Code of Conduct and Code of Ethics for Finance Professionals

Code of Conduct

Our integrity and reputation depend on our ability to do the right thing, even when it’s not the easy thing. The Code of Conduct is a collection of rules and policy statements intended to assist employees and directors in making decisions about their conduct in relation to the firm’s business. The Code is based on our fundamental understanding that no one at JPMorgan Chase should ever sacrifice integrity — or give the impression that they have — even if they think it would help the firm’s business. Access the JPMorgan Chase Code Of Conduct

Code of Ethics for Finance Professionals

The purpose of the Code of Ethics for Finance Professionals Policy (Policy) is to promote honest and ethical conduct and adherence with the law, particularly as related to the maintenance of JPMorgan Chase & Co (firm) financial books and records and the preparation of its financial statements. Noncompliance with applicable ethics laws and regulations can result in significant legal and regulatory exposure to JPMC, as well as cause serious reputational harm.

The obligations outlined by this Policy are a supplement to, and do not replace Employee responsibilities and obligations listed in the firm's Code of Conduct. Adherence to this Policy is a term and condition of employment for Finance Professionals. The firm will take all necessary actions to enforce this Policy, up to and including immediate dismissal. Violations of this Policy may also constitute violations of law, which may expose both Employees and the firm to criminal or civil penalties.

This Policy applies to the conduct and reporting requirements of the Chief Executive Officer, Chairman, Chief Financial Officer and Principal Accounting Officer of JPMC (JPMC Finance Officers) and to all other professionals of the firm worldwide serving in a finance, accounting, LOB Treasury, tax or investor relations role (Finance Professionals).

Standards of Conduct

JPMC Finance Officers and Finance Professionals must act honestly, promote ethical conduct and comply with the law, particularly as related to the maintenance of the firm's financial books and records and the preparation of its financial statements. They are specifically required to:

  • Carry out their responsibilities honestly, in good faith and with integrity, due care and diligence, exercising at all times their best independent judgment
  • Comply with applicable government laws, rules and regulations of federal, state and local governments and other appropriate regulatory agencies
  • Never take, directly or indirectly, any action to coerce, manipulate, mislead or fraudulently influence the firm's independent auditors in the performance of their audit or review of the firm's financial statements
  • Assist in the production of full, fair, accurate, timely and understandable disclosure in reports and documents that the firm and its subsidiaries file with, or submit to, the Securities and Exchange Commission and other regulators and in other public communications made by JPMC
  • Take all reasonable measures to protect the confidentiality of non-public information relating to JPMC and its clients

Reporting Requirements

JPMC Finance Officers and Finance Professionals must:

  • Address actual or apparent conflicts of interest between personal and professional relationships by disclosing to their appropriate Legal or Compliance officer any material transaction or relationship that reasonably could be expected to give rise to such a conflict, and
  • Promptly report (anonymously, if they wish to do so) any known or suspected violation of this Policy or any other matters that would compromise the integrity of the firm's financial statements

Reports may be made anonymously to the Code Reporting Hotline or in any of the ways set forth in the Code of Conduct (see below).

The reporting requirements do not prevent employees from reporting to the government or regulators conduct that the employee believes to be in violation of law, and it does not require employees notifying JPMC prior to reporting to the government or regulators.

JPMC strictly prohibits intimidation or retaliation against anyone who makes a good faith report about a known or suspected violation of this Policy, or of any law or regulation.

Reporting by phone

Calling the Hotline 1-855-JPMCODE (576-2633) is the easiest way to make a report. You will speak with a trained interviewer (who is not a JPMC employee), and translation services are available.

Other reporting methods

Mail
The Network, Inc.
333 Research Court
Norcross, GA 30092 USA

Report online
www.tnwgrc.com/JPMC

Email
JPMC@tnwinc.com

Fax
1-770-409-5008 or 1-800-748-6159

By writing a letter to the General Counsel of JPMorgan Chase

Mail
JPMorgan Chase & Co.
Attn: General Counsel
270 Park Avenue
New York, NY 10017

Email
fraud.prevention.and.investigation@jpmchase.com