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Our Code of Conduct helps us drive Responsible Growth every day

To my teammates:
Bank of America continues to stand strong for shareholders, clients, teammates and communities as we operate in a changing environment. We’re able to do this today — just as we have for the past decade — through our continued focus on driving Responsible Growth.
Our Code of Conduct guides how we do this important work for all our stakeholders. It also outlines how we bring our company’s shared values to life by upholding the highest ethical standards and delivering on our purpose to help make financial lives better.
That’s why we take the time each year to review, acknowledge and understand our Code of Conduct. This important step helps us drive Responsible Growth every day.
Thank you for all you do to deliver for all those we serve.

Code of Conduct Disclosure
Bank of America Corporation (the “Corporation”) periodically updates the Bank of America Code of Conduct (the "Code") applicable to all employees, including our principal executive officer, principal financial officer and principal accounting officer under U.S. Securities and Exchange Commission rules.
On January 12, 2026, changes were made to the Code, including updates or clarifications regarding (i) responsible use of AI and tools and technology, (ii) employee responsibilities, (iii) manager obligations for monitoring the work environment, (iv) workplace safety disclosures, (v) interactions with third parties, (vi) Forms of confidential and proprietary information, (vii) the misuse of company-approved applications, third party websites or devices, (viii) the use of non-company-approved applications, third party websites or devices, including AI-enabled search engines, (ix) insider trading restrictions, and (x) matters related to written electronic communications. Additionally, the Code was updated for consistency with the Corporation’s enterprise messaging, policy references and other non-substantive updates.
The above summary of the January 12, 2026 updates to the Code is qualified in its entirety by reference to the full text of the Code.