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JPMorgan Chase & Co. (“JPMorganChase”, the “Firm” or “it”) strives to support principles of human rights as they relate to its business segments and Corporate in each region of the world where it operates. The Firm recognizes that human rights issues are a global challenge and acknowledges that human rights considerations may arise in connection with its operations and business relationships.
The principles set forth in the United Nations Universal Declaration of Human Rights inform JPMorganChase’s respect for the protection and preservation of human rights, and the United Nations Guiding Principles on Business and Human Rights inform the Firm’s approach to respecting human rights in its own operations and business relationships. In addition, the Firm seeks to comply with applicable legal requirements in the jurisdictions in which it operates.
JPMorganChase considers human rights when engaging with the Firm’s employees, suppliers, clients and customers, as described in this statement.
Employees: JPMorganChase strives to support the human rights of its employees and is guided by applicable laws and regulations, as well as its internal employment policies and practices. The JPMorganChase Code of Conduct (“Code”) highlights the personal responsibility of every employee to operate with the highest standards of integrity and ethical conduct. Each year, employees must affirm their compliance with the Code.
JPMorganChase’s Equal Opportunity, Anti-Discrimination and Anti-Harassment Statement expresses the Firm’s intent to maintain 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. JPMorganChase does not tolerate unlawful discrimination, harassment, sexual harassment or inappropriate conduct by or against applicants, employees, customers, clients, vendors, contractors, contingent workers or any other individuals who conduct business with the Firm. Additionally, employees are required to complete training on topics such as conduct, anti-money laundering, privacy and data protection, and anti-corruption.
Suppliers: JPMorganChase expects suppliers to demonstrate ethical business conduct and adhere to the law at all times. The Supplier Code of Conduct communicates the Firm’s expectations of suppliers across a range of issues, including the need to adhere to human rights laws by working to prevent forced labor and human trafficking in their operations and supply chains, and by instituting practices that are consistent with the framework provided by the United Nations Guiding Principles on Business and Human Rights.
The Firm executes risk-based due diligence on its suppliers across a range of sustainability and governance matters, including screenings for human rights issues. Firmwide internal standards establish expectations for appropriate escalation and remediation in the event issues are reported.
Clients and Customers: The Firm works to make commercial decisions to support the strength of the franchise and sustained value to shareholders. JPMorganChase seeks to identify human rights-related risks with respect to its clients’ business models and operations. The Firm’s risk policies and standards indicate client activities and locations that are subject to enhanced review and assessed on a case-by-case basis. Where existing or potential risks have been identified, the Firm performs due diligence to facilitate a comprehensive understanding of the associated risks, determining the severity of these risks, the client's ability to manage them, and the level of residual risk to the Firm and our commercial interests. It is the Firm’s policy that it will not knowingly provide financial services to clients where it determines that there is substantiated evidence of human rights violations and where such client has not put into place adequate practices and policies to prevent or remediate such human rights abuses.
The Firm's risk policies and standards also consider human rights concerns of marginalized communities such as Indigenous Peoples. JPMorganChase recognizes that Indigenous Peoples, as social groups with identities that are distinct from mainstream groups in national societies, are often among the most marginalized and vulnerable segments of the population. Where relevant and as appropriate, the Firm considers a range of internationally recognized principles to inform its approach, including the International Finance Corporation (“IFC”) Performance Standards that address the treatment of Indigenous Peoples and include the principles of Free, Prior, and Informed Consent (“FPIC”), and may engage with clients concerning alignment with these internationally recognized principles.
The Firm’s policies and standards require that Lines of Business assess, as appropriate, the following risks related to the rights of Indigenous Peoples, which are outlined in the Firm’s Nature and Social Risk Taxonomy:
Where risks are identified, the Firm engages with companies and may require them to take steps to address implications for Indigenous Peoples’ lands and natural resources with appropriate policies and procedures, including FPIC, before proceeding with a transaction, including general corporate purpose, asset-specific financing and capital facilitation activities.
The Firm’s Fair Lending Statement outlines JPMorganChase’s commitment to treating all individuals fairly and equitably in the conduct of its lending businesses in all jurisdictions where it conducts business in accordance with all applicable laws. In the United States, relevant laws require the equitable treatment of all credit applicants without regard to race, sex (including sexual orientation and gender identify), color, national origin, religion, age, marital status, disability or familial status. Additionally, customers shall not be denied access to financial products or services based on characteristics protected by law or the Firm’s internal policies.
Governance: The Firm’s corporate governance structures define responsibility for oversight and management of sustainability and governance matters, such as human rights issues, at multiple levels within the organization, including the Board of Directors and senior management.
The Firm’s Business Principles, Code and Supplier Code of Conduct communicate the Firm’s expectation that business be conducted ethically and in compliance with applicable laws and regulations. Employees and suppliers who become aware of or who suspect violations of the Code, the Supplier Code of Conduct, Firm policy, or a law or regulation related to JPMorganChase business are required to report such concerns to the Firm. Concerns can be raised through various channels, including the Firm’s Conduct Hotline and to the Firm's Human Resources and Global Security teams. The Firm's Conduct Hotline is available 24 hours a day, seven days a week; the option of anonymity is available, where permitted by law. Designated internal teams review allegations of misconduct. The Firm strictly prohibits intimidation or retaliation against anyone who makes a good faith report about a potential or actual violation of the Code, Firm policy, or any law or regulation governing its business.
JPMorganChase recognizes that consideration of and respect for human rights is an ongoing effort. The Firm engages with a range of stakeholders on this topic and aims to annually review its policies described in its Human Rights Statement to support their ongoing appropriateness, considering changing circumstances and policy environments.
1 The information provided in this statement reflects JPMorganChase’s approach to human rights as at the date of this statement and is subject to change without notice. The Firm does not undertake to update any of such information in this statement. This statement is not intended to, nor can it be relied on, to create legal relations, rights or obligations.
