Driving Responsible Growth through our Code of Conduct

To my teammates:

In 2014, Bank of America adopted the four tenets of Responsible Growth. Since then, this common focus on how we deliver for our clients, teammates, communities and shareholders has served as the foundation for our strong performance and progress.

Our Code of Conduct is aligned with our focus on Responsible Growth, guiding us in how we do our work. Our Code of Conduct outlines how we live our company’s shared values, uphold our ethical standards and deliver on our purpose to help make financial lives better.

To support these important outcomes, we are each annually required to review, acknowledge and understand our Code of Conduct. Thank you for doing that, and for all you do every day 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 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 summary of updates to the Code is qualified in its entirety by reference to the full text of the Code.