Bank of America Code of Ethics and Values
Transcript of 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.
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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
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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.
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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.
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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 -
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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
7 Back to Table of Contents
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.
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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
8 Back to Table of Contents
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 -
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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
9 Back to Table of Contents
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 -
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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.
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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.
11 Back to Table of Contents
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.
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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.
12 Back to Table of Contents
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.
http://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.0f2459b099329986f9f9c21155a71bba/?vgnextoid=5d4234bbde1a4010VgnVCM100000597ab1abRCRD&vgnextfmt=default&mname=flagscape_5d4234bbde1a4010VgnVCM100000597ab1abRCRDhttp://flagscape.bankofamerica.com/portal/site/complianceriskmanagement/menuitem.0f2459b099329986f9f9c21155a71bba/?vgnextoid=5d4234bbde1a4010VgnVCM100000597ab1abRCRD&vgnextfmt=default&mname=flagscape_5d4234bbde1a4010VgnVCM100000597ab1abRCRD -
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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.
13 Back to Table of Contents
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.
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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.