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Corporate Statements

Anti-Bribery and Anti-Corruption Statement

Our ethical business practices prohibit our associates from participating in bribery and accepting improper payments. We operate in compliance with all applicable regulations and applicable laws, which include the U.S. Foreign Corrupt Practices Act (opens in a new tab) and similar laws that prohibit improper payments.

We have a Board-approved Prohibited Receipts and Payments Policy that states: No officer, director, associate, agent, or attorney of First Horizon Corporation, First Horizon Bank, or any of their direct or indirect subsidiaries (“FHN”) shall corruptly solicit, demand, accept, or agree to accept anything of value (excluding compensation and expenses paid in the usual course of business) for himself or herself or a third party, intending to be influenced or rewarded in connection with any transaction or business of FHN. No officer, director, associate or agent of FHN shall directly or indirectly give or offer a bribe, kickback, or similar payment or consideration to any person or entity for any reason.

Anti-Money Laundering (AML) Statement

First Horizon is dedicated to being a trusted financial institution and combating money laundering practices. We diligently work to ensure that our banking services are used responsibly and ethically and verify our clients’ identities to prevent any misuse of our bank. We take pride in abiding by all laws pertaining to financial legality. All associates are required to complete annual trainings on the Bank Secrecy Act and Anti-Money Laundering, as well as targeted training on Commercial Loan Fraud and Fraud and Security Awareness.

The purpose of our Board-approved Bank Secrecy Act Anti-Money Laundering (“BSA”) Policy is to ensure First Horizon’s compliance with the Bank Secrecy Act, USA PATRIOT Act, Office of Foreign Assets Control and related regulations through its BSA/AML Compliance Program. The policy establishes steps that must be taken to meet the requirement to identify clients for the Client Identification Program (“CIP”). The Enterprise Bank Secrecy Act Compliance Officer, in conjunction with the Compliance Risk Working Group, formulates the BSA Policy and recommends changes as appropriate. The policy and program is reviewed at least annually and any recommended changes approved by the board of directors. The board of directors also receives annual training on BSA and the BSA/AML Compliance Program.

Code of Business Conduct and Ethics

First Horizon adopted our Code of Business Conduct and Ethics to set forth the overarching principles that guide the conduct of every aspect of our business. Among other topics, the code covers conflicts of interest, confidentiality, insider trading, political activities and associate matters. Our Code of Business Conduct and Ethics applies to all associates, officers and directors of First Horizon and its subsidiaries and, in certain cases, to its agents and representatives as well. First Horizon has also adopted a Code of Business Conduct and Ethics for Senior Financial Officers, a Compliance and Ethics Program Policy and many other policies with specific guidance on ethical matters.

Our Human Resources, Legal, Compliance and Corporate Security teams work together to oversee the handling of hotline submissions, Electronic Incident Reports and annual training on matters relating to these ethics codes and policies. Associates can anonymously report unethical or illegal activity in the workplace via the Ethics Hotline at 800-217-3031.

Code of Business Conduct for Suppliers

First Horizon seeks to outperform the competition fairly and honestly, and has a legacy of succeeding through such honest business competition. We seek competitive advantages through superior performance, not through illegal or unethical business practices.

Consistent with the First Horizon Code of Business Conduct and Ethics that sets the basic standards for associate conduct, we adopted a Code of Business Conduct for Suppliers that establishes our expectations for our suppliers (i.e., third parties that provide goods or services to First Horizon).

The Code of Business Conduct for Suppliers includes our expectations for suppliers related to conducting their business legally and ethically and covers topics such as bribery, confidentiality, fair dealing, human rights, non-discrimination and harassment, recordkeeping and reporting.

Data Privacy/Cybersecurity Statement

First Horizon is committed to protecting clients’ personal information from unauthorized access and use, and continues to remain vigilant with its measures to safeguard and secure all proprietary and confidential information.

We are steadfast in our commitment to safeguard our client and financial data. Our business practices, processes and controls regarding the protection and privacy of client data are subject to numerous federal regulations, including the Gramm-Leach-Bliley Act and the Health Insurance Portability and Accountability Act. Additionally, the Bank is routinely subject to regulatory scrutiny and examination from entities such as the Tennessee Department of Financial Institutions and the Federal Reserve Board.

We dedicate substantial resources to cybersecurity to protect the confidentiality, integrity and availability of financial and personal data, and First Horizon is continually making investments in new technologies and cybersecurity professionals to strengthen our defenses, mitigate cybersecurity threats and adhere to regulatory requirements.

Our associates receive fraud and information security training annually while dedicated personnel monitor FHNC systems and networks.

Diversity and Inclusion Statement

We remain committed to creating a more equitable society, and that starts with our associates, our clients and the communities we serve. We do this by elevating equity, providing capital and counsel, and committing to excellence in everything we do.

Firearms Statement

We continue to follow all laws, acts and applicable regulations in accordance with federal law related to the manufacturing, sale and use of firearms.

We believe gun policy and the associated applicable regulations are best addressed through the cooperation of the American public and policymakers.

Human Rights Statement

First Horizon respects individual human rights and is committed to operating our company in an environment where everyone is treated with dignity. While we believe our government and policymakers are primarily responsible for the laws and regulations that enable the preservation and protection of human rights, our company values (opens in a new tab) and business practices support our belief that all people should be treated fairly and with respect.

Our Commitment

Everyone will be treated without discrimination or harassment based on race, color, religion, sex, sexual orientation, gender identity, national origin, age, veteran status or disability.

First Horizon and our subsidiaries are also committed to a position of lending fairness and to making available meaningful services to all of our clients and communities on a fair and equitable basis.

Any associate who engages in unlawful activities or violates First Horizon’s Code of Business Conduct and Ethics or any of the company’s policies is subject to disciplinary action, including dismissal.

First Horizon honors our commitment to human rights by:

  • Conducting our business in a manner that is consistent with the fundamental human rights principles described in the United Nations Universal Declaration of Human Rights (opens in a new tab).
  • Requiring all associates to complete Code of Business Conduct and Ethics training upon hire, and annually thereafter, and to certify upon completing each training session that they have read, and that they understand, the Code.
  • Providing to all associates for annual acknowledgment the Associate Handbook (including Section 3 entitled “A Matter of Principles”) as well as full copies of the Code of Business Conduct and Ethics, Prohibited Receipts and Payments, Conflict of Interest and Confidentiality and Outside Affiliation and Indemnification policies.
  • Instituting a Corporate Social Responsibility (CSR) Committee to help us build stronger communities and guide our responsible business practices. The CSR Committee meets quarterly to review, recommend and report to the Executive Management Committee and the board of directors on CSR and environmental, social and governance (ESG) business and reputation topics.
  • Protecting the privacy of client information. All associates, even after leaving the company, must comply with the policies described in our Privacy Policy.
  • Establishing multiple ways for associates and clients to raise concerns, ask questions and report potential policy violations or unethical or suspicious behaviors with confidence and without fear of retaliation.
  • Operating our business in accordance with all applicable lending, labor, safety, health, anti- discrimination and other diversity and inclusion workplace regulations and laws.
  • Adopting a Code of Business Conduct for Suppliers that establishes our expectations for our suppliers (i.e., third parties that provide goods or services to First Horizon), consistent with the First Horizon Code of Business Conduct and Ethics that sets the basic standards for associate conduct.

Immigration Policy Statement

We believe topics related to immigration policy are best served through the cooperation of the American public and policymakers.

For more than 157 years, we have built our bank by valuing our people, standing behind our clients, strengthening our communities and being committed to fair lending practices.

We have considered both the implications of providing financing to organizations that provide government-funded services in support of immigration policy along with honoring the current contractual commitments to our clients.

For us, good corporate citizenship includes maintaining our clients’ privacy, and as such, we are not at liberty to discuss individual client business.

As we move forward and consider new commitments, our decisions will continue to be guided by our evaluation process that takes into account current lending regulations as well as our business goals, values and obligations to our stakeholders.