Employee Code of Conduct

Doing What's Right
 

The BNY Code of Conduct guides our actions and decisions as individuals and as a global financial services company responsible for overseeing nearly $50 trillion in assets for our clients – managing it, moving it and keeping it safe. The Code aligns with our strategic pillars: Be More For Our Clients, Run Our Company Better and Power Our Culture. Our guidelines for ethical behavior in our day-to-day work are guided by our culture of integrity, which means we do what is right, always, regardless of the impact on a specific transaction or short-term working relationship.

The Code provides six key guidelines that relate to many of the situations you may encounter working at our company: Respecting Others, Avoiding Conflicts, Conducting Business, Working with Governments, Protecting Company Assets and Supporting Our Communities. Topics range from protecting client and employee records and meeting our privacy obligations to responsibly growing our company with our own environmental, social and responsible business practices and conduct, which are further explained in our Sustainability Report.

However, the Code alone cannot address every possible situation. We expect all employees to exercise good judgment, using the Code as a primary resource to better understand our guidelines on ethical behavior, and to seek help when unsure of the right course of action. Above all, each of us, regardless of level, is obligated to put the interests of our company, clients and shareholders above any personal interest.

While the Code is fundamental, it is not your only resource. Your manager, Legal, Audit, Compliance and Ethics, and The People Team are readily available to answer your questions. When in doubt, I urge you to use these resources and escalate situations if you feel they are not getting the proper attention. You should never be afraid or reluctant to speak up.

Being a BNY employee means exercising good judgment and conducting yourself in a manner that is above reproach. Please take the time to review the Code of Conduct and keep it in mind to help ensure you always do what is right.