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INNOVATIONApril 2020 COLLABORATION LEADERSHIP RESPECT DIVERSITY OPPORTUNITY
STEVE J. SQUERICHAIRMAN AND CHIEF EXECUTIVE OFFICERHow we do our work is just as important as what we do. One of our Blue Box values is “we do what’s right” andI believe that is among the things that makes us a great company – and charts a path to an even greater future.To guide us, we rely on our Code of Conduct, which lays out how we conduct business at American Express.I expect everyone to know and follow the Code. No matter your level, where you’re located or what your role is,everyone in this company has a voice. If a business practice doesn’t feel right, speak up. You can raise concernsto your leader, your Colleague Strategic Partner, a Compliance Officer or through the Amex Ethics Hotline. Youcan do so without fear of retaliation – we take that very seriously. Do not allow anything to compromise yourintegrity – not financial targets, not competitive pressures and not even direct orders from your leader.Each time you take this Code of Conduct training, you renew that commitment. Know the Code. Understand it.Put it into practice every day. Nothing could be more critical to your success and the continued success ofAmerican Express.Thank you,i
AMERICAN EXPRESSBLUE BOX VALUESWe’ve alwaysbeen guided bystrong principles,stood behind ourpromises and builtour business aroundextraordinaryservice. Today,we know thoseprinciples as ourBlue Box Values.They’re the heart ofour culture at Amex.WE DELIVER FOR OURCUSTOMERS.We’re driven by our commitment todeliver exceptional products, servicesand experiences to our customers.We value our strong customerrelationships, and are defined by howwell we take care of them.WE MAKE IT GREAT.We deliver an unparalleled standard ofexcellence in everything we do, stayingfocused on the biggest opportunitiesto be meaningful to our customers.From our innovative products to ourworld-class customer service, ourcustomers expect the best — and ourteams are proud to deliver it.WE DO WHAT’S RIGHT.Customers choose us because theytrust our brand and people. We earnthat trust by ensuring everything wedo is reliable, consistent, and with thehighest level of integrity.WE RESPECT PEOPLE.We are a diverse and inclusivecompany, and serve diversecustomers. We believe we are abetter company when each of us feelsincluded, valued, and able to trustcolleagues who respect each of us forwho we are and what we contribute toour collective success.WE NEED DIFFERENT VIEWS.By being open to different ideas fromour colleagues, customers and theworld around us, we will find moreways to win.WE WIN AS A TEAM.We view each other as colleagues – partof the same team, striving to deliverthe brand promise to our customersand each other every day. Individualperformance is essential and valued, butnever at the expense of the team.WE CARE ABOUT COMMUNITIES.We aim to make a difference in thecommunities where we work and live.Our commitment to corporate socialresponsibility makes an impact bystrengthening our connections.ii
TABLE OFCONTENTSProtection of Property and Information.16Physical Property.16Intellectual Property.16Confidential Information and Trade Secrets.16Third-Party Property and Information.19Privacy.19Communicating with the Public aboutAmerican Express. 20LETTER FROM THE CEO. iOperating in an Open Network Environment. 22AMERICAN EXPRESS BLUE BOX VALUES. iiExport of Encryption Items. 25INTRODUCTION. 1Other Trading in American Express Securities.27Our Shared Responsibilities.2Disclosure of Nonpublic Information and Tipping.27Our Leaders’ Responsibilities.2Insider Trading. 26Disciplinary Action.2OUR COMMITMENT TO OUR CUSTOMERSAND BUSINESS PARTNERS.28WHERE TO SEEK HELP AND REPORT CONCERNS. 3Products and Services. 28Making Reports. 4Sales and Advertising. 29Non-Retaliation. 4Gifts and Entertainment. 29Training, Confirmation & Code of Conduct Disclosures. 4Antitrust and Fair Competition. 32OUR COMMITMENT TO EACH OTHER. 5Treatment of Colleagues and Others.5Diversity and Equal Employment Opportunity.5Freedom from Harassment. 6Contacts with Competitors. 32Competitor Information. 33Contacts with Customers and Vendors. 34Communications. 34Workplace Safety and Health.7OUR COMMITMENT TO OUR COMMUNITIES.35Drugs and Alcohol.7Money Laundering and Terrorist Financing. 35Violence.8Anti-Corruption. 36Workplace Violence Prevention Program.8Improper Payments.37OUR COMMITMENT TO OUR SHAREHOLDERS.9Conflicts of Interest. 9Outside Positions.10Employment of Relatives.11Business Opportunities. 12Outside Investments. 12Books and Records. 13Financial Statements and Accounts.14Maintenance of Records. 15Relationships with Auditors and GovernmentInvestigators or Regulators. 15Expediting Payments. 38Political Activities. 39Personal Political Activities. 39American Express Political Activities. 39Environment. 40Charitable Contributions. 40Modern Slavery and Human Trafficking. 40CLOSING NOTES. 41WHERE TO SEEK HELP AND REPORT CONCERNS. 42THE AMEX ETHICS HOTLINE.43
INTRODUCTIONAmerican Express Company’s reputation is a priceless asset. Built over 160years, it leads our customers and business partners to do business with us, ourshareholders to invest in us, and the best talent to join us in working for AmericanExpress (“our Company”). By following the high standards of business ethicsset forth in the Code of Conduct (“Code”), we each protect and maintain thisreputation. We must uphold these standards in all of our dealings with each otherand our stakeholders—including our customers, shareholders, vendors, otherbusiness partners and government regulators.Throughout the Code, you’ll find references to important Company policies.These policies are available on the Policy Center home page on The Square.In addition, individual business units issue policies that provide more specificguidance about certain business practices. If you need help finding orunderstanding a policy, please speak with your leader, your Compliance Officeror the General Counsel’s Organization (“GCO”).No waivers or exceptions to the Code will be made under any circumstances forAmerican Express colleagues. Third parties can request waivers on a case bycase basis.1
OUR SHARED RESPONSIBILITIESThe Code applies to all American Express colleagues. Weare all expected to read, understand and comply with theCode and all Company policies. We also must conductbusiness in accordance with all applicable laws andregulations at all times. If we find ourselves in a situationwhere customary conduct is at odds with the Code,Company policy or applicable laws or regulations, wemust comply with the more stringent standard. If you’reunsure which rule to follow, seek guidance from yourleader, your Compliance Officer or the GCO.If you know about or suspect a violation of the Code,Company policy or an applicable law or regulation, youowe it to your colleagues and our Company to promptlyreport your concerns to your leader, your ComplianceOfficer or anyone listed in the “Where to Seek Help andReport Concerns” (page 3) section of the Code.Our vendors and other business partners are alsoexpected to uphold our Company’s ethical standards andthe Blue Box Values. If you know or suspect that a vendoror other business partner is violating these high ethicalstandards or applicable laws or regulations, you owe itto your colleagues and our Company to promptly reportthe situation to your leader, your Compliance Officeror anyone listed in the “Where to Seek Help and ReportConcerns” section of the Code.OUR LEADERS’ RESPONSIBILITIESLeaders are expected to serve as ethical role models forall colleagues by exemplifying the Blue Box Values at alltimes. They must also communicate the importance ofthe Code and ethical conduct.Leaders must strive to create a positive work environmentin which colleagues feel comfortable asking for help andraising concerns about compliance with the Code. Leadersmust also be alert to any situations or actions that mayviolate the letter or spirit of the Code or Company policy,or may damage our Company’s reputation. It is importantthat they take immediate action to address such situations.When leaders receive reports of a situation that is unethicalor potentially damaging to our Company’s reputation,or suspect that one exists, they must promptly notifytheir Compliance Officer and work to resolve the issue.Resolution of the issue may also involve consultation withthe appropriate subject matter expert.Leaders who know about, or should know about,misconduct and do not act promptly to report it to theirCompliance Officer and correct the situation will besubject to disciplinary action up to and including discharge.Leaders must never engage in or tolerate retaliatory actsmade against anyone working on American Express’behalf, and are expected to clearly communicate to theirteams our Company’s “non-retaliation” policy.DISCIPLINARY ACTIONTo maintain the highest standards of integrity, we mustdedicate ourselves to complying with our Code, Companypolicies and procedures, and applicable laws andregulations. Individuals who fail to do so will be subjectto disciplinary action that may include termination. Theextent of any disciplinary measures will depend on thecircumstances of the violation. All discipline will be appliedin a manner consistent with our Company’s policiesand practices, as well as the law. In addition, applicableregulatory authorities may impose fines and criminal orcivil penalties on at-fault individuals.Anyone who retaliates against a person as a result oftheir making a good faith report or participating in aninvestigation will be subject to disciplinary action thatmay include termination.2
WHERE TOSEEK HELP AND REPORT CONCERNSAt times, we may encounter situations in which the rightchoice is not perfectly clear. If you need to ask for help orvoice a concern, your leader is likely the best person tospeak to because he or she knows your line of businessand your situation. However, you are always encouraged tocontact any of the following resources to seek guidance orreport your concerns: Your business unit’sCompliance Officer Your business unit’sColleague ExperienceGroup representative orthe Colleague & LaborRelations (CLR) Your business unit’sController The General Counsel’sOrganization The Corporate Secretary Internal AuditYou will find the contact information for these resources atthe end of the Code. See “Where to Seek Help and ReportConcerns.”If you prefer, you may make an anonymous (where legallypermissible) or confidential report with the Amex EthicsHotline. You will find the Amex Ethics Hotline contactnumbers and website at amex.ethicspoint.com.3
WHERE TOSEEK HELP AND REPORT CONCERNSMAKING REPORTSIf you have reason to believe that any American Express colleague, or anyone working onour Company’s behalf, may have engaged in illegal or unethical conduct, you have a dutyto your colleagues and our Company to promptly report your concerns. Doing so helps ourCompany to address issues and prevent future miscond
American Express Company’s reputation is a priceless asset. Built over 160 years, it leads our customers and business partners to do business with us, our shareholders to invest in us, and the best talent to join us in working for American Express (“our Company”). By
