjN8Q2hpbGRJRD0tMXxUeXBlPTM=&t=1http://digitalasset.bankofamerica.com/BOA_DAL/dalibrary.do?name=00-08-6083NSB.pdfhttp://digitalasset.bankofamerica.com/BOA_DAL/dalibrary.do?name=00-08-6083NSB.pdf


15/19

Q: As a manager, how can

I promote ethical behavior?

A: First and foremost, lead by

example. Include discussions

about workplace ethics in

team meetings. Allow team

members to feel comfortable

asking questions when they

have concerns. Remind

associates that they will not

be retaliated against for

reporting information in

good faith in accordance

with this Code.


Business continuity is every associates business. You must:

Know the emergency response procedures for your building.

Know your role in your groups business continuity plan.

Be familiar with the Emergency Notication and Associate Communication Tool (ENACT), and have your

Person Number on hand.

Keep contact details current in the corporate personnel system(s).

Keep wallet cards and key contact information readily available at all times.

Call Security Operations (SOACC) to report life safety and security incidents, robberies, building security or

any suspicious activity.

Discrimination and harassment

At Bank o America, we work to build a culture that is diverse, inclusive, and ree o

discrimination or harassment. We do not tolerate discrimination or harassment. For more

inormation, review the complete Sexual Harassment, Discrimination and Harassment Policy.

Workplace safety and business continuity

We are committed to the saety and security o our teammates around the globe. In order to

avoid risk to yoursel or those around you, you must ollow all applicable saety and security

procedures, as well as applicable laws and regulations. You should report unsae working

conditions to your manager or compliance ofcer.

Business continuity is vital to our success as an organization. It allows us to plan or

and respond to a variety o potential business interruptions. You must understand your

responsibilities to support the specifc plans or your line o business and what to do to

respond during a business interruption.

Special obligations of managers

We all are responsible or abiding by the Code; requesting advice rom appropriate resources;

reporting known or suspected violations o the Code, rules, standards, policies or procedures;

questioning business practices that may contradict or violate our Code; and cooperating in

investigations o potential violations.

Managers have additional obligations to do the ollowing:

Lead by example: actively practice ethical behavior, manage risks within the Companys Risk

Framework and live the standards o our Code and our values.

Hold others accountable or acting in accordance with our values, our Code and our

Risk Framework.

Make sure that teammates are aware o the standards contained in our values, our Code

and related policies and procedures.

Maintain a workplace environment that encourages candid discussions about ethics issues

with no ear o reprisal.

Do not abuse your position or inuence (e.g., improperly pressure teammates or personal

beneft or activities).

Treat all employee reports and ethics complaints confdentially and consistently ollow

company policies and procedures or handling them.
http://digitalasset.bankofamerica.com/Procurement/dal/dalibrary.nsf/(LinkToItemByNumber)?OpenAgent&00-13-2041NSBWhttp://digitalasset.bankofamerica.com/Procurement/dal/dalibrary.nsf/(LinkToItemByNumber)?OpenAgent&00-13-2041NSBW


16/19

Q: Where can I nd information

about identifying red ags

for money laundering?

A: The Anti-Money Laundering

Program Policy contains

several red ags. AML also

provides Quick Reference

Cards to identify suspicious

or unusual activity.

The Interofce Mail policy

outlines the proper use of the

Interofce Mail service across

the United States for associates

in all lines of business, afliates

and subsidiaries, and

contractors with access to the

interofce mail system. Proper

use of Interofce Mail will

assist Bank of America in

meeting federal regulations

that require the payment of

postage to the United States

Postal Service (USPS) for most

items that are sent via the

Interofce Mail system.


We Respect Laws and Regulations

We must not take any action, either personally or on behal o Bank o America, which violates

any law, regulation or internal policy aecting Bank o America business.

It is impossible to list all applicable laws. While other topics are addressed elsewhere in the

Code, this section presents two additional topics regarding regulations o which Bank o America

associates must be aware:

Anti-money laundering

Money laundering is disguising the proceeds o criminal activity through a series o otherwise

legitimate transactions.

We all have a role to play in Bank o Americas anti-money laundering (AML) eorts.

For example, you:

Should be able to recognize red ags and report potentially suspicious or unusual activities

Must make reasonable eorts to determine the true identity o all customers

Must ollow Know Your Customer procedures or your line o business

Must complete all required AML training courses or your line o business

For an overview o AML, visit the Anti-Money Laundering website.

Books and records

Accurate record keeping and reporting reects on our reputation, our integrity and our credibility,

each o which promotes the interests o our shareholders. You must maintain accurate books

and records consistent with business needs and legal requirements.

To ensure the integrity o its consolidated fnancial statements, Bank o America has

established internal accounting and operating controls and procedures, including disclosure

controls and procedures, and a Disclosure Committee.

All associates responsible or the preparation o the corporations fnancial statements, or who

provide inormation as part o that process, must maintain and adhere to these controls so that

all underlying transactions, both within Bank o America and with third parties, are properly

documented, recorded and reported.

In addition, we all have the responsibility to promote ull, air, accurate, timely and understandable

disclosure in reports and documents that Bank o America fles with or submits to the U.S.

Securities and Exchange Commission or other global regulators, as well as in other public

communications made by the corporation.

The Audit Committee o the board o directors has established procedures or the receipt,

retention and treatment o complaints regarding accounting, internal accounting controls or

auditing matters. You may raise any such concerns to the Ethics and Compliance Hotline.

You will not be retaliated against or reporting inormation in good aith in accordance with

this requirement.
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17/19

What is material, nonpublic information?

The defnition o material, nonpublic inormation is broad. You should consider inormation

to be material i a reasonable investor would consider it important in making an investment

decision. Examples include merger and acquisition inormation, signifcant leadership

changes and earnings-related and other signifcant fnancial inormation.

You should consider inormation nonpublic i it is not generally available to the investing

public. Please see the Inormation Wall Policy or more inormation regarding material,

nonpublic inormation.

You must be familiar with,

understand and comply with

the Enterprise Information Wall

Policy and all other policies

and procedures that relate to

your area of responsibility.

These policies are designed to:

Prevent the ow of

information from associates

in units that may receive

material, nonpublic

information about issuers

of securities or nancial

instruments to associates

in units that buy, sell or

recommend securities and

nancial instruments to

duciary and nonduciary

accounts.

Provide additional guidance

on prohibitions against the

misuse of material, nonpublic

information, including

additional restrictions on

personal trading for certain

designated units.

Address other issues raised

by the activities of each

designated unit.

For more information,

please visit the

Information Wall Policy.


We Will Not Misuse Information

Restrictions on trading in Bank of America securities

You must not buy, sell, recommend or trade in Bank o America securities either personally

or on behal o someone else while in possession o material, nonpublic inormation relating

to the corporation, except through personal trading programs pre-approved by the Legal

Department.

In addition, you must not communicate or disclose such inormation to others who may trade

in Bank o America securities. Doing so may not only be a violation o your duty to keep such

inormation confdential, but also may be a violation o U.S. ederal and state laws, and the laws

o many countries.

I you are a Bank o America Corporation director or have been designated as an insider by

the corporation, you must obtain special approvals beore trading in Bank o America securities.

Bank o America associates must not engage in speculative trading o Bank o America

securities. This generally prohibits short sales and trading in puts, calls and other options

or derivatives with respect to such securities, unless such transactions are or legitimate,

nonspeculative purposes. I you have questions regarding the potential speculative nature

o your transaction, please talk with your manager or line o business compliance ofcer.

Please note: This paragraph does not apply to the exercise o Bank o America associate

stock options. For more inormation, please reer to Additional Guidance While Trading in

Bank o America Securities.

Restrictions on trading in other securities or nancial instruments

I you are in possession o material, nonpublic inormation about securities or fnancial

instruments, you are prohibited rom buying, selling, recommending or trading such securities

or fnancial instruments in breach o a duty o trust or confdence owed to the issuer o the

securities or fnancial instruments, the shareholders o that issuer or any other person who

is the source o the inormation.

In addition, you must not communicate or disclose such inormation to others who may

misuse it, including amily members. Doing so not only would be a violation o your duty

o trust or confdence, but also may be a violation o ederal and state laws, and the laws

o many countries.
http://discoveryll.il.nbgfn.com/Discovery/livelink/58573494/Additional_Guidelines_for_Trading_in_Bank_of_America_Securities.doc?func=doc.Fetch&nodeid=58573494&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/58573494/Additional_Guidelines_for_Trading_in_Bank_of_America_Securities.doc?func=doc.Fetch&nodeid=58573494&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/58573494/Additional_Guidelines_for_Trading_in_Bank_of_America_Securities.doc?func=doc.Fetch&nodeid=58573494&viewType=1http://discoveryll.il.nbgfn.com/Discovery/livelink/58573494/Additional_Guidelines_for_Trading_in_Bank_of_America_Securities.doc?func=doc.Fetch&nodeid=58573494&viewType=1


18/19


19/19


Arts We are encouraged as Bank o America associates to support arts and heritage

programs around the world, stimulating the mind, the economy and community engagement.

Through unique programs such as Museums on Us, which oers ree admission to more

than 100 museums across the U.S. to Bank o America customers, and Art in our

Communities, which provides loans o ully-curated exhibits rom our own art collection,

we help provide communities with greater access to enriching arts and cultural experiences

and bring new revenue opportunities or participating organizations.

Environment We are deploying the power o our human and fnancial capital to connect

our customers, clients and associates to opportunities in the new environmental economy.

Associates are encouraged to consider their environmental impact through our partnership

with the Pew Center on Global Climate Change and $3,000 hybrid vehicle reimbursement

program. As a company, we address global climate change through our 10-year, $20 billion

environmental initiative, launched in 2007, promoting a more sustainable uture. Through

this initiative, we have provided more than $8 billion in lending, products and services

and investments.

Diversity & Inclusion Bank o America partners with organizations that promote diversity

and inclusion, providing a business advantage o understanding and meeting the needs

o our customers, clients and shareholders. We work with national and local community

partners, such as the National Council o La Raza, the National Urban League and the

National Association or the Advancement o Colored People, addressing issues that are

important to our diverse customer base.

bank of america code of ethics and values

Documents