Code of Conduct 2018 (PDF) - JPMorgan Chase

1 Code of Conduct 2018 Code of Conduct It Begins with MeJPMorgan Chase stands committed to maintaining the highest levels of integrity, fairness and responsibility. Our Code of Conduct guides us each day as we strive to meet our obligations to all our constituents customers, employees, the Board, shareholders, regulators and to ourselves. We recognize that in business, as in every other arena, ethical behavior does not just happen. It needs to be cultivated and repeatedly affirmed throughout the organization. Our Code of Conduct lays out the firm s expectations for each employee, providing the necessary information and resources to Conduct business ethically.

2 It is your responsibility to fully understand and comply with our Code. It s how we do business with the highest levels of transparency and accountability and how JPMorgan Chase continues to be a company of which we can all be proud. Remember, each of us has a duty to speak up whenever we see or suspect illegal or unethical activity. If something doesn t look or feel right to you, raise the issue. Don t ever hesitate to report a possible violation or concern. A company is only as good as its people, and our people are the best. Our integrity begins with you. Jamie Dimon June 2018 Our Code Principles: A Shared ResponsibilityAt JPMorgan Chase & Co.

3 ( JPMC ), preserving our strong ethical culture is a top priority; we must continue to embed the values of integrity, fairness, and accountability in all that we do. We all share a responsibility to build on this proud heritage, and to maintain exceptional relationships with our customers, shareholders, each other, and the neighborhoods and communities in which we operate. We must never underestimate the importance of our Conduct , and always take personal responsibility for our actions it is how we do business. The Code of Conduct is our shared commitment to operate with the highest level of integrity and ethical Conduct . Code Reporting Hotline Code Resource Page Code Specialist LOB/Regional/Corporate FunctionCompliance Officer Human Resources/Access HR Code of Conduct Intranet Site Code of Ethics for Finance Professionals Firmwide Policy Portal Follow the letter and spirit of the Code andrelated policies Speak up!

4 If you are aware of or suspectviolations of the Code, Company policy,law or regulation, you are obligated to promptly report the violation throughthe Code Reporting Hotline or anotherappropriate resource Annually train and affirm to theCode of ConductRemember, you may be subject to more restrictive LOB/Regional/Corporate Function policies to access supplemental policies/ procedures. Go to: Know and comply with the Code and speak up if you have concerns or suspect violations Comply with applicable laws, regulations and policies wherever you operate in the world Protect confidential information trust is essential to our business success Practice sound ethical decision-making, and take actions that will preserve an ethical workplace Ensure ethical business practices always deal fairly and in good faith and never take unfair advantage of anyone through manipulation, concealment or abuse of privileged information Never buy, sell, or tip others off while in possession of material.

5 Non-public information relating to those securities Personal investment activities should never conflict with JPMC or client interests Never offer, give, solicit or receive anything of value if it is intended to give, or appears to give, an improper business advantage or benefit Protect all Company assets our physical assets, information, intellectual property and business relationships Avoid personal conflicts of interest, inside and outside of the workplace Communicate responsibly seek authorization to speak on behalf of the Company, and use good judgment on social media Treat others with dignity, and respect the diversity of cultures, backgrounds and experiences Do your part to promote a safe workplace, and report any activity that can pose a threat to others Recognize your responsibility as a global citizen give back to the communities where you work and live, and do your part to reduce the environmental impact of our operations Make sure political activities and charitable contributions comply with laws, regulations and applicable JPMC policiesOur Code Principles.

6 A Shared Responsibility HeritageYour Code ResourcesYour ResponsibilitiesAccess the Code and Related PoliciesOur Customers and the MarketplaceOur Company and ShareholdersEach OtherOur Neighborhoods and CommunitiesTable of ContentsA Shared Responsibility Our Heritage Personal Integrity Ethical Decision-making Manager Compliance with the Law Dealing with Confidential Information Sharing Concerns and Reporting Violations Non-retaliation Administration of the Code of Our Customers and the Marketplace Insider Trading and Information Barriers Personal Investment Activities Ethical Business Practices Anti-money Laundering Economic Sanctions Regulations and Anti-boycott Competition, Antitrust and Tying Anti-bribery.

7 Anti-Corruption Ta xe s Other Obligations of Some Our Company and Shareholders Protecting JPMorgan Chase s Assets and Using Them Appropriately Maintaining Accurate Records Avoiding Conflicts Personal Relationships Personal Finances Outside Activities Gifts and Entertainment Acting on Behalf of Our Company Communicating Responsibly Use of Social Media and Other Online Speaking on Behalf of the Company Other Types of Communication Leaving JPMorgan Each Other Diversity A Safe Workplace Alcohol-free and Drug-free Workplace Our Neighborhoods and Communities Political Activities Charitable Contributions Human Rights Corporate Responsibility Environmental Stewardship Closing ThoughtsNeed to Report a Potential Violation or Other Concern?

8 Glossary1 2355579911121315161617171818202122232324 2526 282829292930323334343637383939394142431 Our people, our services and our enduring commitmentto integrity have made us one of the largest and mostrespected financial institutions in the world. We all shareresponsibility for preserving and building on this proudheritage. A strong reputation can t be bought or soldand should never be compromised. Code of Conduct It begins with A Shared Responsibility to Our Personal IntegrityThousands of employees from our many predecessor institutions have worked to build our success now, we are responsible for preserving it.

9 Our Code of Conduct is an important tool in that respect. It lays out the expectations the Company has for each of us and provides the information and the resources we need to Conduct business ethically and in compliance with the law everywhere we operate. Our Code helps to ensure that the actions we take today will preserve this great legacy for the future. The Code applies to all of who work for, or on behalf of, JPMorgan Chase have a duty to demonstrate the highest standards of business Conduct . Our Code applies to employees and directors of JPMorgan Chase & Co. and its direct and indirect subsidiaries (the Code will refer to these companies as our Company or JPMorgan Chase ).

10 In general, consultants, agents and contract or temporary workers are expected to comply with the underlying principles of the Code as well as the Suppliers Code of the Code, you ll find information, links to definitions of key terms, Q&A s and links to some related policies to guide you in making ethical decisions. What you won t find is the answer to every question you may face at work or every related policy. In the absence of a specific policy, you have a responsibility to use good judgment, comply with the spirit of the Code and seek help from your Code Specialist if you have any questions or Code Specialist is an important resource.