Access the JPMorgan Chase Code of Conduct PDF

Required Pre-clearance of Outside Activities
Do I need to seek pre-clearance of …
… an Outside Business Activity? Yes, almost always.
X
You must pre-clear:
• Anything for which you will be paid (for example, a second job or paid service for a not-for-profit organization)
• Any writing or speaking engagements, teaching positions, etc. — paid or unpaid — where the subject matter relates to JPMorgan Chase’s
business (see the Communicating Responsibly section)
• Any affiliation with another business — paid or unpaid — as a director, officer or holder of an official position; advisory board or committee
member; consultant or advisor; general partner, owner or holder of 5% or more of the business’ voting equity interests; or any similar position,
unless there is an exception listed in the Exceptions below (Note that service on the boards of public companies is generally discouraged and is
subject to enhanced review and approval requirements. Contact your Code Specialist for additional information.)
Exceptions — situations where pre-clearance is not required:
• Appointments that the Office of the Secretary has determined are made by our Company in the normal course of routine business
• Unpaid affiliations or positions with a trade association, professional association or other similar organization related to your position at our
Company — but talk to your Code Specialist and Government Relations in advance if the organization is involved with lobbying activities and you
are either an executive officer or board member or involved with the association’s government relations activities or political contributions
• Unpaid positions with co-op boards, condominium associations and similar entities where the sole business is to hold title or manage real
property in which you reside
• Unpaid positions with holding companies, trusts or other non-operating entities that engage in no activities other than holding your or your
family’s investments, where the investments themselves wouldn’t otherwise require pre-clearance if held directly
… an Unpaid Not-for-profit Activity? Sometimes, yes. In general, you do not need pre-clearance, but there are certain situations that require it.
You must pre-clear in situations where:
• You are an officer or director/trustee of the not-for-profit organization and it is a customer of the Company (other than for routine branch
banking services)
• You are an officer or director/trustee of the not-for-profit organization and you have been requested to serve by a customer or supplier of your
business unit
• Your service would otherwise present a real or apparent conflict of interest
• Your service could pose significant reputational risk to our Company
… Government Service? Yes, always.
You must pre-clear:
• Any government position, whether paid or unpaid, elected or appointed (for example, an elected official or member, director, officer or
employee of a government agency, authority, advisory board or other board, such as a public school or library board)
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