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GOVERNANCE

Political Engagement and Public Policy Statement

JPMorgan Chase believes that responsible corporate citizenship demands a strong commitment to a healthy and informed democracy through civic and community involvement.

Our business is subject to extensive laws and regulations at the international, federal, state and local levels, and changes to such laws can significantly affect how we operate, our revenues and the costs we incur. Because of the potential impact public policy can have on our businesses, employees, communities and customers, we engage with policymakers in order to advance and protect the long-term interests of the Firm.

Oversight & Compliance

The Public Responsibility Committee of the Board of Directors (PRC) provides oversight of the Firm’s positions and practices on public responsibility matters. At least once per year the PRC, which is composed entirely of independent outside directors, reviews the Firm's significant policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships, including their continued relevance to the Firm's public policy objectives.

The Firm’s political engagement and public policy activities are managed by global Government Relations and Public Policy (GRPP). GRPP reports to the Head of Corporate Responsibility, who is responsible for GRPP’s legal compliance and reports regularly to the PRC about the Firm’s political activity, expenditures and engagement. This organization and leadership helps us focus the Firm’s political engagement efforts on those public policy issues most relevant to the long-term interests of the enterprise overall and to our clients and shareholders.

Political Contributions, Expenditures and Payments

The Firm has strict internal policies and compliance processes to ensure adherence to relevant legal and regulatory requirements. We are fully committed to complying with all applicable laws regarding political contributions, such as MSRB Rule G-37, SEC Rule 206(4)-5, CFTC Rule 23.451, SEC Rule 15Fh-6, FINRA Rule 2030, as well as all national, state and local limits and requirements applicable to our business.

Corporate Payments

Our policies prohibit the use of corporate funds to contribute to candidates, political party committees and political action committees, including SuperPACs and political committees organized under Section 527 of the Internal Revenue Code (IRC) to promote the election or defeat of candidates for office. The Firm does not use corporate funds to make independent political expenditures or electioneering communications. The Firm restricts trade associations and 501(c)(4) organizations to which we belong from using our membership dues for any such election-related activity.

The Firm may contribute corporate funds for the purpose of supporting or opposing state or local ballot initiatives that may materially affect the Firm or our business operations. When the Firm contributes funds in connection with a ballot initiative we will disclose the amount and recipient of such payment, which may include a 501(c)(4) organization, on our Political Engagement Report.

Employee Political Action Committees

Throughout the Firm’s history, JPMorgan Chase has been active in the political process. We believe this engagement is essential to advance and protect the long-term interests of the Firm and our shareholders. The JPMorgan Chase & Co. Political Action Committees (PACs) are funded entirely by voluntary contributions from eligible employees. They support candidates, parties and committees whose views on specific issues are consistent with the Firm’s priorities, and fund dues payments and ballot contributions to entities organized under Section 527 of the IRC. Contributions are directed by GRPP on a bi-partisan basis and are not made to candidates running for U.S. president. In deciding whom to support, GRPP prioritizes candidates who represent the communities we serve, who serve on relevant committees or in leadership positions and who have shown support for issues of importance to the Firm. Issues of importance to the Firm include: banking issues; financial services policy; financial markets; the economy; small business; housing; trade; tax; inclusive and sustainable economic growth (e.g., financial health, affordable housing, workforce, second chance, responsible energy transition); diversity, equity, and inclusion (e.g., racial and gender equality, LGBTQ+ rights, disability rights); and military and veteran issues.

No single criterion or policy determines a candidates’ eligibility for PAC contributions. Legislators address a wide range of complex issues, and we recognize that we will not align with all positions of candidates. PAC disbursement decisions are intended to reflect areas of common interest with candidates. The firm looks at a broad set of issues that impact the long-term health of the economy, country and company and reviews and refreshes contribution criteria annually, with inputs from internal stakeholders. GRPP participates in a rigorous election-cycle budget process while actively monitoring for opportunities to align our giving with the firm’s organizational priorities and the firm’s values.

The Head of GRPP is responsible for administration and supervision of the PACs, with oversight by the PRC. PAC contributions are reported to and made publicly available by the Federal Election Commission and relevant State or local election authorities in accordance with applicable law. The Firm publishes a summary of PAC contributions on our Political Engagement Report. In the event that the Firm identifies a substantial misalignment between issues of importance to the firm and recipients of political contributions, the Firm will disclose the information in the annual Political Engagement Report.

Compliance

Decisions regarding PAC contributions and corporate payments, including those for memberships and ballot initiatives, are made exclusively to promote the interests of the Firm, without regard for the personal political views or interests of senior management. GRPP works closely with our Legal Department to ensure that all PAC contributions and corporate payments are made in accordance with applicable law, Firm policies and this statement.

Lobbying

GRPP represents the Firm’s policy interests before government bodies globally to provide information and perspective on legislative matters of significance to the Firm and our lines of business. On the state and local level, GRPP lobbies primarily in states in which the Firm has a retail presence or other material business operations. Information about our retail locations is linked in our Political Engagement Report.

The Firm complies with all national, state and local laws concerning lobbying registration and reporting by GRPP. The Firm makes quarterly lobbying filings with the U.S. Congress disclosing our lobbyists’ federal lobbying expenditures and the issues on which they have lobbied. GRPP’s state and local lobbying costs are disclosed where and as required by applicable law. If the Firm engages in grassroots lobbying, we will disclose such activity where and as required by law. A summary of our federal lobbying expenditures and instructions for searching our filings and issues lobbied is available on our Political Engagement Report.

The Firm belongs to a number of trade associations that advocate on major public policy issues of importance to the Firm and the communities we serve. The Firm’s participation as a member of these associations comes with the understanding that we may not always agree with all the positions of an association or its other members, and that we are committed to voicing our concerns as appropriate through GRPP and the Firm leaders who interact with these associations. A list of the Firm’s principal trade associations, along with the portion of our membership dues attributable to lobbying, is disclosed on our Political Engagement Report.

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