M&T Corporation Subsidiaries and Affiliates - Addendum A

M&T Bank Corporation

The M&T Bank Corporation Wolfsberg is applicable to all of its subsidiaries and affiliates, including: Manufacturers & Traders Trust Company (“M&T Bank”) M&T Canada Branch M&T Cayman Islands Branch M&T Securities, Inc. M&T Insurance Agency, Inc. M&T Realty Capital Corporation Wilmington Trust Company Wilmington Trust, N.A. Wilmington Trust Investment Advisors, Inc. Wilmington Funds Management Corporation Wilmington Trust (London) Limited Wilmington Trust SP Services (Frankfurt) GmbH WT SP Services (London) Limited Wilmington Trust Services (Dublin) Limited Wilmington Trust (Paris) SAS

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M&T Corp. Anti-Bribery and Anti-Corruption Addendum M&T’s policies approved by the Board or the Risk Committee of the Board consistently take the position that violations of law, including anti-bribery and anti-corruption laws are prohibited and are grounds for dismissal. M&T has a number of processes that constitute its compliance program for anti-bribery and anti-corruption laws that are conducted by the Human Resources, Compliance Risk Management, Operational Risk, Third Party Risk Management, Finance, Audit and Business Lines with foreign country contact. From a general perspective, M&T does not engage in transactions with foreign governments, any agency, department or instrumentality of a foreign government or any public international organization.

• M&T has two bank branches and corporate trust operations in foreign countries and does retain third party vendors in foreign countries. Contacts with foreign officials in those instances involve routine actions necessary to conduct business and supervisory oversight of banking activities in the Canadian and Cayman branches.

• M&T has a political activities program that governs gifts, lobbying and contributions involving domestic government officials.

Human Resources. The Code of Business Conduct and Ethics Policy is maintained by the Human Resources Department and is part of the Employee Handbook. This policy covers a wide range of business practices, providing guidance to employees to avoid any conduct that could give rise to impropriety or the appearance of impropriety. More specifically, the policy addresses our international business and our obligations to abide by both the spirit and letter of the laws (foreign and domestic). These laws include the FCPA and UK Bribery Act. The policy also addresses competition and fair dealing practices, outlining how employee behavior in professional relationships should not result in an unfair advantage. Exerting influence to gain unfair advantage, includes bribery (in the form of gifts, or currency) and abuse of privileged information. Employees who violate the Code of Business Conduct and Ethics, are subject to corrective action, up to and including termination of employment or other status. During employee orientation, each employee is required to sign, and acknowledge that they are familiar with the topics in this policy and will abide by all laws, policies, and procedures. In addition, three annual enterprise wide training sessions pertain to FCPA. These are:

• European and Canadian Code of Conduct and Harassment Awareness • US Code of Conduct and Harassment Awareness, and; • Enterprise Policies and Regulations

There are a number of ways to report potential violations of the Code of Business Conduct and Ethics. Employees are encouraged to report such violations to their managers, Human Resources or Compliance Risk Management or call the confidential Employee Complaint Hotline (whistle blower line), or file a report on the ethicspoint web page.

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Compliance Risk Management. SmartSpend is the official tracker and approval system for travel and expenses for the organization including expenses associated with government or public officials. All expenses associated with gifts, entertainment or other forms of gratuity; to be reimbursed by the company, are submitted through the SmartSpend system for reimbursement. Government/public official expenditures are called out via a check box in SmartSpend to indicate the expense was related to government or union officials. On a monthly basis, Compliance Risk Management monitors SmartSpend for any expenses associated with government or public officials. All expenditures are then cross referenced with the political activities pre-clearance database to ensure each expense/activity has been pre-approved by Compliance Risk Management. The pre-approval process involves a thorough review of the expense and applicable laws. If discrepancies are found, they are escalated to the appropriate first line risk officer for resolution and any necessary corrective action. Compliance Risk Management also assists Government Affairs in the management and governance of M&T Corp’s political activities program, which governs gifts, lobbying and contributions involving domestic government officials (especially with respect to state and municipal government entities with which we do business.) Operational Risk. As noted above, expenses associated with business, which are to be reimbursed by the company, are submitted through the SmartSpend system. These expense reimbursement submissions need to be approved by the appropriate manager for the cost center, and are systemically sent to the manager for review and approval by SmartSpend. Once approved by the manager, the SmartSpend expense submission is systemically sent to the Accounts Payable Department for reimbursement. Without managerial approval, the SmartSpend submission cannot be reimbursed. This process is captured in the Job Aid SmartSpend Travel and Expense Reports, and the Employee Handbook, Client Meals and Entertainment Policy. Failure to adhere to policy may result in corrective action, up to and including termination. Third Party Risk Management. At the time of establishing a contract/agreement with our vendors and in updates as appropriate, the domestic master services agreement section 6 (ix) establishes the that the vendor will not engage in the bribery of public officials in connection with the services and deliverables noted in each agreement and will maintain and enforce a policy that prohibits bribery of public officials as defined in the intergovernmental Organization for Economic Co-operation and Development Convention on combating of Bribery of Foreign Public Officials, including practices prohibited in Anti-Bribery laws. In addition, the offshore Master Services Agreement Section 21.20 addresses the FCPA directly, prohibiting the bribery of public officials in connection with the services in the agreement. Violations of these agreements may result in termination of services.

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Finance. M&T is subject to 15 U.S.C. §§ 78m (b)(4-7) (Section 13 (b)(4-7) of the Securities Exchange Act of 1934), which governs accounting transparency requirements to maintain books and records that accurately and fairly reflects M&T’s transactions and to have an adequate system of internal accounting controls. The Finance Department has extensive policies and procedures addressing these accounting requirements, which are implemented in the production of M&T Corp. financial statements. Business Lines with Foreign Country Presence. The Wealth and Institutional Services Division (WISD) has contact and conducts business with foreign countries. WISD Fiduciary Compliance Policy B.14 addresses FCPA. In the policy, compliance with FCPA is mandatory, making the Board of Directors of M&T Bank, Wilmington Trust National Association (WTNA), and Wilmington Trust Company (WTC) and their respective subsidiaries responsible to supervise and oversee the activities of WISD to ensure proper exercise of fiduciary power by the Trust Affiliates. The Fiduciary, Agency and Asset Management Risk Committee oversees the risk management framework. Additionally, the WISD Business Line Risk Incident Management form is provided on the Insider web pages for employees to report risk incidents. This form is confidential, and can be used to report misconduct, fraud, bribery, and other risk issues. Global Capital Markets conducts business worldwide and therefore, employees need to obey the laws of the countries in which they do business. Procedure CCM346 ensures that employees, related entities and agents associated with Institutional Client Services (ICS), abide by FCPA. Specifically, the procedure calls out the necessity to have employees take and annual training on FCPA, pass the assessment, and attest that they understand and agree to follow internal procedures that are in place to abide by Anti-Bribery law FCPA. Employees that violate policies and procedures may be subject to disciplinary action up to and including termination. Audit. The Internal Audit Department conducts detailed audits on all areas of the organization. Compliance with anti-bribery laws is included during regularly scheduled, internal, overarching audits of business units to which this law would apply. The results of the audit are documented as findings and risk rated by internal criteria. All findings are remediated with approval of that remediation at both the senior management level and Internal Audit.