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 December 15, 2024, changes were made to the Code, including updates or clarifications regarding (i) the reporting of unethical or illegal conduct by the Corporation’s clients and prospective clients, (ii) the notice to employees, (iii) the reporting of workplace safety matters, (iv) the reporting of gifts and entertainment, (v) client authorization in connection with products, services and maintenance activities, (vi) the use of third party websites and personal devices, (vii) insider trading and (viii) matters related to written business related electronic communications, social media guidelines and the reporting of questionable or improper payments. 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 December 15, 2024 updates to the Code is qualified in its entirety by reference to the full text of the Code.

• Bank of America Code of Conduct