Summary

JPMorganChase is committed to building and maintaining a safe, productive, inclusive, professional, collegial and secure work environment in which all individuals are treated with respect and have an equal opportunity to succeed and make an impact through their work. Unlawful discrimination, harassment, sexual harassment or inappropriate conduct is not tolerated in any form by or against applicants, employees, customers, vendors, contractors, contingent workers or any other individuals who conduct business with JPMorganChase.

All employees, including managers and employees in non-managerial positions, are responsible for supporting equal opportunity and taking appropriate steps to promptly report and prevent discrimination, harassment, sexual harassment and inappropriate and abusive conduct. They are also expected to help create and maintain an atmosphere where concerns under this policy can be raised without fear of retaliation or intimidation.

This policy applies to conduct at JPMorganChase offices, work locations and while engaged in work-related activities outside the workplace, such as business-related meetings, recruiting activities, interview, conferences, trips, social events and communications, as well as non-work related social gatherings with other applicants, employees, customers, clients, vendors, contingent workers, contractors or any other individuals who conduct business with the firm.

Equal Opportunity; Prohibition Against Discrimination and Harassment

JPMorganChase is committed to providing equal opportunity in accordance with applicable local law and in all areas of people management, including recruitment, hiring, employment, assignment, transfer, promotion, compensation, benefits and training.

The firm seeks to attract and retain the best talent and makes employment decisions based upon legitimate business criteria and the qualifications, skills and experience of individuals. The firm prohibits discrimination, harassment, bias or prejudice in its terms and conditions of employment on the basis of an individual’s:

  • Age
  • An individual being the victim of domestic violence, sexual assault or abuse
  • An individual being the victim of, or witness to a crime
  • Any other protected status under applicable local law
  • Citizenship Status
  • Color
  • Creed
  • Ethnic Origin
  • Gender/Sexual Identity or Expression
  • Genetic Information
  • Marital or Relationship Status or Civil Partnership
  • Membership in the Traveller community or any community group protected by law
  • Military/Veteran Status
  • National Origin/Ancestry
  • Physical/Mental Disability
  • Pregnancy, maternity, paternity or caring responsibilities
  • Race
  • Religion /Religious Affiliation
  • Sex/Gender (including intersex or intergender status)
  • Sexual Orientation
  • Transgender Status

In addition, reasonable accommodations are made for applicants’ and employees’ religious practices and beliefs, mental and physical disabilities, and for pregnancy, childbirth and related medical conditions, including lactation, in accordance with applicable local law.

Prohibited Harassment

Harassment is any unwelcome conduct (verbal, nonverbal or physical) that has the purpose or effect of creating a hostile or offensive environment, or can reasonably be expected to cause an individual to feel unsafe, uncomfortable, intimidated, threatened, bullied, humiliated, offended or distressed.

Also prohibited are unwelcome sexual advances, requests for sexual favors and other verbal or nonverbal behavior or physical contact of a sexual nature (regardless of how the overture is communicated), whether it occurs one time or as a repeated act or pattern of behavior and whether it occurs in person, virtually, or via electronic device, social media or other means.

It is important to understand that:

  • Inappropriate conduct, harassment, sexual harassment may involve individuals of the same or different sex or gender and is prohibited regardless of sex, gender identity or whether the individual submits to the overture or rejects it.
  • Harassment, sexual harassment and/or inappropriate conduct are often defined by the impact to the recipient rather than by the intent of the person causing the offense.
  • Repeated inappropriate incidents and behavior can constitute harassment and/or sexual harassment even if one single incident may not be considered the same.
  • Real or perceived power that often comes from different levels of seniority, responsibility or job level/position and the ability to use position to coerce will be considered when assessing claims of harassment.

Inappropriate behavior will not, therefore, be excused or justified by claiming that it was unintentional or humorous or because it occurred under the influence of alcohol or other substances.

Reporting

Employees who are aware of possible violations of this policy must immediately contact their Manager, Human Resources or report the incident via JPMorganChase’s Code Reporting Hotline. The Hotline is operated by an external company, staffed 24/7 and callers have the ability to identify themselves or report anonymously (where permissible by law). It can be reached by phone or via internet, mail or fax, and translation services are available on request. Managers who become aware of potential violations of this policy must immediately report the information to the Code Reporting Hotline.

Reporting obligations to the company do not prevent employees from reporting to the government or regulators conduct that they believe to be in violation of the law.

JPMorganChase is committed to promptly and effectively reviewing all potential violations and taking action to address as appropriate.

Confidentiality will be maintained to the extent possible consistent with JPMorganChase conducting a thorough inquiry or investigation and responding where appropriate.

Non-Retaliation

JPMorganChase prohibits intimidation of or retaliation against an individual because he/she objected to behavior prohibited under this policy, reported a concern in good faith, or assisted with any inquiry or investigation under this policy.

Oversight

The Firm’s “How We Do Business” Principles serve as a guide for how employees are expected to conduct themselves, and the Firm’s Code of Conduct sets forth the Firm’s expectations for each employee.

Senior Leadership is responsible for setting the “tone at the top” consistent with our Business Principles. The Board of Directors provides oversight of the business and affairs of the Firm, including its culture and conduct. Each of the Board committees oversees reputational risks and conduct risks within its scope of responsibility. The Compensation and Management Development Committee (“CMDC”) oversees the Firm’s Business Principles, culture and significant employee conduct issues and any related actions. The Audit Committee receives regular reports from management on the Code of Conduct program. Each member of the board annually affirms his or her compliance with the Code of Conduct.

Workplace Training

Frequent training and awareness programs for employees are designed to promote a workplace free of discrimination and harassment. All employees must complete the firm’s required training when assigned.

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