Code of Conduct - RBC

1 A Message From our CEO. Our Vision and Values Table of Contents Living Our Values Speaking Up Integrity in Dealing with RBC Clients, Communities and Others Integrity in Working Together at RBC. Integrity in How We Do Business Integrity in code of Conduct Safeguarding Entrusted Assets Integrity: Doing What's Right Publication date: January 1, 2022. Conclusion A Message A Message from David McKay From our CEO. President and CEO. Our Vision and Values Building trust by speaking up and doing the right thing At RBC, holding ourselves to the highest standards of integrity plays a critical role in achieving our Purpose to help clients thrive and communities prosper, and our Vision to be among the Table of Contents world's most trusted and successful financial institutions.

2 In short, how we do things is just as important as what we do. Our Values and our code of Conduct guide us and set expectations for our behaviour Living Our Values and decision-making. Our code is the roadmap we follow to serve our clients with the highest standards of integrity. It also lays the foundation for how we work together in a respectful, transparent and fair environment. Speaking Up Guided by our Leadership Model, we are each responsible for speaking up and doing the right thing to protect and enhance RBC's reputation and put our clients first. We all have a duty to report actual or possible misconduct and the right to be treated with dignity and respect when we do.

3 And that includes speaking up, challenging Integrity in and reporting unethical behaviour when it occurs, without fear of retaliation. Dealing with RBC Clients, Communities and Others Together, we can foster a culture that's built on trust, dignity and respect for all. Please read the code carefully, discuss what it means with your manager and Integrity in colleagues, and ask questions to ensure you understand it and what it requires Working Together at RBC of you. Our success depends on these principles. And it starts with each one of us. Integrity in How We Do Business Integrity in Safeguarding David McKay Entrusted Assets President and CEO. A Message from David McKay, President and CEO i Conclusion RBC's Values define what we stand for everywhere we do business.

4 They are reflected in our behaviour and the way We demonstrate our Vision To be Among the World's Our Vision A Message we build relationships and deliver value to all our clients, Most Trusted and Successful Financial Institutions From our CEO. employees, shareholders, communities and others we by living our Values in the decisions and actions we deal with. Guided by our shared Values and united in a common purpose, we can achieve our strategic goals and Values take every day. These five Values set the tone for our culture and unify us across geographies and businesses: Our and accomplish great results. Vision and Values Table of Contents Living Our Values Client First Collaboration Accountability Diversity & Inclusion Integrity Speaking Up We will always earn the right We win as One RBC.

5 We take ownership for We embrace diversity for We hold ourselves to to be our clients' first choice. personal and collective innovation and growth. the highest standards B. elieve in each other and Integrity in high performance. to build trust. P. ut client needs above our trust in teamwork and S. peak up for inclusion and Dealing with RBC Clients, own whatever our role, to colleagues' intentions B. e bolder, reach higher, empower people to grow B. e respectful, transparent Communities and Others build lasting relationships act with courage to realize and achieve more and fair in all relationships S. hare knowledge, listen potential and make a S. eek out and respect S.

6 Tand up for what we L. isten with empathy, and teach to learn and difference different perspectives to believe; speak with understand client needs to achieve more together Integrity in offer the right advice and O. wn it; seek out challenge conventional candour; constructively Working Together at RBC L. ook beyond ourselves to solutions accountability and approaches challenge see the bigger picture for empowerment to grow I dentify and act on the B. uild trust of clients, B. ring the best of RBC to opportunities and solutions and excel opportunities and needs colleagues and community deliver excellent value Integrity in B. e curious and learn that client diversity brings partners by listening to and differentiated client How We Do Business experiences continuously to build skills and understanding their and careers interests and needs Integrity in Safeguarding Entrusted Assets At RBC we bring these Values to life every day continuing to earn the trust of RBC's clients and each other and ensuring our strong reputation for doing what's right.

7 Our Vision and Values ii Conclusion Table of Contents A Message From our CEO. Our 1. Living Our 1 5. Integrity in How We Do Vision and Values Acting with Integrity Doing What's 1 Business 10. Our Shared Commitment and Avoiding and Managing Conflicts of 10. Approval of the Managing Our Close Personal Relationships in RBC Dealings 11. Table of Contents Managing Close Personal Relationships at Work 11. Managing Outside Activities and External Directorships 12. 2. Speaking Managing Gifts and Entertainment 13. Living Our Values Speaking Up, Asking Questions and Constructively Managing Inside Information and Securities Trading 14. Reporting Accepting Appointments or Inheritances 14.

8 Investigations, Inquiries and 4 Preventing Financial Crime .. 15. Speaking Up RBC's Commitment to 4 Fair 15. What We Expect of Our People 4 Global Economic 16. Integrity in Dealing with RBC Clients, 3. Integrity in Dealing with RBC Clients, Communities 6. Integrity in Safeguarding Entrusted 17. Communities and Others and Protecting RBC Client 17. Protecting RBC Client Protecting RBC 17. Integrity in Protecting RBC Business Keeping Accurate Books and 19. Working Together at RBC Protecting RBC's Reputation in Our Responding to Government or Regulatory 7. 20. Accessibility at Integrity in How We Do Business 4. Integrity in Working Together at 8. Respectful Integrity in Safeguarding Equal Opportunity, Fair Workplace and Human Rights.

9 8. Entrusted Assets Personal Information About 9. Workplace Health and 9. Conclusion A Message From our CEO. 1 Living Our Values Our Acting with Integrity Doing What's Right Vision and Values Throughout the code , RBC means RBC is a values-based organization. Our respect for and our commitments to our clients, shareholders, royal bank of canada and all its subsidiaries. communities and each other are rooted in our Values. RBC's code of Conduct (the code ) incorporates RBC's Values, and in particular our Value of Integrity, to guide our day-to-day actions and decisions so we For resources and information, can always do the right thing. visit Doing What's Right on RBCNet.

10 Table of Contents Every day our actions demonstrate not only our Value of always earning the right to be our clients' first choice, but also our personal commitments. We each have a responsibility to be truthful, respect others and comply with laws, regulations and RBC's policies (in the code , the word policy includes policies, procedures, standards, standing orders and frameworks). Over many years RBC has earned trust and a Living Our Values reputation for doing what's right through the actions of those who work here. A continued strong focus on doing what's right will sustain and build on that trust the cornerstone of the financial services industry and our relationships with clients and communities.