Wells Fargo Sustainability & Governance Report
Published August 2024

Table of contents
3

Introduction

39 Code of Conduct

4

About Wells Fargo

39 Anti-harassment and anti-discrimination policy

5

A letter from the Chief Executive Officer

39 Prioritizing employee safety and health6

Our approach

40 Governance7

Sustainability

41 Corporate governance and ethics

82023 sustainability impact highlights

44 Risk management

9

Operations and supply chain

47 Customer and product responsibility

15 Customer and client support

48 Cybersecurity and privacy protection

21 Community impact

50 Policy advocacy

31 Employee support

51 Respecting human rights

32 Living our Expectations

52 Disclaimer and forward-looking statements

33 Learning and Development

55 Appendix

35 Compensating employees competitively

56 United Nations Sustainable Development Goals

35 Employee benefits

57 Sustainability Accounting Standards Board (SASB) index

38 Employee feedback

62 Global Reporting Initiative (GRI) content index

38 Caring for employees in times of transition

69 Sustainable Finance Eligibility Criteria

39 Diversity, equity, and inclusion

75 Management’s assertion
76 Independent Accountants’ Review ReportTable of contents

Introduction

Sustainability

Employee support

GovernanceAppendix

Introduction
4

About Wells Fargo

5

A letter from the Chief Executive Officer

6

Our approach3

Table of contents

Introduction

Sustainability

Employee support

GovernanceAppendix

About Wells Fargo
Wells Fargo & Company is a leading financial
services company that has approximately$1.9 trillion in assets. We provide a diversified
set of banking, investment and mortgage
products and services, as well as consumer
and commercial finance, through our four
reportable operating segments: Consumer
Banking and Lending, Commercial Banking,Corporate and Investment Banking, andWealth and Investment Management.
Wells Fargo ranked No. 34 on Fortune’s 2024
rankings of America’s largest corporations.
We ranked fourth in assets and third in themarket value of our common stock among all
U.S. banks at December 31, 2023.

1

Cautionary notes:
This document contains forward-looking
statements about our business, including
discussion of the Company’s plans, objectives
and strategies, and expectations for ouroperations and business related to ourenvironmental, social, and governanceactivities. For additional information,
including about factors that could cause
actual results to differ materially from our
expectations, refer to the Disclaimer and
Forward-Looking Statements section of thisdocument and our reports filed with the
Securities and Exchange Commission,

including the discussion under “Risk Factors”
in our Annual Report on Form 10-K for theyear ended December 31, 2023, and in our
subsequent quarterly reports, as filed with
the Securities and Exchange Commission
1
and available on its website at www.sec.gov.
Data herein is as of December 31, 2023,
unless otherwise indicated.

Wells Fargo has provided external links within this document for your convenience, but Wells Fargo does not endorse and is not responsible for the content, links, privacy policy, or security policy of these websites.

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Introduction

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GovernanceAppendix

A letter from the Chief Executive Officer
At Wells Fargo, we are focused on building a sustainable, inclusive future by supporting housing affordability, small business growth,financial health, and a low-carbon economy. Our customers and communities are experiencing rapidly changing opportunities andchallenges, and we are evolving to meet their needs.
We continue to be balanced in our approach to environmental, social, and governance (ESG) issues, and we recognize that consumers andbusinesses want to do business with a company that has a strong reputation. A strong reputation is achieved not just from strong financial
performance, but from actively supporting employees, customers, and communities – especially those most in need.
Wells Fargo strives to have real impact in our communities and I’m proud of the work we do. I’m pleased to share Wells Fargo’s
Sustainability & Governance Report and hope you enjoy reading about the progress that we’ve made on our priorities and our ongoing
efforts to address today's challenges and prepare for tomorrow.

Charlie Scharf
Chief Executive Officer
Wells Fargo & Company

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Introduction

Sustainability

Employee support

GovernanceAppendix

Our approach
Since our founding, Wells Fargo has continuously
evolved to meet the financial needs of ourcustomers, clients, and communities. From
households to large businesses, in small towns
to urban centers, they can depend on us for thefinancial tools they need to address today’s
challenges and prepare for tomorrow.
Today, Wells Fargo is evolving to meetenvironmental and social challenges, finding
opportunities for meaningful impact, andcontinuing to support the financial needs of ourcustomers. The transition toward a resilient,equitable, sustainable future is a journey for all,across the broader economy.

Reviewing our priorities

To inform our approach to environmental,social, and governance related efforts weperiodically review underlying topics related totheses areas to help us understand which topics
are most important to the Company and our
stakeholders, and as a result should be prioritized.
As part of these reviews we consider a range ofstakeholder viewpoints and assess our internalbusiness strategy and sustainability impact
areas, as well as external voluntary standards,
frameworks and industry best practices to help
us maintain a balanced approach to these issues.
The most recent results of this review are generally
consistent with previous assessments, and continue
to inform our disclosures and other efforts. That is
why we have included topics such as sustainability
and climate, corporate governance and ethics, risk

management, and employee well-being inthis report.

Progressing our sustainability strategy

As part of our overall sustainability strategy,
we have established a framework around several
sustainability topics where we can make a positive
impact by leveraging our expertise, size, and scale.
Our focused impact areas, categorized around
Climate Action and Community Impact, highlight
opportunities to collaborate across our own
operations and with strategic community impact
organizations. Underlying our sustainability
impact areas, we maintain a focus on vulnerable
communities’ access to the opportunities
associated with a transition to a low-carbon
economy. Reflecting on the progress of thisstrategy in 2023, a few highlights stand out acrossour focused impact areas.

Reporting on our efforts

In this report, we aim to provide more informationon the progress toward our sustainability goals andpriorities, continued integration of sustainability
into our business, support for communities andemployees, and corporate governance activities.
We are proud of the progress we’ve made, andwe’re excited about the opportunities ahead.

We are making an impact in our communities as
we aim to address housing access and affordability,
support small business growth, and increasefinancial health. We continue to scale clean energy
in our operations and provide solutions to help ourcustomers do the same in their own sustainability
and resiliency efforts.
Wells Fargo plans to continue to evolve and play
an important role in meeting the changing needsof our customers, clients, and communities in thetransition to a lower-carbon economy and insupporting resilient communities for future
generations.

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Table of contents

Introduction

Sustainability

Employee support

GovernanceAppendix

Sustainability
82023 Sustainability impact highlights

9Operations and supply chain

15 Customer and client support
21 Community impact

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Introduction

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Employee support

GovernanceAppendix2023 sustainability impact highlights
Awarded a$7.5M

grant to Habitat for
Humanity International

advised, or facilitated approximately

Provided Credit
Builders Alliance aof mentorship forConnect to More℠
participants

Donated

$650M+

to help address housing
access and affordability
since 2019*For further information on our 2030 operational sustainability goals,
please see our Operations and Supply Chain section of this report.

~$23M

$1.5M

in sustainability-focused
grants to nonprofit
organizations

grant to assist organizations
serving credit insecure individuals

2030 Operationalsustainability progress*

Provided

Provided~17K hours

Donated$8.3M

in grants to strengthen the deployment of Greenhouse Gas Reduction
Fund (GGRF) capital into low-income and disadvantaged communities

GHG emissions(Scope 1 and Scope 2)

Energy

36%

36%

Waste

Water

73%

48%

of goalof goalOriginated, committed, advised,or facilitated approximately$178B

in sustainable financeactivities since 2021

Community impact

Provided$2.4B

in tax equity financing
for wind and solar projectsof goalof goalRenewable energy

6%of goalClimate action

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Introduction

Sustainability

Employee support

GovernanceAppendix

Operations and2
supply chain
Advancing sustainability
across our operations

Across our operational footprint, Wells Fargo
is working to make progress toward our goals
listed below. For example, in 2023, we continued
replacing existing lighting with high-efficiency
options across our branches and other locations.
We also advanced our efforts to adopt sustainable
design principles to create more efficient andcomfortable spaces for our employees.

At the same time, we continued to explore
programs to reduce waste and increase diversion
from landfills by decreasing material use at thesource, implementing composting, increasing
recycling, and seeking other ways to lower
our environmental impact.

to our employees where possible. In 2023,
we launched an initiative to reduce the saleof plastic bottled beverages from our foodservice operations. We worked with our waste
management and food service vendors to findalternative packaging solutions such as cans,
cartons, and glass bottles, depending on therecycling infrastructure available in the market.

Some examples of our progress include reducing
single-use plastic beverage containers in our
offices and providing filtered water filling stations

Wells Fargo has set operational sustainability goals for 2030

Reducing GHG
emissions (Scope 1
and Scope 2) from2019 levels by 70%.

Reducing total
waste stream from2019 levels by 50%.

Reducing energy
usage from 2019
levels by 50%.

Reducing
water usage
from 2019
levels by 45%.

Meeting 100%of our annual
purchased electricity
consumption needs
with new renewablesources.**Wells Fargo has been meeting 100% of its electricity consumption with renewable energy primarily with unbundled Renewable Energy Certificates from existing assets, with a goal to transition to long-term agreements that directly support new sources of renewable energy.

2Environmental and energy use data included in this report is subject to measurement uncertainties resulting from limitations inherent in the nature and the methods used for determining such data.

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GovernanceAppendixAchieving 100% renewable energy

Wells Fargo promotes the use of clean, renewable energy within our facilities. Our energy, water, and waste reduction work complements our ongoing
efforts to transition to new renewable energy sources. Our renewable energy work is supported, in part, through Wells Fargo’s multiyear purchaseagreements for electricity from renewable sources.
Since 2017, we have matched 100% of our global electricity consumption in our operations with renewable energy, and we aim to continue to transition
3
to long-term contracts for new renewable energy sources to meet future needs.
For Scope 1 GHG emissions that remain after our reduction efforts and Scope 2 (market-based) GHG emissions, Wells Fargo works closely with third4
party consultants with subject matter expertise to purchase carbon removal credits. With their support, we evaluate potential credit purchases against
specific quality criteria.

Renewable energy
5

Total electricity consumed

6

Total renewable energy purchased% of total electricity consumption covered by renewable energy
7purchases% of renewable energy purchases sourced from new long-term
3
renewable energy projects

Unit

2021

2022

2023

MWh

1,550,417

1,579,854

1,509,777

MWh

1,673,872

1,584,509

1,522,223

%

108

100

101

%

4

6

6

3

Wells Fargo has been meeting 100% of its electricity consumption with renewable energy primarily with unbundled Renewable Energy Certificates from existing assets, with a goal to transition to long-term agreements that directly support new sources of renewable energy.
New sources of renewable energy are defined as assets where commercial operation was achieved no earlier than 12 months prior to contract execution.
4
For further information on carbon credits, please see our Information Relevant to the California Voluntary Carbon Market Disclosures Act section of our Climate Report, which can be found on ourGoals and Reporting website.
5
Includes purchased electricity and self-supplied electricity generated through Wells Fargo’s on-site solar program.
6
Total renewable energy purchased includes self-supply renewable energy where Wells Fargo generates renewable energy from on-site solar installations, power purchase agreements, which are contracts for the purchase of power and associated Renewable Energy Certificates,
as well as Unbundled Renewable Energy Certificates, which are sold, delivered, or purchased separately from the electricity generated from the renewable resource.
7
Wells Fargo secured enough Renewable Energy Certificates to meet or exceed our annual consumption of purchased electricity.

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Introduction

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GovernanceAppendix

Operational Performance Data
Energy usage
Unit

2019 (baseline)

2020

2021

2022

2023

Fuel (includes fuel oil, propane, and fuels for fleet vehicles) MWh

24,713

16,97920,33023,712

23,042Natural gas

MWh383,277

353,183

310,483

321,539

296,898MWh

1,816,629

1,654,354

1,550,417

1,579,854

1,509,777

District heating

MWh

13,51813,211

12,911

13,2698,705

Total energy consumptionMWh2,238,137

2,037,727

1,894,141

1,938,375

1,838,422

Reduction in total energy consumption (from 2019baseline)

%

—

9

15

13

18

8

Electricity

9®

LEED buildings
Unit2019 (baseline)

2020

2021

2022

2023

Cumulative square feet of LEED-certified projects# of square feet

43,896,577

44,521,605

44,941,226

46,779,524

47,597,653

Cumulative number of LEED-certified projects# of projects

834

907

912

917

919

10

8

Includes purchased electricity and self-supplied electricity generated through Wells Fargo’s on-site solar program.
District heating includes purchased steam.
10
Includes certifications and recertifications under all LEED rating systems for relevant leased and owned spaces.
911

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GovernanceAppendix

Water
Unit

2019
(baseline)

2020

2021

2022

2023

Total water consumption (municipal water use)

Cubic meters 7,729,753

6,678,849

5,454,839

6,326,450

6,066,842

Reduction in water consumption (from 2019 baseline)

%

—

14

30

18

22

Unit

2019
(baseline)

2020

2021

2022

2023

General recycling: plastic, metal, and cardboard

Short tons

5,536

5,791

3,992

3,678

3,753

Other recycling/waste diversion

Short tons

6,980

4,376

5,070

4,648

4,453

Paper recycled

Short tons

40,092

24,356

21,203

21,624

20,106

Total recycling

Short tons

52,60834,52330,26529,95028,312

Total waste to landfill

Short tons

28,582

24,647

19,874

22,39923,058

Total waste stream

Short tons

81,19059,17050,13952,34951,370

Reduction in total waste stream (from 2019 baseline)

%

—

24

38

36

37

Waste

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GHG emissions

Wells Fargo calculates our operational Scope 1
and Scope 2 GHG emissions in accordance with
the Greenhouse Gas Protocol. Scope 1 emissions
are direct emissions that occur from sources
controlled or owned by an organization. Scope 2
emissions are indirect GHG emissions that result
from an organization’s use of purchased
electricity, steam, heat, or cooling. Scope 3
emissions are all indirect emissions (not includedin scope 2) that occur in the value chain of thereporting company, including both upstream anddownstream emissions. For the 2023 reporting
year, Wells Fargo engaged a third-party carbon
accounting software platform to perform GHG
emissions calculations for Scope 1, Scope 2,
and Scope 3 (categories 3 and 7). Engagementof the third-party resulted in certain carbon
accounting methodology and emission factor
changes for Scope 1, Scope 2 and Scope 3(categories 3 and 7) which did not result insignificant changes in emissions. Therefore, priorperiod emissions have not been updated to reflect
the changes implemented in 2023.

Introduction

Sustainability

Employee support

GovernanceAppendix

Scope 1 and Scope 2 emissions
11(location and market-based)
12

Unit
Total Scope 1

2019(baseline)

2020

2021

2022

2023
82,410*

MTCO2e 86,602

78,08773,319*77,476*

13

MTCO2e 771,327

694,011569,633*

593,495* 558,616*

13

Total Scope 2 (market)

MTCO2e 4,988

3,614

1,792*

4,424*

Total Scope 1 and Scope 2 (location)

MTCO2e 857,929

772,098

642,952*

670,972* 641,026*

Total Scope 1 and Scope 2 (market)

MTCO2e 91,591

81,701

75,111*

81,901*

86,044*

Carbon credits purchased and retired

MTCO2e 98,981

92,01981,809*82,414*86,044*

Remaining Scope 1 and Scope 2
15(market)MTCO2e 0

0

0*

0*

0*

Reduction in total Scope 1 and Scope 2(location) GHG emissions (from 2019baseline)

%

10

25

22

25

Total Scope 2 (location)

14—

3,633*

16

Scope 3 emissions

Unit

2021*

2022*

2023*

Category 1: Purchased goods and services

MTCO2e 1,429,619

1,300,698

1,415,876

Category 2: Capital goods

MTCO2e 348,249

293,289455,831

Category 3: Fuel and energy-related activities
17(not included in Scope 1 or 2)

MTCO2e 121,357

123,938

228,465

Category 5: Waste generated in operations

MTCO2e 13,058

12,73013,026

Category 6: Employee business travel(air travel only)

MTCO2e 4,795

27,40338,354

Category 7: Employee commuting (excluding
remote work)

MTCO2e 218,795

289,051

253,813*Wells Fargo’s Statement of Greenhouse Gas Emissions, which can be found on our Goals and Reporting website, has been reviewed by an independent accountant for the years ended
December 31, 2021, 2022, and 2023.

11

Totals in this figure and others in this report may not add exactly due to rounding.
MTCO2e stands for metric tons of carbon dioxide equivalent.
A location-based method reflects the average emissions intensity of grids on which energy consumption occurs (using grid average emission factor data). A market-based method reflects emissions from electricity that Wells Fargo has purposefully chosen. It derives emission factors from contractual
instruments, which include any type of contract between two parties for the sale and purchase of energy bundled with attributes about the energy generation, or for unbundled attribute claims.
14
For further information on carbon credits, please see our Information Relevant to the California Voluntary Carbon Market Disclosures Act section of our Climate Report, which can be found on ourGoals and Reporting website.
15
As part of its journey toward net zero, Wells Fargo has implemented carbon reduction strategies and purchased energy attribute certificates and carbon credits sufficient to cover its total Scope 1 and Scope 2 (market-based) emissions for 2023.
16
This report includes relevant Scope 3 categories for which Wells Fargo calculated emissions for the year ended December 31, 2023.
17
In 2023, we updated our calculation methodology to reflect a change in emission factors.
12
13

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Engaging with our suppliers andstakeholders on sustainability

We regularly engage with suppliers and otherstakeholders on a range of environmental, social,and governance topics. In 2023, we held
approximately 50 forums, reaching more than
5,000 internal and external participants. We’re also
working across our supply chain and throughout ourlines of business to help reduce carbon impacts.
At Wells Fargo, we expect our suppliers to operate
in a way that is consistent with our Supplier Codeof Conduct (PDF), all applicable laws andregulations, and contract terms. As we work with
suppliers to understand their environmental andsocial considerations, we encourage them to
implement systems designed to mitigate negativeenvironmental and social impacts.

Introduction

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Employee support

GovernanceAppendix

Further, the following table shows how we’ve
engaged certain suppliers to report theirenvironmental data through the CDP (formerly
Carbon Disclosure Project) climate questionnaire.
This helps us better understand their emissions
profile and approach to climate resiliency.
Wells Fargo’s Supplier Code of Conduct, which
we review periodically and update as needed,
can be found on our Goals and Reporting website.
It outlines our expectation that suppliers not
only comply with applicable laws, regulations,and contract terms, but also conduct themselveswith the highest standards of ethical businesspractices.

Integrating ESG into supplier engagement
Suppliers invited to participate in CDP survey

Unit

2023

# of suppliers

372

Supplier CDP survey participation# of suppliers

234

Responding suppliers who have self-reported
science-based targets for Scope 1 and Scope 2
emissions# of suppliers

94

18

18

Completing the CDP survey is a voluntary effort undertaken by companies at their discretion.

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GovernanceAppendix

Customer and19
client support
As a bank, we have an opportunity to make an
impact through the work we do with our clientsand customers in support of their sustainabilityrelated business drivers.

Making progress toward oursustainable finance goal

We continue to make progress on our goal to
deploy $500 billion in sustainable finance by 2030.
Set in 2021, this goal is one component of ourbroader sustainability strategy. Wells Fargo
identifies and enables sustainable financeopportunities through our capabilities across ourlines of business, solutions, and broad range of
products. Sustainable finance at Wells Fargo
supports both environmental and social
sustainability activities. Similar macroeconomic
factors that influence broader financial markets
also impact our sustainable financing. While we do
not expect our progress to be linear, our Company
continues to support our clients, customers, andcommunities, especially as sustainable activities
become more integrated into the fabric of oureconomy.
The following figure provides an overview ofprogress toward our $500 billion goal (see nextpage) measured using our Sustainable Finance
Eligibility Criteria (“the criteria”), which areincluded in the Appendix of this report.

19

From 2021 to 2023, Wells Fargo originated,
committed, advised, or facilitated approximately$178 billion in sustainable finance activities,
representing approximately 36% of our goal
to deploy $500 billion of sustainable financebetween 2021 and 2030. Our sustainable financeactivity is divided into three categories: financingaligned to common industry sustainability-related
standards and frameworks (“standard-aligned
sustainable finance”), environmental finance, andsocial finance. For more details on each category
please see our Sustainable Finance Eligibility
Criteria in the Appendix of this report.
Approximately 57% of our progress through 2023
supported standard-aligned sustainable finance,
while close to 27% supported environmental
finance, and about 16% supported social finance.
For each of our first three years of progress
toward our $500 billion goal, we obtained limited
assurance on our assertion of the total amount ofsustainable finance activities originated,
committed, advised, or facilitated that meet thecriteria. For more information about the limited
assurance, please see the Independent Accountants'
Review Report in the Appendix.

In this section Wells Fargo references information from third-party sources, Wells Fargo cannot guarantee accuracy of this information.

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GovernanceAppendix

Sustainable finance progress*(2021-2023)

Sustainability bonds$21.1B (12%)

Sustainability-linked
loans and bonds$58.7B (33%)

Other Environmental$0.5B (<1%)

Green loans
and bonds$18.0B (10%)$178B

Pollution prevention andcontrol and circular economy$1.6B (1%)
Green buildings$6.3B (4%)

Social loans
and bonds$4.2B (2%)

Energy efficiency$7.3B (4%)

Housingaffordability$18.1B (10%)

Cleantransportation$15.7B (9%)
Energygeneration$16.1B (9%)

Other Social$0.7B (<1%)

Socioeconomic
advancement andempowerment$9.5B (5%)*See Sustainable Finance Eligibility Criteria in the Appendix of the this report for more details. Showing 2021-2023 sustainable finance activities that have been originated, committed, advised, or facilitated that meet the Sustainable Finance Eligibility Criteria.
Totals may not sum due to rounding. Showing categories with ≥ $0.1B, anything less than 1% is categorized as either “Other Environmental”, which includes sustainable water and wastewater management, or “Other Social” which includes education and healthcare.

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Supporting the transition to moresustainable operating models

Across the economy, many companies arenavigating complex transitions to achieve
their environmental, social, and business goals.
We work with our clients to develop thoughtfulfinancing structures that help advance theirgoals, address transition-related challenges,
and leverage transition-related opportunities.
We believe we have built the track record andexpertise to make Wells Fargo among the leadersin sustainable finance. In 2023, according toBloomberg, Wells Fargo ranked third insustainability-linked loan bookrunning in the
United States.
At the request of our clients, Wells Fargo may
structure transactions to support theirsustainability goals. For example, Teradata
Corporation set a 2025 goal to reduce both its
Scope 1 and Scope 2 GHG emissions by 34% froma 2021 baseline. To support their goals, Teradata
worked with us to add an ESG amendment to its$400 million credit line and a $500 million termloan. We crafted a deal structure that includes
key performance indicators (KPIs) selectedby Teradata. The first KPI is focused on the
Company’s Scope 1 and Scope 2 emissionsreduction goals.

Introduction

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We also work with our clients to bring moresustainable financing options to the marketplace.
Wells Fargo worked with Panama-based BAC
International Bank, Inc. to arrange a $270 million
broadly syndicated loan facility, which included
a sustainability tranche of $135 million. The
sustainability tranche enabled BAC International
Bank, Inc. to use the proceeds primarily to financerenewable energy projects in the Central
American region.
Transitioning to more sustainable operating
models includes both social and environmental
aspects of sustainability. In 2023, theInternational Finance Corporation (IFC), a
member of the World Bank Group, issued a social
bond totaling $1.5 billion in proceeds. Wells Fargo
acted as joint lead manager on the transaction.
The transaction represents IFC’s largest-eversocial bond. Bond proceeds will fund a diverse
range of social projects, including affordable basic
infrastructure (e.g., clean drinking water, sewers,
sanitation, transport, and energy), access toessential services (e.g., healthcare, financing, andfinancial services), affordable housing, supporting
women-owned small- and medium-sizedbusinesses that lack access to finance, foodsecurity, and supporting companies thatincorporate people at the base of the economic
pyramid into their value chain.

GovernanceAppendix

Fleet electrification is often a key lever for clients
pursuing sustainability goals. Wells Fargo isscaling the adoption of electric vehicles (EV) in
commercial fleets by providing financing for avariety of zero- or low-emissions vehicles andcharging structures for our customers. We offer
leasing products on commercial vehicles thatmonetize the Inflation Reduction Act (IRA)
Section 45W tax credit, which results in a lower
interest rate for the lessee. We have also
developed a streamlined, point-of-sale financing
option for EV vendors to help facilitate EV
deployment.

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Scaling clean energy

Wells Fargo provides the capital needed tosupport the expansion of sectors aimed at making
industry more environmentally sustainable.
Tax equity financing, which lowers the cost of
renewable energy by allowing developers toefficiently realize tax credits, is a cornerstone of
the renewable energy market. Launched in 2006,
our Renewable Energy & Environmental Finance(REEF) team has years of experience in helping
clients navigate these often complex structures.
REEF provided approximately $2.4 billion in tax
equity financing for wind and solar projects in
2023, bringing REEF’s lifetime investment to$18.2 billion. This included a tax equity
transaction with Avangrid, Inc. and Copenhagen
Infrastructure Partners for a large offshore windproject, Vineyard Wind 1.
In addition to our tax equity offerings, Wells Fargo
is also a capital provider and advisor to renewableenergy companies looking to scale their business.
In 2023, Wells Fargo served as the Sole Green
Loan Coordinator for Leeward Renewable
Energy’s $407.6 million green bridge loan tofinance the initial construction costs of greenfieldsolar and battery storage projects. Leeward is a
U.S.-based renewable energy company that owns
and operates utility scale wind, solar, and energy
storage facilities across nine states, totaling
approximately 2,700 MW of generating capacity.
We also supported Leeward in the structuring of aGreen Loan Framework, which defines the eligible
green activities the loan can be used for, themanagement of the loan proceeds, and the annual
impact reporting requirements.

Introduction

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Proceeds from this financing will be allocated totwo projects:•

Morrow Lake is an approximately 200 MW
solar electricity-generation facility located in
Frio County, Texas. Construction on the
project began in mid-2023, and Morrow Lake
Solar is expected to be operational by late 2024.

•

Antelope Valley Battery Energy Storage
System (BESS) project is an approximately
126 MW, 504 MWh stand-alone facility
colocated with another solar project in
Kern County, California. The project isdesigned to support the resiliency andreliability of the California electrical grid.

GovernanceAppendixBattery storage deployment is critical toadvancing clean-energy adoption. Wells Fargo has
the capabilities to support our clients in bringing
large-scale battery energy storage projects to thegrid. For example, Wells Fargo acted as the solerating advisor and coordinating lead arranger on
a $2.4 billion construction and term loan for a
portfolio of solar and battery projects for The
AES Corporation. The two solar-plus-storage
projects and one solar project in the portfolio
are anticipated to total 855 MW and 2,400
MWh, respectively. Plans also call for a 14-miletransmission line that will connect the project toSouthern California Edison’s Windhub Substation.

First-of-its-kindTax equity transaction for a large offshore wind project in Massachusetts with Vineyard Wind 1

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Adopting more sustainable options

Wells Fargo supports our individual customers’
actions to adopt clean-energy technologies andsustainable products for their homes and small
businesses. For example, in 2023 we financed
more than one in six EV loans in the United States.
As an exclusive financing partner for the HVAC
manufacturers Trane Technologies and Carrier
Corporation, we provide financing for customers,
including those who install ENERGY STARqualified, efficient HVAC systems from thosemanufacturers. ENERGY STAR appliances can
reduce costs and be more efficient for customers.

Introduction

Sustainability

Employee support

Our Wealth and Investment Management (WIM)
financial advisors support clients who areinterested in integrating sustainability or personalvalues into their investments. WIM clients haveaccess to a broad suite of investment solutions
and strategies that integrate values alignment,
impact investing, and ESG analysis. WIM alsooffers clients analysis of their investment
exposures to help tailor their investment
portfolios to their personal goals and values.
We encourage consumers to adopt electronic
statements to reduce paper volume. For example,
we offer paperless account statements throughour digital channel, paperless options at ATMs,
and digital account-opening processes. We
implemented a new digital marketing strategy in
2021 to increase awareness and drive consumers
to adopt electronic statements versus mailed
paper statements.

GovernanceAppendix

Supporting more environmentally*
sustainable cities
Wells Fargo financing supports projects
that help cities and regions across theUnited States in their efforts to become
more environmentally sustainable. In 2023,
Wells Fargo served as the Senior Manager
for the Washington Metropolitan Area
Transit Authority’s (Metro) sustainability
bonds, which totaled $797.8 million.
These were the first Metro bonds to securea Sustainability-Climate Transition
designation from the International CapitalMarket Association. Metro is one of thelargest transit organizations in the U.S.,
with a service area of approximately
1,500 square miles across Washington, D.C.,
Maryland, and Virginia. In Metro’s fiscal year
2023, Metro carried 199.7 million riders
across its rail, bus, and MetroAccessservices. The bonds will fund Metro capitalprojects, including bus garage rehabilitation
and replacements, bus fleet replacement
and zero-emission bus transition, automatictrain control equipment upgrades, traction
power upgrades, work on Metro’s existing
fleet of trains and its next generation ofrailcars, and rail station LED lighting
improvements.
*In this section Wells Fargo references information from publicly available third-party
sources, Wells Fargo cannot guarantee accuracy of this information.

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Employee support

GovernanceAppendix

Understanding nature considerations

We understand that protecting and conserving
biodiversity, maintaining ecosystems, andmanaging natural resources are importantfactors for global sustainability.
In 2023, we conducted a nature landscapeassessment to better understand nature-related
considerations and practices across our industry.
In support of our corporate clients, we areworking directly with them to support theirunderstanding of nature and biodiversity impacts
and dependencies of their operations. This can
support dialogue on sustainable financing options
suited to help them achieve their biodiversity
and nature-related objectives.

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GovernanceAppendix

20

Community impact

Wells Fargo takes a thoughtful approach tophilanthropy in support of programs forcommunities that need it most. Through ourbusinesses and the Wells Fargo Foundation,
we strive to align our resources and expertise to
make a positive impact in communities, addresscomplex societal issues, and help build a more
inclusive, sustainable future for all. We aspire tostrengthen historically underserved communities
through investments in pathways to economic
advancement and generational wealth. In addition,
we focus our social impact on supporting
nonprofits that strategically align with ourfunding priorities: housing access andaffordability, small business growth, financial
health, and sustainability. In addition, theCompany supports community needs in local
markets.

21,22

2023 philanthropic giving by focus area

Small business growth 18%
Financial health 13%

Housing access andaffordability 40%$300M

Sustainability 8%

Human and social services 6%

Other 6%

Education 4%
Civic engagement 2%
Workforce development 2%
Arts and culture 1%

20

In this section Wells Fargo references information from third-party sources, Wells Fargo cannot guarantee accuracy of this information.
Priority focus areas are bolded. Focus area categorization is based on the primary assigned focus area of each grant at the time of application. Grants with multiple focus areas are sown only under their primary area of focus.
22
Numbers are rounded to the nearest whole percentage.
21

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Improving housing accessand affordability

Wells Fargo strives to innovate solutions that
increase access to affordable, sustainable, andwealth-generating housing for vulnerable
populations and communities.
Since the beginning of 2019, we’ve donated morethan $650 million to help address housing access andaffordability in the country, including supporting
affordable rentals and home ownership to keeppeople housed.

Partnering to construct andrepair affordable housing

In 2023, the Wells Fargo Foundation announced
new commitments with Habitat for Humanity
International and Rebuilding Together, twonational nonprofits focused on housing thosein need.
Through the 2023 Wells Fargo Builds program,
Habitat for Humanity International received a$7.5 million grant, enabling local Habitat for
Humanity affiliates to build and repair more than360 homes nationwide, including accessibility
modifications to meet the needs of low-income
older adults and people with disabilities.

Introduction

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GovernanceAppendix

The 2023 Wells Fargo Builds program also
awarded $1.4 million in grants to Rebuilding
Together, allowing approximately 90 homes in
49 communities across the country to receive
essential home repairs and safety modifications.
Since 2010, Wells Fargo has donated more than
$18 million to Rebuilding Together and its
affiliates in other communities to support
rebuilding efforts across the country with a focus
on helping veterans, older adults, people withdisabilities, families with children, and victims ofdisaster remain in their homes.

Housing Affordability Breakthrough Challenge

The Wells Fargo Foundation expanded its
commitment to housing affordability throughanother $20 million competition with Enterprise
Community Partners to find housing solutions
focused on three categories: financing,
construction, and access and resident support.
The winning solutions included a workforce
training program that prepares students forhomeownership; a new way of financing housing
in rural communities like the Mississippi Delta;
and a new construction technology that reduces
the carbon footprint of multifamily buildings.

Since 2010, Wells Fargo and the Wells Fargo
Foundation have donated more than $129 million
to Habitat for Humanity International and local
affiliates, including grant funding for new homeconstruction and repairs, disaster response andrebuilding efforts, and Habitat’s Aging in Place
program to enable people to remain in theirhomes as they age.

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23

Introduction

Sustainability

Supporting small business growth

Venture Fellows programThis included working with Silver Lining to launch
their Small and Medium-sized Businesses (SMB)
Mental Health Series, a public-engagement
campaign aimed at connecting with small businessowners to help them realize the significance of
their contributions to their families, communities,
and the economy. Feedback gleaned from thesmall business owners resulted in the creation of afree SMB De-stress Guide to help entrepreneurs
cope with stress and avoid burnout.

Small Business Resource Navigator

A key pillar of our community impact work
focuses on improving access to capital, networks,
and knowledge for underserved entrepreneurs.

Connect to More℠

Developed in partnership with the Nasdaq
Entrepreneurial Center, the Connect to More℠program provides women entrepreneurs access to
networking opportunities, coaching, and a libraryof tailored resources to assist them to overcome
distinct challenges. The program includes theopportunity to leverage the Center’s signature24
12-week Milestone Circles mentorship program.
By the end of 2023, Connect to More℠
participants collectively received approximately
17,000 hours of mentorship support and reported
tremendous benefits because of the program.

23
24

Employee support

GovernanceAppendix

With a grant awarded by the Wells Fargo
Foundation, Larta Institute successfully
established its Venture Fellows program, whichsources cleantech innovations directly fromentrepreneurs in underserved communities.
The program aims to help diverse innovators
scale their ideas and help their communities
become more resilient in response to theimpacts of climate change. In its first year,
the Venture Fellows program supported
14 early-stage startups with technical assistance,
mentoring, access to capital, and legal services.

The Community Reinvestment Fund, USA useda Wells Fargo Open for Business grant tosuccessfully launch its Small Business Resource
Navigator, an online portal helping connect
small- business owners to potential financing
options and technical assistance throughCommunity Development Financial Institutions(CDFIs) across the United States. Since its
launch, the Small Business Resource Navigator has
introduced nearly 2,500 small businesses to CDFIs
for potential credit opportunities and technicalassistance services. This online tool simplifies andstreamlines the capital process for entrepreneurs,
helping them quickly and effectively identify
potential options.

In this section Wells Fargo references information from publicly available third-party sources, Wells Fargo cannot guarantee accuracy of this information.
Figures related to Milestone Circles are self-reported to Wells Fargo by grant recipients and as such, Wells Fargo cannot guarantee the accuracy of the totals.

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Open for Business Fund

Wells Fargo established the Open for Business
Fund by voluntarily donating all gross processing
fees from PPP loans made in 2020 —approximately $420 million to provide grants forCommunity Development Financial Institutions andother nonprofit organizations. Since its launch in2020, the multiyear Open for Business Fund has
aimed to provide small business owners withaccess to capital and resources to help themnavigate the ups and downs of the economy.
Through December 31, 2023, the initiative has
deployed the grant funds to nonprofits focusedon serving small businesses at the community
level, with an emphasis on assisting diverse smallbusiness owners. Funded nonprofits leveraged theOpen for Business Fund to raise more than $2.2
billion to help small businesses scale their
25
enterprises.

Introduction

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GovernanceAppendix

Open for Business Fund program impact
26(through 2023)~337K

Businesses served

79%

53%

71%

~461K 1.1M

Businesses
servedthat areraciallyor ethnicallydiverseowned

Businesses
servedthat are
women
owned

Businesses
served thatare owned
by low- tomoderateincome
individuals

Jobs createdor preserved

Hours oftechnical
assistanceprovided

Passing learnings onto others
The spirit of entrepreneurship can encourage small business owners to extend their resources to support others. Stephanie Vasquez, owner ofFair Trade Café in Phoenix, is an example. She received a small business loan through the Open for Business program for her cafe, as a memberof the Arizona Hispanic Chamber of Commerce and in partnership with Raza Development Fund. She then took fellow business owners under
her wing to help them learn how to scale their businesses through her nonprofit organization, Empowering Latina Leaders in Arizona.

25
26

Figures related to the Open for Business Fund are self-reported to Wells Fargo by grant recipients and as such, Wells Fargo cannot guarantee the accuracy of the totals.
Open For Business grant recipients report on cumulative impact data for up to three years following receipt of an Open For Business grant. Impact data will continue to be tracked through early 2025.

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Supporting financial health•Wells Fargo aims to open pathways to economic
advancement in our communities, with a special
focus on investing in diverse and low- tomoderate-income communities. We collaborate
with trusted industry and community groups todevelop programs that offer improved financial
security for the long term.
Our efforts to build an inclusive economy include
programs and resources that help increase
equitable access to economic opportunity andenable individuals to increase their savings, reduce
debt, secure credit, and acquire assets in pursuitof their financial goals. Many of these resources
are available through the Wells Fargo Financial
Health hub.

11.9M

customers
accessed their.
free FICO® scoresprovided by Wells Fargo

In addition, the Wells Fargo Foundation
strategically supports nonprofits to help unbanked
individuals find the resources and take the steps
necessary to build credit and move into the financial
mainstream. Key programs supported throughgrants in 2023 include:•

Sustainability

Employee support

Credit Builders Alliance Capitalizing Credit
Deserts program: Credit Builders Alliancereceived a $1.5 million grant to assist
organizations serving credit-insecureindividuals in six states identified as credit
deserts, which are generally lower-income
communities where an above-average
number of people don’t have credit scoresand lack access to mainstream, lower-interest
sources of borrowing money. The programprovides access to training, tools, andsupport for organizations to better address
their clients’ needs.
Compass Working Capital: With a$3.45 million multiyear grant commitment,
Wells Fargo became a leading funder of thestrategic growth campaign for Compass
Working Capital, a leader in leveraging thefederal Family Self-Sufficiency program tohelp improve the financial health of families
living in public and subsidized housing.

Additionally, from 2018 to 2023 the Wells Fargo
Financial Capability and Credit-Building grant
programs donated more than $36 million to
grantees in support of financial coaching and27
credit-building programs. These programs
have helped people increase savings by acollective $41 million and reduce debt by nearly$77 million. They’ve also helped 83,000 people
establish or improve their credit scores, and33,000 people acquire bank accounts or otherfinancial assets.
.

27

Introduction

GovernanceAppendixFinding success with help from theInternational Rescue Committee

International Rescue Committee, which is fundedby our Financial Capability grant program:
Arriving in California from Afghanistan in 2017,
Palwasha brought an unwavering determination
to build a better future for her children in the U.S.
She sought to open her own childcare business,but she was unbanked, had no credit, and lacked
the financial stability to become a businessowner. After receiving financial coaching throughthe International Rescue Committee’s Pathways
program, Palwasha was able to open checking
and savings accounts, and obtain a creditbuilding loan. After making payments toward
her loan, she was approved for an unsecured
credit card. After attending additional tax,
credit-building, budgeting, and banking
workshops, Palwasha received a businesslicense and opened her childcare business,doubling her household income and buildinga brighter future for her family.

Programs have self-reported data and outcomes provided here.

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Deploying sustainability-focused
philanthropy

Wells Fargo leverages its philanthropy to support
an equitable transition to a low-carbon economy
with an emphasis on mitigating climate impacts
and expanding sustainable finance solutions inlow- and moderate-income communities.

Improving climate resiliency

One priority of our sustainability philanthropy
efforts is on improving climate resiliency inhistorically underserved communities. Severe
weather events can cause significant property
damage, but physical impacts are just one aspect.
Climate change can also affect livelihoods andhouseholds, particularly when those affected lackthe financial means to respond to such crises.

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Employee support

Establishing the Communities Reimagining
Energy (CoRE) initiative at the National
Renewable Energy Laboratory (NREL)In addition to providing grants directed to localorganizations, we also support the development ofstudies and research frameworks for key national
intermediaries. With our support NREL launched its
CoRE initiative, a first-of-its-kind hub for inclusive
and equitable research that seeks to provide support
to low-income communities as they build and pursue
energy-transition strategies. NREL’s work with thesecommunities will also help to inform its broader
efforts, especially around applied clean energy
research and innovation.

GovernanceAppendix

Promoting urban forestry to confront urban
heat islands
We also provided support for Conservation Law
Foundation (CLF) to accelerate efforts to growand maintain urban forests, which can play a rolein promoting physical and mental health, as wellas influencing energy needs for heating andcooling buildings. CLF has noted that this work
can benefit historically underserved populations,
who often reside in areas with lower existing
tree canopies.

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GovernanceAppendix

Accelerating and broadening cleantech adoption

Even though many low-carbon technologies are considered deployment-ready, barriers to adoption persist, especially for low- to moderate-income
communities. Our cleantech-related grant making seeks to directly address these barriers, with the goal of accelerating adoption and broadening accessto the various benefits of low-carbon technologies.

2

In July 2023, we announced our 12th IN cohort, comprised of seven sustainableagriculture startups with solutions aiming to address the climate mitigation andadaption needs of global food systems. Each startup received up to $250,000 in
non-dilutive funding and will work alongside researchers at the Donald Danforth
Plant Science Center in St. Louis, the world’s largest independent plant science
research institute.
2

The Wells Fargo Innovation Incubator (IN )Established in 2014 in partnership with NREL,2
IN is a cleantech incubator that helps earlystage startups develop and deploy innovative,
technology-based sustainability solutions.
2
IN provides cleantech startups with technicalassistance and access to labs and equipment, withthe goal of demonstrating technical feasibility andmarket relevance for high-potential solutions inpriority sectors (commercial and residential realestate and agriculture).
2

IN also engages a network of 60+ Channel
Partners across the U.S. to support an accelerated,2
equity-focused climate transition. The IN
portfolio now includes 72 companies that haveraised more than $2.06 billion in external followon funding, equivalent to an average of more than
2$101 for every $1 awarded through IN .

Two of the startups participating in the cohort are highlighted below:

InnerPlant (Davis, California)
Develops seed technology to access the natural response pathways of plants andcode crops to communicate early and specific stresses (e.g., drought) via easy-tocollect optical signals. The technology helps farmers understand plant needs andprescribe the right amount of fertilizer and crop-protection products at the optimal
time.

HabiTerre (St. Louis)
Uses remote sensing, process models, and artificial intelligence to evaluate past,present, and future cropland performance, including net GHG emissions, soil-carbon
sequestration, crop rotation, management history, yield, water use, and nutrient
dynamic.

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Identifying justice, equity, diversity, andinclusion best practices for cleantech
In 2023, Wells Fargo funded Elemental
Excelerator's landscape analysis of justice, equity,
diversity, and inclusion (JEDI) practices and sharedneeds across the cleantech innovation ecosystem.
After conducting a survey of current practices,
Elemental convened representatives from 26
cleantech accelerator and investor organizations toshare opportunities to deepen practices toward thegoal of improving access to emerging cleantech
solutions by historically disadvantaged
communities.
Key opportunities that were identified included
enhanced preparation for traditionally excluded
founders to secure investments, incorporating
lived experiences into hiring practices, andimproved case-making through communications
and storytelling through a JEDI lens.

Supporting equitable implementation
28of the Inflation Reduction Act

The IRA has catalyzed climate-related activity
in the U.S. In addition to the new incentives andopportunities it has created for private capital, the
IRA has also established new programs intended
to support historically underserved communities.
The largest of these programs, the Greenhouse
Gas Reduction Fund (GGRF), is expected to award$27 billion in 2024 to nonprofit intermediaries (e.g.,green banks and community development financial
institutions) that will lend and provide funding for anarray of decarbonization projects, including many in
low-income and disadvantaged communities.
28
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Employee support

Preparing nonprofit intermediaries todeploy GGRF funds

To help nonprofit intermediaries prepare to receiveand deploy GGRF funding, we provided $8.3 million
in technical assistance and capacity-building grants
to strengthen organizations’ knowledge on topics
like developing clean energy finance products.
This work included supporting GGRF applicants
Climate United and the Coalition for Green Capital,
as well as partnering with the University of New
Hampshire on a $1.2 million grant to deliverclean energy finance training to the community
development financial institutions sector and tobuild out lending tools. The training reached 95
financial institutions who learned about leveraging
IRA incentives for building decarbonization, loan
product design, and business planning for29
decarbonization lending.
Helping community-based organizations
access clean energy capital for low-income
communities
Another area we focus our sustainable philanthropy
on is equitable access to climate solutions. Due tosocial and economic factors, historically underserved
communities are often at greatest risk from theimpacts of climate change. We support efforts togive these communities an active voice in thedevelopment of solutions.

GovernanceAppendix

Wells Fargo provided a $1.6M grant to theseorganizations so that their work in racial justice,affordable housing, small business, and other issue
areas could integrate a climate focus. The grant will
support a climate vulnerability assessment and thedevelopment of a strategy positioning for theirmember organizations to respond on behalf of
their communities to various climate funding andpolicy opportunities.
Demonstrating how IRA incentives canbe used to decarbonize affordable housing
In 2023, Wells Fargo supported the National
Housing Trust with a $1 million grant to launch
the IRA Bootcamp for affordable housingdevelopers and state housing finance agencies.
The purpose of the affordable housing developers
training was to provide technical assistance onfederal decarbonization programs, such as the U.S.
Department of Housing and Urban Development(HUD) Green and Resilient Retrofit Program,to help developers access potential subsidies
available for their projects. The trainings for state
housing finance agencies focused on aligningfederal incentives with each state’s affordable
housing programs to enhance both existing andnew funding features designed to help individuals
stay in their homes long term.

The National Urban League, UnidosUS, and National
Coalition for Asian Pacific American Community
Development are national membershiporganizations serving African American, Latinx, andAsian American and Pacific Islander communities.

In this section Wells Fargo references information from publicly available third-party sources, Wells Fargo cannot guarantee accuracy of this information.
Figures related to clean energy finance training are self-reported to Wells Fargo by grant recipients as such, Wells Fargo cannot guarantee the accuracy of the totals.

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Volunteering and giving
to amplify our impacts

Our employees have long supported ourcommunities and the causes we and they careabout both through financial contributions andvolunteer service and commitments. Wells Fargo
is dedicated to raising awareness of sustainable
and social-impact opportunities and supporting
employee engagement in their communities —providing flexibility for employees to serve inways that speak to them. The Company alsooffers eligible employees 16 hours of paid
volunteer time each year to serve their causes.

Introduction

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Employee support

GovernanceAppendix

830,000
employee service hours

Volunteering in 2023: highlights

Following the 2022 launch of our Employee
Impact teams, which connect employees tolocal volunteer opportunities, Wells Fargo saw
a 20% participation rate in overall membership
across our 53 Employee Impact teams. Employee
Impact teams raise awareness of our philanthropic
priorities and elevate the visibility of sustainability
while providing flexibility for employees to servearound their personal interests. These teams
promote key sustainability and social impact
issues, and community involvement. They leadand organize activities such as educational
opportunities, operational projects, volunteer
events, membership recruitment, and otheractivities.

$14M provided by employees to eligible charities through our Community Care Portal in 2023

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In addition, we aim to amplify the generosityof our employees through the Wells Fargo
Community Care Grants program. Community
Care Grants are philanthropic dollars provided
by Wells Fargo that employees can direct toorganizations of their choosing. Employees may
qualify for up to $2,000 in Community Care Grants
per year for their preferred eligible charities.
Now in its second year, the Welcome Home
Program seeks to create more affordable andsustainable homes and communities through amonth-long, company-wide volunteer initiative.
In 2023, over 200 different charity partners
received direct volunteer support from
employees, more than doubling the numberof nonprofit partners served in 2022. Over thecourse of five weeks, the program saw morethan 7,300 employees volunteer more than
34,000 hours across 443 opportunities.
The Global Fellows Program, executed in partnershipwith the Grameen Foundation, connects Wells Fargo
employees with nonprofit partners in the U.S. andbeyond. This program helps selected organizationsin under resourced communities by utilizing
Wells Fargo employees’ unique talents and expertiseto support the needs of these nonprofits. In 2023,
teams comprising 84 Wells Fargo employees usedtheir professional skills to solve a business problem
for 15 organizations.
Wells Fargo expanded our skills-based volunteer
programming in 2023 beyond the Global Fellows
Program through a new partnership with Taproot
Foundation, which helps connect mission-driven
organizations with skilled volunteers.

Introduction

Sustainability

Employee support

GovernanceAppendix“I can’t thank you all enough for the [Global Fellows] support.
Both teams did an incredible job and provided great insight andsupport. These have been two of the best volunteer-driven‘consulting’ projects that I’ve been involved with in my 15 years
at W!se. The enthusiasm, teamwork, analytical skill set, hard work,and creativity were all on full display every time we met with thetwo teams. It was a true pleasure to work with them. Thank you!”David J. Anderson, W!se President and CEO,A nonprofit that aims to improve economic mobility by developing financial literacy

Wells Fargo developed a “pro bono marathon”,
in which 51 Wells Fargo employees provided
free professional services to 12 Wells Fargo
Foundation rural-serving grant recipients.
Over the course of two to three days, Wells Fargo
employee volunteers worked as virtual teams with
nonprofit partners to develop a discrete solution
to an organizational challenge.

Volunteering our talents to
support nature and biodiversity
In addition to leveraging their expertise to
assist entrepreneurs and small businesses,
Wells Fargo employees engaged in otherefforts to support nature and biodiversity.
In 2023, our employees volunteered with
the Billion Oyster Project, an effort torestore oyster reefs in New York Harborthrough public-education initiatives. The
volunteers helped build reef structures,
prepared shells for hatching, sorted andcounted baby oysters, and participated in
educational activities.
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Employee support
32 Living our Expectations
33 Learning and Development
35 Compensating employees competitively
35 Employee benefits
38 Employee feedback
38 Caring for employees in times of transition
39 Diversity, equity, and inclusion
39 Code of Conduct
39 Anti-harassment and anti-discrimination policy
39 Prioritizing employee safety and health31

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Employee support
Our people are what set Wells Fargo apart andare critical to our success. We continue to invest
in our employees by offering market-competitivecompensation, career-development
opportunities, a broad array of benefits, andstrong work-life programs. We provide all eligible
full- and part-time employees with acomprehensive set of benefits designed tosupport their physical, emotional, and financial
health to help them make the most of their wellbeing. We are dedicated to recruitment and careerdevelopment practices that support ouremployees and promote diversity throughout
our workforce, including leadership positions.

Living our Expectations
At the foundation of Wells Fargo’s culture is aset of core Expectations that play a vital role inthe strength of our Company, and our ongoingcommitment to attracting, retaining, anddeveloping the best people to propel ourtransformation journey. Our Company
Expectations establish the highest standards ofintegrity and operational excellence and guide
how we collaborate and execute as a team;embrace our differences; simplify and improve
the work that we deliver; and develop, recognize,
and inspire our employees to achieve performanceexcellence. We celebrate and hold employees
accountable for demonstrating behaviors inalignment with these Expectations throughout theyear – they are a cornerstone of our performance
management and recognition programs.

Wells Fargo Expectations

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Employee support
Learning and Development
Wells Fargo invests in the development of ouremployees and managers. During 2023, weinvested approximately $200 million in a varietyof employee Learning and Development
programs, including functional training,
regulatory compliance, leadership andprofessional development, and early careerdevelopment programs. The curriculum includes
90 unique training programs for new hires.

Global Early Careers

In 2023, the Global Early Careers team continued
to make progress toward its strategic goals to
attract, develop, and retain a best-in-classpipeline of talent across Wells Fargo. We continue
delivering on traditional talent programs at theintern, analyst, and associate levels while also
expanding scope to include strategic partnerships
within our local communities that emphasize
skills-based hiring. These emerging talent
programs – inclusive of high school and college
apprenticeships as well as sophomore
development opportunities – aligned with
nontraditional talent profiles and allowed us tohire, retain, and upskill junior-level talent outsideof core campus recruitment efforts.

Manager development and support

We recognize that having effective managers
is key to employee engagement and retention.
In 2023, we introduced a Monthly Manager Series,
an ongoing initiative to put timely information
and resources in the hands of leaders throughout
the year, as well as educate and reinforce themanagers’ role in the performance management
cycle activities. The sessions allow managers toapply external thinking to their daily work. Topics
were timed to deliver relevant information when
it would be most useful. Approximately 13,400
managers participated in the program in 2023.
In addition, we launched and delivered live
webinars that include internal and external
expert speakers on key topics throughout theyear. These webinars provide managers tools andpractical tips to lead themselves and their teams.
Building essential skills for managers has been
another area of focus. The New Manager
Essentials Learning Path of courses provides anopportunity for new managers to attend sessions,participate in self-paced learning opportunities,
complete activities on the job, and find resources
on a variety of topics. We launched additional
resources such as the new ‘Manager Toolkit’for the first 90 days in the role to support theirtransition as well as a ‘Manager Connections
Newsletter’ to provide ongoing advice.

Nine Brandon Hall Excellence Awards in 2023

Our Learning and Development efforts earned nine Brandon Hall Excellence Awards in 2023, recognizing
achievements in diversity and inclusion training, innovative use of gaming, video instruction, and other training
program content.
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GovernanceAppendix

Employee support“Doing the right thing, being the best manager I can be, adhering toCompany policy (both by the letter and in spirit) are very important
to me. HR Manager Advisory helps me do that.”
Feedback from a Manager

Manager Advisory fills the gap in support for
managers who don’t have a direct contact for
their general Human Resources (HR) advice
needs. Following our 2022 launch, we expanded ourManager Advisory support to all U.S. managers
with an enhanced level of support to provide skill
development, guidance, and advice to effectively
lead their teams. The function provides directaccess to experienced HR professionals to help
managers effectively and consistently apply
Wells Fargo’s procedures, guidelines, and manager
expectations as they build high-performing teams
throughout the Company. Support includes
interpretation and application of HR-related
policies and development of strategies forcoaching, managing employee performanceand talent, and optimizing team dynamics.
Feedback from managers also helps Wells Fargo
continually enhance the level of support bybuilding resources and expertise in the areas
where help is most often requested.

Career management and mentoring

We provide the tools and resources our employees
need to achieve their career goals at Wells Fargo.
We have launched a career framework thatprovides employees and managers resources tohelp assess skills, understand options, and planfor future career steps. We have learning anddevelopment programs in place to support skillbuilding in strategic areas, such as Technology andProduct and core businesses such as Consumer,
Small, and Business Banking.

With officer titles aligning to job levels, it is now
easier for employees to navigate their career
paths across the Company.
The Wells Fargo Global Mentoring programprovides employees with the tools and resources
they need to grow their careers. Mentees gain
access to, and advice from, a trusted, usually moresenior colleague, while mentors have a chance tofine-tune their coaching skills, become more
active listeners, and pay forward lessons learned
that have helped shape their careers.

In 2023, we launched a new global officer title
framework grounded in our job architecture —the way we consistently describe and organize
jobs and give our employees more clarity about
their roles, responsibilities and expectations.
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Employee support“We want our employees to have the tools available to bring theirbest selves to work. That’s why we offer comprehensive benefits that
focus on well-being – physical, emotional, and financial. Through this
holistic approach, our programs support a healthy, engaged, andhigh-performing workforce.”
Dr. Brent Pawlecki,
Wells Fargo Chief Health Officer

Compensating employees competitively
Competitive and fair compensation is key toattracting and retaining the best talent. We
provide clear and simple guidelines on how
compensation is determined.
Wells Fargo pays for performance andcompensation is linked to Company, businessgroup, and individual performance, including
meeting regulatory expectations and creating
long-term value consistent with the interestsof shareholders.

Wells Fargo promotes risk management throughcompensation which promotes effective risk
management and discourages imprudent orexcessive risk-taking.

leave, critical illness and accident insurance,life insurance, disability coverage, personalizedreferral and discount services, flexible spending
accounts, and legal services plan coverage.

Wells Fargo is also focused on attracting andretaining talent to drive superior long-term
Company performance.

Eligible employees in the U.S. have an opportunity
to participate in our 401(k) Plan and receive adollar-for-dollar Company match of up to 6%
of eligible compensation. In addition, eligible
employees earning less than $75,000 a year
receive an automatic 401(k) Plan contribution
of 1% of eligible compensation. Eligible U.S.
employees may also participate in a stock
purchase plan.

Employee benefits

Wells Fargo provides eligible employees witha comprehensive set of benefits designed tosupport their physical, emotional, and financial
health.
We adjusted our U.S. benefits eligibility in 2023
so that eligible employees can take advantage ofmany of our benefits offered from their first dayof employment at Wells Fargo. These “Day One”
benefits include healthcare coverage, parental

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Employee support“I was at my heaviest weight in 2022, and one year later I have lost over
100 pounds. I am living the Well Life every day by making healthy eating
choices. Wells Fargo supports this in so many ways, including Well Life
programs, on-campus fitness centers, and the Real Appeal Program.”
Kathy Deaver,Corporate Security General Associate Manager

Workplace flexibility

Well Life
Well Life focuses on the employee experience andthe ways that Wells Fargo enables employees tolive their fullest lives — both inside and outside of
the Company. It centers on building a connection
between Wells Fargo and employees and potential
employees. In 2023, we debuted Well Life Stories,
which highlights diverse employees sharing theirunique experiences such as their career journeys
and health triumphs, and launched the Let’s Talk
About It internal campaign that contributed to anincrease in use of our Employee Assistance
Program (EAP), which provides free counselingsessions.

We provide our employees with opportunities andbenefits to support balancing work and life. This
includes time away programs and, depending on
the employee's role, hybrid-flexible work
schedules.

Physical healthWells Fargo offers comprehensive andcompetitive medical benefits. Medical plans in the
U.S. offer preventive care services covered at
100%, prescription drug benefits, and a networkof doctors and hospitals to help employees andtheir families maintain their health. In 2024, we
introduced a health care concierge service at no
additional cost to U.S. medical plan members.
This service offers expert second medical opinions,health care navigation, billing and claims support,
high-quality provider recommendations and 24/7
clinical advice.

Wells Fargo contributes up to 85% of the perpaycheck cost of medical insurance, depending
on compensation level, for U.S. employees.
Employees, spouses, and domestic partners
enrolled in certain U.S. medical plans can earn
health and wellness dollars for completing
specified wellness-related activities. In addition,
employees earning up to $100,000 and enrolled incertain medical plans receive automatic funding ina health savings account.

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Employee support
Mental healthFamilyThrough comprehensive support, Wells Fargo
aims to reduce the stigma sometimes attached tomental health challenges and promote employee
well-being. In 2023, our comprehensive mental
health campaign included manager and employee
resource guides and featured personal stories
from both external experts and employees. While
resources available to employees vary across theglobe, in the U.S. and in some other countries,
these include a mental health mobile app, one-onone wellness coaching, weekly mindfulness
meditation, and virtual yoga classes.

Family building benefits in the U.S. include
support for fertility treatments, adoption
reimbursement, parental leave, and free breast
milk shipping for employees who are traveling on
Company business. In 2023, we also introduced a
new surrogacy and fertility donor reimbursement
program, giving all eligible U.S. employees theopportunity to be reimbursed up to a $35,000
lifetime maximum in eligible surrogacy and donor
expenses. In 2024 we expanded that benefit
to offer up to a $35,000 combined lifetime
maximum for expenses related to surrogacy
and adoption. Additionally, we understand theimportance of flexibility in addressing familyneeds. In the U.S., we provide up to 16 weeks ofpaid time off following the birth or adoption of achild. In 2024, we made this paid time off available
to eligible U.S. employees on day one of
employment. Market competitive paid time off
following the birth or adoption of a child is alsooffered internationally. When regular childcarearrangements fall though, employees in the U.S.
and some other countries have access to backup
in-home and center-based childcare. Backup adultcare is also available. Both options are throughprearranged partnerships with Wells Fargo andavailable to employees with a copay for services.

In 2023, we enhanced our U.S. Employee
Assistance Program to offer our employees andtheir eligible dependents six free in-person or
virtual counseling sessions per issue for up to
12 free sessions per calendar year. Employees
can also receive customized referrals to licensed
EAP counselors and easy access to available
appointment times to simplify scheduling.
Similar counseling services that provide
immediate support for mental health needs
are available across the globe.

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Employee support
payment adjusted according to the local
compensation levels.

with resources to help their career transitions,which include the following:

Employee feedback•

Employees that are displaced are provided
a 60-day notice period, as required by theWells Fargo’s Displacement Policy, unlessotherwise required by federal, state, or local
laws. Individuals are still considered employedduring the entire notice period.

•

During the notice period, they have theopportunity to be considered for open roles
within the Company by using the internal
hiring or internal movement process.

•Employees are eligible for a minimum of eightweeks of severance and up to 52 weeks, basedon their completed years of service, during
which they will also have continued accessto health coverage.

•

Employees who are displaced are offered
access to career transition services through athird-party service provider that offers careercoaching, professional resume writing,connections to hiring managers andrecruiters, and interviewing practices.

We believe in listening to and learning from ouremployees. We leverage employee feedback toenhance the employee experience and drive
improvements to our culture and processes.
Employees are invited to share their thoughts
through surveys, town halls, direct engagement
between managers and employees, and leader-led
sessions.
Employees submit ideas through our employee
feedback platform called Loudspeaker, and someof the ideas that have been implemented in recent
years have led to efficiencies, innovation, andgreater employee engagement.

Recognition
The Global Recognition Program focuses onrecognizing employees’ performance plus
personal and professional achievements. In 2023,
approximately 176,000 employees received
awards for outstanding performance andmilestone anniversaries through our recognition
program. In addition, the program supports peerto-peer recognition and appreciation via e-Cards.

One-time cash payment

In 2024, in appreciation of employees' efforts
towards supporting our customers, a one-time
cash payment of $1,000 was announced for U.S.
employees making $75,000 or less in annual
salary and less than $85,000 in total cash
compensation. Eligible employees outside of theUnited States also received a one time cash

We conduct various surveys throughout the year,
including our Global Employee Survey andquarterly pulse surveys. The surveys are a way for
employees to share their candid thoughts andfeedback. Senior leadership and our directors
analyze employee feedback, as shared in thesurvey results, to help the Company improve
employee experience, workplace engagement,
and the way we do business.

Caring for employees intimes of transition
As Wells Fargo continues transforming ourbusinesses, we recognize that employees may be
impacted, and we provide communication about
the programs and opportunities they can accessfor support. U.S. employees who may be displaced
due to organizational restructuring are supported

Where we operate outside of the U.S., thepractices of managing redundancies andworkforce restructuring vary based on legal
and regulatory requirements and local market
practices. International support may include
enhanced severance pay arrangements, employee
assistance programs, and career transition
services.

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Employee support
Diversity, equity, and inclusion
Wells Fargo is committed to advancing diversity,
equity, and inclusion with a belief that acompany’s workforce should reflect thecustomers they serve. More information isavailable in our annual Diversity, Equity, andInclusion Report, which can be found on ourGoals and Reporting website.

Pay equity
Wells Fargo is committed to fair and equitablecompensation practices. We have conducted anannual pay equity review through engagementwith a third-party consultant for a number ofyears. The pay equity review compares thecompensation of women to men globally and U.S.
minorities versus U.S. non-minorities, taking into
account factors such as role, level, tenure, andgeography. We may make adjustments tocompensation in the event the review identifies
gaps. The year-end 2023 review showed thatwomen at Wells Fargo continue to earn more than99 cents for every $1 earned by their male peers,and U.S. employees that are racially/ethnicallydiverse earn more than 99 cents for every $1
earned by their Caucasian/white peers.

Code of Conduct
The Wells Fargo Code of Conduct (Code), which
can be found on our Goals and Reporting website,
applies to all employees, including executive
officers. Employees are expected to adhere to theCode, Global Employee Handbook, and Company
policies and to comply with applicable laws andregulations. The Code covers topics including
anti-bribery and corruption,

anti-competitive behavior, insider activities,
gifts, conflicts of interest, global compliance,
discrimination, information confidentiality andsecurity, and reporting potential misconduct.

Anti-harassment andanti-discrimination policy
Our Anti-harassment and anti-discrimination
policy establishes that Wells Fargo does nottolerate harassment or discrimination based on
any characteristics protected by applicable laws,
including age, race, color, gender, national origin,sexual orientation, or disability.
This policy applies broadly to all Wells Fargo
employees and covers conduct both inside andoutside the workplace, including during workrelated or company-sponsored events, businesstravel, at customer locations, and remote work.

range of potential safety concerns, including
ergonomic issues.
New employees are expected to complete safety andhealth training, and targeted employee groups haveadditional training made available. Managers are
expected to provide training on job-specific hazards
at the time of an employee’s initial assignment andprovide retraining as necessary.
In 2023 we piloted our Workplace Safety
Advocates initiative. The advocates are employee
volunteers trained on basic ergonomics and hazard
identification. The purpose of the initiatives to help
promote safety and health in the workplace by
establishing communication and cooperation
amongst employees. Advocates help reduce theincidence of work-related injuries and illness byprioritizing safety in the work environment.

It encourages and sets expectation that all
employees should report any concerns related
to harassment or discrimination, whether it’s
directed at the employee or someone else, even if
all the facts are not immediately available or if it isunclear whether the conduct violates the policy.

Prioritizing employee safety and healthWells Fargo understands the importance ofproviding a safe and healthy environment.
The Safety & Health Program was further
augmented in 2023 with initial training for
a new Workplace Safety Advocates initiative.
Workplace Safety Advocates received two daysof training, learning how to identify a wide

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Governance
41 Corporate governance and ethics
44 Risk management
47 Customer and product responsibility
48 Cybersecurity and privacy protection
50 Policy advocacy
51 Respecting human rights
52 Disclaimer and forward-looking statements

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Corporate governanceand ethics
Commitment to sound and effective
30
corporate governance practices
Wells Fargo and its Board of Directors arecommitted to sound and effective corporate
governance practices.
Our Board has adopted Corporate Governance
Guidelines, which provide the framework for thegovernance of our Board and Company, including
the independence of a significant majority of thedirectors on the Board, and all members of the
Audit, Governance and Nominating, Human
Resources, Corporate Responsibility, and Risk
Committees. Additionally, the Board adopted
Director Independence Standards. These Director
Independence Standards consist of the New
York Stock Exchange’s “bright line” standardsof independence, as well as additional standards.
At the Board level, the Governance and Nominating
Committee is responsible for overseeing corporate
governance practices, and the Corporate
Responsibility Committee provides primary
oversight for significant strategies, policies, andprograms related to social and public responsibility.

30

Further information related to the Corporate Governance Guidelines, the Governance and Nominating Committee, and the Corporate Responsibility Committee can be found on ourLeadership and Governance website.

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Board and board committee oversight of ESG issues

Risk Committee

Oversees our company-wide risk management framework andindependent risk management function.

Board Oversightof Sustainability, Human CapitalManagement, DEI, and related
Social Responsibility Matters

Corporate Responsibility Committee

Oversees our significant strategies, policies, and programs on social andpublic responsibility matters, including environmental sustainability,
climate change, and human rights.

Human Resources Committee

Oversees our human capital risk and human capital management,
including DE&I, and also oversees the Company’s culture.

Members of our senior leadership team have specific areas of oversight related to sustainability, social, and DE&I matters:

Head of Public Affairs

Head of Diverse Segments, Representation, and Inclusion

Reports to the CEO and is responsible for strategies and initiatives onsocial and public responsibility matters, including sustainability andcommunity impact.

Reports to the CEO and is responsible for advancing
DE&I efforts in the marketplace and the workplace.

Chief Sustainability Officer
Leads coordination of sustainability
initiatives, including the Climate
Implementation Initiative and theInstitute for Sustainable Fiance.

Head of Philanthropy andCommunity Impact
Leads community engagement andenterprise philanthropy, including theWells Fargo Foundation.

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Executive compensation

31

The Human Resources Committee of the Board
oversees Wells Fargo’s performance management
and incentive compensation programs andapproves all compensation for Operating
Committee members. The Human Resources
Committee oversees the performance goals set
for our Operating Committee members, andapproves goals for the Chief Executive Officer,
with the aim of aligning goals with the Company’s
strategic plan, risk appetite, and risk and control
framework.
More information about the Company andindividual Named Executive Officer performancefor 2023 and other aspects of our executive
compensation program is available in the 2024
Wells Fargo Proxy Statement, which can be foundon our Annual Reports and Proxy Statements
website.

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Our Board believes that our directors bring to our
Board a variety of different backgrounds, skills,
professional and industry experience, and otherpersonal qualities, attributes, and perspectives that
contribute to the overall diversity of our Board.
The Board expects to maintain its focus on Board
diversity, as well as on other desired qualifications
and experience identified by the Board in future
director recruitment efforts. More information about
Board diversity is available in the 2024 Wells Fargo
Proxy Statement, which can be found on our
Annual Reports and Proxy Statements website.
More information about our Corporate
Governance Guidelines can be foundon our Leadership and Governance website.

Board diversity
The Governance and Nominating Committee andour Board of Directors believe it is essential thatthe composition of our Board reflects the diversityof the communities we serve. As described in the
Corporate Governance Guidelines and theGovernance and Nominating Committee’s charter,
the Governance and Nominating Committee willconsider, in identifying or evaluating first-timecandidates or nominees for director, the current
composition of our Board and the interplay ofcandidate’s or nominee’s experience, education,
skills, background, gender, race, ethnicity, and otherqualities and attributes with those of the other
Board members.
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Risk management
Wells Fargo manages a variety of risks that cansignificantly affect our financial performance andability to meet the expectations of our customers,
shareholders, regulators, and other stakeholders.
Our Risk Management Framework sets forth thethe Company’s core principles for managing andgoverning its risk. Many other documents andpolicies flow from its core principles. The Risk
Management Framework is annually reviewed forappropriate updates and approved by the Board’s
Risk Committee.
Risk is part of our business model. Risk is thepossibility of an event occurring that could
adversely affect our ability to achieve ourstrategic and business objectives. The Company
routinely takes risks to achieve our business goals
and serve our customers. These risks include
financial risks, such as interest rate, credit,
liquidity, and market risks; and nonfinancial risks,such as operational (which includes complianceand model risks), strategic, and reputation risks.
Risk is managed by everyone. Every employee, inthe course of their daily activities, creates risk andis responsible for managing risk. Every employee
has a role to play in risk management, including
establishing and maintaining the Company’s risk
and control environment. Every employee mustcomply with applicable laws, regulations, andCompany policies.

Risk and culture. Senior management sets thetone at the top by supporting a strong culture,defined by Wells Fargo’s expectations and Codeof Conduct, that guides how employees conduct
themselves and make decisions. The Board is
responsible for holding senior management
accountable for establishing and maintaining thisculture and effectively managing risk. Senior
management expects employees to speak up
when they see something that could cause harm
to our customers, communities, employees,
shareholders, or reputation. Because risk
management is everyone’s responsibility, allemployees are empowered and expected tochallenge risk decisions, when appropriate, andescalate their concerns when they have not beenaddressed. The Company's performance
management and incentive compensation
programs are designed to establish a balanced
framework for risk and reward under core
principles that employees are expected to know
and practice. Effective risk management is acentral component of employee performance
evaluations.

Risk operating model —roles and responsibilities
The Company has three lines of defense formanaging risk: the Front Line, Independent Risk
Management, and Internal Audit. Each line ofdefense has distinct risk management
responsibilities.
•

Front Line: The Front Line, which comprises
principal lines of business and certain enterprisefunction activities, is the first line of defense.
The Front Line is responsible for understanding
the risks generated by its activities, applying
adequate controls, and managing risk in thecourse of its business activities.

•

Independent Risk Management:
Independent Risk Management is the secondline of defense. It establishes and maintains
the Company’s risk management programand provides oversight, including challenge toand independent assessment and monitoringof, the Front Line’s execution of its risk
management responsibilities.

•

Internal Audit: Internal Audit is the third line ofdefense. It is responsible for acting as anindependent assurance function and validates
that the risk management program isadequately designed and functioning effectively.

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Risk governance
The Board oversees the Company’s business,
including its risk management. It assesses senior
management's performance and holds senior
management accountable for maintaining andadhering to an effective risk management
program. The Board carries out its risk oversight
responsibilities directly and through its
committees. The Risk Committee oversees
management’s implementation of the Risk
Management Framework, including how the
Company manages and governs risk.

Environmental and Social Impact
32
Management Framework
As part of our dedication to a strong risk culture,
Wells Fargo recognizes that environmental andsocial issues have the potential to impact various
risk types covered by our Risk Management
Framework, including reputation risk, credit risk,
and strategic risk.
Our Environmental and Social Impact Management(ESIM) Framework is designed to provide clarity andtransparency to our stakeholders about how weapproach the environmental and social impacts
associated with certain financial relationships. It is
intended to reflect enterprise policy and procedurerequirements that establish expectations andrequirements for identifying, assessing, andmanaging actual and potential adverse

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environmental and social impacts associated withcertain commercial clients and financings.
Wells Fargo requires additional environmental andsocial impact due diligence for certain industries
and activities, which are described in the ESIM
Framework. Business groups work with the ESIM
team, who may determine that escalated reviews areappropriate. In those cases, the transaction or client
would be assessed for elevated risk factors andpotentially subject to review and approval by seniorbusiness leaders, and, as appropriate, the relevant
governance committee.
Our approach to managing environmental and social
impacts associated with our client relationships isinformed by globally recognized standards and bestpractices, including:•Equator Principles•

United Nations Guiding Principles on
Business and Human Rights•

UK Modern Slavery Act•

International Finance Corporation
Performance Standards•

Task Force on Climate-Related
Financial Disclosures

The ESIM Framework can be found on our Goals and Reporting website.

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Bank Secrecy Act and Anti-Money
Laundering program

Wells Fargo’s risk-based global Bank Secrecy Act
and Anti-Money Laundering (BSA/AML) programis designed to comply with applicable BSA/AML
laws commensurate with our risk profile. The BSA/AML program is approved by our Board of Directors
through its Risk Committee. The BSA/AML
program includes the following core elements:
BSA officer, policies, risk assessments, testing,training, data analytics, customer due diligence,
sanctions screening, transaction monitoring,
regulatory reporting, internal controls, andindependent audit.

Compliance with economic sanctions
laws and regulations

Wells Fargo has implemented a comprehensiverisk‐based sanctions compliance program
intended to facilitate compliance with applicableeconomic sanctions laws and regulations in every
jurisdiction in which we operate.

GovernanceAppendix

Wells Fargo prohibits the offering, providing,soliciting, receiving, or authorizing of anything ofvalue to or from any person to improperly
influence the performance of the recipient's
duties, obtain or retain business, or otherwise gain
an unfair business or personal advantage.
Wells Fargo maintains an EthicsLine where
employees can confidentially report unethicalor illegal activities or policy violations, including
those related to bribery and corruption.
Wells Fargo’s program includes evaluating bribery
and corruption risk on (1) gifts, entertainment,
and transfers of value; (2) offers of employment;(3) third-party engagement; and (4) strategictransactions. The program also includes regularenterprise-wide risk assessments, training, andmanagement reporting.

Anti-Bribery and Corruption Compliance
ProgramWells Fargo does not tolerate bribery andcorruption in any form and has implemented a
global risk-based Anti-Bribery and Corruption
Compliance Program designed to confirm
adherence to the U.S. Foreign Corrupt Practices
Act and applicable anti-bribery and corruption
laws in the jurisdictions where Wells Fargo does
business.

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Customer and productresponsibility
Fair and transparent products, services,and business practices

Doing what is right for customers must be at thecenter of our actions. We have taken important
steps to embed this mindset into our decisions,which feeds into all the ways in which we impact
customers. This extends from product design andpricing to our coverage and service models andhow we approach complaints and remediations.
We recognize that our actions speak much louder
than our words.
Wells Fargo established the Office of Consumer
Practices in 2021 as a company-wide, consumerfocused advisory group within the Chief
Operating Office. It is designed to help ensure our
products, services, and business practices are fair
and transparent and reinforce a customer-centricculture.
The Office of Consumer Practices’ work
complements efforts already underway to
improve our business practices. Its activities
include:••Assessing and advising on consumer-related
products, services, and business practices toenable the customer perspective to play asignificant role in decision-making.
Reviewing complaint metrics and other datato help identify and advise on potential
consumer-related issues, trends, and outcomes.

•

Providing advice on policies, procedures,and training that impact how Wells Fargo
interacts with consumers, including older
adults and vulnerable customers.

•

Developing and advancing the “Treating
Consumers Fairly Principles” — a set of five clear
standards to help guide customer interactions
and confirm fairness considerations are central
in decision-making about products and services.

Our Treating Consumers Fairly Principles are
standards to guide interactions with ourcustomers and help promote the inclusion of
consumer fairness considerations when making
decisions about our products and services.
•

Do what’s right for consumers and treat
them as we would want to be treated, withtransparency and respect.

•

Design our consumer products and services sothat all customers are treated fairly.

•

Clearly disclose the features, costs, and termsof our products and services so consumers
can make informed choices to meet theirindividual needs.

•

Design our marketing and communications to
be consistent, simple, and easily understood.

•

Listen carefully to consumer feedback andaddress fairness issues with urgency.

For example, within Consumer, Small, andBusiness Banking we introduced Extra Day Grace,
which gives customers an extra business day
to make deposits and avoid overdraft fees.
It benefited over 5 million customers in 2023,
helping them avoid over $750 million in overdraft
fees.

Client satisfaction and protection

Wells Fargo’s Enterprise Complaints andRemediations organization brings together key
functions from across the Company to effectively
care for customers who have expressed a concern
or been adversely affected by the Company.
Our Complaints team listens to our customers
and works to capture, understand, and address
their concerns. Additionally, the insights sharedby the Complaints team are used to support thecontinuous improvement of front-line operations.
Our Remediations team works to make customers
whole, when appropriate, by providing
remediation in a high-quality, consistent, andtimely manner. Across our organization, ourteams are committed to doing what’s right forour customers and supporting the continued
transformation of our Company.

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Cybersecurity andprivacy protection
Information security risk management
Information security risk, which includes
cybersecurity risk, is a significant operational risk
for financial institutions such as Wells Fargo andincludes the risk arising from unauthorized access,use, disclosure, disruption, modification, or
destruction of information or information systems.
The Board’s Risk Committee has primary oversight
responsibility for information security risk andapproves the Company’s information security
program, which includes information protection
and cyber resiliency. The Risk Committee receives
regular reports from the Company’s Head ofTechnology, as well as from Operational Risk
Management representatives, on information
security risks. The Board receives a report fromthe Head of Technology on Wells Fargo’s
information security program and receives
reports from management on significant
information security developments, including
certain incidents involving third parties.
At the management level, Operational Risk
Management has oversight responsibility for
information security risk. As a second line ofdefense, Operational Risk Management reviews
and provides guidance to the Front Line
Technology team, including with respect to thedevelopment and maintenance of risk
management policies, governance documents,
processes, and controls, and oversees andchallenges the Front Line Technology team’s
risk assessment activities.
The Company’s Cybersecurity team, which is partof the broader technology team, provides frontline information security risk assessment andmanagement and is responsible for protecting theCompany’s information systems, networks, anddata, including customer and employee data,
through the design, execution, and oversightof our information security program.
The Wells Fargo information security program isdesigned to, where appropriate, follow
information security standards including:•National Institute of Standards andTechnology Cybersecurity Framework•

NIST 800-53 Revision 5: Security and Privacy
Controls for Federal Information Systems
and Organizations•

International Organization forStandardization 27001:2013 standard•

Control Objectives for Information and
Related Technology•

Federal Financial Institutions Examination
Council Information Technology Examination
Handbook

The Technology team is led by the Company’s
Head of Technology, who reports to the CEO andleads our efforts to manage information security
and related risks across the enterprise, including
overseeing the Company’s Chief Information
Security Officer (CISO).
The Company has processes designed to prevent,detect, mitigate, escalate, and remediatecybersecurity incidents, including monitoring of
the Company’s networks for actual or potential
attacks or breaches. The Company’s incident
response program includes notification,
escalation, and remediation protocols forcybersecurity incidents, including to our Head ofTechnology and CISO. In addition, to help monitor
and assess our exposure to ongoing and evolving
risks in these areas, the Company has a cyber andinformation security focused risk committee ledby the CISO and a technology risk committee ledby the Head of Technology.
Additional components of the Company’s
information security program include: (i)enhancing and strengthening of our practices,
policies, and procedures in response to theevolving information security landscape; (ii)designing our information security program toalign with regulatory and industry standards;(iii) investing in emerging technologies toproactively monitor new vulnerabilities and reduce
risk; (iv) conducting periodic internal and thirdparty assessments to test our information security
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information security program; (vi) evaluating andupdating our incident response planning andprotocols; and (vii) requiring employees and thirdparty service providers who have access to oursystems to complete annual information security
training modules designed to provide guidance for
identifying and avoiding information security risks.
In addition, Operational Risk Management
oversees the Company’s third-party risk
management program, which, among otherthings, is designed to identify and address
information security risks arising from third-party
service providers. Components of this program
include incorporating information security andcybersecurity incident notification requirements
into contracts with third-party service providers,requiring third parties to adhere to defined
information security and control standards, andperforming periodic third-party risk assessments.
Wells Fargo and other financial institutions, aswell as our third-party service providers, continue
to be the target of various evolving and adaptive
information security threats, including
cyberattacks, malware, ransomware, othermalicious software intended to exploit hardware
or software vulnerabilities, phishing, credential
validation, and distributed denial of service, inan effort to disrupt the operations of financial
institutions, test their cybersecurity capabilities,
commit fraud, or obtain confidential, proprietaryor other information. Cyberattacks have also
focused on targeting online applications andservices, such as online banking, as well as cloudbased and other products and services provided
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infrastructure of the internet causing thewidespread unavailability of websites anddegrading website performance. As a result,information security and the continued
development and enhancement of our controls,
processes, and systems designed to protect our
networks, computers, software, and data fromattack, damage, or unauthorized access remain apriority for Wells Fargo. Wells Fargo is also
involved in industry cybersecurity efforts andworks with other parties, including our thirdparty service providers and governmental agencies,
to continue to enhance defenses and improve
resiliency to information security threats.

Responsible use of artificial intelligence

Wells Fargo is focused on the responsible use of
artificial intelligence (AI) and machine learning.
The responsible use of AI includes reasonablesafeguards to manage bias risk, model risk
management, performance monitoring, andgovernance around data and model usage. Our AI
solutions are developed and governed crossfunctionally to take into account business, risk,
technology, compliance, and legal considerations.

Embracing a privacy culture

As a global provider of financial services and products
to consumers, corporate clients, small businesses,
governments, and other institutions, Wells Fargo iscommitted to the protection and appropriate useof the personal data we collect and process.

GovernanceAppendix

Our Privacy Compliance function, which is partof Independent Risk Management, promotes astrong privacy risk culture through publication andmaintenance of our Privacy Policy, which applies
globally to all Wells Fargo business groups andenterprise functions that access, collect, process,or store individuals’ personal information.
Individuals includes current, former, or prospective
Wells Fargo customers or consumers, businesscustomers (including employees of businesscustomers, representatives, beneficial owners,
guarantors, officers, and directors), third-party
service providers (including sole traders andemployees of third-party service providers),
current or former Wells Fargo employees, job
applicants, and contingent resources.

Providing a web-based privacy center

We honor our customers’ privacy preferences
regarding the processing of their personal data
as described in our U.S. privacy policies andnotices, which can be found on the Wells Fargo
Privacy Center web portal.
The Wells Fargo Privacy Center web portal is a
resource for individuals to learn information about
the types of data we collect, how it is used, choices
available to individuals, and can be found on our
Privacy, Cookies, Security, and Legal website.

Controls designed to promote and protect
privacy are in place throughout the enterprise.
Wells Fargo also mandates company-wide privacy
training to manage privacy risk.
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GovernanceAppendix

Policy advocacy
We strive to manage our legislative and politicalactivities in a manner consistent with good corporate
governance practices.
•••

Wells Fargo participates in the U.S. public policy
arena on a wide range of issues that may impact
the Company. We disclose federal lobbying
activities in accordance with the Lobbying
Disclosure Act, which requires quarterly reports
to be filed with the United States Congress.
More information on specific advocacy activities
is available in the Climate Report, which can befound on our Goals and Reporting website.

Pursuant to Company policies, we do not use
Company money or resources to influence any
U.S. or foreign candidate elections. We do not
use Company money to financially support
candidate campaign committees, politicalparties, or caucuses, and we do not makeindependent expenditures on other politicalcommittees.

Wells Fargo's engagement in public policy
advocacy includes membership in financial
services industry trade associations. We regularly
review our participation model and believe thatengagement through these trade organizations is
an integral part of our public policy strategy andbest serves our customers, Company, employees,
and communities.

Wells Fargo’s Political Action Committees are
funded through voluntary contributions from
eligible exempt employees and managed by
the Government Relations and Public Policy
team. Our Political Action Committees reportto the Federal Elections Committee and/or tostate agencies as required by law.

Participation in these groups comes with theunderstanding that we may not always agreewith every position taken. In instances where
we identify significant misalignment with tradeassociations to which we belong, we aim toshare our perspective in a constructive manner.
Additionally, we are not members of any taxexempt organization in the U.S. that is primarily
organized to write, endorse, and promote model
legislation.
The Board’s Corporate Responsibility Committee
oversees our significant government relations
strategies, policies, and programs.
More information on our Political Action
Committees and corporate political spending canbe found on our Government Relations and Public
Policy, and our Wells Fargo Political Action
Committees contributions (PDF), websites.

Public policy lobbying and Political Action Committee spending
Unit
33

2023

Spending on federal lobbying activities

USD

4,310,000

34

USD

777,800

PAC contributions

33
34

Federal lobbying activities are disclosed under the Lobbying Disclosure Act, which requires reports to be filed quarterly with the United States Congress. Lobbying Disclosure Act reports are available for review on theU.S. House website https://lda.senate.gov/system/public/.
Contributions to federal and state committees from the employee-funded Political Action Committee.

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GovernanceAppendix

35

Respecting human rights

As described in our Human Rights Statement,
Wells Fargo is committed to respecting humanrights throughout our operations, products, andservices. Our efforts are guided by the Universal
Declaration of Human Rights and the United
Nations Guiding Principles on Business andHuman Rights, which identify a responsibility
for corporations to respect human rights intheir operations and through their business
relationships.
Wells Fargo recognizes its responsibility to respect
the rights of Indigenous Peoples, which include theright to determine their own way of life on their own
lands, according to their time‑honored cultures,
traditions, and beliefs. We take that responsibility
into account in conducting our business activities.
We have existing policies and procedures to evaluate
potential risks to Indigenous communities, and weperiodically review and evaluate those policies andprocedures, consistent with our standard policy
management process and our enterprise risk andcontrol programs.

35

We strive to engage with suppliers whose values
and business principles reflect respect for thehuman rights of the people and the communities
they do business with. While we recognize thateach supplier has varying policies and approaches
to human rights, we expect our suppliers toadhere to the standards and values expressed in
our Supplier Code of Conduct, which can be foundon our Goals and Reporting website.
We promote the understanding of and compliancewith our human rights related policies andprocedures by developing and deploying training
courses for employees on enterprise policy
requirements. We have also incorporated a
voluntary human rights training section on our
employee Learning and Development platform.
Wells Fargo also engages with external parties,
including those focused on human rights, to shareand learn best practices. These organizations canprovide additional learning opportunities for
Wells Fargo employees, and in 2023 we co-hosted
a session on the United Nations Guiding Principles
on Business and Human Rights.

Further information related to our Human Rights Assessment, Human Rights Statement, and the Indigenous Peoples Statement can be found on our Goals and Reporting website. Our UK Modern Slavery Act Statement can be found on our EMEA Disclosures and Disclaimers website.

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GovernanceAppendix

Disclaimer and forwardlooking statements
This document is provided for information
purposes only. The information provided in thisdocument reflects Wells Fargo & Company's (the“Company”) approach to the topics herein as ofAugust 20, 2024. The approach is subject tochange in the Company’s sole discretion without
notice. The Company does not undertake toupdate this document, or any information
contained in this document, to reflect changes or
events that occur after that date. Any goals,
targets, commitments, objectives, or otherinformation discussed in this document are notguarantees of future results, occurrences,
performance, or conditions.
This document contains forward-looking
statements about our business, including
discussion of the Company’s plans, objectives andstrategies, and expectations for our operations
and business related to our environmental, social,and governance (ESG) activities such as our goals,
targets, commitments, and objectives relating togreenhouse gas emissions reductions, operationalsustainability, and renewable energy andsustainability financing and investment, among
others. Because forward-looking statements are
based on our current expectations andassumptions regarding the future, they are
subject to inherent risks and uncertainties. Do not
unduly rely on forward-looking statements as
actual results could differ materially from36

expectations. Forward-looking statements speak
only as of the date made, and we do notundertake to update them to reflect changes or
events that occur after that date. Factors that
could cause actual results to differ materially fromthose forward-looking statements described inthis document include the precautionary
statements and disclaimers included in this report
as well as the following factors: the challenges
associated with data availability and quality; theevolving standards and methodologies formeasuring, reporting and verifying ESG-related
metrics; the necessity of technologicaladvancements; the evolution of consumer
behavior; the need for thoughtful climate andsustainability policies; the need for collaboration
and action on the part of various stakeholders to
help achieve climate and sustainability goals; thepotential impact of legal and regulatory
obligations; and changes in management’s
strategy for balancing our aspirational short-termtargets, goals and commitments with otherinterests such as the prioritization of energy
security and achievement of an orderly andequitable energy transition, among other factors.
For additional information about factors that
could cause actual results to differ materially fromour expectations, refer to our reports filed with
the Securities and Exchange Commission,
including the discussion under “Risk Factors” in
our Annual Report on Form 10-K for the year

ended December 31, 2023, and in our subsequent
quarterly reports, as filed with the Securities andExchange Commission and available on its website
36
at www.sec.gov.
While this document describes events, including
potential future events, that may be of interest or
significance to our stakeholders in the context of
our ESG priorities and related activities, anyreferences to terms such as “significant,”“important,” or “material” or similar terms should
not be read as necessarily rising to the level ofmateriality of disclosures required under U.S.
federal securities laws or other laws andregulations.
The Company is not providing any financial,economic, legal, accounting, tax, or investment
advice or recommendations. This document
should not be used as a basis for trading in the
securities of the Company or for any otherinvestment decision.
This document reflects certain positions andapproaches to ESG as of the date of thisdocument that are subject to change at any timein the Company’s sole discretion without notice,
and we do not undertake to update this document
to reflect any such changes. Any references to“sustainable investing,” “sustainable financing,”“renewable energy,” “clean energy,” “ESG,” or

We do not control this website. Wells Fargo has provided this link for your convenience but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website.

52

Table of contents

similar terms in this document are intended as
references to the internally defined criteria of theCompany, as applicable, and, except as specificallystated, not to any jurisdiction-specific regulatory
definition that may exist. Such terms can be
subjective in nature, and there is norepresentation or guarantee that these terms, as
used herein, or judgment exercised by Wells Fargo
in the application of these terms, will reflect the
beliefs or values, policies, principles, frameworks,
or preferred practices of any particular investor orother third party, or reflect market practices ortrends. Wells Fargo's ESG, sustainability, climate,sustainable investing, or sustainable finance goals,
targets, commitments, and initiatives are
aspirational and purely voluntary, are not bindingon the Company's business, investment decisions,
and/or management, may be amended orcancelled at any time, and do not constitute a
guarantee or promise of achievement of any suchgoals, targets, or commitments or regarding
actual or potential positive impacts or outcomes.
Information contained herein is sourced from avariety of internal and external sources and may
be based on emerging or evolving practices.
Similarly, statistics and metrics relating toclimate- and other ESG-related matters are
estimates and may be based on assumptions anddeveloping standards. In addition, disclosuresrelated to environmental sustainability, including
disclosures related to the Company’s resource
consumption and greenhouse gas emissions, aswell as certain internal estimates andassumptions, are based in part on third-party
data. Uncertainties, inaccuracies, or omissions in
any of these inputs may potentially have

Introduction

Sustainability

Employee support

compounding effects on the accuracy andcompleteness of resulting emissions and resource
consumption figures. The suitability of the designand effectiveness of any third-party systems andassociated controls over the accuracy andcompleteness of the data has not been
independently assessed by us. Also, while theCompany set client portfolio emissions targets forcertain sectors to enable it to track the alignmentof its financing activities to its net-zero goal,
these targets, even if met, do not guarantee
reductions of absolute greenhouse gas emissions
in the real economy. The reduction of absolutegreenhouse gas emissions in the real economy will
ultimately depend on the efforts and actions ofvarious stakeholders outside of our control.
Relatedly, given the indirect nature of financial
institution emissions target setting and thechallenges of drawing causality between bankfinancing and real economy emission outcomes,
these targets reflect our efforts to help align the
Company's financed emissions to its net-zerogoal, and should not be construed as acommitment by the Company to achieve aparticular emissions outcome or a claim to realize
a specific climate effect.
With respect to data and other information that is
not also included in the Company’s Statement ofGreenhouse Gas Emissions or Management's
Assertion with respect to sustainable financing
activities, the Company makes no representations
or warranties as to the quality, completeness,accuracy, or fitness for a particular purpose andshall not be liable for any use by any party of, forany decision made or action taken by any party inreliance upon, or for any inaccuracies or errors in,GovernanceAppendixor omissions from, such data and otherinformation. GHG Protocol requires restatement
when changes in calculation methodology or
improvements in the accuracy of emissions
factors or activity data significantly impact thebase year emissions data. As data availability andquality continue to improve, and as the standards,
methodologies, and approaches used in preparing
this document continue to evolve, information weare currently disclosing may need to be changed
or restated in the future. Other than as expressly
stated herein, the Company does not undertake
any duty to restate or correct data should suchinformation later prove to be incorrect.
This document provides general information
regarding a number of the Company’s policies,
procedures, and positions relating to ESG issues.
The description of such policies, procedures, andpositions herein does not purport to be complete
and such policies, procedures, and positions may
be subject to approved exceptions. Further, there
can be no assurance that the Company’s policies,
procedures, and positions relating to ESG issues
will continue; such policies, procedures, andpositions, including the initiatives, goals, andtargets related thereto, could change, evenmaterially. The Company may determine in its
sole discretion that it is not feasible or practical to
implement, comply with, or achieve certain of its
policies, procedures, positions, goals, or targets
relating to ESG issues based on cost, timing, orother considerations. Except where indicated, thisdocument and the data contained herein have notbeen verified or otherwise assured by anindependent third party.

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The United Nations Sustainable Development
Goals (SDGs) are also aspirational in nature. The
analysis involved in determining whether and how
certain initiatives may contribute to the SDGs isinherently subjective and dependent on a numberof factors. There can be no assurance thatreasonable parties will agree on a decision as towhether certain projects, initiatives, investments,
or other aspects of our business contribute to aparticular SDG. Accordingly, investors or otherstakeholders should not place undue reliance on
our application of the SDGs, as such application is
subject to change at any time and in our sole
discretion.

Introduction

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Employee support

GovernanceAppendixregarding the non-infringement of any
information contained herein.

The Company has provided external links within
this document for your convenience, but theCompany does not endorse and is not responsible
for the content, links, privacy policy, or security
policy of these websites. The content of any thirdparty websites is not in any way included in orincorporated by reference into this document.
This document is not intended to makerepresentations as to the ESG initiatives of any
third parties, whether named herein or otherwise,
which may involve information and events thatare beyond Wells Fargo's control.
All third-party trademarks or brand names are theproperty of their respective owners. The use of
any third-party trademarks or brand names is for
informational purposes only and does not imply
an endorsement by the Company or that suchtrademark owner has authorized Wells Fargo topromote its products or services. The Company
disclaims any representations or warranties

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GovernanceAppendix

Appendix
56 United Nations Sustainable Development Goals
57 Sustainability Accounting Standards Board (SASB) index
62 Global Reporting Initiative (GRI) content index
69 Sustainable Finance Eligibility Criteria
75 Management’s assertion
76 Independent Accountants’ Review Report55

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GovernanceAppendix

United Nations Sustainable Development Goals
1 NO
POVERTY

3 GOODHEALTH AND
WELL-BEING

4 QUALITYEDUCATION

5 GNDEREQUALITY

7 AFFORDABLE
AND CLEAN
ENERGY

8 DECENT WORKAND ECONOMICGROWTH

9 INDUSTRY,INNOVATION AND
INFRASTRUCTURE

10 REDUCEDINEQUALITIES11SUSTAINABLE
CITIES ANDCOMMUNITIES

13 CLIMATEACTION

Wells Fargo recognizes that we have a responsibility to do our part to help address the many global challenges facing the communities
we serve. We continue to evolve our business for the future. The United Nations Sustainable Development Goals are a universal
framework for accomplishing 17 desired global outcomes by 2030. We have identified the above 10 goals as most germane to
our efforts and were informed by them as we defined our Sustainability Impact Areas of Climate Action and Community Impact,
as referenced in the Introduction of this report.

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GovernanceAppendix

Sustainability Accounting Standards Board (SASB) index
The information cited in the index below relates to Wells Fargo company-wide as of or for the year ended December 31, 2023, unlessotherwise noted.
SASB Disclosure topic
Business Ethics
FN-CB-510a.1
FN-IB-510a.1

FN-CB-510a.2
FN-IB-510a.2

SASB Accounting metricWells Fargo does not disclose total monetary losses as a result ofTotal amount of monetary losses as a result oflegal proceedings associated with financial industry laws orlegal proceedings associated with fraud, insider
regulations. However, Wells Fargo provides information regarding
trading, antitrust, anti-competitive behavior,market manipulation, malpractice, or other related material legal matters in accordance with SEC requirements and U.S.
GAAP in its Annual Report and applicable SEC filings.
financial industry laws or regulations

Description of whistleblower policies andprocedures

Systemic Risk Management
FN-CB-550a.1
Global Systemically Important Bank score, by
FN-IB-550a.1
category

FN-CB-550a.2
FN-IB-550a.2

Wells Fargo Response/Disclosure location

Description of approach to integrate mandatory
and voluntary stress tests into capital adequacy
planning, long-term corporate strategy, and otherbusiness activities

Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions
Wells Fargo Code of Conduct, Speaking up, Nonretaliationcommitment, which can be found on our Goals and Reporting
website.

2023 List of Global Systemically Important Banks (G-SIBs) (https://www.fsb.org/wp-content/uploads/P271123.pdf)
Wells Fargo has provided external links within this document for yourconvenience, but Wells Fargo does not endorse and is not
responsible for the content, links, privacy policy, or security policy ofthese websites.
Company-Run Stress Test Reports

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SASB Disclosure topic
Professional Integrity
FN-IB-510b.2

Introduction

Sustainability

Employee support

Governance

SASB Accounting metricWells Fargo Response/ Disclosure location

Number of mediation and arbitration cases
associated with professional integrity, including
duty of care, by party

Wells Fargo does not disclose this information. However, Wells Fargo
provides information regarding material legal matters in accordancewith SEC requirements and U.S. GAAP in its Annual Report andapplicable SEC filings.

Appendix

Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions
FN-IB-510b.3

Total amount of monetary losses as a result oflegal proceedings associated with professional
integrity, including duty of care

Wells Fargo does not disclose total monetary losses as a result oflegal proceedings associated with professional integrity, including
duty of care. Wells Fargo provides information regarding material
legal matters in its Annual Report and applicable SEC filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

FN-IB-510b.4

Description of approach to ensuring professional
integrity, including duty of care

Wells Fargo Code of Conduct, Accountability; Upholding our ethicaland legal obligations, which can be found on our Goals and Reporting
website.
Wells Fargo 2024 Proxy Statement (PDF), Sustainability, Human
capital Management, and DE&I

Customer Privacy
FN-CF-220a.2

Total amount of monetary losses as a result oflegal proceedings associated with customer
privacy

Wells Fargo does not disclose total monetary losses as a result oflegal proceedings associated with customer privacy. However,Wells Fargo provides information regarding material legal mattersin its Annual Report and applicable SEC filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

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Governance

SASB Disclosure topic
Data Security

SASB Accounting metricWells Fargo Response/ Disclosure location

FN-CB-230a.2
FN-CF-230a.3

Description of approach to identifying andaddressing data security risks

Wells Fargo Sustainability & Governance Report, Governance,
Cybersecurity, and privacy protection

Appendix

Wells Fargo 2023 Annual Report (PDF), Risk Management; Risk
Factors
Discriminatory Lending
FN-MF-270b.2
Total amount of monetary losses as a result oflegal proceedings associated with discriminatory
mortgage lending

FN-MF-270b.3

Wells Fargo does not disclose total monetary losses as a result oflegal proceedings associated with discriminatory mortgage lending.
However, Wells Fargo provides information regarding material legal
matters in accordance with SEC requirements and U.S. GAAP in its
Annual Report and applicable SEC filings.

Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions
Description of policies and procedures for ensuring Wells Fargo responsible lending - What It Means at Wells Fargo
nondiscriminatory mortgage origination

Employee Diversity and Inclusion
FN-IB-330a.1
Percentage of (1) gender and (2) diversity group Wells Fargo Diversity, Equity, and Inclusion Report, which can be
representation for (a) executive management, (b) found on our Goals and Reporting website.
non-executive management, (c) professionals, and(d) all other employees
Wells Fargo EEO-1 Tables, which can be found on our Goals andReporting website.
Employee Incentives and Risk Taking
FN-IB-550b.3
Discussion of policies around supervision, control,and validation of traders’ pricing of Level 3 assets
and liabilities
Financial Inclusion and Capacity Building
FN-CB-240a.1(1) Number and (2) amount of loans outstanding
qualified to programs designed to promote small
business and community development

Wells Fargo 2023 Annual Report (PDF), Note 15: Fair Values ofAssets and Liabilities

Wells Fargo does not separately disclose number and amount ofloans outstanding qualified to programs designed to promote small
business and community development. However, Wells Fargo
provides information regarding total loan amounts for Consumer
and Small Business Banking in its Annual Report.
Wells Fargo 2023 Annual Report (PDF), Earnings Performance59

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SASB Disclosure topic
Financed Emissions
FN-CB-410b.2
FN-CB-410b.3
FN-CB-410b.4

Lending Practices
FN-MF-270a.3

Introduction

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Employee support

SASB Accounting metricWells Fargo Response/ Disclosure location

Gross exposure for each industry by asset class

Wells Fargo 2023 Climate Report, Metrics and Targets

GovernanceAppendix

Percentage of gross exposure included in the
Wells Fargo 2023 Climate Report, Metrics and Targets
financed emissions calculation
Description of the methodology used to calculate Wells Fargo 2023 Climate Report, Metrics and Targets
financed emissions

Total amount of monetary losses as a result of
Wells Fargo does not disclose total monetary losses as a result oflegal proceedings associated with communications legal proceedings associated with communications to customers or
to customers or remuneration of mortgage loan
remuneration of loan originators. However, Wells Fargo provides
originators
information regarding material legal matters in accordance with SEC
requirements and U.S. GAAP in its Annual Report and applicable SEC
filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

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SASB Disclosure topic
Selling Practices
FN-CF-270a.4

SASB Accounting metric

Introduction

Sustainability

Employee support

GovernanceWells Fargo Response/ Disclosure location(1) Number of complaints filed with the Consumer Wells Fargo does not publicly disclose this information. However, thisFinancial Protection Bureau (CFPB
information is disclosed publicly on the Consumer Financial(2) percentage with monetary or non-monetaryProtection Bureau website (https://www.consumerfinance.gov/).
reliefWells Fargo has provided external links within this document for your(3) percentage disputed by consumer(4) percentage that resulted in investigation by the convenience, but Wells Fargo does not endorse and is not
CFPB
responsible for the content, links, privacy policy, or security policy ofthese websites.

FN-CF-270a.5

Total amount of monetary losses as a result oflegal proceedings associated with selling andservicing of products

Wells Fargo does not disclose total monetary losses as a result oflegal proceedings associated with selling and servicing of products.
However, Wells Fargo provides information regarding material legal
matters in accordance with SEC requirements and U.S. GAAP in its
Annual Report and applicable SEC filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

Disclosure topic

Activity metricResponse/ Disclosure location

Activity Metrics
FN-MF-000.A

Appendix(1) Number and (2) value of mortgages originated Wells Fargo 2023 Annual Report (PDF), Table 9a: Consumer Banking
by category: (a) residential and (b) commercial
and Lending - Income Statement and Selected Metrics,
Wells Fargo does not disclose this information for Commercial
Banking.

FN-MF-000.B
FN-IB-000.A
FN-IB-000.C

FN-CB-000.B(1) Number and (2) value of mortgages purchasedby category: (a) residential and (b) commercial(1) Number and (2) value of (a) underwriting, (b)advisory, and (c) securitization transactions(1) Number and (2) value of market making
transactions in (a) fixed income, (b) equity, (c)currency, (d) derivatives, and (e) commodity
products(1) Number and (2) value of loans by segment: (a)personal, (b) small business, and (c) corporate

Wells Fargo 2023 Annual Report (PDF), Managed Servicing Portfolio
Wells Fargo 2023 Annual Report (PDF), WIM Advisory Assets; Note
16: Securitization and Variable Interest Entities
Wells Fargo 2023 Annual Report (PDF), Corporate and Investment
Banking - Income Statement and Selected Metrics

Wells Fargo 2023 Annual Report (PDF), Consumer Banking andLending - Balance Sheet; Commercial Banking - Balance Sheet;
Corporate and Investment Banking - Balance Sheet; Wealth andInvestment Management

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GovernanceAppendixGlobal Reporting Initiative (GRI) content index
The information cited in the index below relates to Wells Fargo company-wide as of or for the year ended December 31, 2023, unlessotherwise noted.
GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

GRI 2: General disclosures
The organization and its reporting practices
2-1

Organizational details

Wells Fargo 2023 Annual Report (PDF), General information
Wells Fargo Global Locations

2-2
2-3

2-5

Entities included in the organization’ssustainability reporting
Reporting period, frequency and contact point

Wells Fargo 2023 Annual Report (PDF), Note 1: Summary of
Significant Accounting Policies
Wells Fargo Sustainability & Governance Report, Introduction, About
Wells Fargo

External assurance

corporateresponsibility@wellsfargo.com
Statement of Greenhouse Gas Emissions, which can be found on ourGoals and Reporting website.

Activities, value chain, and other business
relationships

Wells Fargo Sustainability & Governance Report, Introduction, About
Wells Fargo

Activities and workers
2-6

Wells Fargo 2023 Annual Report (PDF), Note 20: Operating
Segments
2-7

Employees

Wells Fargo Diversity, Equity, and Inclusion Report, which can befound on our Goals and Reporting website.
Wells Fargo EEO-1 Tables, which can be found on our Goals andReporting website.

Governance
2-9

Governance structure and composition

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo 2024 Proxy Statement (PDF), Director Nominee
Highlights; Our Director Nominee’s Qualifications; Board Diversity;
Board Committee Composition and Oversight Responsibilities

2-10

Nomination and selection of the highest
governance bodyWells Fargo 2024 Proxy Statement (PDF), Board and GovernanceMatters; Annual Independent Chair Selection

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Governance

GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

2-11

Chair of the highest governance bodyWells Fargo 2024 Proxy Statement (PDF), Our Director Nominees

2-12Role of the highest governance body inoverseeing the management of impacts

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics

Appendix

Wells Fargo 2023 Climate Report, Governance

2-13

2-14

Wells Fargo 2024 Proxy Statement (PDF), Oversight of
Sustainability, Social, and DE&I
Delegation of responsibility for managing impacts Wells Fargo 2023 Climate Report, GovernanceRole of the highest governance body insustainability reporting

Wells Fargo 2024 Proxy Statement (PDF), Sustainability, Human
Capital, and DE&I; Risk is Managed by Everyone
Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo 2024 Proxy Statement (PDF), Oversight of
Sustainability, Social, and DE&I

2-15

Conflicts of interest

Wells Fargo 2024 Proxy Statement (PDF), Board and GovernanceMatters; Director Independence; Information About Related Persons
Wells Fargo & Company Related Person Transaction Policy andProcedures (PDF)

2-16

2-17

Communication of critical concerns

2-19Collective knowledge of the highest governancebody
Evaluation of the performance of the highest
governance body
Remuneration policies

2-20

Process to determine remuneration

2-21

Annual total compensation ratio

2-18

How to Contact the Board of Directors
Wells Fargo 2024 Proxy Statement (PDF), Shareholder Engagement;
Communicating with Our Board
Wells Fargo 2024 Proxy Statement (PDF), Director Orientation,
Training, and Education
Wells Fargo 2024 Proxy Statement (PDF), Board Evaluation process
Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo 2024 Proxy Statement (PDF), Compensation Design;Compensation Discussion and Analysis
Wells Fargo 2024 Proxy Statement (PDF), CEO Pay Ratio andMedian Employee Annual Total Compensation

Strategy, policies and practices
2-22Statement on sustainable development strategy

Wells Fargo Sustainability & Governance Report, Introduction, Ourapproach63

Table of contents

Introduction

Sustainability

Employee support

Governance

GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

2-23

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics

Policy commitments

Appendix

Wells Fargo Code of Conduct, which can be found on our Goals andReporting website.
2-24

Embedding policy commitments

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo Code of Conduct, Our Code, which can be found on ourGoals and Reporting website.

2-25

Processes to remediate negative impacts

2-26
2-27

Mechanisms for seeking advice and raisingconcerns
Compliance with laws and regulations

2-28

Membership associations

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo Code of Conduct, Speaking Up, which can be found on
our Goals and Reporting website.
Wells Fargo provides information regarding material legal matters in
its Annual Report and applicable SEC filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions
Membership Associations, which can be found on our Goals andReporting website.

Stakeholder engagement
2-29

Approach to stakeholder engagement

Wells Fargo 2024 Proxy Statement (PDF), Shareholder Engagement

3-1

Process to determine material topics

3-2

List of material topics

3-3Management of material topics

Wells Fargo Sustainability & Governance Report, Introduction, Ourapproach
Wells Fargo Sustainability & Governance Report, Introduction, Ourapproach
Wells Fargo Sustainability & Governance Report, Introduction, Ourapproach; Governance, Corporate governance and ethics

GRI 3: Material Topics

GRI 201: Economic Performance
201-1
Direct economic value generated and distributed
201-2
201-3

Financial implications and other risks andopportunities due to climate change
Defined benefit plan obligations and otherretirement plans

Wells Fargo 2023 Annual Report (PDF), Our Performance, Income
Statement
Wells Fargo 2023 Annual Report (PDF), Risk Management; Risk
Factors
Wells Fargo 2023 Annual Report (PDF), Employee Benefits

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Introduction

Sustainability

Employee support

Governance

GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

GRI 203: Indirect Economic Impacts
203-1
Infrastructure investments and services
supported

Wells Fargo Sustainability & Governance Report, Sustainability,
Community impact

GRI 205: Anti-corruption
205-2
Communication and training about anticorruption policies and procedures
GRI 302: Energy

Appendix

Wells Fargo Code of Conduct, Our Code, Anti-Bribery and AntiCorruption, which can be found on our Goals and Reporting website.

302-1

Energy consumption within the organization

Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain

302-2

Energy consumption outside the organization

Wells Fargo 2023 Climate Report, Metrics and Targets
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain

302-3

Energy intensity

Wells Fargo 2023 Climate Report, Metrics and Targets
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and Supply Chain

302-4

Reduction of energy consumption

Wells Fargo 2023 Climate Report, Metrics and Targets
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Metrics and Targets

GRI 303: Water and Effluents
303-5

Water consumption

Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Strategy

GRI 305: Emissions
305-1

Direct (Scope 1) GHG emissions

Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Strategy
Statement of Greenhouse Gas Emissions, which can be found on ourGoals and Reporting website.

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Introduction

Sustainability

Employee support

Governance

GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

305-2

Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain

Energy indirect (Scope 2) GHG emissions

Appendix

Wells Fargo 2023 Climate Report, Strategy

305-3

Other indirect (Scope 3) GHG emissions

Statement of Greenhouse Gas Emissions, which can be found on ourGoals and Reporting website.
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Strategy

305-4

305-5

GHG emissions intensity

Reduction of GHG emissions

Statement of Greenhouse Gas Emissions, which can be found on ourGoals and Reporting website.
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Strategy
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Wells Fargo 2023 Climate Report, Strategy

GRI 306: Waste
306-1
306-2
306-3
306-4
306-5

Waste generation and significant waste-related
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
impacts
Management of significant waste-related impacts Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Waste generated
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Waste diverted from disposal
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain
Waste directed to disposal
Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain

GRI 308: Supplier Environmental Assessment
308-1
New suppliers that were screened using
environmental criteria

Wells Fargo Sustainability & Governance Report, Sustainability,
Operations and supply chain

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GRI Disclosure Number GRI Disclosure NameGRI 401: Employment
401-1
401-2

Introduction

Sustainability

Employee support

GovernanceWells Fargo Disclosure Location

New employee hires and employee turnoverWells Fargo Diversity, Equity, and Inclusion Report, which can befound on our Goals and Reporting website.
Benefits provided to full-time employees that are Wells Fargo Sustainability & Governance Report, Employee support,
not provided to temporary or part-time
Employee benefits
employees
Wells Fargo 2023 Annual Report (PDF), Employee Benefits

GRI 403: Occupational Health and Safety
403-1
Occupational health and safety management
system

Wells Fargo Sustainability & Governance Report, Employee support,
Prioritizing employee safety and health

GRI 404: Training and Education
404-2
Programs for upgrading employee skills andtransition assistance programs
404-3
Percentage of employees receiving regularperformance and career development reviews

Wells Fargo Sustainability & Governance Report, Employee support,
Learning and development
Wells Fargo Sustainability & Governance Report, Employee support,
Learning and development

GRI 405: Diversity and Equal Opportunity
405-1
Diversity of governance bodies and employees

405-2
GRI 408: Child Labor
408-1

Appendix

Ratio of basic salary and remuneration of women
to menOperations and suppliers at significant risk forincidents of child labor

Wells Fargo Sustainability & Governance Report, Governance,
Corporate governance and ethics
Wells Fargo 2024 Proxy Statement (PDF), Board Diversity
Wells Fargo Sustainability & Governance Report, Employee support,
Diversity, equity, and inclusion
Wells Fargo UK Modern Slavery Act Statement (FY 2023),
Wells Fargo Governance, Policies, and Training Related to Modern
Slavery Issue; Wells Fargo’s Human Rights Due Diligence and Risk
Assessment Approach, five of which can be found on our EMEA
Disclosures and Disclaimers website.
Wells Fargo Human Rights Statement, Safe and Respectful
Workplaces, which can be found on our Goals and Reporting website.

GRI 409: Forced or Compulsory Labor
409-1
Operations and suppliers at significant risk forincidents of forced or compulsory labor

Wells Fargo UK Modern Slavery Act Statement (FY 2023),
Wells Fargo Governance, Policies, and Training Related to Modern
Slavery Issue; Wells Fargo’s Human Rights Due Diligence and Risk
Assessment Approach, five of which can be found on our EMEA
Disclosures and Disclaimers website.
Wells Fargo Human Rights Statement, Safe and Respectful
Workplaces, which can be found on our Goals and Reporting website.
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GRI Disclosure Number GRI Disclosure Name

Introduction

Sustainability

Employee support

GovernanceAppendix

Wells Fargo Disclosure Location

GRI 413: Local Communities
413-1

Operations with local community engagement,
Wells Fargo Sustainability & Governance Report, Sustainability,
impact assessments, and development programs Community impact

GRI 415: Public Policy
415-1

Political contributions

Wells Fargo Sustainability & Governance Report, Governance, Policy
advocacy

Additional topic-specific disclosures
GRI Disclosure Number GRI Disclosure Name

Wells Fargo Disclosure Location

GRI 417: Marketing and Labeling
417-1
417-2

Requirements for product and service
information and labeling
Incidents of noncompliance concerning productand service information and labeling

Wells Fargo Sustainability & Governance Report, Governance,
Customer and product responsibility
Wells Fargo does not disclose incidents of noncompliance withregulations and/or voluntary codes concerning product and service
information and labeling. However, Wells Fargo provides information
regarding material legal matters in accordance with SEC
requirements and U.S. GAAP in its Annual Report and applicable SEC
filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

417-3

Incidents of noncompliance concerning marketing Wells Fargo does not disclose incidents of noncompliance with
communications
regulations and/or voluntary codes concerning marketing
communications. However, Wells Fargo provides information
regarding material legal matters in accordance with SEC
requirements and U.S. GAAP in its Annual Report and applicable SEC
filings.
Wells Fargo 2023 Annual Report (PDF), Note 13: Legal Actions

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Introduction

Sustainability

Employee support

GovernanceAppendix(1)

Sustainable Finance Eligibility Criteria
Category

Eligible Activities

Standard-Aligned Sustainable Finance
Financial products either directly dedicated to or linked to environmental and/or social outcomes that aim to align with sustainable financestandards or principles.
Standard-Aligned Transactions•

Products that align with sustainable finance standards or principles based on
Bloomberg’s and/or Dealogic’s designation, where available. Otherwise, thestructure of the transaction is reviewed internally for alignment withsustainable finance standards or principles. When Wells Fargo underwrites orlends under the transaction or facilitates the use/issuance of these products,
and it meets one of these two criteria, we will include them in our sustainablefinance reporting.

(2),(3)

Environmental Finance

Financial products and services that support clients or client activities that promote environmental sustainability.
Clean Transportation

Green Buildings

•
•
•
•

Low- or zero-emission vehicles
Infrastructure dedicated to electrified transport
Financing of manufacturers that exclusively support clean transportation
Energy-efficiency upgrades for new or existing commercial and multifamily
buildings meeting any of the following certifications: LEED® (Platinum, Gold,and Silver), BREEAM (Outstanding, Excellent, and Very Good), GreenPoint(Platinum, Gold, and Silver), National Green Building Standard (NGBS)(Emerald, Gold, Silver), Green Globes (three or higher), or other equivalent(4)levels in state or regional certification schemes.

Energy Efficiency•

Manufacturers and/or businesses dedicated to the development or
deployment of clean technology that serves to reduce or avoid greenhousegas emissions, including district heating, energy storage (mechanical,
chemical, etc.), fuel cell manufacturing, smart/microgrid infrastructure, andnew construction or improvements to transmission, distribution.

Energy Generation

•
•
•
•
•
•
•

Solar
Onshore and offshore wind power
Geothermal
Small hydropower (<20 MW)
Biofuels
Tidal
Repairs and improvements to existing water infrastructure, including
pipelines and associated pumping infrastructure; water treatment facilities,
including water recycling and wastewater treatment facilities; anddevelopment and deployment of desalination technology.

Sustainable Water and Wastewater Management

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Category
Pollution Prevention and Control and Circular Economy

Sustainable Agriculture

Introduction

Sustainability

Employee support

GovernanceAppendix

Eligible Activities
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Reduction of air pollution emissions
Greenhouse gas control
Treatment of contaminated soil
Waste prevention
Waste reduction
Waste recycling and energy/emission-efficient waste-to-energy
Recycling and composting facilities
Technologies and infrastructure supporting pollution prevention and circular
economyDevelopment and introduction of environmentally sustainable products
Production agriculture with third-party certifications (USDA organic)
Equipment finance that supports qualifying production agriculture clients
Forestry, timber production with third-party certification (Forest
Stewardship Council)
Bio-refineries
Fisheries and fishing with certification for sustainable management (Marine
Stewardship Council)

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Category
Transition FinanceIntroduction

Sustainability

Employee support

GovernanceAppendix

Eligible Activities•

Financial products and services provided to projects, firms, or sovereigns that
contribute to a specified sustainable transition strategy for the production
and/or consumption of energy, industrial processes, or other activities thathave historically negatively impacted the environment, in line with achieving
net zero by 2050 to align with 1.5°C pathways.

(5),(6)Social Finance

Financial products and services that serve underserved, excluded, or marginalized people or communities.
Education•
Accredited historically Black colleges and universities, and tribal colleges anduniversities•
Projects that promote access to education in low- to moderate-income(7)(8)
communities or majority-minority census tract areas, , including
apprenticeship training programs, community and junior colleges, publicschools, colleges, and universities.
Healthcare•
Nonprofit or public sector emergency healthcare facilities that provide freeof-cost or subsidized service to underserved populations•
Voluntary health organizations as defined by the North American Industry(9)
Classification System (NAICS).
Housing Affordability•
Projects financed via the Low-Income Housing Tax Credit program•
Financing of nonprofit organizations dedicated to addressing housing
affordability•
Financing of state and/or local housing finance agencies•
Financing for activities that conform to government or governmentsponsored enterprise definitions and frameworks for affordable housing
Socioeconomic Advancement & Empowerment
Projects financed via the New Markets Tax Credit program•
Supranational and development agency activities••
Loans to small- or medium-sized enterprises (annual revenues <$50 million)
operating in low- to moderate-income or majority-minority census tract
areas or that are minority- or women-owned•
Financing activity to and investments in Minority Depository Institutions as
defined by the Federal Deposit Insurance Corporation
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)

Includes only revenue-generating business activities; philanthropic giving is therefore out of scope. Our Sustainable Finance Eligibility Criteria were updated for calendar year 2022 related to Green Buildings (inclusion of additional green building certification schemes),
Housing Affordability (inclusion of financing that meets government or government-sponsored enterprise definitions of affordable housing), and Standard-aligned Sustainable Finance (inclusion of transactions not captured by Dealogic or Bloomberg and reviewed internally).
See details herein. We aim to (as we have done here) obtain a review of our progress toward our $500 billion goal from an independent accounting firm on an annual basis.
Transactions that are not aligned to a sustainable finance standard but for which the use of proceeds and/or the counterparty can be determined by mapping the use of proceeds to meet an activity to support environmental activities as defined by Environmental finance categories.
Transactions that fall within both eligible Environmental and Social financing activities herein are counted only as Environmental finance, with the exception of qualifying Housing Affordability projects, which are counted as Social.
Equivalent levels in other certification schemes are reviewed by subject matter experts (SMEs) as part of an internal eligibility review process.
Transactions that are not aligned to a sustainable finance standard but for which the use of proceeds and/or the counterparty can be determined by mapping the use of proceeds to meet an activity to support social activities as defined by Social finance categories.
Transactions that fall within both Environmental and Social financing types are counted only as Environmental finance, with the exception of qualifying Housing Affordability projects, which are counted as Social.
“Under the Community Reinvestment Act (CRA), the term low- and moderate-income refers to communities that in certain geographies have income levels that fall between certain ranges, as determined by the Census Bureau. A low-income community means there is a median family
income of less than 50% of the area median income. A moderate-income community means that the median family income is at least 50% and less than 80% of the area median income.” Source: Federal Reserve (https://www.federalreserve.gov/consumerscommunities/cra_resources.htm)
Note: Wells Fargo does not control this website. Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website.
Wells Fargo and the Federal Housing Finance Agency (FHFA) consider a “minority census tract” to be a census tract that has greater than or equal to 50% nonwhite population.
The North American Industry Classification System (NAICS) is the standard used by federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.

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Introduction

Sustainability

Employee support

GovernanceAppendix

Sustainable Finance Tracking and Reporting Overview
Product

Measurement Criteria(1)

Reporting Scope(2)

Standard Aligned Transactions
Green, Social,
Bond issuances based on Bloomberg’s or Dealogic’s designation for League table credit methodology based on
Sustainability,
green, social, sustainability, sustainability-linked, or transition finance. Bloomberg’s or Dealogic’s criteria is utilized,
defined as splitting capital market origination
Sustainability-Linked,
and Transition Bonds
credit equally among named bookrunners.
League table credit methodology based on
Sustainability-Linked
Loans based on Bloomberg’s or Dealogic’s designation, whereLoans
available, as sustainability-linked loans including any loan instrument Bloomberg’s or Dealogic’s criteria is utilized where
for which the financial or structural characteristics are linked toavailable, defined as splitting origination credit
predefined sustainability performance targets. Otherwise, theequally among named bookrunners. Otherwise,
structure of the transaction is reviewed internally for alignment with committed amount (limit at execution) of credit
facilities is counted.
Loan Market Association (LMA)/Asian Pacific Loan Market
Association (APLMA)/Loan Syndications and Trading Association(LSTA) Sustainability-Linked Loan Principles.
Green Loans & Social
Loans

Loans based on Dealogic’s or Bloomberg’s designation as a green
loan or social loan including any type of loan instrument madeavailable exclusively to finance or refinance, in whole or in part, newor existing eligible green or social project.

League table credit methodology, defined as
splitting origination credit equally among named
bookrunners, is utilized where available. Otherwise,committed amount (limit at execution) of credit
facilities is counted.

Bond Investments

Bond investments based on Dealogic’s or Bloomberg’s designation
as green, social, sustainability, sustainability-linked, or transition
finance.

Commitment amount is counted.

Environmental and Social Finance: Transactions that are not aligned to a sustainable finance standard but for which the use of proceeds or thecounterparty can be determined (through reasonable commercial means) to support environmental or social finance activities as defined by theWells Fargo Sustainable Eligibility Finance Criteria.
Equity Capital Markets Sustainability-linked convertible bonds, green convertible bonds, and League table credit methodology based onany equity issuance from renewable energy companies, based on
Dealogic’s criteria is utilized, defined as splitting(3)
capital market origination credit equally among
Dealogic’s designation are counted .
named bookrunners.
Mergers andAdvisory mandates where the target’s operating revenue aligns with Based on Dealogic’s criteria for M&A advisory
Acquisitions Advisory
the Wells Fargo Sustainable Finance Eligibility Criteria, as designated services ranking credit.
by Dealogic.
Other Environmental,
Social and Transition
Qualified Debt CapitalMarkets activity

Corporate, project, municipal, or supranational bonds, asset-backed
finance, commercial mortgage-backed securities, and loan
syndications issued/originated by a company or to finance a project(4)
where the use of proceeds or the Company’s NAICS code aligns
with the Wells Fargo Sustainable Finance Taxonomy eligible
activities; however, the bond is not designated by Dealogic or
Bloomberg as a green bond, social bond, sustainability bond,(5)transition bond, or sustainability-linked bond .

League table credit methodology is utilized,
defined as splitting capital market originationcredit equally among named bookrunners.

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Product
Other Environmental,
Social and Transition(5)
Qualified Lending(5)

Other Investments

Introduction

Sustainability

Employee support

GovernanceAppendix(1)

Measurement Criteria
Reporting Scope
Loans for which the facility use of proceeds or the Company’s
Committed amount (limit at execution) of facilities(4)
is counted.
NAICS code aligns with the Wells Fargo Sustainable FinanceTaxonomy eligible activities; however, the facility does not explicitlyalign and is not designated by Dealogic or Bloomberg as a green loan
(3)or social loan or sustainability-linked loan .
(3)Other investments , including:•Renewable energy tax credit investments•
Housing tax credit investments•
New market tax credit investments•
Equity investments

Committed amount of investment is counted.
These investments are where the use of proceeds
is for eligible activities defined herein.

.
(1)
(2)
(3)
(4)
(5)

Throughout Reporting Scope, commitment as defined by U.S. generally accepted accounting principles (U.S. GAAP).
Eligible transactions are those meeting the description for the product and reported as such by Bloomberg or Dealogic where available. Otherwise, the structure of the transaction is reviewed internally for alignment with Loan Market Association (LMA)/Asian Pacific Loan Market
Association (APLMA)/Loan Syndications and Trading Association (LSTA) Sustainability-Linked Loan Principles.
Eligible transactions not designated by Dealogic or where the North American Industry Classification System (NAICS) code does not explicitly align with an eligible code in Eligible NAICS Code Table2023 are reviewed as part of an internal eligibility review process by subject matter
experts to identify and review transactions that fall within our eligibility criteria but are not captured by our rules-based approach.
The North American Industry Classification System (NAICS) is the standard used by federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.
Eligible transactions are determined based on the NAICS code associated with the lending. See mapping of eligible NAICS codes in Eligible NAICS Code Table 2023.

Eligible qualifying refinancing activity

Refinanced facilities that qualify are counted when:•

Any qualifying facility is refinanced and upsized with no change in the use of proceeds, or when a commitment is counted at transaction close
but increases due to accordion or prescribed upsize over the tenor of the transaction; in either case, only the incremental amount will be counted.

•

Any qualifying facility is refinanced to support new qualifying projects that meet the criteria herein; in which case full renewal amount is counted.

•

A sustainability-linked loan is renewed; in which case full renewal amount is counted.

•

A facility that was not previously qualified is refinanced as a standard-aligned or use of proceeds facility with appropriate amendments to the terms andconditions; in which case the full renewal amount is counted.

•

A facility that was previously qualified changes its structure or product type to a new qualifying facility (e.g., green loan to sustainability-linked loan)
with appropriate amendments to the terms and conditions; in which case the full renewal amount is counted.

Extensions to existing facilities that do not meet any one of the conditions stated above will not be counted.

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Employee support

GovernanceAppendix

Eligible NAICS Code Table(1)

Sustainable Finance Category
Education

NAICS Code611210Description
Junior Colleges

Energy Generation

221111

Hydroelectric Power Generation

Energy Generation

221114

Solar Electric Power Generation

Energy Generation

221115Wind Electric Power Generation

Energy Generation

221116

Geothermal Electric Power Generation

Healthcare

813212

Voluntary Health Organizations

Pollution Prevention & Control and Circular Economy

562920Materials Recovery Facilities

Socioeconomic Advancement & Empowerment

624110Child and Youth Services

Socioeconomic Advancement & Empowerment

624120Services for the Elderly and Persons with Disabilities

Socioeconomic Advancement & Empowerment

624210Community Food Services

Socioeconomic Advancement & Empowerment

624221

Temporary Shelters

Socioeconomic Advancement & Empowerment

624229Other Community Housing Services

Socioeconomic Advancement & Empowerment

624230Emergency and Other Relief Services

Socioeconomic Advancement & Empowerment

624310

Vocational Rehabilitation Services

Socioeconomic Advancement & Empowerment

712190Nature Parks and Other Similar Institutions

Socioeconomic Advancement & Empowerment

813211

Grantmaking Foundations

Socioeconomic Advancement & Empowerment

813219Other Grantmaking and Giving Services

Socioeconomic Advancement & Empowerment

813311

Human Rights Organizations

Socioeconomic Advancement & Empowerment

921150American Indian and Alaska Native Tribal Governments

Sustainable Agriculture

112910

Apiculture

Sustainable Water and Wastewater Management

221320

Sewage Treatment Facilities(1)

NAICS Code 335911 (Storage Battery Manufacturing) was removed from the NAICS Code System as part of the 2022 NAICS Code update.

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Employee support

GovernanceAppendix

Management’s assertion
Wells Fargo & Company asserts that approximately $178 billion in sustainable finance activities have been originated, committed, advised, or
facilitated by Wells Fargo during the calendar years 2021, 2022, and 2023 that meet the Sustainable Finance Eligibility Criteria included in thisreport on pages 69 through 74. Wells Fargo is responsible for the completeness, accuracy, and validity of this management assertion.

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GovernanceAppendix

KPMG LLP
345 Park Avenue
New York, NY 10154-0102

Independent Accountants’ Review Report
To the Board of Directors and Management of Wells Fargo & Company and Wells Fargo Bank N.A.:
Report on Wells Fargo & Company’s assertion of sustainable finance activities covering the calendar years 2021, 2022, and 2023
Conclusion
We have reviewed management of Wells Fargo & Company’s (the Company’s) assertion on page 75 of the Wells Fargo Sustainability &Governance Report covering the calendar years 2021, 2022, and 2023, which includes the Sustainable Finance Eligibility Criteria (the Criteria)
used by management of the Company as a basis for the assertion (“Management’s Assertion”).
Based on our review, we are not aware of any material modifications that should be made to Management’s Assertion in order for it to be
fairly stated.
Our conclusion on Management’s Assertion does not extend to any other information that accompanies or contains Management’s Assertionand our assurance report.
Basis for Conclusion
Our review was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants inthe versions of AT-C section 105, Concepts Common to All Attestation Engagements, and AT-C section 210, Review Engagements that are
applicable as of the date of our review. We are required to be independent and to meet our other ethical requirements in accordance with
relevant ethical requirements related to the engagement. We believe that the evidence we have obtained is sufficient and appropriate toprovide a reasonable basis for our conclusion.
Responsibilities for Management’s Assertion
Management of the Company is responsible for Management’s Assertion as well as:•

designing, implementing and maintaining internal control relevant to the preparation of Management’s Assertion such that it is free frommaterial misstatement, whether due to fraud or error;•

selecting or developing suitable criteria as a basis for Management’s Assertion and appropriately referring to or describing the criteria used;and•fairly stating Management’s Assertion.
KPMG LLP, a Delaware limited liability partnership and a member firm of
The KPMG global organization of independent member firms affiliated with
KPMG International Limited, a private English company limited by guarantee.

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GovernanceAppendix

Our Responsibilities
The attestation standards established by the American Institute of Certified Public Accountants require us to:•plan and perform the review to obtain limited assurance about whether any material modifications should be made to Management’s
Assertion in order for it to be fairly stated; and•express a conclusion on Management’s Assertion based on our review.

Summary of the Work We Performed as the Basis for Our Conclusion
We exercised professional judgment and maintained professional skepticism throughout the engagement. We designed and performed our
procedures to obtain evidence that is sufficient and appropriate to provide a basis for our conclusion. Our procedures selected depended on our
understanding of Management’s Assertion and other engagement circumstances, and our consideration of areas where material misstatements
are likely to arise. In carrying out our engagement, we performed procedures that consisted primarily of:•inquiring of management to obtain an understanding of the Company’s sustainable finance activities;•

inquiring of management to understand the processes and systems used to aggregate data and prepare the sustainable finance activities
information;•

inspecting documentation related to a selection of recorded sustainable finance activities to evaluate whether they met the Criteria; and•evaluating Management’s Assertion for consistency with our understanding of the Criteria and other review procedures performed.

The procedures performed in a review vary in nature and timing from, and are substantially less in extent than, an examination, the objectiveof which is to obtain reasonable assurance about whether the assertion is fairly stated, in all material respects, in order to express an opinion.
Because of the limited nature of the engagement, the level of assurance obtained in a review is substantially lower than the assurance thatwould have been obtained had an examination been performed.

New York, New York
July 19, 2024

77