2016 Code of Conduct | Bank of America values 1

2016 Code of Conduct 2016 Code of Conduct

ACCEPTED

03-16-00761-CV

13871917

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/18/2016 11:12:26 AM

JEFFREY D. KYLE

CLERK

 RECEIVED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/18/2016 11:12:26 AM JEFFREY D. KYLE Clerk
2016 Code of Conduct | Bank of America values 2

Bank of America values

Our values 

Across our businesses, we’re committed to helping make financial lives better 

for our customers and clients through the power of every connection. 

Our values guide and inspire how we work together to serve our customers and 

clients, our shareholders and each other, helping us realize our purpose. To do 

this, we must: 

Deliver together 

We believe in the importance of treating each customer, client and teammate 

as an individual and treating every moment as one that matters. We strive to go 

the distance to deliver with discipline and passion. We believe in connecting with 

people person-to-person, with empathy and understanding. We believe everything 

we do for customers, clients, teammates and the communities we serve is built 

on a solid business foundation that delivers for shareholders. 

Act responsibly 

We believe that integrity and the disciplined management of risk form the 

foundation of our business. We are aware that our decisions and actions affect 

people’s lives every day. We believe in making decisions that are clear, fair and 

grounded in the principles of shared success, responsible citizenship and 

community building. 

Realize the power of our people 

We strive to help our employees reach their full potential. We believe that 

diverse backgrounds and experiences make us stronger. We respect every 

individual and value our differences—in thought, style, culture, ethnicity 

and experience. 

Trust the team 

We believe that the best outcomes are achieved when people work together 

across the entire company. We believe great teams are built on mutual trust, 

shared ownership and accountability. We act as one company and believe when 

we work together, we best meet the full needs of our customers and clients. 

Across our businesses, 

we’re committed to 

helping make financial 

lives better for our 

customers and clients 

through the power of 

every connection.

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2016 Code of Conduct | Our foundation for success Next | 3

Code of Conduct: 

our foundation for success 

To my teammates: 

Every day, we strive to make financial lives better. As we help people, 

businesses and institutions achieve their financial goals, it is important 

that we always act responsibly—with honesty, integrity and fairness. 

Based on our company’s values, the Code of Conduct is our guide to 

putting those values into action. We are each required annually to 

review, acknowledge and understand our Code of Conduct. 

Thank you for upholding our ethical standards and commitment to our 

values in all you do every day for our customers, clients, teammates 

and communities.

Brian Moynihan 

Chief Executive Officer 

Bank of America
2016 Code of Conduct | Introduction 4

Introduction

Bank of America Corporation is committed to the highest standards of ethical and 

professional conduct. The Bank of America Code of Conduct (the “Code of Conduct” or 

the “Code”) provides basic guidelines of business practice and professional conduct that 

we are expected to adopt and uphold as Bank of America employees. 

To instill public trust and confidence, this Code is intended to guide our conduct and 

illustrate how we live our values as individuals and as a team. 

The Code of Conduct contains the following key themes consistent with our values:

We honor our Code. 

We act ethically. 

We manage risk effectively. .

We are fair and honest in our communications. .

We safeguard information. .

We protect Bank of America assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

We conduct our financial affairs responsibly. .

We value each and every teammate. .

We respect laws and regulations. .

We will not misuse information. .

We invest in our communities. .

Your manager or compliance officer will provide you with access to any manuals, policies, 

procedures and training related to your specific job. You should visit HR Connect to 

access learning content and refer to the Employee Handbook for additional information 

on employee conduct.

The corporation may publish additional policies as deemed necessary or appropriate. 

You are expected to follow this Code, other policies referred to in the Code, additional 

policies that apply to your specific job, and the spirit and letter of all laws and regulations. 

Violation of the Code of Conduct or other policies, procedures, laws and regulations 

constitutes grounds for disciplinary action, including termination of employment and 

possible legal action.

Notice to employees

Nothing in this Code prohibits or limits any employee or their counsel from initiating 

communications directly with, responding to any inquiry from, volunteering information to, 

or providing testimony before, the Securities and Exchange Commission, the Department of 

Justice, Financial Industry Regulatory Authority, Inc., any other self-regulatory organization 

or any other governmental, law enforcement, or regulatory authority, in connection with any 

reporting of, investigation into, or proceeding regarding suspected violations of law, and no 

employee is required to advise or seek permission from the Company before engaging in any 

such activity. In connection with any such activity permitted above, employees should identify 

any information that is confidential and ask the government agency for confidential treatment 

of such information. Despite the foregoing, employees are not permitted to reveal to any 

third party, including any governmental, law enforcement, or regulatory authority, information 

employee came to learn during the course of employee’s employment with the Company 

that is protected from disclosure by any applicable privilege, including but not limited to 

the attorney-client privilege, attorney work product doctrine and/or other applicable legal 

privileges. The Company does not waive any applicable privileges or the right to continue to 

protect its privileged attorney-client information, attorney work product, and other privileged 

information. Additionally, employees recognize that employee’s ability to disclose information 

may be limited or prohibited by applicable law and the Company does not consent to 

disclosures that would violate applicable law. Such applicable laws include, without limitation, 

laws and regulations restricting disclosure of confidential supervisory information or 

disclosures subject to the Bank Secrecy Act (31 U.S.C. §§ 5311-5330), including information 

that would reveal the existence or contemplated filing of a suspicious activity report.

Confidential supervisory information includes any information or materials relating to the 

examination and supervision of the Company by applicable bank regulatory agencies, 

Company materials responding to or referencing non-public information relating to 

examinations or supervision by bank regulatory agencies, and correspondence to or from 

applicable banking regulators.

The terms “Bank of America,” “the Bank,” “the Company,” “corporation” and “company” refer to 

Bank of America Corporation and its direct and indirect subsidiaries. For convenience, we use these 

terms because various companies within Bank of America use this document. The use of these 

terms here or in other publications does not mean you are an employee of Bank of America 

Corporation. The use of these terms or issuance of this document does not change your existing 

at-will employee status. Employees remain employed at will, and the at-will employment relationship 

can only be changed by an authorized company representative in writing. Similarly, the use of these 

terms or the requirement to read and adhere to this Code does not change the employment status 

of the employees of the Company’s third parties or contractors. 

The term “associate,” “employee,” “teammate” or “you” refers to any Bank of America director, officer 

or employee. 

The 2016 Code of Conduct supersedes and replaces any prior communications, policies, rules, 

practices, standards and/or guidelines that are less restrictive or to the contrary, whether written or 

oral. To the extent there are any conflicts with the Employee Handbook, the language of this Code 

supersedes the Employee Handbook. 

If any provision of this Code conflicts with your local law, the provisions of your local law apply.
2016 Code of Conduct | We honor our Code 5

We honor our Code

Making good decisions 

Countless decisions are made every day at Bank of America. Every decision we 

make as an institution and as employees impacts not only the corporation and 

our teammates, but our shareholders and communities as well. We all strive to 

make good decisions and to do the right thing. However, making decisions is 

not always easy. While in certain situations the right result is obvious and the 

decision can be made easily, in many situations the right result is less clear-cut 

or you may be facing time or other business pressures. Regardless of the nature 

of a particular decision, keep the following in mind to help you make informed, 

thoughtful decisions: 

• Make sure you have the relevant facts. 

• Take into account relevant laws, rules, regulations and policies. 

• Consider competing interests. 

• Identify potential options and their consequences. 

• Uphold Bank of America values. 

Fair dealing and responsibilities to customers 

At Bank of America, we are expected to deal fairly with our customers, 

competitors and third parties. 

• You should not take unfair advantage of any customers, competitors or 

third parties through manipulation, concealment, misuse of proprietary and 

confidential information, knowingly false misrepresentation of facts or any 

other unfair business practice. 

• You must not give or accept bribes, kickbacks, promises or preferential 

extensions of credit. 

• You must approve or award orders, contracts and commitments based on 

objective business standards to avoid favoritism or perceived favoritism. 

• You must not conspire or collude in any way with competitors. 

Every decision we make as an 

institution and as employees 

impacts not only the corporation 

and our teammates, but our 

shareholders and communities 

as well.

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2016 Code of Conduct | We honor our Code 6

Reporting certain conduct—

Code complaints and possible violations 

Bank of America can be held criminally liable if one of its employees or 

agents commits certain crimes. Subject to the Notice to Employees

in this Code, you must promptly report any knowledge or information 

about conduct by another employee or agent of the corporation that you 

reasonably believe to be: 

• A crime 

• A violation of law or regulation or policy

• A dishonest act, including misappropriation of funds or anything of 

value from Bank of America, or the improper recording of corporation’s 

assets or liabilities 

You also must report any other circumstances or activities that may 

conflict with the Code of Conduct.

If you have any questions or concerns regarding the Code of Conduct: 

• Consult your manager or compliance officer. 

• Refer to the Global Compliance website for additional 

information and compliance contacts.

To report complaints or possible violations regarding ethical 

issues or other inappropriate activity, call the Ethics and 

Compliance Hotline: 

• Employees in the U.S., Canada, Puerto Rico and U.S. Virgin Islands call toll-free 

1.888.411.1744 or submit a report online at reportlineweb.com/bankofamerica

• For other international employees, toll-free dialing instructions will vary by 

location. Please see the Ethics and Compliance Hotline International Dialing 

Instructions for details. International employees may submit a report online at 

reportlineweb.com/bankofamericainternational

Complaints or possible violations can be submitted anonymously and in complete 

confidence. However, because of strict data privacy laws, particularly in the European 

Union, employees working outside the U.S. may be subject to certain limitations on 

reporting to the Ethics and Compliance Hotline. If you are outside the U.S., consult 

your local policies and procedures on reporting, or contact your local human resources 

or compliance department, and they will be able to advise on the rules applicable to 

you and appropriate local reporting channels. 

Bank of America will not retaliate, and prohibits all employees from retaliating, 

against any employee who in good faith reports suspected unethical conduct, 

violations of laws, regulations or Company policies. 

Please review special consideration for EMEA employees, contractors and 

other workers for more information.

For individuals in the U.K., concerns of inappropriate activity by the bank or its 

employees can be reported directly to the Financial Conduct Authority (FCA) 

or the Prudential Regulation Authority (PRA). Reporting to the FCA/PRA is not 

conditional on a report first being made internally. It is possible to report internally 

and to the FCA/PRA (simultaneously or consecutively). For more information, please 

refer to the UK Whistle-blowing Policy.

Bank of America takes claims of retaliation 

seriously. We will investigate allegations of 

retaliation, and anyone found responsible 

for retaliating against an employee who 

reported to the Ethics and Compliance 

Hotline is subject to disciplinary action, up 

to and including termination of employment 

and possible legal action.

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2016 Code of Conduct | We honor our Code 7

The Ethics Oversight Committee resolves issues regarding the Code of Conduct, 

including potential violations and certain exceptions, and reviews information from 

the Ethics and Compliance Hotline. The committee includes the corporation’s 

general auditor, general counsel, global risk executive, global compliance executive 

and global human resources executive. 

Non-retaliation 

Bank of America values clear and open communications, and respects the 

contributions of all employees. You will not be retaliated against for reporting 

information, in good faith and in accordance with this Code, that you reasonably 

believe relates to possible misconduct, unethical acts and/or securities law 

violations. Retaliatory conduct includes discharge, demotion, suspension, threats, 

harassment, and any other manner of discrimination in the terms and conditions 

of employment because of any lawful act you may have performed in connection 

with such reporting. 

Observing the Code of Conduct and annual training 

As a Bank of America employee, you are required to agree to observe the Code of 

Conduct and take Code of Conduct training, which includes an acknowledgment, 

on an annual basis. 

Code waivers 

The board of directors must approve any waiver of the Code of Conduct for the 

chief executive officer, the chief financial officer, the chief accounting officer and 

any executive officer or director. The corporation will promptly disclose any such 

waiver on its website or through a press release or other public filing as required 

by applicable law, rule or regulation.

Special obligations of managers 

We all are responsible for abiding by the Code; reporting known or suspected 

violations of the Code, laws, rules, regulations, policies or procedures; questioning 

business practices that may contradict or violate our Code; and cooperating in 

investigations of potential violations. 

Managers have additional obligations to do the following: 

• Lead by example: actively practice ethical behavior, manage risks in accordance with 

the Company’s Risk Framework and live the standards of our Code and our values. 

• Hold others accountable for acting in accordance with our values, our Code and our 

Risk Framework. 

• Make sure that teammates are aware of our Code and related policies and procedures. 

• Maintain a workplace environment that encourages candid discussions about ethics 

issues with no fear of reprisal. 

• Refrain from conduct that could be considered an abuse of your position or influence 

(for example, improperly pressure teammates for personal benefit or activities). 

• Treat all employee reports and ethics complaints confidentially and consistently follow 

Company policies and procedures for handling them.

Q: As a manager, how can I promote ethical behavior? 

A: First and foremost, lead by example. Include discussions 

about workplace ethics in team meetings. Allow team 

members to feel comfortable asking questions when they 

have concerns. Remind employees that they will not be 

retaliated against for reporting information in good faith 

and in accordance with this Code.

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2016 Code of Conduct | We act ethically 8

We act ethically 

At Bank of America, integrity is required and employees are expected to be 

honest, ethical and trustworthy.

Conflicts of interest 

Bank of America faces actual, potential and perceived conflicts of interest on a 

regular basis during the normal course of business. The Code of Conduct provides 

basic guidelines of ethical business practices, management of conflicts of interest, 

and conduct that we are expected to adopt and uphold as Bank of America 

employees or as individuals performing duties and assignments on behalf of the 

Company through third party relationships. 

What is a conflict of interest? 

Conflicts of interest may occur when: 

• Personal business or financial interests or activities compete or interfere—or 

even appear to compete or interfere—with your obligations to the corporation, 

its shareholders or customers. 

• The interests of two or more of the corporation’s customers conflict, potentially 

giving rise to a material risk of damage to the interest of one or both of 

the customers. 

• The corporation’s interests conflict with those of its customers. 

Conflicts of interest also arise when you or your family members receive 

improper personal benefits, products, services or preferential treatment as a 

result of your position, or the position of a family member, in the corporation. 

Such situations might interfere with your judgment or ability to properly fulfill your 

responsibilities on behalf of Bank of America, its customers or its shareholders. 

You are responsible for identifying and managing actual or perceived conflicts 

in accordance with applicable regulatory requirements and Bank of America 

policies, including this Code.

At Bank of America, 

integrity is required 

and employees are 

expected to be honest, 

ethical and trustworthy.

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For purposes of this Code, family member includes spouse or domestic partner, child 

(including by adoption), parent, grandparent, grandchild, cousin, aunt, uncle, sibling, 

parent-in-law, brother-in-law or sister-in-law of the employee or the employee’s 

spouse or domestic partner, as well as step relationships of the foregoing.
2016 Code of Conduct | We act ethically 9

It is impossible to define every action that could be reasonably interpreted as a 

conflict of interest. This section defines several potential conflicts of interest as 

examples of which you must be aware: 

• Gifts and entertainment 

• Gifts among employees 

• Information disclosure and dissemination 

• Outside business activities 

• Political contributions and activities

• Third parties 

• Anti-bribery and anti-corruption 

• Interactions with government employees 

Some general considerations for identifying potential conflicts of interest: 

• Perception: Could the activity or transaction be perceived as a potential 

conflict by others? 

• Intent: Is the offer or request an attempt to influence the recipient’s or 

your judgment? 

• Impact: Will the Company, its shareholders or its customers be disadvantaged 

without legitimate reason if you participate in the activity or transaction? 

• Objectivity: Will participation in the activity or transaction affect a customer’s or 

your judgment or your ability to be objective with regard to any business decision? 

• Time considerations: Will the time required by the outside business activity 

interfere with your ability to effectively carry out your job responsibilities to the 

Company, its shareholders or its customers? 

Steps to take if you think a conflict of interest may exist: 

• Seek counsel through your manager or your primary compliance or risk officer. 

• Employees in the U.S., Canada, Puerto Rico and U.S. Virgin Islands 

also may call toll-free 1.888.411.1744 or submit a report online at 

reportlineweb.com/bankofamerica. 

• For other international employees, toll-free dialing instructions will vary by location. 

Please see the Ethics and Compliance Hotline International Dialing Instructions

and “Reporting certain conduct; Code complaints and possible violations” section 

of this Code for details. International employees may submit a report online at 

reportlineweb.com/bankofamericainternational. 

Gifts and entertainment 

Providing gifts, including promotional items and entertainment, is often customary in 

the financial services industry; however, many jurisdictions have rules that regulate 

these activities. You must adhere to such rules to avoid impropriety or the appearance 

of impropriety that could expose Bank of America to civil or criminal liability or 

threaten the public’s trust in Bank of America. 

A conflict of interest may arise when you provide or receive gifts or entertainment to 

or from clients, prospects or third parties. Such activities must be legal, and should 

not be frequent or extravagant. 

You must not provide or accept entertainment to or from current or prospective 

customers or third parties unless it is for a valid business purpose, provides an 

opportunity for a meaningful business conversation and is otherwise in conformance 

with our enterprise and local policies and the Anti-Bribery/Anti-Corruption Policy. 

Before entertaining or giving any item of value to a government employee, you 

must confirm your requirements under applicable policies and procedures, which may 

include obtaining pre-approval from your manager and your compliance officer. 

You must not give or receive gifts of cash or cash equivalent instruments to or from 

current or prospective customers or third parties, unless given as part of, and in 

compliance with, an approved Bank of America customer satisfaction program. 

These restrictions are not intended to apply to gifts or entertainment based on family 

relationships where the circumstances make it clear that it is the relationship—rather

than Bank of America’s business—that is the motivating factor for giving the gift. 

Based on industry laws and regulations, and particularly for employees in certain 

businesses, your gift and entertainment activities may be restricted to specific 

dollar limits or subject to certain pre-approval thresholds. Specific tracking and 

reporting requirements may also apply. Please confirm your obligations with your 

compliance officer and refer to the Anti-Bribery/Anti-Corruption Policy for 

specific requirements.

You must not provide or accept entertainment to or from 

current or prospective customers or third parties unless it is 

for a valid business purpose, provides an opportunity for a 

meaningful business conversation and is otherwise in 

conformance with our enterprise and local policies and the 

Anti-Bribery/Anti-Corruption Policy. 

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2016 Code of Conduct | We act ethically 10

Gifts among employees 

A conflict of interest may arise when you provide or receive gifts to or from another 

employee, and especially when gifts are exchanged among employees in the same 

reporting line or in positions of influence.

You must not give or receive gifts to or from another employee that may create a 

real or perceived conflict of interest. Additionally, gifts must not be used as a form 

of compensation or reward for job performance.

Note that you may provide gifts in connection with life events (for example, weddings, 

birthdays, births, etc.) where the circumstances make it clear that it is the life 

event— rather than Bank of America’s employment relationships—that is the 

motivating factor for giving the gift.

Under all circumstances, employees must exercise good judgment to ensure that 

any gift is reasonable for the occasion, is not lavish or frequent, does not create any 

appearance of impropriety, and could not be perceived to be compensation.

Information disclosure and dissemination 

A conflict of interest may arise if you make certain types of information public. 

Subject to the Notice to Employees in this Code, you must not disclose or 

disseminate to the public, except as part of your job responsibilities, proprietary and 

confidential Company information, including such information regarding customers, 

employees, third parties, market conditions or business events, and employee 

information learned in the course of your work. Even if you inadvertently or 

accidentally share or disclose such information, a conflict of interest may arise. 

Outside business activities 

A conflict of interest may arise from activities, employment or other relationships 

outside your role with Bank of America. 

You must not act on behalf of or appear to represent the corporation in any business 

transaction outside your role and responsibilities with Bank of America. Inform your 

manager and obtain all required approvals before you: 

• Pursue additional employment outside Bank of America

• Engage in an independent business venture 

• Perform services for another business organization 

• Run for or accept appointment to any political office

You must not misuse Bank of America resources while pursuing such outside business 

activities and relationships (including but not limited to physical space, supplies, 

communications methods or time) or allow any outside business, civic or charitable 

activities to interfere with your job performance. Bank of America generally discourages 

employees from serving on a board of a for-profit organization in a personal capacity, 

particularly the board of a public company, and other approvals are required. For 

more information, and to disclose your involvement in an outside business activity or 

outside directorship, please visit the Outside Business Activities website.

Q: I would like to work part time on the weekends at a local department 

store to make extra money for the holidays. Is this a conflict? 

A: Before starting a second job, you must obtain your manager’s approval and 

inform compliance. The second job must not interfere in any way with your job 

performance at the Company.

Q: I’ve been asked to serve on the board of a local non-profit organization. 

Do I need to report this? 

A: You must obtain approval from your manager before serving on a board of an 

organization, whether a for-profit or a non-profit entity. Additional approval and 

reporting may also be required. For additional information and guidance, please 

visit the Outside Business Activities website.

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2016 Code of Conduct | We act ethically 11

Political contributions and activities 

In general, you may make personal political contributions, within applicable legal 

limits, to candidates, parties, committees, and other entities that make political 

expenditures. Because of industry regulations and state or local laws, employees of 

particular businesses or employees with certain coverage responsibilities may be 

restricted from making some political contributions or engaging in certain political 

activities. Please confirm with your compliance officer and refer to the Anti-Bribery/ 

Anti-Corruption Policy if you are subject to such limitations and any pre-clearance 

requirements prior to making or soliciting others to make political contributions or 

otherwise engaging in political activities. Employee political contributions are made 

in your own personal capacity and are not reimbursable. 

Under no circumstance may you coerce or pressure other employees to make 

political contributions. Employees may not engage in or make use of any Company 

assets or personnel to engage in political fundraising or solicitation activities for 

their own political interests on Company premises.

For more information, visit the U.S. Employee Political Activities website. 

Third parties 

A conflict of interest may arise from relationships with third parties or other service 

providers. If you are authorized to approve or award orders, contracts, commitments 

or engagements to third parties of goods or services, you must do so based on 

objective business standards to avoid any real or perceived favoritism. 

Anti-bribery and anti-corruption 

You are expected to comply with the U.S. Foreign Corrupt Practices Act, the U.K. 

Bribery Act, as well as all other anti-bribery and anti-corruption laws whenever and 

wherever you conduct business on behalf of Bank of America. You may not give, 

promise or offer money or anything of value, or authorize any third party working on 

behalf of Bank of America to give, promise or offer anything of value including but 

not limited to currency, offers of employment, lavish gifts and entertainment to any 

customer, government employee or any other person for the purpose of improperly 

influencing a decision, securing an advantage, avoiding a disadvantage or obtaining 

or retaining business. If you engage in such behavior, you expose yourself and the 

corporation to potential civil and/or criminal liability and significant reputational 

harm, and undermine the trust of our customers, shareholders and communities. 

For more information, visit the Anti-Bribery and Anti-Corruption website.

Interactions with government employees 

Interactions with government entities and their employees may 

expose the corporation and its employees to a myriad of public policy, 

legal and compliance concerns. Prior to these contacts, you must 

confirm with your compliance officer if there are any limitations or 

requirements that apply to your contact (for example, limits on gifts 

and entertainment, requirement to register as a lobbyist). 

You are expected to be particularly vigilant when interacting with government 

employees and must not engage in behavior that could be seen as being intended 

to improperly influence a Bank of America business relationship. 

You must not offer, give or promise to give money or anything of value to any 

executive, official or employee of any government, agency, state-owned or controlled 

enterprise, political party or candidate for political office if it could be seen as being 

intended to influence a Bank of America business relationship. You must be sensitive 

to those situations or circumstances that could create an appearance of impropriety 

or potential conflict of interest, or raise bribery or corruption concerns.

Nothing in this section is intended to prohibit employees from filing a complaint with 

governmental agencies such as the Securities and Exchange Commission (SEC), the 

Financial Industry Regulatory Authority, Inc. (FINRA), the National Labor Relations 

Board (NLRB), the Occupational Safety and Health Administration (OSHA), and similar 

regulatory entities. Refer to the Notice to Employees in this Code for further guidance.

Q: I am interested in running for a local office. 

Because I am not sure if I will win, can I wait 

until after the election to get my manager’s 

approval to serve in that position? 

A: No. You must obtain the approval of your manager 

and compliance before running for or accepting 

appointment to any political office.

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2016 Code of Conduct | We manage risk effectively 12

We manage risk effectively 

Bank of America is in the business of taking risks. You are 

responsible for understanding what risks impact the Company, 

managing those risks and ensuring an appropriate risk/reward 

balance. The Company must practice effective risk management 

regardless of whether the Company performs the activity 

internally or through a third party. The Company’s use of third parties does not 

diminish the responsibility to ensure that the activity is performed in a safe and 

sound manner and in compliance with applicable laws. 

Individual accountability is at the heart of our risk culture—this means that 

each employee is responsible for understanding and complying with all applicable 

policies, completing all mandatory risk-related training, and for using his or her 

judgment to manage risk in their daily business activities. We are all accountable 

for identifying and debating risk-related issues, escalating concerns, taking a stand 

and making sound judgments about the risk/reward trade-offs of business decisions. 

You should take an open, candid and fact-based approach to discussing risks, 

making all relevant facts and information available so the Company can consider 

all possible options and make decisions. You also are responsible for promptly 

communicating and escalating matters to management that may cause risk or 

potential harm to the Company, such as operational problems, policy violations, 

illegal activities or other risks. Always act to protect the Company and the 

interests of shareholders. For more information, please refer to the Risk 

Framework. 

Individual accountability is at the heart of our 

risk culture—this means that each employee 

is responsible for understanding and complying 

with all applicable policies, completing all 

mandatory risk-related training, and for using 

his or her judgment to manage risk in their 

daily business activities.

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2016 Code of Conduct | We are fair and honest in our communications 13

Responding to media inquiries 

We work to both advance and protect the Bank of America brand through engagement 

with the news media as part of our larger marketing, communications, public policy and 

corporate affairs activities. It is the Company’s policy that only employees designated by 

Bank of America’s Media Relations staff are authorized to speak with the media as spokesperson for and on behalf of the Company. If you are contacted or approached by a reporter 

or member of the media and asked to speak on behalf of the Company, you should direct the 

reporter to Bank of America Media Relations. Employees who anticipate speaking or 

otherwise communicating with the media on behalf of the Company are required to 

comply with applicable line of business specific policies and procedures and obtain 

approval from a member of the Media Relations staff prior to engaging in any media 

(including social media), public relations or communication(s).

You must refer all contacts and requests received from the media for comment on behalf 

of the Company to Media Relations. This includes requests for information or comments 

on behalf of the Company about company business, plans, organizational or administrative matters, results of operations, or information about the Company’s performance to 

Media Relations. This also includes requests for comments or information on behalf of 

the Company either on an “on-the-record” or “off-the-record,” or “background” basis. This 

also prohibits employees on behalf of the Company from giving members of the media 

access to or a summary of Company confidential or proprietary information, such as 

internal conference calls, webcasts, internal emails or other written materials or presentations, without prior involvement and approval of the Media Relations Team.

These policies are not intended to infringe upon or violate rights protected under applicable 

employment, securities, or other applicable laws, rules and regulations. However, whether 

speaking on behalf of themselves or the Company, employees may not disclose proprietary 

and confidential information learned in the course of one’s work (such as salary 

information about others learned in the course of your employment with the Company) 

or any confidential customer or client information, except as specifically provided in the 

Company’s policies or as described in the Notice to Employees in this Code.

Failure to comply with this section of the Code of Conduct constitutes grounds for 

disciplinary action up to, and including, termination of employment.

We work to advance and protect the 

Bank of America brand through engagement 

with the news media as part of our larger 

marketing, communications, public policy 

and corporate affairs activities.

We are fair and honest in our 

communications

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2016 Code of Conduct | We are fair and honest in our communications 14

Electronic communications and social media 

Bank of America recognizes that, when used properly, electronic communications 

and social media can positively impact our customers’ experience. Enhancements in 

electronic communications help employees save time and improve overall business 

efficiency. Electronic communications are an important part of how Bank of America 

does business. Adhering to this section of the Code builds and preserves customer 

trust, protects our brand, minimizes risk (reputational, regulatory, litigation) and 

maximizes the appropriate use of electronic communications and social media by 

employees to help drive Bank of America businesses in a compliant manner. 

During their non-work time, associates are permitted personal use of the internet, 

email and any other of the Company’s electronic tools. Bank of America may monitor 

and inspect all associate use of these resources to ensure productivity is not 

negatively impacted, maintain the integrity of the systems 

(such as monitoring for the introduction of malware or high 

volume) and avoid activities that may give rise to Company 

liability (such as claims of unlawful harassment or conduct). 

Employee and/or authorized user behavior in all electronic 

communications and social media (both internal and external usage) must adhere to 

the standards of this Code and in the Employee Handbook, as applicable.

All electronic communications sent over the Company’s systems and/or to or from 

Company-issued devices or Company permissible devices when those devices are 

connected to the Company’s network, tools and applications, including communications 

via social media, are, to the fullest extent permissible by law, subject to monitoring 

and retention by or on behalf of Bank of America. In the United States and other 

countries, where permissible, based on local laws and regulations, as applicable, 

employees should have no expectation of privacy with respect to electronic 

communications that are transmitted or stored on systems, platforms, hardware or 

software that are controlled by the Company or that are publicly available, including 

any publicly available social media, whether or not controlled by the Company. For 

questions regarding local laws and restrictions, employees should contact their local 

compliance officer or legal department.

Duty to cooperate 

You must fully and truthfully cooperate with any internal or external investigation or 

audit, or any regulatory examination or request for information. You need to be aware 

of and comply with any applicable business-specific policies and procedures regarding contact with regulators, which among other things, may require you to report 

such contact to either your manager and/or compliance officer. Additionally, you 

must immediately inform your manager if you are the subject of an external investigation unless laws, regulations or the investigating authority prohibit you 

from doing so.

We are all accountable to:

• Think independently

• Take a stand

• Actively escalate issues

• Assume personal accountability

• Take action

Back to Introduction |
2016 Code of Conduct | We safeguard information 15

We safeguard information

Except as permitted by applicable Company policies, and subject 

to the Notice to Employees in this Code, we must keep the 

following information confidential and secure: 

Customer information 

You must not access customer information or use customer 

information except for appropriate business purposes and must protect the 

confidentiality and security of customer information. 

You should be familiar with, and handle customer information in accordance 

with, Bank of America’s privacy notices, which detail our commitment to privacy 

and information protection, and internal privacy and information security policies 

and standards. You should also be familiar with the “need to know” policy for 

material, nonpublic information and certain other confidential information 

related to our corporate clients. 

For more information, including guidance on different classifications of data, 

please visit the Information Security website and the Privacy website and 

read the Information Security Policy and Information Wall Policy. 

We must keep the following confidential and 

secure: customer information, Bank of America 

information, employee information, third party 

information, intellectual property of others and 

corporate opportunities.

Any assets you create for Bank of America or while using 

Bank of America resources are the corporation’s property, 

and remain its property even if you leave Bank of America. 

Bank of America has guidelines with which you should be familiar 

to ensure the protection of intellectual property, records and 

other information. Please visit the following websites: 

• Intellectual Capital & Property 

• Records Management 

• Unsolicited Ideas Guidelines

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2016 Code of Conduct | We safeguard information 16

Bank of America information 

Subject to the Notice to Employees in this Code, you must keep secure and not 

disclose nonpublic information about Bank of America such as business plans, 

market conditions and third party information. Such information should only be 

shared within the corporation with other employees who “need to know” the 

information to perform their duties. Consult your manager if you have questions 

about sharing information about Bank of America on a “need to know” basis. 

Employee information 

As part of the Company’s commitment to protect employee information, 

Bank of America has processes and controls in place to govern the use, transmission, 

sharing, storage, disclosure, transfer, security, accuracy, and access to employee 

information globally. The U.S. Employee Privacy Policy establishes requirements 

for how employees, managers and third parties must treat U.S. employee 

information. Outside the U.S., country specific Data Protection Notices (DPNs) are 

in place, which can be provided by your local HR partner or compliance officer.

Third party information 

You must keep confidential and secure any information about the corporation’s 

purchase of products or services. Sharing this information with the wrong source 

could provide an improper advantage to the third party or its competitors and 

violates agreements Bank of America has with third parties. In some instances, it 

also might violate the “need to know” policy for material, nonpublic information. For 

more information, please visit the Third Party Management website.

For more information on privacy, visit the Privacy website. The 

Information Security website contains helpful information 

about confidentiality and information security at Bank of America. 

The “We will not misuse information” section of this Code of 

Conduct explains the prohibitions on misuse of material, 

nonpublic information as outlined in the Information Wall 

Policy, as well as relevant line of business specific policies.

Intellectual property of others 

We respect the intellectual property rights of others. Employees must not obtain or 

use the intellectual property of others in violation of confidentiality obligations or 

law. The use, sale or other distribution of intellectual property in violation of license 

agreements or intellectual property laws is prohibited. Additional information is 

available on the Intellectual Capital & Property website.

Corporate opportunities 

You must not deprive the corporation of an opportunity by: 

• Competing with the corporation or using corporate property, information or your 

position for personal gain 

• Taking for yourself an opportunity that belongs to the corporation, or helping others 

do so, if they are in a position to divert a corporate opportunity for their own benefit

Back to Introduction |
2016 Code of Conduct | We protect Bank of America assets 17

We must properly 

care for and protect 

Bank of America 

property and assets.

We must properly care for and protect Bank of America property and assets, 

which should be used for legitimate business purposes only. 

You must not: 

• Steal, embezzle or misappropriate money, funds or anything of value from 

Bank of America. Doing so subjects you to potential disciplinary action, 

according to the law and Bank of America policy. 

• Use Bank of America assets for personal gain or advantage

• Remove Bank of America assets from the facilities unless you have your 

manager’s approval 

• Use official Bank of America stationery, the corporate brand, documents or 

the Bank of America name for commercial gain

• Misuse your internet, phone or email privileges. During their non-work time, 

employees are permitted personal use of the internet, email and any other of 

the Company’s electronic tools. Bank of America may monitor and inspect 

all employee use of these resources to ensure productivity is not negatively 

impacted, maintain the integrity of the systems (such as monitoring for the 

introduction of malware or high volume) and avoid activities that may give 

rise to Company liability (such as claims of unlawful harassment or conduct). 

Therefore, employees should have no expectation of privacy when using 

Company electronic tools. More information on these and other policies is 

available in the “Working at Bank of America” section of the Employee 

Handbook, as well as in the Electronic Communications Retention – 

Enterprise Policy and Electronic Communications Guide.

We protect Bank of America assets

Bank of America assets include, but are not limited to, items such as: 

Computer software Innovations Customer lists or information

Intellectual property Data processing systems Money and funds

Databases Records Equipment

Reference materials Furnishings Reports

Files Supplies Ideas

Technology Information about corporate or customer 

transactions

The corporation’s private computer systems, 

including your email and your internet access

Back to Introduction |
2016 Code of Conduct | We conduct our financial affairs responsibly 18

You should conduct your personal financial affairs responsibly and keep your 

business expenses in order. 

You are responsible for your financial activities in the following areas: 

Borrowing

You may not personally borrow money from or lend money to third parties, 

customers or other employees unless the loan is to or from a family member or 

from an institution normally in the business of lending; and there is no conflict of 

interest. 

An occasional loan of nominal value (such as for lunch) to another employee or 

acquaintance is acceptable, as long as no interest is charged. 

Business expenses 

You must report your business expenses accurately and in a timely manner. You 

also must not use business credit cards for any purpose other than appropriate 

business expenses. 

You may not make purchases directly from or enter into contracts with third 

parties. The Company has established requirements for efficient and compliant 

purchasing, contracting and payments for products and services acquired from 

third parties.

More information on appropriate business expenses and purchasing channels is 

available in the Enterprise Expense Management Policy, the Enterprise 

Third Party Policy and the related Global Expense Standard. 

Personal accounts and fees 

Misuse of your personal accounts and banking services is prohibited. Additionally, 

you may not accept personal fees or commissions for any transaction on behalf 

of Bank of America unless you are specifically authorized to do so. 

You should conduct your personal financial 

affairs responsibly and keep your business 

expenses in order.

We conduct our financial 

affairs responsibly

Back to Introduction |
2016 Code of Conduct | We value each and every teammate 19

Diversity & Inclusion

At Bank of America, we value our differences—in culture, 

ethnicity, sexual orientation, gender identity, experience 

and thought—understanding that diversity and inclusion 

are good for business and make our company stronger. We strive to empower all 

employees to excel on the job and reach their full potential, and reward and 

recognize employees based on performance and results.

Encouraging a diverse and inclusive workplace gives us the business advantage 

of understanding and meeting the needs of our diverse customers, clients and 

communities. Our diversity also provides fresh ideas and perspectives and, when 

coupled with inclusion, results in an innovative environment.

Bank of America is proud to be a leader in supporting diversity and has been 

widely recognized for its progressive workplace practices and initiatives to 

promote inclusion.

Visit the Diversity and Inclusion website for more information.

Discrimination and harassment

At Bank of America, we are committed to maintaining a workplace free of 

discrimination and harassment based on race, color, religion, sex (including 

pregnancy, childbirth or related medical condition), gender, gender identity, 

sexual orientation, national origin, citizenship status, age, ancestry, marital 

status, medical condition, disability status or veteran status, or any other factors 

prohibited by local law (“Prohibited Behavior”). Bank of America considers such 

behavior unacceptable and contrary to the Company’s core values in that it 

undermines the goal of providing an inclusive environment.

At Bank of America, we value our differences 

—in culture, ethnicity, sexual orientation, 

gender identity, experience and thought.

We value each and every teammate

At Bank of America, we give everyone a fair opportunity to be part of 

our team and to excel, and we base decisions and rewards on facts 

and results. To help employees excel on the job and reach their full 

potential, we provide professional development strategies, tools and 

processes across the Company.

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2016 Code of Conduct | We value each and every teammate 20

Bank of America does not tolerate unlawful discrimination or harassment of any kind. 

Reported incidents of Prohibited Behavior and/or retaliation will be investigated. 

Investigations are conducted in as discreet a manner as is compatible with a 

thorough investigation of the complaint. If the Company finds violations of the 

Harassment and Discrimination Prevention Policy or other inappropriate conduct of a 

sexual, discriminatory or retaliatory nature has occurred, disciplinary action up to and 

including immediate termination from employment may result.

Generally, harassment may include verbal harassment, physical harassment, visual 

harassment, sexual harassment and abusive conduct. For more information, review 

the Harassment and Discrimination Prevention Policy. 

Workplace safety

We are committed to the safety and security of our teammates around the globe. 

In order to avoid risk to yourself or those around you, you must follow all applicable 

safety and security procedures, as well as applicable laws and regulations. You should 

report unsafe working conditions to your manager or compliance officer. 

Workplace violence

Bank of America strives to provide a safe work environment in which employees treat 

each other with courtesy and respect and resolve any differences in a professional, 

non-abusive and non-threatening manner. All employees are responsible for 

recognizing and mitigating emerging or existing issues and helping to manage risk 

within the Company. This is especially true when it involves the safety and security 

of our employees. Despite the name, workplace violence does not have to involve an 

act of violence. Workplace violence includes acts or threats of physical violence, but it 

also can include conduct or behavior such as harassment and bullying, if it is intended to make another individual fear for his/her safety. Employees have a responsibility 

to report inappropriate behavior before it escalates to violence in the workplace. We 

all have an obligation that if we see something, we say something.

An additional risk associated with workplace violence is domestic violence, defined 

as a pattern of abusive behavior that is used by one partner to gain or maintain 

power and control of another intimate partner. The Company is committed to 

providing training to employees, raising awareness of domestic violence and its 

impact in the workplace, and providing an appropriate level of support for employees 

who are victims of domestic or other violence. The Company encourages employees 

to reach out to their manager, Human Resources or Corporate Security if they are 

experiencing difficulties at work because of domestic violence or require assistance in 

dealing with the impacts of domestic violence. The Company encourages employees 

to speak up if they become aware that a co-worker is being subjected to domestic 

violence. The Company also prohibits the misuse of Company property, vehicles, 

telephones, other employees and/or computers to commit acts of domestic violence, 

including stalking, harassment, or threats.

Additional information can be found within the Violence Free Workplace Policy.

Business continuity 

Business continuity is the methodology used for responding to a business interruption. 

Floods, power outages, hurricanes and pandemics are just a handful of events which 

could negatively impact business operations. 

When these types of business interruptions occur, you may be called into action and 

asked to perform your duties at a different work location. That’s why Bank of America 

has made it a priority to ensure you know what your responsibilities are before, 

during and after a business interruption.

There are four primary objectives in which we classify our business continuity efforts: 

1 To ensure our employees’ safety

2 To mitigate further business impacts by taking positive actions to continue 

business operations

3 To restore critical processing by implementing our recovery plans to ensure 

critical functions are working properly

4 To return to business as usual as quickly as reasonably possible

Business continuity is every employee’s responsibility. You must:

• Know the emergency response procedures for your building.

• Keep your personal contact information updated within HR Connect.

• Talk with your manager before a business interruption occurs so you understand 

your role in recovery.

• Be familiar with the Emergency Notification and Associate Communication 

Tool (ENACT), and have your Person Number on hand.

• Keep wallet cards and key contact information readily available at all times.

• Call Security Operations (SOACC) to report life safety and security incidents, 

robberies, building security issues or any suspicious activity.

• If you are contacted by a member of the media, direct them to the “Are You a 

Journalist” section of the Bank of America Newsroom on bankofamerica.com.

Back to Introduction |
2016 Code of Conduct | We respect laws and regulations 21

We respect laws and regulations

We must not take any action, either personally or on behalf of Bank of America, 

which violates any law, rule, regulation or internal Company policies or procedures. 

It is impossible to list all applicable laws, rules, regulations, 

policies and procedures. While other topics are addressed 

elsewhere in the Code, this section presents additional 

topics regarding laws, rules and regulations of which 

Bank of America employees must be aware. 

Anti-money laundering and economic sanctions 

Money laundering is making money derived from unlawful activities “clean” 

by making it appear that the money comes from legitimate sources or 

transactions. Economic Sanctions are financial restrictions imposed by 

governments or international bodies to try to isolate or impede a specified 

individual or jurisdiction for some specified purpose. 

We all have a role to play in helping to prevent criminals and targets of 

sanctions from using Bank of America’s products and services. This includes an 

obligation to identify and report suspicious activity. Learn how to do your part 

through mandatory Global Financial Crimes Compliance training. For more 

information, visit the Global Financial Crimes Compliance website. 

Books and records 

Accurate record keeping and reporting reflects on our reputation, our integrity 

and our credibility, each of which promotes the interests of our shareholders. 

You must maintain accurate books and records consistent with business needs 

and legal requirements. 

To ensure the integrity of its consolidated financial statements, Bank of America 

has established internal accounting and operating controls and procedures, 

including disclosure controls and procedures, and a Disclosure Committee. 

All employees responsible for the preparation of the corporation’s financial 

statements, or who provide information as part of that process, must maintain 

and adhere to these controls so that all underlying transactions, both within 

Bank of America and with third parties, are properly documented, recorded and 

reported. 

We must not take any action, either 

personally or on behalf of Bank of America, 

which violates any law, rule, regulation or 

internal Company policies or procedures. 

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2016 Code of Conduct | We respect laws and regulations 22

In addition, we all have the responsibility to promote full, fair, accurate, timely and 

understandable disclosure in reports and documents that Bank of America files with 

or submits to regulators.

The Audit Committee of the board of directors has established procedures for the 

receipt, retention and treatment of complaints regarding accounting, internal 

accounting controls or auditing matters. You may raise any 

such concerns to the Ethics and Compliance Hotline. You will 

not be retaliated against for reporting information in good 

faith in accordance with this requirement.

Q: Where can I find information about identifying and reporting 

unusual or potentially suspicious activity? 

A: Visit the Global Financial Crimes Compliance website where you will 

find potential indicators of money laundering and the online transaction 

review memo used to report unusual or potentially suspicious activity.

Back to Introduction |
2016 Code of Conduct | We will not misuse information 23

We will not misuse information

Restrictions on trading in Bank of America securities 

You must not buy, sell, recommend or trade in Bank of America securities—

either personally or on behalf of someone else—while in possession of material,

nonpublic information relating to the Company, except through personal trading 

programs pre-approved by the Legal Department. 

In addition, you must not communicate or disclose such 

information to others who may trade in Bank of America 

securities. Doing so may not only be a violation of your 

duty to keep such information confidential, but also may be a violation of U.S. 

federal and state laws, and the laws of many countries. 

If you are a Bank of America Corporation director or have been designated as 

an “insider” by the Company, you must obtain approvals before trading in 

Bank of America securities. 

You must not buy, sell, recommend 

or trade in Bank of America 

securities while in possession of 

material or nonpublic information 

relating to the corporation.

What is material, nonpublic information? 

The definition of material, nonpublic information (MNPI) is broad. You should 

consider information to be material if a reasonable investor would consider it 

important in making an investment decision (for example, any information that 

likely would affect the market price of a security or financial instrument if made 

public). Examples include merger and acquisition information, significant leadership 

changes, and earnings-related and other significant financial information. In 

other jurisdictions, MNPI is often referred to as “inside information” or “pricesensitive information.” While MNPI and “inside information” or “price-sensitive 

information” are similar, they are not identical and the analysis is increasingly 

fact-specific. Therefore it is the obligation of each employee to be familiar with 

business-specific or jurisdiction-specific policies and procedures applicable to 

them, and if in doubt, to consult with their compliance or legal representative. 

You should consider information nonpublic if it is not generally available to the 

investing public. Please see the Information Wall Policy for more information 

regarding material, nonpublic information.

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2016 Code of Conduct | We will not misuse information 24

Bank of America employees must not engage in speculative trading of Bank of America 

securities. This generally prohibits short sales and trading in puts, calls and other 

options or derivatives with respect to such securities, unless such transactions are 

for legitimate, nonspeculative purposes. Our Directors and Designated Insiders may 

not engage in any such transactions for any purpose. If you have questions regarding 

the potential speculative nature of your transaction, please talk with your manager or 

compliance officer. Please note: This paragraph does not apply to the exercise of 

Bank of America employee stock options. For more information, please refer to 

Additional Guidance While Trading in Bank of America Securities.

Restrictions on trading in securities or financial instruments of other 

companies or issuers 

If you are in possession of material, nonpublic information about securities or 

financial instruments, you are prohibited from buying, selling, recommending or 

trading such securities or financial instruments. Under the securities laws, such 

activities constitute insider trading because they involve a fraud on the market by 

illegally permitting an individual or company to profit from information not otherwise 

available to the investing public.

In addition, you must not communicate or disclose such information to others who 

may misuse it, including family members. Doing so not only would be a violation of 

your duty of trust or confidence, but also may be a violation of federal and state 

laws, and the laws of many countries.

You must be familiar with, understand and comply with the Information Wall 

Policy and all other policies and procedures that relate to your area of responsibility. 

These policies are designed to: 

• Prevent the flow of information from employees in units that may receive material, 

nonpublic information about issuers of securities or financial instruments to 

employees in units that buy, sell or recommend securities and financial instruments 

to fiduciary and nonfiduciary accounts 

• Provide additional guidance on prohibitions against the misuse of material, 

nonpublic information, including additional restrictions on personal trading for 

certain designated units 

• Address other issues raised by the activities of each designated unit 

For more information, please visit the Information Wall Policy.

Back to Introduction |
2016 Code of Conduct | We invest in our communities 25

We invest in our communities

Corporate Social Responsibility

Being a responsible business is integral to our success, and 

that of the customers, clients, shareholders and communities 

we serve around the world. Corporate Social Responsibility

(CSR) is embedded in our values and informs how we conduct 

business, develop products and services, and deliver on our goals and commitments. 

CSR is integrated across six core areas, where we continue to focus our resources:

Responsible business practices: We rigorously review our business practices 

and policies and are continuing to simplify information for customers, maintain 

a strong risk culture, build industry-leading levels of capital and manage our 

businesses to be accountable to shareholders and stakeholders, including customers, 

clients, employees, regulators, and community and nonprofit organizations.

Strong economies: We support the economic health of communities, from 

financing affordable housing and small businesses in low-income neighborhoods 

to providing grants in the areas of housing, hunger and jobs.

Environmental sustainability: We put our capital and expertise to work to 

address climate change, reduce demands on natural resources and advance 

lower-carbon economic solutions.

Leadership and service: We support programs that develop emerging women 

leaders around the world as well as student leaders and high-performing 

nonprofits across the United States. Our employees volunteer their time and 

expertise, helping individuals to gain financial stability, feeding the hungry and 

building affordable housing.

Arts and culture: We promote local economic growth and community engagement 

worldwide, providing grants to help preserve works of art globally, lend exhibits 

to museums, and support free admission to U.S. cultural institutions.

Diversity and inclusion: With a global workforce in more than 40 countries 

—in thought, style, experience, culture, ethnicity and sexual orientation— 

we recognize that diversity and inclusion are good for business, attract and 

retain talent and enable our company to better serve employees, customers, 

clients and shareholders.

Corporate Social Responsibility is 

embedded in our values and informs 

how we conduct business, develop 

products and services, and deliver on 

our goals and commitments.

Back to Introduction |

© 2016 Bank of America Corporation | BRO-02-16-0627.A | ARXTM6KR