Modern Slavery Group Statement

For year ended December 31, 2022

I. Introduction
JPMorgan Chase & Co. (“JPMorgan Chase”, the “Firm” or “we”) supports fundamental principles of human rights
across all our lines of business and in each region of the world where we have a presence. We recognize that
modern slavery issues, such as forced labor, child labor and human trafficking, are a significant global challenge.
We believe it is the role of government and the business community in every country to protect human rights. We
also believe that our Firm has a role to play in promoting respect for human rights. It is our policy not to provide
lending, capital markets or advisory services to clients if there is evidence of forced or child labor, human
trafficking or slavery. To that end, this Group Statement (“Statement”), made pursuant to section 54 of the United
Kingdom (“U.K.”) Modern Slavery Act 2015 and section 16 of the Australia Modern Slavery Act 2018 (Cth), outlines
the steps we are taking across JPMorgan Chase to mitigate the potential risk of modern slavery occurring in our
business and supply chain.

II. About Our Organization

JPMorgan Chase is a leading financial services firm with assets of $3.7 trillion and operations worldwide. The Firm
is a leader in investment banking, financial services for consumers and small businesses, commercial banking,
financial transaction processing and asset management. Under the J.P. Morgan and Chase brands, we serve
customers in the United States (“U.S.”) and the U.K., as well as many of the world’s most prominent corporate,
institutional and government clients. We have a presence in over 100 markets globally, including the U.K. and
Australia, and have over 290,000 employees in 63 countries, with over 60% of those employees located in the U.S.
In addition, our supply chain is global and includes over 19,000 suppliers across 53 countries 1, providing goods
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and services, such as marketing, communications, professional and information technology related services.

As a financial services firm that seeks to comply with relevant local employment laws and regulations, we are
focused on addressing modern slavery risks in our supply chain and in the context of the business activities of our
customers and clients – as this is where such risks are most likely to be present. Nevertheless, this Statement
outlines practices and policies we have in place to mitigate the potential risk of modern slavery occurring
throughout the activities of our entire Firm.

III. Our Efforts on Human Rights and Modern Slavery

JPMorgan Chase recognizes that our business has the potential to impact surrounding communities and the
environment, and therefore it is important that we consider environmental and human rights issues when making
business decisions. Our Firm’s respect for the protection and preservation of human rights is guided by the
principles set forth in the United Nations Universal Declaration of Human Rights. Further, we acknowledge the
United Nations Guiding Principles on Business and Human Rights (“Guiding Principles”) as the recognized
framework for corporations to protect and respect human rights in their own operations and through business
relationships. JPMorgan Chase may consider a range of international recognized standards to inform the Firm’s

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Countries are based on the JPMC legal entities and not supplier location.

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approach in managing environmental and social (“E&S”) risks, including the Equator Principles and the IFC
Performance Standards.

Our Human Rights Statement outlines our commitment to support fundamental principles of human rights across
our lines of business and in each region of the world where we have a presence. In addition, the Firm’s Business
Principles, our firmwide employee Code of Conduct and our Supplier Code of Conduct (“Supplier Code”)
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 of Conduct,
Supplier Code, firm policy, or a law or regulation related to JPMorgan Chase business, are obligated to report such
concerns to the Firm. This can be done through various channels as described in the Code of Conduct and the
Supplier Code, including the Firm’s Conduct Hotline (administered by a third party), Human Resources and Global
Security. The JPMC Conduct Hotline is available 24 hours a day, seven days a week for all employees, customers,
and suppliers to raise conduct concerns, with the option of anonymity where permitted by law. Designated internal
teams investigate allegations of misconduct. In addition, we have a range of policies and procedures that pertain to
human rights issues, including modern slavery, across our business and supply chain.

A. Employees
As a global financial services firm, we have a broad base of employees who work across various lines of business,
regions and functions to deliver products and services to our clients and customers, as well as employees who
provide expertise in risk management, technology, legal, policy and regulation, finance, accounting, controls,
human resources and many more areas. As of year-end 2022, 94% of our employees worked full-time, while over
17,700 were part-time employees. Our workforce also includes over 14,600 contractors 2. 1F

JPMorgan Chase is committed to respecting the human rights of our employees through our internal employment
policies and practices and by respecting local laws and regulations related to human rights. Fostering diversity,
equity and inclusion is a cornerstone of our corporate culture, and we strive to ensure that employees are able to
work in a safe, professional work environment. We continue to reinforce our culture of respect and inclusion and
anti-harassment efforts across the Firm through engagement activities, internal communications and training.
Prior to the first day of employment or service, we complete background assessments on all new employees and
new contractors, respectively, to confirm hiring requirements are met.

In addition, a total rewards portfolio including compensation, benefits and policies are an important part of our
human capital strategy and help to attract, retain and motivate our workforce. We are committed to providing
competitive and equitable compensation for our employees, and benefits that support our employees’ needs, such
as health, family planning, financial health programs and retirement benefits and other programs to bolster work-
life balance. We look closely at how we compensate employees, including by conducting pay equity reviews at all
levels of our Firm, taking into account factors such as an employee’s role, tenure, seniority and geography.

B. Suppliers
JPMorgan Chase is committed to holding ourselves and our supplier community to high standards of business
conduct and integrity. We facilitate annual targeted surveys and attestations of our supply chain to inquire and
confirm that suppliers have programs and oversight practices in place to ensure that they and their own suppliers
do not engage in, encourage or condone modern slavery practices and are respectful of human rights. The surveys
and attestations target key suppliers in spend categories – such as electronics, apparel and hospitality – where such

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The contractor summary is a year-end total of in-scope contractors only.

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industries face greatest potential exposure to modern slavery risks. Potential issues or concerns found during the
review process are escalated to relevant Line of Business Control Managers for further review and escalation. In
addition, we conduct due diligence on prospective suppliers, including negative media screenings, which covers a
range of high-risk issues – such as modern slavery. Our Supplier Code of Conduct sets out our principles and
expectations for suppliers, vendors, consultants, contractors and other third parties working for or on behalf of the
Firm, as well as the owners, officers, directors, employees, consultants, affiliates, contractors, temporary workers
and sub-contractors of these supplier organizations and entities. The Supplier Code communicates the
responsibilities of suppliers on a range of issues, including the need to promote and respect human rights by
working to prevent child and/or forced labor and human trafficking in their operations and supply chains, and by
instituting practices and operations that are consistent with the framework provided by the Guiding Principles. For
example, suppliers must comply with all labor laws and employ only workers who meet applicable minimum age
requirements in the jurisdiction, provide a non-violent, safe work environment, free of threats or intimidation or
physical harm, and comply with all applicable wage and hour labor laws and regulations governing employee
compensation and working hours.

The Supplier Code also includes an obligation for our suppliers to report any concern or suspected violation of the
law or regulation related to JPMorgan Chase’s business or a violation of the Supplier Code. While no such violations
have been reported to date, we maintain firmwide operational risk practices in place that enable appropriate
escalation and remediation of issues in the event such violations are reported. Finally, JPMorgan Chase’s standard
contractual agreements require suppliers to adhere to all laws and regulations, and to the Supplier Code.

C. Products, Services and Customers

As part of our broad effort to integrate respect for human rights into the business activities of the Firm, JPMorgan
Chase has various policies and procedures designed to prevent our products and services from being used for
improper purposes. These include:

• Policies and procedures pertaining to Anti-Corruption, Anti-Money Laundering (“AML”) and Know Your
Customer (“KYC”) due diligence. JPMorgan Chase has in place a Referral of Unusual and Potentially
Suspicious Activity Standard, which defines the requirements for identifying and referring unusual or
potentially suspicious activity, including raising potential concerns related to human trafficking and
modern slavery. The Firm also has a Global Anti-Money Laundering Compliance Program that includes
policies, procedures and internal controls designed to comply with all applicable U.S. and international
AML and counter-terrorist financing laws and regulations. As part of this program, the Firm works to help
identify customers whose financial activity may show involvement in human trafficking or other forms of
modern slavery and communicates actionable information directly to law enforcement. JPMorgan Chase
conducts targeted AML investigations to assist in identifying human trafficking networks, and in the U.S.
participates in various private-public partnerships aimed at disrupting trafficking activity and
organizations. The Firm is a member of the Wolfsberg Group, an association of 13 global banks that aims
to develop frameworks and guidance for the management of financial crime risks, particularly with respect
to AML and counter-terror financing policies. In addition, the Firm participates in the Joint Money
Laundering Intelligence Taskforce, a public-private information sharing forum in the U.K., which is working
to understand and disrupt funding flows linked to threats such as organized immigration crime, human
trafficking and modern slavery.
• Policies and standards in place relating to environmental and social risk indicate certain sectors, activities
and financial products subject to enhanced due diligence. We continue to evaluate policies and processes
instituted by clients to avoid or mitigate modern slavery risks within their operations and supply chains

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 and, where material risks are identified, we engage with the client to discuss the allegations and
remediation actions.
• The Global Corporate Governance Principles and Voting Procedures and Guidelines outline J.P.Morgan
Asset Management’s (“JPMAM”) approach to proxy voting and engaging with companies on environmental,
social and governance (“ESG”) issues. JPMAM also publishes a Sustainable Investing Statement which
describes its sustainability integration approach in its investments and across its operations, including its
engagement approach to human capital management and human rights. For listed equities and fixed
income, JPMAM’s due diligence and engagement on the topic is supported by its proprietary quantitative
ESG score and qualitative fundamental research. It also monitors companies identified by third-party
vendors as contravening the UN Global Compact Principles including human rights abuses. For further
engagement details please refer to JPMAM’s annual Investment Stewardship report.

D. Training
Where relevant to their line of business and function, employees receive training on policies and procedures that
pertain to products and services we provide to our clients and customers. This includes training on the ethical
principles in our Code of Conduct as well as the Firm’s Anti-Corruption, AML and KYC policies and practices. In
addition, employees must affirm their compliance with the Code of Conduct.

JPMorgan Chase has made available an E&S risk course designed to help employees understand how E&S risks,
including human rights-related issues, could impact our clients and our businesses, as well as how to escalate
concerns.

IV. Consultation Between Reporting Entities

Several groups were engaged as part of the process to produce this Statement, including regional Legal and
Compliance teams, as well as subject-matter experts, for example Human Resources, Supplier Services and Global
Financial Crimes Compliance. In addition, representatives of relevant local and parent-level entities were consulted
and any feedback has been incorporated in this Statement.

V. Our Evolving Process

We strive to measure the effectiveness of our actions to manage modern slavery risks and engage with a range of
stakeholders on this topic. We periodically assess the effectiveness of our policies and practices described in our
Modern Slavery Group Statement, which includes considerations of changing global circumstances and evolving
policy environments.

This Statement applies to entities 3 of JPMorgan Chase & Co. that are subject to the requirements of section 54 of
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the U.K. Modern Slavery Act 2015 and section 16 of the Australia Modern Slavery Act 2018 (Cth). This Statement
was prepared in consultation with relevant firmwide functions and JPMorgan Chase has consulted with the in-scope
entities under the Australian law. This Statement was approved by the JPMorgan Chase & Co. Board of Directors on
April 18, 2023 for the year ended December 31, 2022. It has been published on the Human Rights section of the

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The Boards of Directors of each entity we have determined to be in-scope have approved this Statement, including: Aldermanbury Investments Limited; J.P. Morgan SE;
J.P. Morgan Capital Holdings Limited; J.P. Morgan Europe Limited; J.P. Morgan GT Corporation; J.P. Morgan Limited; J.P. Morgan Markets Limited; J.P. Morgan Securities
plc; JPMorgan Asset Management (UK) Limited; JPMorgan Asset Management International Limited; J.P. Morgan Investment Management Inc.; JPMorgan Chase & Co.;
JPMorgan Chase Bank, N.A.; JPMorgan Chase Holdings LLC, JPMorgan Funds Limited and specifically with respect to this joint Modern Slavery Statement (Australia):
JPMorgan Chase Bank, N.A., J.P. Morgan Securities Australia Limited, J.P. Morgan Australia Group Pty Limited, J.P. Morgan Administrative Services Australia Limited, J.P.
Morgan Securities plc, J.P. Morgan Securities LLC, JPMAM RE GP 3 LP and J.P. Morgan SE. For additional information, please contact: OTS-London@jpmorgan.com.

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JPMorgan Chase & Co. webpage (see https://www.jpmorganchase.com/about/our-business/human-rights) and will
continue to be reviewed annually.

Jamie Dimon
Chairman & Chief Executive Officer
JPMorgan Chase & Co.