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 and similar laws that prohibit improper payments.

We have a board-approved Prohibited Receipts and Payments Policy that states that no officer, director, associate, agent or attorney of First Horizon Corporation, First Horizon Bank or any of their direct or indirect subsidiaries 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 First Horizon. The policy also provides that no officer, director, associate or agent of First Horizon shall directly or indirectly give or offer a bribe, kickback or similar payment or consideration to any person or entity for any reason.

Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Office of Foreign Assets Control (OFAC)

First Horizon is dedicated to being a trusted financial institution and combating money laundering. We diligently work to provide responsible, ethical banking services and verify our clients’ identities to prevent any misuse of our bank. All associates are required to complete an annual BSA/AML/OFAC training. Board members also receive annual BSA/AML/OFAC training. In addition, targeted training is provided covering Fraud and Security Awareness and Commercial Loan Fraud.

The purpose of our board-approved BSA Policy and Program (which also covers AML and OFAC) is to ensure First Horizon’s compliance with the related regulations through its BSA/AML/OFAC Compliance Program. The policy and program establish steps that must be taken to meet the requirements of the regulations. Key processes addressed include collecting and verifying the identity of clients for the Customer Identification Program (CIP), identifying beneficial owners of entities, establishing processes for the monitoring, identification and reporting of suspicious activity and performing initial and ongoing OFAC sanctions screenings on all clients. The Chief Compliance Officer and the Enterprise Bank Secrecy Act Compliance Officer, in conjunction with the Compliance Risk Committee, formulate the BSA Policy and Program and recommend changes as appropriate. The Policy and Program are reviewed at least annually, and any recommended changes are approved by the Board.

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 competition fairly and has a legacy of succeeding with honest business practices and superior performance.

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 defines 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.

Fair and Responsible Business Marketing

The Company’s Fair and Responsible Banking policy covers Fair Lending, marketing and UDAAP (Unfair, Deceptive, or Abusive Acts or Practices) to create a consistent and common focus on treating all clients fairly. First Horizon ensures that the principles of fair and responsible banking are incorporated into its overall client business strategy. 

Fair Lending and UDAAP are integral parts of the Company’s policies and procedures, marketing efforts and relationships with third parties involved in banking processes. The Company’s management believes that this commitment to fair and responsible banking is a good and sound business practice that allows the Company to serve a wide range of clients and communities, which is essential to the economic vitality of the Company and the communities it serves. 

To fulfill its commitment to fair and responsible banking, the Company has empowered and requires each of its officers, associates and agents to use their best personal and professional efforts and resources to always offer products and services that meet the needs of all clients and communities on a fair and equitable basis. The Company will not tolerate noncompliance by any of its officers, associates or agents in serving its clients and potential clients. 

Internal controls, system automation and monitoring by the three lines of defense are in place to ensure compliance. The Chief Compliance Officer in conjunction with the Compliance Risk Committee is responsible for maintaining a Fair Lending Compliance Program overseen by the Fair Lending Officer that provides for a system of internal controls to ensure ongoing compliance, monitoring and training for appropriate personnel. Each Line of Business, including marketing, is responsible for conducting transactions in compliance with the Fair Lending Laws and regulations. Line of Business Management will implement and maintain appropriate compliance procedures, training, forms and monitoring systems to ensure compliance. Line of Business Management may delegate its authority to appropriate company officers to carry out that responsibility. 

The Board of Directors has delegated authority to the Risk Committee to revise this policy to address changes in Fair Lending laws and regulations, internal reorganization affecting the company or any other reason the Risk Committee may deem appropriate.

Political Involvement

Our Code of Business Conduct and Ethics includes the following statement on political matters: The Company is subject to certain limitations and/or prohibitions under federal and state law concerning political contributions and political activities. In addition, the Company is allowed to engage with federal, state and local officials, but may be required to register as a lobbyist when doing so, and there are restrictions on the gifts that company associates may give to government officials. Because applicable federal and state laws and regulations in this area are quite technical, company directors, officers and associates should seek the guidance of the Company’s General Counsel before engaging in any political activities that involve the Company.

Certain associates may also be solicited for contributions to the First Horizon Political Action Committee (PAC). All contributions are voluntary. In general, directors, officers and associates of the Company may voluntarily engage in personal political activities as long as they do so on their own time and without Company resources. However, certain directors, officers and associates are subject to restrictions on their personal political activities under federal and state law or under Company policies and procedures. These individuals must comply with the policies and procedures adopted by their respective business lines concerning personal political activities. The Company notifies associates who are subject to these restrictions.

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 and business practices support our belief that all people should be treated fairly and with respect.

We are firmly committed to non-discrimination and equal access for our associates, clients and suppliers. First Horizon’s Code of Business Conduct and Ethics outlines the principles that guide the conduct of every aspect of our business. 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 our agents and representatives.

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. We do not restrict or deny products or financial services based on a client’s or potential client’s religious or political beliefs or lawful activities.

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.
• 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.
• Instituting a Corporate Responsibility working group to help us build stronger communities and guide our responsible business practices. The Corporate Responsibility Working Group meets quarterly to review, recommend and report to the Executive Management Committee and the Board of Directors on corporate responsibility 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 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.

Other Corporate Governance Documents

Our Board has adopted the following key corporate governance documents. These are available, along with several other governance documents on our website.

Corporate Governance Guidelines provide our directors with guidance as to their legal responsibilities, promote the functioning of the Board and its committees, and establish a common set of expectations as to how the Board should perform its functions.

Code of Ethics for Senior Financial Officers promotes honest and ethical conduct, proper disclosure of financial information and compliance with applicable governmental laws, rules and regulations by our senior financial officers and other associates who have financial responsibilities.