" In 2018, the Vendor Code of Conduct was specifically updated to clarify our expectation that Vendors should not engage in any practice that could reasonably be considered as employing or encouraging child labor, forced labor, slavery or human trafficking. "

"Bank of America has a disciplined process to ensure effective contracts are in place with Vendors, including language that requires Vendors and their subcontractors to comply with Bank of America policies, procedures and other instructions. In 2017, Bank of America updated its global contract template to specifically require Vendors and their subcontractors to abide by labor laws and regulations in the regions where they conduct business, including those that address child labor, forced labor, slavery, human trafficking, equal pay and non-discrimination in the workforce. The contract template also specifically prohibits Vendors from engaging in any practice that could reasonably be considered as employing or encouraging child labor, forced labor, slavery or human trafficking. "

In addition, Bank of America requires Vendors as part of their contractual obligations to:

i.require their subcontractors to comply with applicable labor laws;

ii.implement policies, procedures training and guidance to ensure compliance with applicable laws;and

iii.perform background checks of their staff including ensuring eligibility to work in the relevant jurisdiction to safeguard against human trafficking or forced labor."