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.

Brian_Moynihan signature

Brian T. Moynihan
Chair and Chief Executive Officer

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.*

On January 30, 2024, updates were made to the Code, including a general refresh and reorganization of the covered topics, in many cases without substantive changes to the underlying topic. Such updates include:

  • the addition of (i) an “Accountability and discipline” section, which combines certain information previously included in multiple places in the Code and (ii) an “Antitrust and fair competition” section;
  • the reorganization of the (i) "Harassment, discrimination and retaliation" section to expand and clarify the scope of the Corporation's intolerance of discrimination, harassment and hate speech, (ii) conflicts of interest discussion into a standalone section of the Code, which includes streamlining and clarification of employee responsibilities and potential conflicts of interest in the context of family members, (iii) discussion of company, third party and employee information under the heading “Confidential information” including identification of personally identifiable information, (iv) “Electronic communications” and “Social media” discussions into separate sections with updated information in each case, (v) “Books and records” section, including clarification regarding disposal of records; (vi) discussion of reporting obligations under the heading “Reporting misconduct and workplace malpractice” and clarification of applicability to the conduct of third parties and (vii) “Business continuity,” “Workplace violence” and “Domestic violence” sections;
  • clarifications and/or streamlining of information in the (i) “Bribery and corruption” section regarding employee responsibilities, including third party conduct and (ii) “Bank of America assets,” including the use of non-company approved applications, third party websites and devices, such as generative artificial intelligence chatbots, and “Responding to media inquiries” sections; and
  • a procedural change regarding the submission of arrest disclosure and additional whistleblowing resources for jurisdictions outside the U.S.

Additionally, the Code was updated to better align with the Corporation’s enterprise messaging, reflect changes to relevant resources and for other non-substantive updates.

The above summaries of updates to the Code are qualified in their entirety by reference to the full text of the Code.

*December 15, 2024, updates are reflected in the English version below. Updates to the translations are forthcoming.