JPMorgan Chase Supplier Code of Conduct

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1 PMorgan Chase Supplier Code of Conduct Purpose This Code sets out the minimum principles that we expect You to follow in Your provision of products and services to PMorgan Chase Bank & Co. and any of our affiliates (PMC). You or Your means you as an individual or as a company, including your officers, directors, employees, and contractors. You and Your team engaged in providing products and services is expected to read, understand and act in accordance with it. We recognize that custom, practice, regulation and laws differ around the world. This Code should be read as applying globally, but we would highlight that specific regional changes (for EMEA, APAC and LATAM) may apply. This Code should be read in conjunction with (and is incorporated into) the agreement which governs our working relationship and sets forth the parties rights and obligations. There are other policies and documents that are incorporated into the agreement as well. We fully expect You to read and act in accordance with those policies and documents as well. In case of a conflict between the Code and the agreement, the agreement controls unless as otherwise specified herein or as otherwise required by law. You will ensure any subcontractors You use in furtherance of Your provision of products and services to PMC (if PMC permits such use) understand and comply with the Code. We retain the right to audit Your compliance with the Code at any time. The Code may change from time-to-time and You agree to be bound by the most current version. It can be found at: We strongly encourage that You review it carefully now and continually throughout our relationship. Section 1: Doing Business with PMC Requirements A. Assets of PMorgan Chase & Co. During the course of Your duties, You may come into contact with PMC assets. PMC assets include financial assets, physical assets, technology assets, intellectual property rights, PMC's name and brand, and information about, our products, services, customers, systems and people. You are expected to protect all PMC assets from theft, waste or other types of loss and use such assets solely in the course of Your duties. Telephones, systems and other electronic communication devices provided by PMC are the property of PMC and should be used for business purposes only. You must not forward s from a PMC managed account to either Your personal account or any other account for any purpose. PMC reserves the right to monitor, review and disclose all such data and communications through automated and manual processes as it deems appropriate, to the maximum extent allowed by law and this Code. B. Records You are not to falsify any records related to Your provision of products or services to PMC. If You maintain, manage or share information (regardless of media type), You must comply with PMC s global

2 record retention policy for records as directed by Your PMC relationship manager created as a result of business activities conducted on behalf of PMC. You are obligated to notify the PMC information/owner relationship or business unit manager in writing of a change to Your process that would create a new record or modify, replace or make an existing record obsolete. Retention obligations should be revisited with Your PMC relationship manager on an ongoing basis. C. Gifts A "gift" is anything of value for which a person is not required to pay the retail or usual and customary cost. A gift may include meals or refreshments, products, services, travel, tickets to entertainment or sporting events, or the use of a residence, vacation home or other accommodations, a raffle prize, travel expenses, a product or service discount, or charitable or political contributions made on supplier's own behalf. Gifts given to family members of PMC employees are considered gifts to PMC employees. Gifts from You for the benefit of those associated with PMC are generally discouraged and only permitted under very limited circumstances. Meals, refreshments and entertainment offered during the course of a meeting or other occasion are permitted as long as: (1) the purpose is business related, (2) attendance of PMC employees or persons associated with PMC relates to their job, (3) You attend the event, (4) the cost is reasonable and customary, and (5) it s an infrequent invitation. Tickets to entertainment events (e.g. sporting events or concerts) for personal use of PMC employees are prohibited even if the PMC employee pays for the tickets. Cash, gift cards, lines of credit, instruments of ownership (e.g., stock certificates) or any other thing of value redeemable for cash are never permissible as a gift. D. Conflicts of Interest You will disclose all actual or potential conflicts of interest due to either business or personal relationships with customers, suppliers, business associates, or competitors of PMC, or with other PMC employees. If You discover a potential conflict of interest involving any PMC employee or another third party supplier, You will tell Your PMC relationship manager. E. Political Activities and Lobbying You will not make any political contributions or present any gifts in the name of PMC to any candidate for public office or elected officials and You will ensure that any recipient of Your own political contributions (including any affiliated political action committees) does not represent an endorsement from PMC. Unless given prior written approval, You may not undertake activities on our behalf that would require registration as a lobbyist. Section 2: Your Commitments to PMC and Third Parties A. Confidential Information You are expected to comply with the agreement and all applicable laws and regulations governing the protection, use and disclosure of PMC proprietary, confidential and personal information. You are expected to safeguard the confidential information of third parties, including anything that You created, received or learned while working with previous employer(s) and while providing services to other customers. You should not use any third party confidential information for the benefit of PMC or

3 disclose any third party confidential information unless it has already been made public through no action of Your own. Such unauthorized disclosure is unethical and can also expose You and PMC to legal liabilities for which we will hold You accountable. B. Privacy Most jurisdictions have regulations relating specifically to the privacy of individuals, including employees and customers. You must be familiar with those regulations and policies that apply to them. Personal information should never be disclosed to anyone outside PMC except as permitted by law and in the proper conduct of our business, where disclosure is required by legal process or proper PMC legal approval. C. Honesty, Fair Dealing and Bribery and Anti Corruption You will always endeavor to deal fairly and in good faith with PMC customers, suppliers, competitors, business partners, regulators, and employees. You are not to make any facilitation payments to influence actions or to obtain an advantage for PMC. PMC does not tolerate bribery or corruption in any form. You will not give, or offer anything of value to anyone, whether a government official or corporate representative, to influence actions or to obtain an improper advantage for PMC, itself or any third party. D. Human Rights PMC expects You to be dedicated to exemplifying good corporate citizenship through Your commitment to respecting human rights as well as through a broader commitment to corporate responsibility generally. PMC also expects Your company s values and business principles to be consistent with those of PMC. This includes playing a constructive role in helping to promote respect for human rights through Your actions and by engaging with the governments of the countries in which You operate. Our respect for the protection and preservation of human rights is guided by the principles and initiatives we support in our Human Rights Statement located at E. Child Labor PMC will not engage in nor support the use of child labor. You are required to comply with applicable child labor laws and employ only workers who meet the applicable minimum legal age requirement for their location. F. Compensation and Working Hours & Conditions You are required to comply with all applicable wage and hour labor laws and regulations governing employee compensation, reimbursements, taxes and working hours. G. Health and Safety You are required to provide a non-violent and safe work environment, free of threats, intimidation and physical harm, that also supports accident prevention and minimizes exposure to health risks. You are required to comply with all applicable safety and health laws and regulations in the jurisdictions in which You operate.

4 H. Discrimination & Diversity You are required to comply with all applicable laws concerning discrimination in hiring and employment practices. PMC encourages You to provide an inclusive and supportive working environment, free of harassment and discrimination, in which all employees are valued and empowered to succeed (including the use of minority owned and other diverse businesses). I. Knowing Your workforce members Our agreement may require Your employees and other workforce members to be screened before and during Your engagement. Please refer to the agreement for specifics.. Environmental Compliance & Sustainability Objectives You are required to comply with all applicable environmental laws and regulations in the countries in which You operate. You are required to conduct Your operations in a manner that protects the environment by making reasonable efforts to meet industry best practices and standards with respect to managing energy use, greenhouse gas emissions and waste, and, where appropriate, having policies and management practices that encourage environmental stewardship from Your suppliers. You should inform PMC about environmentally-preferable services and product offerings, such as those with environmental certifications. You should also cooperate with assessments that PMC may undertake to evaluate Your environmental performance and compliance. K. Inside Information and the Policy on Information Barriers Buying or selling securities while in possession of material non-public information that You acquire by virtue of Your relationship with PMC is strictly prohibited, as is the communication of that information to others, whether expressly or by way of making a recommendation for the purchase or sale of such securities based upon that information. "Inside information" is material, nonpublic information about the securities, activities, or financial condition of a corporation, public entity, or other issuer of securities. Material, nonpublic information concerning market developments may also be construed to be inside information. Information is "material'" if it could have an impact on the market price of securities involved or if it is likely that a reasonable investor would consider the information important in deciding whether to purchase or sell the securities. Information should be considered "nonpublic" unless it is clearly public. If You are providing services to a Line of Business of PMC or area subject to the PMC Information Barrier policy, or to other information barriers designed to meet specific business needs, You are responsible for compliance with the provisions of applicable policies. Check with Your PMC relationship manager if any such policies apply.

5 Section 3: Your obligations and communications with (and about) PMC You are required to have Your own policies and procedures to ensure compliance with all Your Code obligations hereunder. You are expected to comply with applicable international and local legal requirements in the countries in which You operate. You will report any violations of the Code, whether by a member of Your team, a PMC employee, or another third party supplier, to Your PMC relationship manager. You should not promise or threaten to leverage Your potential or existing banking relationship with PMC or its subsidiaries in order to gain preferential treatment. Section 4: Your obligations using Social Media (External and Internal) For the purposes of the Code, social media is defined as interactive online communications in which users can generate and share content through text, images, audio, video and/or other multimedia and technologies accessed through any technological platform (such as desktop computer, laptop, smart phone and tablet) that enable social interaction. You may not make any public announcements about Your provision of goods or services to PMC. No information regarding Your assignment with PMC can be included in Your LinkedIn or other social media profile (including the sharing of Your PMC address (if applicable)). You should not communicate about anything relating to PMC s business unless You are specifically authorized to do so. You should not check in to PMC or a supplier or client location using location-based technologies, such as Foursquare, Facebook Places, Yelp, if You are there for PMC business purposes. This may disclose PMC confidential information or imply a relationship that could create risk for PMC. You should not use social media to discuss any of PMC s brands, products, services or programs. You should not circulate, post or distribute (on the Internet or otherwise) any photo, video or audio recordings taken at PMC facilities (while providing services to PMC) or at PMC work-related event at an external site. You should not connect via Social Media with PMC employees or customers unless You are already friends or family. You should not post, seek or provide recommendations or referrals by or of any PMC employees, customers or service providers. You should not post anything about PMC or its employees, customers, or service providers that others could be construed as offensive, harassing or intimidating, including, but not limited to ethnic slurs, sexist comments, discriminatory comments, insults and obscenities. Internal social media includes using PMC instant messaging tools or the PMC Intranet to connect and collaborate with your PMC colleagues where others can see what you post, such as commenting on a blog, participating in a contest or sharing ideas. If You are authorized to use such tools in connection with your duties at PMC: Speak only on Your own behalf and write in the first person.

6 Be respectful and factual if You choose to disagree with others. Do not be argumentative. Avoid speaking negatively about another person or a competitor s business. Keep internal conversations internal. Information shared on internal PMC social media sites is confidential and proprietary and is for internal, PMC use only. Do not disclose confidential information using internal collaborative tools unless You are permitted to do so. Certain geographies and business units may have local rules and regulations specific to social media that are more restrictive than what is stated herein and those still apply. You must notify PMC, if allowed by law, if You receive any subpoenas, regulatory requests, media inquiries, or other third party request regarding PMC. Section 5: What happens if You violate the Code If You are found to be in violation of the Code, we may terminate our relationship either at the master agreement or schedule level. We may also require supplier entity to reimburse PMC for any costs associated with the violation. If this section 5 conflicts with any term in our agreement, this section 5 shall govern. In closing As referenced above, this Code forms only part of the Agreement. The balance of the terms, conditions, guidelines and processes are contained in the Agreement and the various addenda referenced therein. Please do not hesitate to contact Your PMC relationship manager if You have any questions or concerns. We look forward to a long and mutually beneficial relationship with You.

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