Environmental, Social, and Governance Report Published July 2021 Table of Contents

A letter from the CEO ...... 5

About Wells Fargo ...... 6

Providing enhanced ESG disclosure ...... 7

Identifying our ESG priorities ...... 8

ESG goals and progress ...... 10

Contributing to the United Nations Sustainable Development Goals ...... 11

Working together to drive positive impact ...... 12

Continued response to the COVID-19 pandemic ...... 13

Corporate governance and ethics ...... 15

Board of Directors ...... 15

Select governance practices and shareholder rights ...... 17

Executive compensation ...... 18

ESG governance ...... 19

Code of Ethics and Business Conduct ...... 21

Risk management ...... 24

Public policy and political contributions ...... 28

Tax overview ...... 30

Delivering value to our customers ...... 31

Financial health programs ...... 31

Responsible treatment of customers with debt repayment problems . . . . . 31

Customer satisfaction ...... 33

Integration of ESG criteria in Wealth & Investment Management ...... 35

Expanding financial inclusion ...... 38

2 Responsible marketing supports informed decisions ...... 45

Information and cybersecurity ...... 45

Protecting customer and employee privacy ...... 47

Investing in our employees ...... 49

Culture ...... 49

Diversity, equity, and inclusion ...... 50

Addressing harassment in the workplace ...... 57

Performance management ...... 57

Employee training and development ...... 58

Competitive compensation ...... 59

Employee benefits ...... 61

Employment security and responsible workforce restructuring ...... 64

Safety and health ...... 65

Dealing fairly and ethically with our suppliers ...... 68

Supplier Code of Conduct ...... 68

Third-Party Center of Excellence ...... 68

Supplier diversity ...... 68

Integrating ESG into supplier selection and engagement ...... 70

Community engagement ...... 71

Philanthropy ...... 71

Global philanthropy ...... 74

Employee service and impact ...... 74

3 Understanding environmental and social impacts ...... 75

Global financial crimes risk management ...... 75

Bank Secrecy Act/anti-money laundering ...... 75

Global sanctions ...... 76

Anti-bribery and corruption ...... 76

Environmental and social risk management ...... 76

Respecting human rights ...... 79

Advancing environmental sustainability ...... 84

Climate commitment ...... 85

Climate-related disclosure ...... 86

Sustainable finance ...... 86

Operational efficiency ...... 88

Environmental risk and compliance ...... 90

Forward-looking statements ...... 91

Securities and Exchange Commission filings ...... 91

References and resources ...... 92

4 A letter from the CEO

As communities around the world begin to emerge socioeconomic opportunity, and renewable from the COVID-19 pandemic, it’s incumbent on us energy . We also announced our Banking Inclusion to reflect on the lessons of this difficult period . The Initiative, a 10-year commitment to help past year and a half has clearly demonstrated that unbanked individuals gain access to affordable, significant economic, social, and environmental mainstream, digitally enabled transactional challenges disproportionately impact our most accounts . The initiative will focus on reaching vulnerable communities . unbanked communities, with particular emphasis on helping remove barriers to financial inclusion Wells Fargo has a significant role to play in for Black and African American, Hispanic, and delivering practical solutions to urgent challenges . Native American/Alaska Native families, which We have the resources, business expertise, account for more than half of America’s 7 million ingenuity, and relationships with public and unbanked households .1 private sector organizations to do so . Our work to support an inclusive recovery from the COVID-19 This report provides a comprehensive picture pandemic, and to address the systemic issues it of the environmental, social, and governance has exposed, spans numerous areas . (ESG) work underway at Wells Fargo . I hope it will help inform you and all our stakeholders on In early 2021, Wells Fargo announced a goal of our progress, as it increases our accountability aligning our business activities with the goals of for meeting our ESG-related goals . We know this the Paris Climate Agreement and achieving network has no finish line; we still have much more to zero greenhouse gas emissions by 2050, including do . But we’ve made a long-term commitment to our financed emissions . We also launched an these efforts, and I’m confident they will continue initiative that aims to manage the deployment of to deliver positive impacts . $500 billion in financing to sustainable business activities by 2030 . Climate change is one of the most urgent environmental and social issues of our time . It impacts all communities, particularly our most vulnerable ones, and inaction is not an option . ‒ Charlie Scharf Earlier this year we also issued Wells Fargo’s CEO, Wells Fargo & Company Inclusive Communities and Climate Bond — our first sustainability bond — which will fund projects and programs that support housing affordability,

1. 2019 FDIC Survey of Household Use of Banking and Financial Services, released in October 2020.

5 About Wells Fargo

Wells Fargo & Company is a leading financial services company that has approximately $1 .9 trillion in assets and proudly serves one in three U .S . households and more than 10% of all middle market companies and small businesses in the U .S . Wells Fargo ranked No . 30 on Fortune’s 2020 rankings of America’s largest corporations . In the communities we serve, the company focuses its social impact on building a sustainable, inclusive future for all by supporting housing affordability, small business growth, financial health, and a low-carbon economy .

We provide a diversified set of banking, investment, and mortgage products and services, as well as consumer and commercial finance, through our four reportable operating segments:

Consumer Banking and Lending

Commercial Banking

Corporate & Investment Banking

Wealth & Investment Management

This report contains forward-looking statements, which may include our current expectations and assumptions regarding our future activities, plans, and objectives and other future conditions . Please see the “Forward-looking statements” section for more information about factors that could cause our actual results to differ materially from our forward-looking statements .

6 Providing enhanced ESG disclosure Our ESG Report and ESG Goals and Performance Data (PDF) are our foundational ESG disclosures . They provide an extensive overview of our most Throughout this document you will material ESG topics and how we manage key see the following callout to indicate where information about performance ESG issues . The ESG Report and ESG Goals trends is included in our ESG Goals and and Performance Data are part of a suite of Performance Data (PDF). complementary ESG disclosures, which include the following: Performance trends can be • 2020 Social Impact and Sustainability found in the Highlights Report (PDF) Wells Fargo ESG Goals and • 2020 Task Force on Climate-related Performance Data (PDF) . Financial Disclosures (TCFD) Report (PDF)

• Global Reporting Initiative (GRI) Index (PDF)

• Sustainability Accounting Standards Board (SASB) Index (PDF)

Additional ESG-related resources such as policies, statements, environmental data verification, sustainable investing, Modern Slavery Act statements, memberships and commitments, and ESG viewpoints, can be found on our Goals and Reporting webpage .

We intend to update our foundational ESG disclosures regularly to provide information that is current and relevant . Please refer to the publication date on the cover page as an indication of when updates were last made . We aim to provide the most up-to-date and accurate information in our disclosures . Commitments and time frames may vary .

7 ENGAGING STAKEHOLDERS TO INFORM ESG PRIORITIES

Understanding the perspectives of a wide range of stakeholders is critical Identifying our ESG priorities to identifying and managing our ESG Wells Fargo has an ongoing process to priorities. We engage with relevant assess and prioritize ESG topics that are stakeholders, including customers, employees, community members, most relevant to our company and our suppliers, shareholders, regulators, stakeholders . The topics covered in this media, analysts, and others. Engagement report reflect discussions with subject matter occurs through various channels, including experts from across our company, findings from face-to-face, telephone, email, social media, primary and secondary research, and feedback and surveys. Feedback is monitored and we receive and insights we gain through our shared with relevant groups across the ongoing engagement with stakeholders . organization. At Wells Fargo, we regularly monitor ESG trends to inform our ESG strategy, goals, and reporting priorities . We have been conducting formal ESG materiality assessments periodically since 2009 to identify topics most important for ESG purposes .

Our most recent ESG materiality assessment included substantial research in light of the significant, recent changes in our business and heightened stakeholder feedback about current and emerging socioeconomic and environmental trends . This research included an evaluation of global standard expectations, including the Global Reporting Initiative (GRI), the United Nations Sustainable Development Goals (SDGs), the Sustainable Accounting

8 Standards Board (SASB), and the Task Force on Climate-related Financial Disclosures (TCFD) . The following 14 topics were identified by As part of our most recent ESG materiality Wells Fargo as being the most significant to assessment, we interviewed internal and our internal and external stakeholders in our external stakeholders, including more than most recent ESG materiality assessment: 30 Wells Fargo leaders and subject matter Business ethics experts from across the company, and members of our external Stakeholder Advisory Council . Business policies and practices We also included input from stakeholders Climate risk management representing Wells Fargo customers and employees, ESG investors, government, Community development

media, NGOs, and financial peers . Compensation and benefits

We continue to develop new ESG goals and Corporate governance frameworks to address the themes and topics Corporate risk management and generated by the ESG materiality assessment . compliance

Customer privacy and data security

Diversity, equity, and inclusion

Employee incentives and risk-taking

Environmental and social due diligence

Fair and responsible lending and pricing

Stakeholder engagement

Transparent information and fair advice for customers

9 ESG goals and progress

Performance As a leading global As we move forward, we continue to explore trends can be found in the financial services company, opportunities to deliver solutions that make an Wells Fargo we have a significant impact . In 2021, we committed to deploying ESG Goals and role to play in helping to $500 billion in sustainable financing by 2030 and set Performance Data (PDF) . address social, economic, a goal to achieve net-zero greenhouse gas emissions and environmental — including financed emissions — by 2050 . To challenges . In 2016, we established an integrated, help meet this ambitious goal, Wells Fargo plans to companywide corporate responsibility strategy measure and disclose financed emissions for select that included an ambitious set of goals to carbon-intensive portfolios; set interim emission leverage our products and services, culture reduction targets; deploy more capital to finance and business practices, and philanthropy climate innovation; and continue to work with our to help address these global challenges over clients on their own emissions reduction efforts . a five-year period . We are excited to announce We have launched an Institute for Sustainable that we’ve achieved nearly all of our 2020 goals, Finance to manage our $500 billion commitment, and that we are in the process of reevaluating as well as to support science-based research on low- our long-term commitments so we can take carbon solutions and advocate for policies that enable an active role in addressing pressing societal client transitions . challenges . OurESG Goals and Performance Data (PDF) reflects final progress toward our 2016-2020 goals .

10 Contributing to the United Nations Sustainable Development Goals

At Wells Fargo, we’re guided by a common effort accomplishing 17 desired global outcomes to help our customers succeed financially . We also by 2030 — provide a guide for integrating recognize that we have a responsibility to do our sustainability more deeply into our business . part to help address the many global challenges Throughout this report, we share examples facing the communities we serve . As we strive of how Wells Fargo is contributing to the to strengthen our business for the future, the advancement of certain global priorities United Nations (UN) Sustainable Development outlined in the UN SDGs that are most relevant Goals* (SDGs) — a universal framework for to our business . Those global priorities include:

SDG 1: No Poverty Read more in Delivering value to our customers End poverty in all its forms, everywhere and Community engagement

SDG 5: Gender Equality Read more in Investing in our employees Achieve gender equality and empower all women and girls

SDG 7: Affordable and Clean Energy Read more in Understanding environmental and Ensure access to affordable, reliable, social impacts and Advancing environmental sustainable, and modern energy for all sustainability

SDG 8: Decent Work and Economic Growth Read more in Investing in our employees Promote sustained, inclusive, and sustainable economic growth; full and productive employment; and decent work for all

SDG 10: Reduced Inequalities Read more in Investing in our employees, Reduce inequality in and among countries Delivering value to our customers, and Community engagement

SDG 11: Sustainable Cities and Communities Read more in Delivering value to our customers Make cities and human settlements inclusive, and Community engagement safe, resilient, and sustainable

SDG 13: Climate Action Read more in Understanding environmental and Take urgent action to combat climate change social impacts and Advancing environmental and its impacts sustainability

We’re working hard to make meaningful A number of governments and regulators are and enduring contributions to society . pursuing initiatives that call for greater action This is at the heart of Wells Fargo’s approach and disclosure, including the UK Modern Slavery to effectively managing ESG matters, and this Act and the Task Force on Climate-related report demonstrates the many ways ESG Financial Disclosures (TCFD) . Meanwhile, considerations are integrated into our policies at an intergovernmental level, the UN SDGs* and programs . have become an important benchmark for multinational companies’ ESG efforts . We believe in clearly and transparently demonstrating how we’re delivering on our Increasingly, investors use ESG factors ESG commitments . And we further believe to guide their investment decisions, and that corporate leaders — guided by the highest a growing number of shareholders identify ethical standards — should use their influence as socially responsible . We’re also hearing more and resources to make a positive impact on social questions from customers on such topics as and cultural issues . That’s why we’ve worked so diversity, equity, and inclusion; climate change; hard to help ensure that our management policies and operational efficiency . contribute to positive value for our employees, On all these fronts and beyond, we strive to customers, communities, and investors . contribute meaningful solutions to pressing One of the first things that CEO Charlie Scharf societal challenges, including inequality, COVID-19, did when he joined Wells Fargo was to sign the and climate change, which — as many ESG experts Business Roundtable’s Statement of the Purpose have pointed out — are all interconnected . Going of a Corporation *. In his words, “It’s simple and forward, these challenges will likely be magnified straightforward, and it’s a clear statement as demographics shift, racial and social inequities that businesses are responsible to a broad set continue to grow, population densities increase, of constituents and have responsibilities beyond and extreme weather events become more what some companies have believed historically . frequent . Finding solutions will require global Given the businesses we’re in and the reach we engagement and collaboration, and demands have, I believe our responsibilities and potential that we help navigate significant change to drive for impact are particularly great .” positive impact .

In line with that vision, Wells Fargo closely At Wells Fargo, we’re answering that call . collaborates with the public sector to drive We’re taking actions to help address these responsible business practices . interconnected crises in order to support an inclusive and enduring recovery .

COVID-19 has impacted all of our lives and we continue to navigate the challenges presented by the pandemic . From the We’ve implemented a broad range beginning, we’ve prioritized the urgent of initiatives to help our employees, needs of our employees, customers, and customers, and communities during communities, working tirelessly to address the COVID-19 crisis. You’ll find personal the many challenges we’ve faced during the accounts and stories on Wells Fargo Stories. pandemic . We remain dedicated to working toward an inclusive and enduring recovery .

Helping customers Customers’ needs shifted greatly during the pandemic . In response, we increased system capacity, enhanced automation, and created new features to allow customers to easily access banking and payment options . processing fees in 2020 that will be recognized Throughout the pandemic, we’ve seen as interest income over the terms of the increased digital engagement with current loans . We voluntarily committed to donate and new customers, including adoption all of the gross processing fees received from of our mobile and online offerings . Paycheck Protection Program loans funded in 2020 . Through June 30, 2021, we donated The pandemic also highlighted the importance approximately $234 million of these processing of Wells Fargo’s support for small businesses . fees to nonprofit organizations that support In July 2020, we established the Open for small businesses . Through the Open for Business Fund . We deferred approximately Business Fund, we strive to engage nonprofit $420 million of Small Business Administration organizations to provide capital, technical support, and long-term resiliency programs to small businesses, with an emphasis on those owned by diverse entrepreneurs .

Customers can access additional information available through Wells Fargo’s COVID-19 resources website .

13 Supporting employees • Grants to help support businesses across the U .S . through the pandemic Keeping employees safe remains one of our top priorities . We have taken measures • U .S . capacity-building programs to help to enhance the safety in our offices and branch businesses retool, recover, and restore locations based on the Centers for Disease Control and Prevention guidance . Safety kits Standing with communities were offered to all Wells Fargo employees and We continue to evolve our social impact efforts free, voluntary, on-site or self-administered to aid communities in response to COVID-19 . COVID-19 testing is available for employees In 2020, we reallocated $175 million from the currently working at Wells Fargo locations Wells Fargo Foundation to help address food in the U .S . Globally, employees who choose shortages, public health needs, financial health, to get vaccinated can receive up to eight small business stability, and housing security for hours of additional paid time off for the most vulnerable populations . We expedited COVID-19 vaccine appointments . grant-making at the local level, as well as through Early in the pandemic, we adjusted our child relief efforts with national and international care benefits in the U .S . and Canada to provide organizations, to help serve the immediate needs additional resources and flexibility for employees of our communities . As part of our response impacted by school closures . We also enhanced to the ongoing COVID-19-related humanitarian our health care and time-off benefits in the crisis in India, Wells Fargo committed more U .S . to help cover medical costs associated than $3 million through nongovernmental with COVID-19 and allow high-risk, exposed, organizations to help increase hospital capacity, or infected employees to stay home without supply oxygen concentrators and critical medical having to take paid time off . equipment, provide emergency transportation, and support health care workers . Employees have access to a range of other resources through our internal COVID-19 Wells Fargo is a founding partner of the Ad resource center . Council and COVID Collaborative’s COVID-19 Vaccine Education Initiative, “It’s Up to You .” Engaging our suppliers This is one of the largest public education efforts in U .S . history and is focused particularly We continue to work closely with many of our on communities of color that have been small and diverse-owned suppliers to provide disproportionately impacted by the pandemic . support for a variety of needs during COVID-19 . We’ve utilized virtual communications to provide The campaign urges audiences to visit them with: GetVaccineAnswers .org* (DeTiDepende .org* in Spanish) for the latest information about • Information on the U .S . Small Business COVID-19 vaccines . Administration’s Paycheck Protection Program (PPP)

• Context on the economic impacts of COVID-19

Our Board is committed to sound and effective corporate governance practices and our efforts to transform its culture . We expect our management team and employees to share a common understanding of expectations in order to create a more consistent culture — doing what’s right, acting with integrity, and holding ourselves accountable .

Performance Board of Directors trends can be found in the The Board remains focused on continual Wells Fargo enhancement of its composition, oversight, ESG Goals and Performance and governance practices, and on Board Data (PDF) . succession planning to enable it to continue to oversee the company and its business effectively . Over the past few years, the Board has undergone significant refreshment to enhance the financial services, regulatory, financial reporting, business operations, and corporate governance skills and experiences represented on the Board .

Our Board has adopted Corporate Governance Guidelines (PDF) to provide the framework for the governance of our Board and our company . These guidelines address many matters, including the role of our Board, membership criteria, director retirement and resignation policies, Director Independence Standards, information about Board committees, and other policies and procedures of our Board, including the majority vote standard for directors, management succession planning, our Board’s leadership structure, and director compensation .

15 Board composition Director independence The Board’s current composition is a result of a The Board’s Corporate Governance thoughtful process informed by the Board’s own Guidelines provide that a significant majority evaluation of its composition and effectiveness, of the directors on our Board, and all members and feedback received from our engagement of the Audit Committee, Governance and with shareholders and other stakeholders . The Nominating Committee, Human Resources Board and its Governance and Nominating Committee, and Risk Committee, must be Committee (GNC) expect that the Board as independent under applicable independence a whole has an appropriate balance of skills, standards . Each year our Board evaluates and knowledge, experience, and perspectives determines the independence of each director relevant to our business and strategy . In addition and each nominee for election as a director . to minimum qualifications required for Board service under the Board’s Corporate Governance Independent Board Chair Guidelines, the Board identifies additional Wells Fargo has had an independent Board qualifications and experience through its annual Chair separate from the CEO role since 2016 . self-evaluation process as desirable in light of In 2016, taking into account feedback from our Wells Fargo’s business, strategy, risk profile, and investors, the Board also amended Wells Fargo’s risk appetite . By-Laws (PDF) to require that the Board Chair be independent . The Board has adopted, and annually Each year, the Board conducts a comprehensive reviews and approves, well-defined authority and self-evaluation to assess its effectiveness, review responsibilities of the independent Chair . our governance practices, and identify areas for enhancement . This annual assessment is also a key part of the Board’s director nomination process and succession planning . The GNC reviews and determines the overall approach, ONLINE RESOURCES scope, and content of the Board’s annual self- evaluation process, including whether to engage Annual Reports and Proxy Statements a third party to help the Board conduct its Board committee members and charters self-evaluation . Each of the Board’s standing committees also conducts a self-evaluation By-laws of Wells Fargo & Company (PDF) process annually . The Board’s, and each Code of Ethics and Business Conduct (PDF) committee’s, self-evaluation includes a review of the Corporate Governance Guidelines and its Corporate Governance Guidelines (PDF) committee charter, respectively, to consider Leadership and governance any proposed changes .

16 Board diversity Select governance practices While our Board doesn’t have a specific policy and shareholder rights on diversity, the Board’s Corporate Governance Wells Fargo has a demonstrated track record Guidelines (PDF) and the GNC’s charter (PDF) of responsiveness to shareholders and other specify that the Board and the GNC incorporate stakeholders . As reflected below, our by-laws a broad view of diversity into its director and other corporate governance documents nomination process . The GNC considers the contain provisions that we believe reflect sound current composition of the Board in light of and effective corporate governance principles and the diverse communities and geographies we practices, including provisions that are reflective serve and the interplay of a first-time director of and have enhanced shareholder rights . candidate’s or director nominee’s experience, Governance practices include: education, skills, background, gender, race, • Independent Board Chair with clearly ethnicity, and other qualities and attributes defined authority and responsibilities with those of other Board members . The GNC incorporates this broad view of • Robust shareholder engagement program diversity, in addition to having a diverse with independent director participation candidate pool for each director search • Each share of our common stock is entitled the Board undertakes, when evaluating and to one vote recommending director nominees to serve on our Board so that our Board’s composition as • No “poison pill” a whole appropriately reflects the current and • “Overboarding” policy that limits the anticipated needs of our Board and our company . number of public company boards on which Board committees our directors may serve (a director who is The Board carries out its risk oversight the CEO of a public company may not serve responsibilities directly and through the on more than three total public company work of each of its standing committees . boards, and other directors may not serve All of these committees report to the full on more than four total public company Board about committee activities, including boards, including Wells Fargo) risk oversight matters, and are composed solely • All standing Board committees consist of independent directors . Each Board committee solely of independent directors has defined authority and responsibilities under • Strong executive compensation clawback its charter for primary oversight of specific and forfeiture policies, including reduction risks and works closely with management or forfeiture of equity awards if the company to understand and oversee our company’s or the executive’s business group suffers key risk exposures . a material failure of risk management The Board has six standing committees: • Robust stock ownership and retention Audit; Corporate Responsibility; Finance; policies for our executive officers and Governance and Nominating; Human Resources; nonemployee directors and Risk . Each standing Board committee’s charter is available on our website . The Board appoints the members and chair of each committee based on the GNC’s recommendation .

17 • Anti-hedging policies that prohibit all Executive compensation employees, including executive officers Strong governance and oversight of executive and directors, from engaging in derivative compensation programs is essential to our long- or hedging transactions that involve any term success . The Board’s Human Resources company securities, including our common Committee (HRC), which oversees the company’s stock performance management and incentive • Pledging policy that prohibits our compensation programs and approves all directors and executive officers from compensation decisions relating to the company’s pledging company equity securities executive officers, is composed of independent as collateral for margin or other loan directors with qualifications and experience transactions related to human capital management and risk management . The members of the HRC make Shareholder rights include: market-informed decisions based on discussions • All of the company’s directors are elected throughout the year . The full Board approves the annually by a majority vote in uncontested CEO’s compensation . director elections, and by a plurality vote in contested elections Over the past few years, the HRC has continued to approve changes intended to strengthen • The right to call a special meeting of the alignment between performance and shareholders compensation, and hold executives accountable • A requirement that the Chair of the Board for risk management failures . The HRC and our be an independent director CEO use a total variable compensation model . Under this model, each named executive is provided • A proxy access right to nominate directors a single total variable compensation target level, • Our Certificate of Incorporation and with payout based on performance assessed using By-Laws permit shareholders to act by our holistic performance assessment framework written consent by the minimum number that considers company performance, individual of votes that would be necessary to take performance, and risk management . The total such action at a meeting at which all variable earned amount is awarded partly in cash shareholders entitled to vote were and the majority in long-term incentives that present and voting vest over, or at the end of, a three-year period and that are subject to performance-based vesting conditions . This approach helps reinforce pay for performance and makes our compensation decisions more transparent to shareholders .

18 Our executive compensation programs are those executive officers for whom disclosure is designed and administered in accordance with included in the Compensation Discussion and the following compensation principles, each Analysis and related compensation disclosures of which is an essential component in driving contained in our Proxy Statement (PDF) . strong, risk-managed performance . ESG governance • Pay for performance – Compensation We challenge ourselves to integrate ESG is linked to company, business line, and strategies into our business every day . The day- individual performance, including meeting today execution of our sustainability initiatives regulatory expectations and creating long- lies with our Public Affairs team, which is term value consistent with the interests responsible for driving positive societal impact, of shareholders . proactively engaging with our stakeholders, and • Promote effective risk management – effectively communicating our priorities . The Compensation promotes effective risk team brings together Communications & Brand management and discourages imprudent Management, Social Impact & Sustainability, or excessive risk-taking . Government Relations & Public Policy, and Strategy & Transformation . A number of • Attract and retain talent – People are one councils and committees provide governance, of our competitive advantages; therefore, oversight, and recommendations to help us compensation must help attract, motivate, do this effectively . and retain people with the skills, talent, and experience to drive superior long-term Corporate Responsibility Committee performance . The Corporate Responsibility Committee has Consistent with these principles, the primary oversight responsibility for our significant combination of annual and long-term strategies, policies, and programs on social and incentives is designed to motivate executives public responsibility matters and our relationships to achieve short-, medium-, and long-term and enterprise reputation with external performance that generates sustained stakeholders on those matters . The committee’s shareholder value . Both annual and long- oversight responsibilities include our community term incentives are based on performance . development and reinvestment activities Additionally, we have a Clawback and and performance and strategies, policies, and Forfeiture Policy that, under specified programs relating to environmental sustainability conditions, strengthens our ability to forfeit and climate change, human rights, supplier or recover compensation in the event that diversity, government relations, and the support named executive officers’ and certain other of nonprofit organizations . employees’ actions, or inactions, result in specified types of negative outcomes for our company . Our named executive officers are

19 External Stakeholder Advisory Council We created the Stakeholder Advisory Council in 2017 to provide external insight and feedback to the Board and senior management on current and emerging issues . The council is composed of external experts and thought leaders who represent groups focused on human rights, consumer rights, fair lending, the environment, civil rights, and governance . The council represents a diverse range of perspectives and experiences, and is focused on deepening our understanding of current and emerging ESG issues that are relevant to our stakeholders . Key issues include serving the financial needs of underserved communities, diversity and social inclusion, and environmental sustainability . This group helps us understand and consider a broad range of perspectives — not only in our ESG plans and activities, but also in our day-to-day business operations and decisions .

ESG Disclosure Council In 2018, we formed an internal ESG Disclosure Council comprising senior leaders from the Controller’s Division, the Legal Department, Finance, Corporate Risk, and Public Affairs . The council helps us deliver on our commitment to transparency by providing senior-level accountability for ESG reporting and disclosures, as well as by considering ways to address gaps and deficiencies .

20 Code of Ethics and Business Conduct

The Wells Fargo Code of Ethics and Business While we consider our Code to be the starting Conduct (PDF) (Code) provides clarity and point and not the finish line, it lays out the basic focus on the ethical behavior we expect of all rules for how we conduct business . We encourage employees and Board members . The Code employees to read the Code throughout the year reinforces our commitment to always do so they stay familiar with the following principles: what’s right by our customers, employees, • Anti-bribery and corruption – We do not communities, and stakeholders . And it contains tolerate bribery and corruption . We don’t basic principles and guidance that help our offer or accept bribes or any other kind of employees make decisions that align with these improper payment — including facilitation standards and comply with the laws, rules, and payments or anything of value — and we do regulations that govern our business . To help not do anything through a third party that make sure that the Code is accessible to our we aren’t allowed to do ourselves . diverse workforce, we have made it available in English, French Canadian, and Simplified Chinese . • Antitrust – We believe in free and open competition . We gain our competitive No code of conduct can cover every possible advantage through superior performance, situation, which is why we rely on employees not through anticompetitive business to use good judgment and speak up promptly practices . when they have questions or concerns . Every employee completes Code of Ethics training • Insider trading – Employees must never buy annually . This training provides interactive or sell securities when they have material, activities that guide employees through nonpublic information, nor should they situations they may encounter . Beyond ever “tip” others by providing them with this training, we extend the learning through material, nonpublic information . Insider our online Wells Fargo Ethics site, Manager trading restrictions cover Wells Fargo Center Ethics site, and Ethics Moments securities, as well as the securities of other platform, all located on our employee intranet companies, including customers and third- portal, Teamworks . These resources provide party service providers, and they apply to employees with information to help them all employees and their immediate families . navigate ethical dilemmas and make decisions • Gifts – We generally permit the giving and guided by integrity and ethics . receiving of reasonable business gifts and In addition to the Board’s oversight of conduct entertainment that are neither lavish nor risk, members of the Board also attest annually excessive in frequency; that are consistent that they have read and understand their with accepted, lawful business practices . obligations under the Code . • Conflict of interest – We work to avoid conflicts of interest in our employees’ personal and business activities in a number of circumstances, including through outside employment or business

21 activities and personal transactions, We take violations of our Code seriously . Anyone finances, or relationships . Where conflicts who knowingly violates any of the provisions of can’t be avoided, we aim to be transparent the Code, or the referenced policies and guidelines, about their existence and we strive to take may face corrective action, which may include proactive steps to manage them . termination of employment . Certain actions may also result in legal proceedings, including • Money laundering – As a global financial prosecution for criminal violations . To make institution, we have special responsibilities Wells Fargo the best possible place to work, to help combat money laundering . Our we encourage our employees to ask questions anti-money laundering policy and related if uncertain about the right path and to speak procedures are designed to comply with up to their manager, Employee Relations, or the applicable laws and regulations related to EthicsLine if they see or suspect misconduct or money laundering and terrorist financing . wrongdoing . We require all employees to comply with these policies, procedures, and controls . Our Conduct Risk function, which is part of our Compliance organization, establishes conduct- • Serving communities – We want to related policies and requirements, including the be known as a trusted neighbor in the Code, and provides independent oversight of the communities where we live and operate, company’s adherence to those requirements . and we encourage volunteerism . The frontline Conduct Management function • Human rights – We recognize our is responsible for the allegation management responsibility to respect human rights life cycle, including the intake, research, and throughout our operations, products, investigation of allegations of misconduct, and services . That responsibility includes overseeing and managing our EthicsLine, and consistent treatment among people, performing root cause analysis and customer employee well-being and security, impact assessments . The Ethics Office, which economic and social freedom, and also sits in the frontline Conduct Management environmental stewardship . organization, serves as an employee resource for questions on topics covered in the Code of Ethics • Environment – We are integrating and supports employees as they make decisions environmental mindfulness into all we guided by integrity and ethics . do, and we work across our company to accelerate environmental sustainability . Measuring our progress, employee sentiment scores directly related to “comfort in reporting dishonest or unethical practices without fear of retaliation” have trended upward from early 2020 .

22 Upgraded digital resources support doing what’s right

In 2020, Wells Fargo upgraded its digital tools • New Shared Success eCard designs increase and resources to further empower employees engagement around ethics with cards used and managers worldwide to do what’s right to thank employees for showing courage by by speaking up about ethics-related concerns speaking up about ethics-related concerns without fear of retaliation or other negative and to thank managers for listening to actions . These include: concerns with care and empathy . • The enhanced Ethics site for employees leverages key insights from our Pulse survey results and provides employees the critical tools and resources they need to speak up confidently and without fear of retaliation when they have ethics- related concerns . ENHANCING OUR FOCUS ON ETHICS • The upgraded Manager Center Ethics Enhancements to maintain our focus site empowers managers to be ethical on ethical behaviors include: champions, better prepares them to listen to their employees and provide • Centralized allegation management informed guidance when employees activities under Conduct Management come to them to report misconduct, to create efficiencies, enhance learnings, and reiterates that Wells Fargo does and assess trends. not tolerate retaliation when concerns • Enhanced root cause analysis and data are reported in good faith . Additionally, reporting capabilities to support analysis a new Manager Toolkit helps managers designed to uncover trends and distill insights. understand their reporting options, know what action to take and when, and find • Continued enhancing of processes a range of useful resources organized designed to optimize investigations. by category . • Developed resources to enhance transparency and reiterate our • To simplify the online reporting process commitment to nonretaliation. and enhance the overall user experience, • Continued efforts to understand the upgraded EthicsLine web-reporting employee sentiment about ethics. site, which is hosted by a third-party vendor, is more accessible and makes it easier to submit a report from anywhere and from any device 24 hours a day, 7 days a week, 365 days a year .

23 Updated Speak Up and Nonretaliation Policy Wells Fargo views climate change as a global Speaking up about ethical concerns — including challenge that presents significant impacts for suspected allegations, policy violations, workplace businesses and communities around the world, concerns, process improvements, or other concerns and is committed to finding solutions to help — is an expectation of all Wells Fargo employees mitigate the impacts of climate change related to worldwide as part of doing what’s right and is its activities and to partner with key stakeholders, outlined in the Speak Up and Nonretaliation Policy . including communities and customers, to do the same . We expect climate change to increasingly The policy was revised in December 2020 to: impact the risk types we manage, and will continue • Provide employees updated and expanded to integrate climate considerations into the Risk guidance on how to report a variety of types Management Framework as understanding of of concerns . climate change and risks driven by it evolve .

• Provide improved clarity on roles Wells Fargo’s Environmental and Social Risk and responsibilities, including those Management (ESRM) Framework provides of managers, as they relate to speaking information and transparency about our approach up and nonretaliation . to managing environmental and social risks, including those related to climate change . Our • Provide new and enhanced definitions for ESRM Framework is generally aligned to our terms such as retaliation and misconduct . Risk Management Framework . Environmental • Provide additional requirements for and social issues, including climate change, can international employees including links manifest across risk types . to country-specific policies for Australia; India; the Philippines; and Europe, Middle Risk operating model – roles and responsibilities East, and Africa . Wells Fargo has three lines of defense to Wells Fargo does not tolerate retaliation or manage risk: the Frontline, Independent Risk other negative actions such as harassment or Management, and Internal Audit . Our risk unprofessionalism as a result of an employee operating model creates necessary interaction, speaking up in good faith . interdependencies, and ongoing engagement among the lines of defense: Risk management • Frontline – The Frontline, which is composed of our principal lines of business and certain Every employee has a role in managing risk at enterprise function activities, is the first Wells Fargo . The Risk Management Framework line of defense . In the course of its business sets forth our core principles for managing and activities, the Frontline identifies, measures, governing its risk . Senior management sets the assesses, controls, monitors, and reports tone at the top by supporting a strong culture on risk generated by or associated with its defined by the company’s expectations¹ that business activities and balances risk and guides how employees conduct themselves reward in decision-making while operating and make decisions . The Board holds senior within our risk appetite . management accountable for establishing and maintaining the company’s culture, including its risk management component and effectively managing risk .

1 . Please see the Investing in our employees section for more on the company’s expectations . 24 • Independent Risk Management (IRM) – Risk and culture IRM is the second line of defense . It Employees are encouraged and expected to establishes and maintains our risk speak up when they see something that could management program and provides cause harm to our customers, communities, oversight, including challenge to employees, shareholders, or reputation . Because and independent assessment of, risk management is everyone’s responsibility, all the Frontline’s execution of its risk employees are empowered to and expected to management responsibilities . challenge risk decisions when appropriate and • Internal Audit – Internal Audit is the third to escalate their concerns when they haven’t line of defense . It is responsible for acting been addressed . Effective risk management is as an independent assurance function a central component of employee performance and validates that the risk management evaluations . Our performance management and program is adequately designed and incentive compensation programs are designed functioning effectively . to establish a balanced framework for risk and reward under our core principles that employees In addition to the three lines of defense, our are expected to know and practice . The Board control environment is strengthened by plays an important role in overseeing and enterprise control activities that are performed providing credible challenge to our performance by enterprise functions with specialized subject management and incentive compensation matter expertise such as accounting, reporting programs and reviews, and approves the and tax, human capital, and legal services . compensation of the company’s executive officers and other officers or employees as it determines appropriate .

Please see our most recent Proxy Statement (PDF) for additional details about how risk management is factored into executive compensation .

25 Training Wells Fargo has mandatory, recurring, risk and compliance-related training courses for all new and existing employees . These resources educate employees about our risk management program generally, and on how to recognize, understand, and address the risks they and the company face every day .

Risk and strategy We continue to work hard to strengthen our Our risk profile, risk capacity, risk appetite, company by building the right risk and control and risk management effectiveness are infrastructure. We continue to enhance our risk considered in the strategic planning process, management programs, including our operational which is closely linked with our capital planning and compliance risk management as required by the process . Federal Reserve’s February 2, 2018, and the CFPB/ OCC’s April 20, 2018, consent orders. Wells Fargo’s Independent Risk Management (IRM) organization participates in strategic planning at several points in the process, providing challenge to, and independent assessment of, our self- assessment of the risks associated with strategic initiatives . IRM also independently assesses and challenges the impact of the strategic plan on risk capacity, risk appetite, and risk management effectiveness at the line of business, enterprise function, and aggregate company level . After review by management, the strategic plan is presented to the Board each year for review and approval .

26 Role of the Board and Board committee structure It also reports key challenges, decisions, The Board oversees the company’s business, escalations, other actions, and open issues including its risk management . The Board assesses as appropriate . The Enterprise Risk & Control senior management’s performance, provides Committee, a governance committee, is a credible challenge, and holds senior management decision-making and escalation body that accountable for maintaining and adhering to an governs the management of all risk types . effective risk management program . The impacts of climate-related risks on the The Board carries out its risk oversight financial sector are increasingly an area of responsibilities directly and through its focus for governments and regulators globally . committees . The Risk Committee oversees We’re actively monitoring for potential future Wells Fargo’s Risk Management Framework, governmental policy actions that seek to address including the risk management program, climate change . We engage with policymakers to governance structures used by management understand the policy landscape and potential to execute the risk management program, risk developments that may impact our business or profile, risk appetite, and risk management clients in the future . This informs our approach effectiveness . The Chief Risk Officer (CRO) to managing climate-related risk and our reports functionally to the Risk Committee and efforts to further integrate climate-related administratively to the CEO . The CRO and other risk considerations into our risk management leaders in Independent Risk Management have programs . We aim to continue to improve unrestricted access to the Risk Committee . our ability to identify and assess climate- related risks over time and expect to continue Management committee structure to refine our approach as we strengthen our We have established management committees, understanding of how climate change impacts including those focused on risk, that support our business activities, processes, and risks . management in carrying out its governance and risk management responsibilities . One type of management committee is a governance committee, which is a decision-making body that operates for a particular purpose .

Each governance committee, in accordance with its charter, is expected to discuss, document, and make decisions regarding high-priority and significant risks, emerging risks, risk acceptances, and risks and issues escalated to it . Each also reviews and monitors progress related to critical and high-risk issues and remediation efforts within its scope, including lessons learned .

27 Public policy and political U.S. campaign finance and PACs contributions Wells Fargo’s PACs are funded through voluntary

The Wells Fargo Government Performance contributions from eligible exempt employees . Relations and Public Policy trends can be Decisions about which candidates the PACs found in the support are made by the Government Relations team works closely with our Wells Fargo lines of business to help make ESG Goals and and Public Policy team . Wells Fargo’s PACs report certain that our legislative Performance to the Federal Elections Committee and/or to Data (PDF) . and political activities adhere state agencies as required by law . Contributions to good corporate governance practices and are made without regard to the personal political adhere to Wells Fargo policies and procedures . preferences of the company’s senior management . The Board’s Corporate Responsibility In early 2021, Wells Fargo decided to pause Committee oversees our government PAC disbursements in order to conduct relations activities, as well as our public a comprehensive review of our PAC giving advocacy policies and programs . At least criteria and strategy to ensure it aligns with annually, the committee also receives reports our business goals and expectations . Our from management on political and lobbying comprehensive review included talking with activities in the U .S ., including payments Wells Fargo employees through focus groups, made by Wells Fargo to trade associations . an in-depth survey of PAC members, individual Information on the Wells Fargo political action conversations, and benchmarking against committee (PAC) and corporate political our peers and other Fortune 50 companies . spending can be found on our Government The results of this review informed our future Relations and Public Policy page . PAC giving strategy, and we’ll continue to operate our PACs with transparency . Advocacy and lobbying Wells Fargo participates in the U .S . public policy Policy on political contributions arena on a wide range of issues that may impact Pursuant to company policies, Wells Fargo the company, such as policy issues addressing does not use company money or resources banking, finance, housing, small business, tax, to influence any U .S . domestic or foreign and bankruptcy . We monitor and comment on candidate elections . In accordance with these proposed legislation and regulations that may policies, we don’t assist candidate campaign affect the way we serve our customers . The committees, political parties, or caucuses, and Government Relations and Public Policy team don’t make independent expenditures on other must approve any use of company funds for political committees, or partake in any other type lobbying . Further, we disclose federal lobbying of election-related activity . activities under the Lobbying Disclosure Act (LDA), which requires quarterly reports to be filed with the United States Congress . These reports are publicly available on the U .S . House website .*

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 28 We have policies and procedures in place designed to help make sure that we comply with applicable laws regarding political contributions . Wells Fargo also maintains compliance processes intended to make sure that its activities are conducted in accordance with those policies, our Code, and with applicable laws governing political contributions and lobbying activities .

Employee activity Our Code of Ethics and Business Conduct (PDF) encourages employees to engage in civic and political activities on their own time and based on their individual desires and political preferences . We make it clear that employees must be sure that their personal political opinions and activities are not viewed as those of Wells Fargo . Employees are free to make personal contributions on their own behalf to candidates and related political entities of their choice so long as they comply with the Code and any applicable policies of their business line . Wells Fargo provides eligible employees up to three paid hours away from work to vote in any general, statewide, or special election .

29 Tax overview Wells Fargo files income tax returns in the U .S . and over 30 additional countries and territories in which we operate . Our income tax profile reflects the commercial and regulatory considerations that drive our business structure and strategy . As a taxpayer in many jurisdictions, we’re routinely under examination by various tax authorities .

Wells Fargo emphasizes a culture of strong internal controls and risk management designed to achieve compliance with applicable local income tax laws and regulations . We offer transparency with global tax authorities, including sharing relevant information regarding our business operations and tax profile . In addition, we’ve implemented systems and processes to assist in our global compliance with applicable customer tax information reporting laws, the Foreign Account Tax Compliance Act, and the Common Reporting Standard .

Our consolidated financial statements include information related to the reconciliation of our effective tax rate to the U .S . statutory income tax rate and our net income taxes paid . In addition, we file publicly available legal entity financial statements in certain non-U .S . jurisdictions .

For more information on the impact of income taxation at Wells Fargo, see our Income Taxes footnote regarding our global effective tax rate and our Statement of Cash Flows supplemental information for net cash taxes paid in our Annual Report . Our most up-to-date financial reports can be found here .

30 Delivering value to our customers

Wells Fargo aims to exceed Performance or advertising . The program offers customer expectations and trends can be resources for anyone who wants to found in the provide value to individual Wells Fargo learn more about responsible money customers, investors, and ESG Goals and management . It’s designed to provide small businesses Performance individuals and families with the knowledge Data (PDF) . across the economic they need to take control of their financial spectrum . We’re working hard to enhance future, including educational articles on a the customer experience through innovative variety of topics, classroom resources for product offerings delivered with the highest educators, and self-directed courses for level of customer service . Our customer-centric everyone from seniors and military members strategy aims to put customers first in all that to entrepreneurs and kids . we do, meet customers’ needs in a personal and • The Smarter CreditTM Center includes relevant manner, deliver seamless and frictionless resources to help customers understand, experiences, and ultimately create meaningful build, and improve credit, as well as manage relationships with our customers to help them debt and plan for large purchases . reach their financial goals . • Eligible Wells Fargo customers can access Financial health programs their FICO® credit scores for free through We know that consumers are more likely to Wells Fargo Online® . achieve financial success if they understand • Control Tower® provides simple, secure, the steps they can take to establish healthy and centralized access to Wells Fargo financial habits . That’s why we provide a variety cards and account information, enabling of resources and products designed to enable customers to easily view, manage, and individuals to learn how to manage money monitor their digital financial footprint responsibly, build and improve credit, plan from a single location . and save for the future, and reach their financial goals . Responsible treatment of customers • Hands on Banking® by Wells Fargo with debt repayment problems is a free online learning program We understand that keeping up with loan and provided as a public service to all credit card payments can be difficult, especially individuals, without any endorsements for people who’ve lost a job, been ill, or become overextended with credit .

31 Wells Fargo AssistSM offers a variety of options These services include: and support to customers facing financial • Overdraft Rewind®, a service that helps hardship related to: customers with direct deposit avoid certain Home loans overdraft charges . It may help customers avoid returned payment and related Wells Fargo home preservation specialists help merchant fees, so long as the customer’s homeowners with payment challenges, guiding incoming direct deposit is sufficient to cover them through options and approaches based payments from the prior business day that on their individual situation and loan terms . would have otherwise been returned unpaid . Our Responsible Lending and Servicing Principles for U .S . Residential Real Estate • Automatic zero-balance alerts that notify Products govern our business practices in this online banking customers by email if their area . These principles include providing customers account balances drop to zero or below . with the information they need to make fully • No overdraft or return item fee is charged informed decisions about credit products and for any transaction of $5 or less and for services, pricing those products and services any overdrawn balance of $5 or less . appropriately, only approving applications when we believe the borrower has the ability to repay the • In 2020, we introduced a new low-cost bank credit according to its terms, and providing timely account with no overdraft fees: Clear Access SM responses to customer questions and complaints, Banking . This checkless bank account helps as well as prompt action to correct errors . customers avoid spending more than the amount available in the account without Credit cards incurring overdraft or nonsufficient funds If customers are struggling to make monthly fees . Clear Access Banking is structured to credit card or loan payments, or can’t catch up meet the Cities for Financial Empowerment with past-due payments, we review the nature Fund’s Bank On National Account Standards of the hardship and the customer’s financial for safe and appropriate financial products information to determine whether they qualify that can help people enter or reenter the for alternative payment options . Payment options mainstream financial system . are determined on a case-by-case basis, and may include a lower interest rate and, possibly, a lower Loans minimum payment amount . For customers who have difficulties making Checking accounts payments, we offer a variety of options based on their specific needs . We ask that customers Wells Fargo provides many services to help avoid contact us so we can better understand their overdrafts and manage customer accounts . Online, challenges and talk through options that might mobile, and text banking tools allow customers to work for them . These may include a due date monitor account activity, transfer funds, and help change, payment deferral, loan modification, avoid unexpected overdrafts . or hardship refinance .

32 Customer satisfaction

Keeping customers front and center Consumer Data and Engagement Platforms is at the heart of Wells Fargo’s continued Established in 2020, Consumer Data and evolution . We’re focused on embedding Engagement Platforms (CDEP) is focused customer perspectives directly into our on building a shared enterprise strategy around decision-making processes, and we recently providing better and more seamless experiences established new groups to complement our for our customers — and ultimately improving existing dedication to customer experience . their financial health . Office of Consumer Practices Central to that work is a deep focus on providing Wells Fargo established the Office of Consumer opportunities for sustainable business growth Practices (OCP) in 2021 as a companywide, anchored in delivering meaningful experiences consumer-focused advisory group within the at every customer engagement touch point . Chief Operating Office . The OCP is working to To achieve these goals, CDEP works across the help ensure our products, services, and business Consumer and Small Business Banking, Consumer practices are fair and transparent, and is reinforcing Lending, and Wealth & Investment Management a customer-centric culture across Wells Fargo . lines of business to help develop coordinated The OCP’s work complements efforts already strategies for growth in each of Wells Fargo’s underway to improve Wells Fargo’s sales customer segments . practices and its overall customer experience . In 2021, the group evolved to include Enterprise The group’s activities include: Marketing channels, platforms, and execution . This addition enhanced our ability to build the • Assessing and advising on consumer-related products, services, and business practices next-generation digital, data and analytics, and designed to ensure the consumer’s functional capabilities required to meet the perspective plays a significant role in changing demands of the marketplace, and the decision-making . needs of more sophisticated consumers whose expectations for simple, customizable, and • Engaging in all elements of the customer- personalized services are constantly evolving . product life cycle, including advising on product development processes like Key areas of focus for CDEP in 2021 include: terms, conditions, and pricing . • Financial health: A new assessment tool deployed across our branches and digital • Reviewing complaint metrics and other data to help identify and advise on potential spaces will help us understand customers’ consumer-related trends and outcomes . needs so we can create personalized solutions to meet those needs and support their long- • Providing advice on policies, procedures, term financial health . and training that impact how Wells Fargo interacts with consumers, including older adults and people with disabilities .

33 • Customer Experience Council: The council and data can be counted on at all levels of the brings together the most senior leaders organization, and meet the commitments we’ve across the company to build capabilities made to all of our stakeholder groups . that help us listen to customers, understand ECMO’s complaints management employees their feedback, and use their input to develop utilize Wells Fargo’s integrated, companywide and launch programs that aim to directly complaint technology — the Enterprise improve the customer experience . Complaints Management Platform (ECMP) — • Customer journeys: We’re transitioning to facilitate proper routing, intake, research, and to a focus on the holistic needs of the final resolution of complaints among Wells Fargo’s customer, and aiming to deliver a seamless Frontline employees, line of business complaint experience regardless of the type of product teams, and three ECMO escalated Complaint or service they need, or the channel they Executive Offices . choose to use to interact with Wells Fargo . Together with all of these groups, ECMO tracks • Net Promoter System® (NPS): We continue and addresses complaints that range from the to make significant progress in rolling seemingly simple “service complaints,” which out NPS to lines of business across the are generally addressed by employees upon the enterprise, with employees regularly using initial call, to the more complicated “escalated the NPS to better understand the experience complaints,” which require deeper research, customers are having, and to guide actions operational risk reviews, and final communication we can take to make that experience even of resolution . better . Since the program’s introduction in 2019, nearly 8 million survey responses The ECMP puts up-to-date customer information have been collected, and those have been and capabilities at the employees’ fingertips with the catalyst for driving significant customer data and supportive technology designed to experience change across the organization . enhance their effectiveness . On a planned path of continuous improvement, enhancements to the Enterprise complaints management ECMP are made every few weeks to help employees The Enterprise Complaints Management work more efficiently and consistently to provide Office (ECMO) is designed to provide the kind of experience our customers deserve . standardized and coordinated application In addition, ECMO’s Complaints Data, Analytics, of the Wells Fargo Complaints Management and Reporting (CDAR) team is responsible for root Policy across all Wells Fargo businesses . cause analysis of complaints . CDAR has developed ECMO is monitored by internal and external proprietary Advanced Listening® technology and validation partners and oversight teams via processes that leverage artificial intelligence, updated metrics, reports, and scorecards with natural language, and speech recognition, a goal of ensuring that our processes, procedures, to deliver deeper insight into our customers’ experiences . This helps CDAR identify complaint trends and emerging risks, along with performing

34 diagnostic analysis to help identify potential Our approach systemic issues . When combined with other We’re committed to the effective stewardship of customer satisfaction data, CDAR’s analysis the assets we manage on behalf of our clients . provides actionable evidence in support Our proprietary assessment processes combine of initiatives that seek to improve both the third-party data with our analysts’ insights to customer and employee experience . develop a unique view on individual securities and investment products . Sustainable investing Integration of ESG criteria in teams across WIM include analysts who have Wealth & Investment Management the Sustainability Accounting Standards Board Sustainable investing has gained popularity (SASB) FSA designation and the Chartered SRI as more investors seek strategies that offer Counselor accreditation . Our head of Social both the potential for return and the opportunity Impact Investing for Wells Fargo Private Bank to align investments with their personal values also serves on the Technical Advisory Board of and the general principles inherent in ESG- SASB . focused investing . In April 2020, the Wells Fargo Investor and Retirement Optimism Index survey Our analysts, investment professionals, found that investors want more information and advisors develop strategies and solutions about sustainable investing, with a majority targeted to their clients’ specific needs . of investors saying they would be likely to invest We follow a robust discovery process designed in companies that align with their values . to understand a client’s investment goals and broader sustainability values to deliver solutions As a leading provider of financial and investment that are aligned . WIM offers portfolios designed services, Wells Fargo Wealth & Investment to make ESG accessible to all investors through Management (WIM) leverages its experience our various solutions . across brokerage, investment management, retirement planning, and advice that aims to Wells Fargo Asset Management¹ provide clients with services and portfolios Wells Fargo Asset Management’s (WFAM) aligned with their financial goals, risk tolerance, philosophy, policies, and processes are built and personal preferences . Sustainable investing around the goal of delivering on client and at WIM may include: community expectations in a responsible and • Comprehensive integration of ESG sustainable way . Analyzing salient ESG risks assessment into the investment and wider sustainability themes enables us to management process better assess the investments we make, and combined with serving as responsible stewards • Strategies that align investment portfolios of the assets we manage, ultimately helps lead with client values and ESG principles to better outcomes for our clients . • Active ownership practices, including ESG issues, climate risks, and other engagement and proxy voting considerations that extend beyond • Targeted private capital investments conventional financial statement analysis in impact areas such as water, timber, have long been part of how WFAM’s portfolio health care, and innovation

1 . Wells Fargo & Company announced on February 23, 2021, that it had entered into a definitive agreement to sell Wells Fargo Asset Management (WFAM) . This sale includes Wells Fargo Bank N .A .’s business of acting as trustee to its collective investment trusts and all related WFAM legal entities . The transaction is expected to close in the second half of 2021, subject to customary closing conditions . 35 management teams evaluate investment on our clients’ behalf — is critical to our ability opportunities . WFAM continues to work to: to have a voice and exercise ownership rights • Research and integrate ESG and climate- to affect corporate activities, policies, and related risk elements into ongoing behaviors that impact the portfolio’s long- investment processes and technologies . term, risk-adjusted returns .

• Develop new client solutions across WFAM also sees proxy voting as a significant asset classes and investment styles . opportunity to advocate for strong corporate governance principles and in turn generate • Enhance the client experience through long-term value . upgraded communications and enhanced transparency . ESG industry engagement and thought leadership • Partner and lead in the future development Wells Fargo is involved with leading global of sustainable finance — within WFAM, sustainability initiatives . WFAM is a proud WIM, Wells Fargo — and across the industry . signatory to the United Nations-supported Specific details about how WFAM integrates Principles for Responsible Investment (PRI) . ESG into its investment process can be found in the WFAM approach to ESG and sustainable Additionally, WFAM works closely with leading investing (PDF) . industry associations, disclosure and standard bodies, and nonprofit organizations to drive In 2019, WFAM launched a proprietary ESG risk- integration of ESG considerations in financial scoring framework for corporate issuers globally strategies and processes . We’re a founding across investment grade and high-yield credit . member of SASB’s Investor Advisory Group In addition, WFAM is taking action to address and a member of the SASB Alliance, as well climate-related risks throughout its investment as CDP, Climate Action 100+, and are part process at the security and portfolio level . of the Advisory Council to the Green Bond WFAM created a Climate Change Working Principles and Social Bond Principles Executive Group to research and integrate climate risk committee, and a signatory to His Royal analysis into various facets of its investment Highness The Prince of Wales’ Sustainable process in a structured way . Markets Initiative’s charter, “Terra Carta .” We believe stewardship is core to active WFAM helps to shape the latest thinking and management and goes hand-in-hand with innovations on sustainable investing and global our commitment to integrate ESG into our impact — insights can be found at WFAM’s full investment process . The goal of our Sustainable Investing library . stewardship activities — engaging with companies’ management and voting proxies

36 Wells Fargo Investment Institute Wells Fargo Private Bank The Wells Fargo Investment Institute Wells Fargo Private Bank serves high-net- (WFII) provides education, guidance, worth and ultra-high-net-worth individuals, and insights to inform investment decisions . business owners, family offices, foundations, WFII creates core investment strategies, and endowments . Wells Fargo Private Bank’s investment research, and other forms Social Impact Investing team specializes in of intellectual capital to support WIM managing sustainable and responsible investment businesses . WFII thought leadership includes portfolios for individuals and institutions . ESG the 2020 thematic report on Sustainable analysis is incorporated into the Social Impact Investing ‒ Investing with a purpose . Investing team’s investment decisions and offers clients values-based customization capabilities . WFII’s Global Manager Research (GMR) team Offerings include ESG strategies for separately provides information about how investment managed accounts aligned for specific client managers use ESG criteria in their investment financial goals/values, such as sustainable, offerings . GMR has categorized, according responsible, animal welfare, and religious to a proprietary methodology, all investment values . These are offered across equities managers and solutions on its list of approved and real estate investment trusts (REIT) investment strategies . GMR has published strategies, and — through the Social Impact several pieces which detail the GMR ESG Analysis Investing team’s partnership with the Fixed Framework methodology and highlight the Income Strategies team — fixed income as well . results and findings . GMR’s ESG categorizations The team practices active ownership principles, (immaterial, aware, integrated, key driver, and including engagement and proxy voting, and impact leader) facilitate a better understanding aligns its engagement efforts with the United of investment managers’ level of ESG focus/ Nations Sustainable Development Goals . integration and can help create diversified, ESG-focused solutions that go beyond simple The Private Bank has actively invested millions investment product labels and cursory claims . of dollars in targeted impact and ESG-oriented investments, particularly in the private capital WFII’s Global Portfolio Management team arena, for more than a decade . Such investment manages “ESG Aware/Focus” portfolios opportunities include water, alternative energy, that range from conservative income to sustainable farming, double bottom line aggressive growth investment objectives . businesses, technological enhancement, health The ESG portfolios offer Wells Fargo Advisors care innovation funds that target care for and The Private Bank clients the combined growing middle classes in emerging countries, benefits of sound investment and ESG and a variety of other impact and ESG-specific principles, active mutual fund and passive investments . ETF investing, and the tactical asset allocation guidance, money manager research, and portfolio management best practices provided by WFII .

37 The Private Bank website also offers thought • Educating financial advisors about leadership perspectives including: sustainable investing, including both macro and societal trends as well as Gender Equality and Inclusion internal product options such as WFII’s Sustainable REIT ESG aware portfolios .

ESG Materiality • Providing clients and financial advisors with account- and security-specific ESG Values-based Investment Considerations and product involvement data that details company exposure to certain areas of interest and that utilizes both external Wells Fargo Advisors Performance data sources as well as the recently Wells Fargo Advisors trends can be launched GMR ESG Analysis Framework . found in the (WFA) offers a robust Wells Fargo • Consulting with clients and financial set of solutions designed ESG Goals and advisors to identify values and translate to help clients align Performance Data (PDF) . principles into actionable investment investment portfolios solutions that are consistent with clients’ with personal values and principles . WFA’s ongoing best interests . effort is intended to increase financial advisor and client education as sustainable investing interest Expanding financial inclusion continues to increase exponentially . It is believed that the application of this awareness offers the According to many studies, a significant potential for better client solutions and outcomes percentage of Americans still lack access by combining both financial and values-based to secure and reliable financial services . investing goals and considerations . The fact that many people are outside of the U .S . mainstream financial system WFA offers a variety of sustainable investing highlights the need for access to safe and solutions and resources, including: affordable financial products and services that • Working with partners across WIM, can improve the financial health and capabilities as well as external strategic resources, of low- and moderate-income (LMI) individuals to offer clients access to the latest thought and families, as well as members of historically leadership and products in the sustainable marginalized communities . investing universe .

DISCLOSURES: Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, Members SIPC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company . Sustainable investing focuses on companies that demonstrate adherence to environmental, social, and corporate governance principles, among other values . There is no assurance that social impact investing can be an effective strategy under all market conditions . Different investment styles tend to shift in and out of favor . In addition, an investment strategy’s social policy could cause it to forgo opportunities to gain exposure to certain industries, companies, sectors or regions of the economy which could cause it to underperform similar portfolios that do not have a social policy .

Investment and Insurance Products: Not FDIC Insured No Bank Guarantee May Lose Value 38 We’ve made a concerted effort to develop Advancing Homeownership® Performance products and services to serve all customers among low- and moderate- trends can be found in the in every phase of their financial journeys . income and diverse individuals Wells Fargo We constantly seek to learn about our customers’ Low- and moderate-income ESG Goals and Performance financial needs, behaviors, and goals to glean the Americans and persons Data (PDF) . insights that can help us tackle some of society’s of color continue to have greatest challenges . We strive to support under- difficulty achieving the dream of homeownership . resourced individuals, to serve populations who’ve Our long-term focus on lending to these been historically discriminated against, and to underserved segments is helping to bridge protect vulnerable consumers who may be afraid this homeownership gap . Wells Fargo is the or unable to speak up for themselves . largest lender in the low- and moderate-income communities and the largest affordable housing Banking Inclusion Initiative lender in the U .S¹ . In 2021, we announced the Banking Inclusion Initiative, a 10-year commitment to help In 2016, we made an ambitious five-year unbanked individuals gain access to affordable, commitment to provide $150 billion in new home mainstream, digitally-enabled transactional purchase loans to minority households and $70 accounts — a meaningful entry point to fully billion in loans to LMI households . We’ve made participating in the economy and achieving significant progress toward these commitments . financial stability . This initiative will focus We brought further focus to our work to on reaching unbanked communities and, increase the number of LMI and minority in particular, helping remove barriers to financial homeowners with the launch of Advancing inclusion for Black and African American, Hispanic, Homeownership® . This effort includes and Native American/Alaska Native families . a mix of tools, information, and opportunities, The commitment will be focused on expanding all designed to remove barriers and expand access to affordable products and digital access to homeownership, and support efforts solutions, financial education and advice, and to build stronger communities . Advancing collaboration with stakeholders to develop Homeownership includes 10-year commitments solutions and measure success . to provide $125 billion in home purchase loans for Hispanic homebuyers and $60 billion in loans for Black and African American homebuyers . In addition, we’ve made a commitment to provide a total of $25 million in funding for homebuyer education and counseling programs in support of these efforts .

1 . According to the Mortgage Bankers Association, 2020 . 39 To help achieve these homeownership goals, We aim to achieve these goals while maintaining we’ve developed a comprehensive five-pillar our focus on fair and responsible lending . strategy: Community Reinvestment Act • Mirror the communities we serve by recruiting, hiring, and retaining Wells Fargo Bank, N .A . received a rating of diverse talent . “Outstanding” in its most recent Community Reinvestment Act (CRA) performance evaluation, • Be present in the markets we serve — which covered the years 2012 to 2018 . The CRA physically, virtually, and through was established by the U .S . Congress in 1977 . marketing and outreach . Across the Under the CRA, the Office of the Comptroller country, we’re hiring community home of the Currency (OCC) assesses a national bank’s mortgage consultants to establish record of helping to meet the credit needs of its a greater presence in key diverse entire community, including LMI neighborhoods . and LMI communities . The current performance evaluation (PDF) noted • Develop relationships with key that Wells Fargo is “a leader in making community stakeholders and organizations . development loans,” and cited our “significant use For example, the National Association of innovative and/or flexible loan products” of Real Estate Brokers, National Association to meet credit needs . The performance evaluation for the Advancement of Colored People, also noted that our retail banking options are and National Urban League publicly joined accessible in a majority of the areas surveyed and Wells Fargo to announce our $60 billion that we serve our customers through full-service commitment to Black and African American ATMs, phone banking, online and mobile banking, homeownership . and mobile payments .

• Develop products, programs, and policies Supporting small businesses Performance intended to promote growth in traditionally trends can be We have a long history of found in the underserved markets . In 2016, we launched being a strong partner to the Wells Fargo yourFirst Mortgage®, a home loan program small business community, ESG Goals and Performance that offers a down payment of as little as which we support through Data (PDF) . 3% for fixed-rate mortgages, as well as lower a variety of deposit, lending, out-of-pocket costs, expanded credit criteria, investment, and payment products . and incentives for homebuyer education . Through Wells Fargo Works® for Small Business, • Develop and advance housing policy we provide resources, tools, guidance, and positions designed to increase access to insights for small businesses, including: affordable housing . NeighborhoodLIFT®, • Business planning – complimentary a signature Wells Fargo homeownership resources and tools to help create or revise initiative we executed in collaboration business plans, understand financial basics, with NeighborWorks® America and its and streamline company operations . network members, creates pathways • Marketing – essential marketing resources to homeownership through homebuyer including market research, marketing education and down payment tactics, sales methods, and tips to measure assistance grants . return on investment .

40 • Business management – resources to help We participated in the Paycheck small business owners understand relevant Protection Program (PPP) and funded financials and cash flow, as well as employee approximately 264,000 loans under the management, legal, regulatory, insurance, PPP totaling $13 .2 billion, and more than accounting, tax, and environmental $1 billion of principal forgiveness has considerations . been provided on qualifying PPP loans . We deferred approximately $420 million • Competitive intelligence tool – market of SBA processing fees in 2020 that will be and competitive intelligence to help small recognized as interest income over the terms businesses map competitors, customers, of the loans . We voluntarily committed to and suppliers and develop a targeted donate all of the gross processing fees received marketing campaign . from PPP loans funded in 2020, and we We strive to support diverse small businesses funded $2 .8 billion of PPP loans in first quarter by making it easier for them to access the capital 2021 . In first quarter 2021, we deferred and training they need to grow, manage their approximately $200 million of SBA processing finances, and achieve their business objectives . fees that will be recognized as interest income In 2015, Wells Fargo commissioned a Gallup over the terms of the loans . We’ve committed study to gain insight into the attitudes, needs, to donate any net profits related to PPP loans and motivations of diverse small business owners funded in 2021 . related to their use of credit . The study found the group was more likely than their counterparts Women-owned businesses are one of the in the general small business population to: fastest-growing small business segments . To support women aspiring to run science, • Report having personal credit challenges technology, engineering, and mathematics and be declined for business credit . (STEM) businesses, we’ve partnered with • Have annual business revenues of less than STEM Connector to fund the Million Women $50,000 . Mentors Entrepreneurship Initiative Mentor Program . This one-year business development • Have a business in the startup and early program pairs women who own well-established growth stage . small- and medium-sized businesses with • Be extremely interested in learning how to accomplished executives who mentor and build a strong business credit application . help them strengthen and grow their STEM businesses . Our Diverse Community Capital program was created to respond to the needs identified in this study . We provide grants to Community Development Financial Institutions (CDFIs) to support their work to provide diverse small business owners with access to capital and technical assistance .

41 For dentists, veterinarians, physicians, Additionally, our Elder and Dependent Adult optometrists, and other health care providers Financial Abuse Policy outlines our employees’ interested in running or expanding their own responsibility to understand and identify warning practices, Wells Fargo Practice Finance provides signs, flag unusual activity reports, and report specialized financing and resources — such suspected abuse . as planning tools and project management The U .S . financial system has numerous support — to help them buy, equip, and protections for customer privacy and rules refinance those practices . designed for the prompt execution of financial Protecting aging and dependent adults orders . But older clients and other vulnerable adults are still confronted with constant and The U .S . Census Bureau projects that by 2034, ever-changing efforts by criminals to unlawfully older adults (those 65 and older) will outnumber take their savings . We support systems and laws kids (those 18 and under) for the first time in that provide exceptions to privacy laws U .S . history . As America ages, we recognize that and permit financial institutions to temporarily the risk of financial fraud and exploitation will grow . execute holds that, along with other mechanisms, Aging and dependent adults often rely on others can prevent or mitigate the harm of suspected to assist or direct them in their financial affairs, elder financial abuse . and that makes them more vulnerable to the risk of fraudulent schemes or undue influence . Helping students manage their money At Wells Fargo, we’re concerned about financial Through CollegeSTEPS®, a website we created abuse of aging and dependent adults, and we’ve to help college students manage their money, made dedicated efforts to combat the issue . students can access planning and educational In 2019, we established the Aging Client Services resources on topics such as paying for college, center of excellence that focuses on: finding scholarships, understanding credit, getting • Guiding best practices and procedures ready for school, and managing and earning money for preventing, detecting, reporting, while in school . Making informed decisions enables and responding to financial exploitation . students to responsibly manage their debt, before it can become a hardship in the future . • Building awareness through education and advocacy .

• Championing legislation and regulation to advance elder protection efforts .

• Harnessing companywide data to inform risks and opportunities .

• Assisting with the development of new products and services that enhance the experience of older adults and their families .

42 Addressing unique LGBTQ community needs is expected to immediately contribute to For members of the LGBTQ community, financial health and planning for LGBTQ financial planning needs, from the simple elders during the COVID-19 pandemic, and to the complex, can come with a unique set lay the foundation for a sustainable, ongoing of challenges . These include credit issues for financial health initiative to benefit this highly same-sex partners, adoption by same-sex couples, vulnerable older population long-term . For tax implications, savings plans, elder care, long- more about Wells Fargo’s engagement with term retirement savings, or name changes due SAGE, visit Wells Fargo Stories . to gender reassignment . In the U .S ., we’re proud We also help LGBTQ business owners access to offer this community access to professionals capital and financial resources . In 2004, who are specifically trained to understand the Wells Fargo became the first financial complex financial needs of LGBTQ couples and institution to join the National Gay and individuals . We’ve been at the forefront of our Lesbian Chamber of Commerce* (NGLCC), an industry’s efforts to meet those needs for more organization created to better address the than a decade . Our LGBTQ Resource Center financial and educational needs of LGBTQ provides valuable information, from everyday businesses . We’re proud to be the founding banking to starting a new business . sponsor of the NGLCC Supplier Innovation While the U .S . Supreme Court has extended Center in Washington, D .C ., which is focused marriage rights and employment protections on groundbreaking education and networking to individuals within the LGBTQ community, opportunities for certified LGBTQ businesses . the absence of other federal protections has Supporting America’s service members the potential to impact their financial well-being . To address the financial needs and considerations For nearly 170 years, Wells Fargo has proudly of domestic partners, some Wells Fargo Advisors followed through on our commitment to have been trained on key issues affecting domestic military service members, veterans, and partners and are dedicated to providing tailored their families . We created our Military Affairs investment-planning solutions . Program in 2012 to expand outreach to members of the military community and help Aging LGBTQ adults may experience health them achieve financial success . Our Military conditions and disparities that create high Resource Center provides support for military levels of social isolation, and even higher and veterans through tools and resources that levels of financial insecurity than older include: Americans in general . Wells Fargo is working with SAGE, an advocacy group that offers Financial readiness* services to LGBTQ elders, to design and launch Worldwide Military Banking services a Financial Resiliency Center for LGBTQ Older People . This online financial health program Mortgage services Servicemembers Civil Relief Act benefits

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 43 As the exclusive sponsor of the Military Family Improving accessibility for customers Financial Readiness Council, led by the Military with disabilities Family Advisory Network,* Wells Fargo is As part of Wells Fargo’s ongoing commitment committed to empowering service members, to people with disabilities, we continue to focus veterans, and their families to gain financial on accessibility efforts to ensure customers knowledge and skills that can help them enjoy equal access to Wells Fargo products and manage all stages of life, from permanent services, including physical locations and digital change of station to deployment to retirement . content and services . We strive to follow the To support financial readiness, we offer the Hands Web Content Accessibility Guidelines (WCAG) on Banking® program, a free, noncommercial to make our digital content and services financial education program that offers service accessible . When accessibility is considered members a personalized learning experience throughout the design and development with lessons and resources relevant to a service process, more customers, including people member’s life . In addition, Hands on Banking with disabilities, can better access products is integrated into the National Foundation and services, and conduct financial transactions for Credit Counseling* Sharpen Your Financial online, by phone, and in our branches . Focus® initiative . A national alliance between Wells Fargo and We also support veteran-owned businesses Disability:IN(PDF)* provides continuing through our supplier diversity strategy . education opportunities for disability-owned We’re corporate members of the National business enterprises and service-disabled Veteran-Owned Business Association (PDF),* veteran disability-owned business enterprises . and we work closely together to identify veteran- Wells Fargo underwrites scholarships that owned businesses to compete for Wells Fargo’s help these business owners participate in procurement opportunities . In addition, we invest the Tuck Business School’s diverse business each year in helping veteran-owned businesses education program at Dartmouth College .* grow by sending certain veteran business owners to top executive education programs across the country .

Furthermore, we continue to work internally and collaborate externally with organizations aligned with our mission to support housing affordability, military spouses and families, financial health, small business growth, and military talent through their career transitions . Our ultimate goal is to empower military communities to effectively navigate life’s transitions and achieve ongoing career, community, and financial success, while making a positive impact for others .

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 44 Responsible marketing supports We’re continuously investing in emerging informed decisions technologies and leveraging our digital channels and assets with the goal of making digital banking We aim to provide current and prospective faster, easier, smarter, and safer for our customers . customers with products and services in a transparent, consistent, and responsible Information and cybersecurity manner, and have processes and procedures governance and oversight in place designed to provide customers with information that allows them to make informed Wells Fargo’s Information and Cyber Security decisions . We believe that information should (ICS) organization aims to protect Wells Fargo be provided in a manner that is accurate and systems, networks, and customer data through the understandable . design, execution, and oversight of our Information Security Program (ISP) . ICS is led by our chief Our marketing activity is subject to legal and information security officer, who reports to the head compliance policies designed to help make sure of Wells Fargo Technology . The Wells Fargo Board we’re accurately portraying our products and of Directors annually approves the ISP and is kept services, evaluating content for biases or other informed of the ongoing status of the program . discriminatory practices, and not misleading our customers . Wells Fargo organizations and employees, as well as vendors, nonemployees, and third parties with access Wells Fargo Marketing strives to provide current and to our systems or sensitive information, must adhere potential customers, including diverse populations to the ISP’s policies, procedures, and requirements . and those with disabilities, with equal access to our Those requirements are designed to help make content . That includes our websites, television ads, certain that information security risks are effectively digital videos, emails, social posts, multimedia, and identified, assessed, mitigated, and reported other content channels . We offer communications throughout Wells Fargo . in English and other languages to support those with limited English proficiency . We also have The Wells Fargo ISP is designed to comply with accessibility experts who engage with our marketing applicable laws and regulations and is informed teams and partners to help consider accessibility by industry standards, including from the National in every phase of the marketing campaign Institute of Standards and Technology (NIST) development process . And we have an enterprise Cybersecurity Framework, the International digital accessibility policy that is designed to Organization for Standardization (ISO) 27002 adhere to the industry standard for digital (web) standard, and COBIT 5 . accessibility, the W3C’s Web Content Accessibility Managing information and cybersecurity risk Guidelines (WCAG 2 .0 AA), and the Americans with Disabilities Act (ADA) Title III . Information security risk (including cybersecurity) is a key risk type at Wells Fargo . That’s why Information and cybersecurity information security risk management is guided by a set of foundational principles that direct Wells Fargo manages billions of customer how our company operates, including a functional interactions each year and we take a proactive framework, risk coverage statements, and risk approach to information security and cybersecurity . appetites .

45 Cyber defense management We’ve also implemented data loss prevention From malicious software to phishing emails, technology across the enterprise to help identify cyberattacks on the internet have created or block the transmission or release of confidential an urgent need for all of us to increase our customer information . cybersecurity awareness . Wells Fargo’s ICS Third-Party Information Security Cyber Threat Management team supports Risk Management threat and vulnerability management, and intrusion detection policies . It also develops Wells Fargo has an established Third-Party best practices based on an assessment of the Information Security Risk Management internal and external threat landscape, and leads program that reviews and assesses third companywide efforts to reduce our exposure parties prior to engagement and throughout through continuous monitoring of several key the third-party relationship . The program information security control areas, including: also requires periodic risk assessments to be conducted throughout the term of the Management of security patches and engagement, the type of interval of which security configurations is driven by the risk associated with the Condition and activity monitoring engagement . In providing products and services to Wells Fargo, third parties and their employees Threat and vulnerability management are required to adhere to information security Patch management processes standards and requirements . These standards also apply to third parties located outside Our defense strategy includes continuous of the U .S . who have access to company monitoring, integrated risk management, and consumer information for purposes identification of human risk factors, enhanced of delivering products or services to or on customer awareness, and external engagement behalf of Wells Fargo . As part of this compliance on best practices . We prepare the enterprise obligation, we have contracts in place with third for cyberattack scenarios through education, parties that include confidentiality language, training, and simulations . We also conduct cyber nondisclosure obligations, and security provisions . exercises with other financial services companies and government agencies to help build a stronger, Training employees to protect more secure environment for the entire industry . customer information Employees and contingent resources with access Effective data protection reduces our risk to Wells Fargo’s systems or customer information from incidents related to information theft, are required to complete annual training on loss, or disclosure . We require hard drive customer information protection and Gramm encryption on all laptops . And we also require Leach Bliley Act (GLBA) 501(b) compliance . email encryption for all sensitive data . USB ports They’re also required to abide by our Code are locked down and only available for use with of Ethics and Business Conduct, including a company-approved encrypted thumb drive .

46 its provisions related to the treatment of Protecting data in open banking environments confidential information . We regularly update With the growing number of apps designed to help companywide training, policies, and information- customers lead healthier financial lives, Wells Fargo handling standards to help Wells Fargo employees believes it’s important to support our customers’ understand their role in protecting customer desire to use these apps and to enable sharing of information . We perform employee background their Wells Fargo account information with them checks, which we also require for nonemployees in a seamless and more secure way . We’ve reached and third-party service providers who handle data exchange agreements based on application Wells Fargo’s customer information . programming interfaces (APIs) with numerous Educating customers on digital security third-party personal financial management apps and financial data aggregators . This API-based The world continues to become increasingly data exchange moves away from credential-based digitally interconnected, which allows greater access and ultimately gives our customers greater access to information and services in the transparency into, and control over, the bank financial services industry . In this environment, account information they share with supported we encourage digitally active customers apps, including the ability to turn data sharing to protect their accounts by offering security on or off through our Control owerT ® digital options like two-factor authentication, experience . biometrics, and the ability to turn debit cards on and off . Protecting customer and Our online security center provides customers employee privacy with resources to explore security options, spot Managing privacy risk is the responsibility scams, report fraud, and more . We also provide of every Wells Fargo employee . Wells Fargo educational materials that encourage customers mandates companywide privacy training to create strong passwords, avoid suspicious links, in addition to requiring comprehensive business keep their software updated, limit the personal line procedures to minimize data privacy risk . information they share online, and use a screen lock on mobile devices . The privacy regulatory landscape continues to rapidly expand . The California Privacy Rights Act (CPRA) expands upon the California Consumer Privacy Act of 2018 (CCPA) and will be effective in 2023 . In addition to federal initiatives currently under consideration, other states continue to introduce legislation to further expand privacy rights and protections to state residents . Numerous regions and jurisdictions around the world have enacted or are proposing privacy and data protection laws, including the General Data Protection Regulation or GDPR in the EU . We actively track these developments and enhance our privacy practices accordingly .

47 Privacy governance and oversight As evidenced through our internal policies The front line identifies and controls privacy and supported through three established risks and is responsible for self-assurance lines of defense, our businesses strive to monitoring at the business operations level . effectively manage risks associated with The second line is responsible for maintaining collecting, processing, and retaining personal and publishing policy, providing requirements, data pertaining to customers and employees . developing and deploying certain training, Our internal privacy policies form the basis and providing objective credible challenge on which our processes and controls are to the frontline business operations . built . Specifically, our internal privacy and related policies: • Outline the privacy principles and standards that businesses must observe when collecting, processing, storing, transferring, and/or disclosing personal data . PRIVACY CENTER • Document privacy principles regarding transparency, notice, collection and The Wells Fargo Privacy Center web portal retention, use and disclosure, access, is a resource for people to make requests to see certain personal data we have about and additional topics . them, or ask us to delete certain data that our • Establish a Privacy Compliance Office businesses located in the U.S. have collected to provide independent risk management from them, subject to several exceptions oversight of data privacy risk . and exemptions which are explained in the Privacy Center Important Information (PDF). • Define frontline responsibilities More information about the types of data we to address the risks created by their collect, how we use it, and choices available to business or enterprise function . individuals, is available here.

• Communicate guidance and standards for appropriately responding to data subject requests . The second-line function, Privacy Compliance, as well as frontline privacy functions are independent of one another and report up through their respective senior executives to the Board of Directors . These groups and other privacy stakeholders actively engage with each other and coordinate across Wells Fargo to help manage privacy risk .

48 Investing in our employees

Culture At Wells Fargo, we aim to meet the highest To provide clear direction and help define what standards of integrity and operational success looks like, in 2020 we introduced a set excellence to deliver what’s expected of of common expectations that guide how we us by our stakeholders . Our past provides lead ourselves, collaborate with our colleagues, perspective and guidance, but we’re moving and make decisions, and they apply to everyone with urgency and optimism toward our future . at Wells Fargo, at every level, and in every role: Approaching our work in new ways and Embrace candor challenging past perspectives helps us make the most of the opportunities that exist across all of Do what’s right our businesses . Be great at execution We’re transforming the way we run the Learn and grow company and redefining parts of our culture to be more effective . We understand the Champion diversity, equity, and inclusion importance of organizational culture, Build high-performing teams (for managers) and we want ours to be the reason that employees choose to join and stay at Our expectations are more than just words Wells Fargo, communities welcome us to their on paper . They’re part of our culture and neighborhood, and customers are proud to ingrained in everything we do — from how do business with us . we develop employees and communicate, to how we evaluate our performance and serve We are listening to our employees and our customers . To hold everyone accountable, acting on their feedback . We regularly the expectations constitute the “leading our survey employees to understand what is transformation” performance objective that working and where we have opportunities must be documented and acknowledged to improve . Based on their feedback, we’ve by every employee at Wells Fargo . made enhancements to our compensation and benefits programs, time-away policies, and other programs . From December 2019 to December 2020, we have seen a growth of nine points regarding employee sentiment around our commitment to customers .

49 Diversity, equity, Performance Sustain our diverse supplier program and explore trends can be opportunities with diverse asset managers and and inclusion found in the other business partners Society expects companies Wells Fargo ESG Goals and to have their executive ranks Performance We engage in strategic partnerships across reflect the customers they Data (PDF) . a diverse business community, developing serve and the U .S . population businesses for growth, and engaging with more broadly . They also expect financial community organizations that share our institutions to provide affordable, easy-to-use commitment to DE&I . Specifically, we leverage products and services, to enable the dream of internal and external partners to engage with homeownership, financial well-being and planning, diverse-owned businesses including those and to help in the formation and growth of small owned by racially and ethnically diverse individuals, businesses in diverse communities . We share women, veterans, people with disabilities, and these expectations and we’re developing members of the LGBTQ community . We also and implementing a comprehensive diversity invest in capacity building programs to help agenda that focuses on sustainable progress historically underrepresented suppliers grow and lasting impact . their businesses .

In 2020, we renewed our commitment to • We have steadily increased our annual diversity, equity, and inclusion (DE&I) at the spending with diverse suppliers from direction of our CEO . New DE&I initiatives were $824 million in 2013 to nearly $1 .4 billion put into place to help accelerate our efforts to in 2020, representing 12% of our total increase diverse representation at all levels of the controllable spending, and surpassing the organization, including senior-level roles, creating financial services industry average of 9 .3%¹ . a more inclusive work environment . It also allows • In October 2020, we launched our Diverse us to better serve growing, diverse customer Asset Managers Initiative, a multiyear plan segments, while partnering with diverse suppliers to invest internal assets with asset managers across all business lines . from underrepresented backgrounds while Update on Wells Fargo’s DE&I commitments increasing visibility and building capacity in diverse-owned asset management firms . Require diverse candidate slates and interview We engage with a network of nonprofit teams for key roles with total direct compensation organizations to address systemic and of more than $100,000 structural issues that may be barriers In the U .S ., we now require that at least 50% to asset manager diversity and inclusion . of interview candidates identify with at least Learn more in our Supplier Diversity section . one diversity dimension — and we require a diverse team of interviewers — for most Inclusion of DE&I metrics and activities in all roles with total direct compensation of more regular business reviews than $100,000 . Outside the U .S ., we have DE&I metrics and activities are now included country-specific strategies in place to ensure in all regular business reviews to help ensure that we’re considering diverse candidate slates we accomplish our objectives . for executive-level roles .

1 . As reported by Financial Services Roundtable for Supplier Diversity . 50 Launch a “returnship” program focused Expand the reach of early talent program on diverse talent who have been out of the recruiting by increasing our participation workforce for an extended period to support their with Hispanic-serving institutions (HSIs), return to the industry and historically Black colleges and universities (HBCUs), through visits and in-house We launched our inaugural Glide — Relaunch diversity events program, a 10-week “returnship program” that aims to bring talented professionals with at We’re continuing to focus on early talent least seven years of experience back into the recruitment by working with HBCUs, HSIs, workforce after taking a voluntary career break and other national partners to identify talent of at least two years . and build engagement through our University Programs team . We’ve almost tripled our Create a formal development program for talent sourcing, programming, and sponsorship high-potential employees to build a more diverse investment in 2021 from what we spent in and inclusive talent pipeline 2020 . As part of that investment, we have built We launched a sponsorship program for diverse programs that directly support HBCU and HSI leaders across the company . This program has students, such as our recently launched Senior two components: A companywide program for Leader Speaker Series, a program designed to senior leaders from underrepresented groups, support students’ continued development via and programs within each of our lines of conversations with leaders across the enterprise . business to mentor and sponsor talent across We have also created a Virtual Mentorship Series, different levels within the business . which is designed to keep undergraduate students connected to the Wells Fargo University Programs recruiting process as well as offer professional and networking opportunities .

Update on our Operating Committee member DE&I expectations Increase diverse representation at all levels in their area

Operating Committee members strive to fulfill their commitments to increase diverse representation at all levels . We’ve established a dedicated, diversity-focused talent review twice a year for each line of business and function . These reviews include detailed assessments of the strengths and development areas, career plans, and senior leader support for high-potential leaders from underrepresented groups .

51 Serve as a sponsor for an At Wells Fargo, our 10 ERNs connect colleagues Employee Resource Network through a variety of diversity dimensions:

Our Employee Performance All members of the Operating Committee Resource Networks trends can be now serve as a sponsor for an ERN, providing found in the (ERNs) were formed Wells Fargo an additional way to network with employees to elevate and increase ESG Goals and and provide leadership . visibility of historically Performance Data (PDF) . Host quarterly DE&I-focused conversations in underrepresented groups different markets and create spaces to connect and engage on issues of importance to members . Our Operating Committee members have The ERNs provide valuable opportunities participated in regular DE&I conversations, for career and professional development, and many Operating Committee members have mentoring, leadership engagement, networking, dedicated either all or a portion of their regular and community volunteering . The networks have all-team meetings to discussions of DE&I topics . chapters around the globe and are organized by Increase external DE&I efforts, including at least employees who share a common background, one of the following: experience, or other affinity . The networks and chapters are open to all employees . • Active engagement with one of the HSIs or HBCUs on our core recruiting list .

• Participation in national diversity events, along with a commitment to potentially interview and hire on the spot .

• Identification of, and engagement with, an external diversity-focused organization related to their line of business or function .

Over the past year, every member of the Operating Committee has participated in at least one of the three efforts above .

Our Operating Committee members are sponsoring an enterprise-developed mentorship and sponsorship program within their lines of business or function .

52 Build internal and external diverse New and expanded diversity role reporting leadership pipelines to the CEO

In addition to partnering with HBCUs, We hired a head of Diverse Segments, HSIs, and other national partners, Operating Representation and Inclusion, who reports Committee members are also hosting annual to our CEO and is a member of the Operating internal recruiting events designed to increase Committee . diversity in our internal pipeline of high- Hold education sessions potential talent by offering internships and full-time opportunities for graduating seniors . Our Operating Committee members continue to have highly productive, ongoing dialogue They also engage in line-of-business specific and working sessions with senior Black and forums intended to expand diversity in our African American leaders, and launched a similar pipeline of specialized talent . initiative with our Hispanic and Latino leaders . In June 2020, our CEO made additional They’ve also started to engage executives from commitments to increase Black and African other underrepresented groups, including American employee representation at all Asian American and Pacific Islander leaders, to levels of the company . participate in similar executive forums . This level of engagement will continue throughout 2021 . We Increase diversity in senior Performance management trends can be have multiple new DE&I initiatives underway that found in the were based on recommendations made by Black Wells Fargo We recognize the and African American and Hispanic/Latino leaders ESG Goals and importance of diverse Performance as part of these regular sessions . These DE&I succession plans for senior- Data (PDF) . initiatives have been enhanced and prioritized level positions in the with additional input from subsequent diverse organization, and we’re working to position executive forums . diverse employees to take on those roles . Expand DE&I training This includes providing executive-level and other mentoring programs and resources We’ll require managers to participate to support employee development, and in a live and interactive training program that implementing a talent review process aimed includes learning more about inclusive behaviors, at development of diverse employees to mitigating unconscious bias, and anti-racism . achieve increased representation . Our Operating Committee members attended In June 2020, we committed to increasing new, live, and immersive inclusion training . The Black and African American leadership content from this new program will be rolled out in our executive ranks . Our CEO personally to senior leaders across the company and a version committed to adding diverse representation of the training will be rolled out to all managers — specifically Black leadership — to our during 2021 . In addition to inclusion manager Operating Committee . We continue to work training, we also made unconscious bias training a to increase diverse representation in our senior requirement for all managers in 2021 . leadership teams . Our DE&I curriculum provides the learning tools necessary to establish a core and common approach to DE&I . We encourage all employees and managers to complete training on unconscious bias, understanding and appreciating differences, and leading inclusively . We also offer experiential

53 learning programs to provide deeper learning Compensation linked to DE&I initiatives and collaboration on key DE&I initiatives Increasing executive accountability by linking and topics . DE&I outcomes to compensation is a critical part Increasing diverse Performance of our DE&I initiatives . We recently added a new can be representation throughout trends DE&I executive performance objective for senior found in the our workforce Wells Fargo leaders that is directly connected to increasing ESG Goals and gender, racial, and ethnic representation in our We work with multiple Performance executive ranks . This is now part of year-end organizations that focus on Data (PDF) . racially and ethnically diverse performance evaluations and consideration of communities, women, veterans, people with individual performance for our CEO and each disabilities, and the LGBTQ community . Operating Committee member . In 2020, as part Through a combination of direct recruiting of our culture expectations at work, we rolled out and support of these partner organizations, a DE&I performance objective for all employees . we engage in a host of activities to educate, The objective champions DE&I with a specific support, and attract diverse talent . focus on creating a safe and inclusive environment where differences are respected and we encourage In May 2021, Wells Fargo joined the OneTen diverse ideas that challenge our thinking, where we Coalition to improve hiring, retention, upskilling, build relationships with colleagues and customers and advancement of Black and African who are different than us, and where we help each American talent . other succeed . We added a focus to learn more We’ve supported military service members about unconscious bias in 2021 . and veterans through initiatives to hire and Oversight of our DE&I efforts retain veterans, and through foundation donations, financial health resources, and event The Board and its Human Resources sponsorship . Military talent programs include: Committee oversee our DE&I efforts and progress . The Human Resources Committee • The Veteran Employment Transition engages regularly on our DE&I initiatives and Program: An internship program that provides the full Board receives DE&I updates at its veterans an opportunity to understand the meetings . responsibilities of a Wells Fargo employee . • Military apprenticeships: A structured Our head of Diverse Segments, Representation experiential training program that results and Inclusion (DSRI) reports to the CEO and in skills certification for applicants who do not is responsible for advancing Wells Fargo’s DE&I initially meet required qualifications for the efforts in the marketplace and the workplace . non-apprentice equivalent role . The head of DSRI drives companywide diverse • Boots to Banking: A hiring initiative to recruit customer segments strategy, partnering with military talent for high-volume positions we our line of business CEOs and diverse segment have identified as entry points . teams to deliver products and services designed • Corporate Fellowship Program: to meet the needs of our diverse customer base . In partnership with the U .S . Chamber of Commerce Foundation’s Hiring Our Heroes initiative, military personnel engage in a fellowship experience with the goal of achieving full-time employment .

54 Diversity, Equity, and Inclusion councils COVID-19 pandemic and the recent increase in anti-Asian discrimination and violence . Funds Every line of business and function has provided for these organizations are in addition a Diversity, Equity, and Inclusion council to our ongoing support for these communities aligned with and supporting our enterprise through financial education, college scholarships, DE&I strategy, focusing on workforce and small business support, in-language services, marketplace outcomes, including customers and support of local and national Asian-focused and suppliers, and advocacy outcomes nonprofit institutions and organizations . such as external relationships, community outreach, and reputational efforts . The We work closely with Black and African American councils also collaborate closely with organizations and institutions that help support senior leadership, including the Operating our customers, communities, and society, while Committee members and with our ERNs on advancing our mission to positively reflect, priority initiatives . impact, and uplift Black families and voices . We collaborate with several longstanding U .S . Supporting communities organizations to advance the Black and African We have several external, diversity- American community, such as the United Negro focused initiatives focused on investing College Fund (UNCF), National Urban League, in communities, better serving our diverse the Rainbow PUSH Coalition, the NAACP, the customer base, and increasing supplier Thurgood Marshall College Fund, 100 Black diversity . A few examples include the following: Men of America, the National Council of Negro Women, and U .S . Black Chambers Inc . As of May 2021, Wells Fargo has made investments in a total of 13 Minority Wells Fargo continues to support organizations Depository Institutions (MDIs) and has fulfilled that serve Hispanic and Latino communities and the bank’s March 2020 announcement to future generations, providing economic commit $50 million to Black-owned banks opportunities and programmatic support in communities across the country . As part to organizations such as the League of United of this equity capital investment, we also are Latin American Citizens, the National Association offering access to a dedicated relationship of Latino Elected and Appointed Officials, team that can work with each MDI on financial, Hispanic Scholarship Fund, and many others . technological, and product development We’re a leading lender to minority-owned strategies to help strengthen each institution small businesses, and have strong national and support their growth . partnerships with the U .S . Hispanic Chamber of Commerce, UnidosUS, and Stanford Latino In May 2021, Wells Fargo awarded $1 million Entrepreneurship Institute (a collaboration in grants to provide support for Asian between Stanford University and Latino American and Pacific Islander communities Business Action Network) to encourage capacity and small businesses in response to the building among minority-owned small businesses .

55 We have a legacy of serving Native We continue to focus on accessibility efforts to American, Alaska Native, and Native Hawaiian support customers and employees, to go beyond communities for more than 65 years, and we’re accessibility requirements, and ensure everyone can committed to seeing the communities achieve access and utilize Wells Fargo physical and digital financial sustainability and prosperity . As the properties with ease . leading provider of capital and financial services We have made significant efforts to embrace to tribes and tribal-owned enterprises, we have inclusion through offering benefits to domestic developed banking relationships with many partners of employees, providing employees with tribal nations and business entities . the option to self-identify and to use their preferred In addition, Wells Fargo exceeded the pronouns in email communications and on business $50 million commitment we announced cards . We established a Gender Expression & Identity in 2017 to address unique economic, social, and Advisory Council in 2017 . This volunteer council, environmental needs in Indian Country . Part composed exclusively of transgender and nonbinary of the $50 million commitment included more employees, advises on issues and projects that than $1 million in COVID-19 relief in 2020 for impact the transgender and nonbinary communities organizations serving tribal communities . Going and works closely with our Pride Connection ERN . forward, our tribal philanthropy efforts will In March 2021, Wells Fargo signed the Human focus on delivering social impact, particularly Rights Campaign Business Statement on Anti- in the areas of housing, small business growth, LGBTQ state legislation, opposing harmful and financial health . We continue to work on legislation aimed at restricting the access shared priorities to advance Indian Country of LGBTQ people in society . We’ve provided alongside organizations such as the Alaska programmatic support to LGBTQ organizations such Federation of Natives, the American Indian as the Human Rights Campaign, the National LGBTQ Graduate Center, the National Congress of Chamber of Commerce, Out and Equal, GLSEN, The American Indians, the Native American Finance Trevor Project, Point Foundation, and SAGE . To Officer Association, and the Native Indian provide quality customer service and an inclusive Gaming Association . environment, we respect customers’ and employees’ Approximately one in four U .S . adults — pronouns, regardless of perception of gender or legal 61 million Americans — has a disability that gender markers on their identification or documents . impacts major life activities, according to the All customers and employees, regardless of gender Centers for Disease Control and Prevention identity, sexual orientation, or gender expression Morbidity and Mortality Weekly Report . People have the right to privacy . with disabilities represent vast backgrounds, As a company, we’ve spoken out on a range of issues, experiences, and cultures . This community such as condemning violence against Asian American is part of our global fabric and growth of the and Pacific Islander communities, supporting the future . As of March 2021, more than 15,000 Deferred Action for Childhood Arrivals program, Wells Fargo employees have self-identified as and marriage equality . We will continue to do so . having a disability .

56 Addressing harassment Performance management in the workplace Our performance management program includes We prohibit any form of harassment, including a balanced framework designed to promote sexual harassment, of any of our employees, risk management, discourage imprudent or contingent resources, vendors, employment excessive risk-taking, and encourage personal applicants, or customers on the basis of an accountability . We continuously refine the individual’s race, color, gender, national origin, way we evaluate and manage our employees’ religion, age, sexual orientation, gender identity, performance . Some recent enhancements to our gender expression, genetic information, physical performance management framework include or mental disability, pregnancy, marital status, the introduction of a multilevel rating scale, a hairstyles or hair texture, status as a protected new approach to prioritizing risk management veteran, or any other status protected by federal, via a risk overlay, and the removal of objective state, or local law . And we’re committed to weightings . We’ve also added formal checkpoints protecting those who report harassing behavior between managers and employees, including from retaliation . an opportunity for employees to acknowledge receipt of their performance objectives and The treatment of sexual harassment claims has evaluations . Our Performance Management become an increasingly prominent issue across Policy establishes our performance management all industries . We’ve taken many steps intended expectations and requirements for all Wells Fargo to create and maintain a workplace environment employees . that promotes and protects the safety and well- being of our employees . Among other things, Each year, employees are expected to have defined we decided in 2020 that Wells Fargo will not performance objectives so that they focus time require arbitration for employees in connection and resources appropriately and know how their with any sexual harassment claims . performance will be assessed . On an annual basis, managers complete a mid-year and year-end performance evaluation with their employees where they document key accomplishments against objectives, including risk management .

57 Each employee is provided with both an overall The platform catalogues more than 10,000 performance rating and a risk overlay rating . learning resources, with curricula that range Performance improvement opportunities from four minutes to two weeks in length . are addressed as needed through feedback In 2020, the Learning & Development team and coaching, a documented performance converted in-person training to virtual or improvement plan or improvement goals, or, as self-paced delivery, primarily in response to warranted, a documented performance-related COVID-19 and our transition to a more virtual corrective action . work environment . Wells Fargo spent 23% of Performance objectives for employees whose total training hours in person in 2019, and that roles involve sales activities are subject to was reduced to 11% in 2020 . We continue to additional oversight . implement enhancements to training programs to support more flexible delivery . For more information on performance management, please see our Proxy Statement . We’ve also introduced new programs necessary to establish a core and common Wells Fargo Employee training approach to diversity, equity, and inclusion . and development We designed a leadership opportunities We invest heavily in coaching Performance framework, which includes sponsorships for and training for employees and trends can be individuals in the organization . The program found in the managers . That’s because when Wells Fargo will be managed by individual business units . our employees are properly ESG Goals and A training program on Creating an Inclusive Performance supported, engaged, and Equitable Culture was introduced to Data (PDF) . and confident in their skills, promote inclusive leadership for everyone they’re more effective leaders and can provide in the company . The Operating Committee a better customer experience . We invest participated in the training in 2020 . Managers approximately $200 million annually in employee began to receive training beginning June of learning and development, which includes 2021, and will be followed by the rest of the functional training, regulatory compliance, organization . leadership and professional development, In addition to formal learning programs, and early talent development programs for we support our employees through mentoring, employees . coaching, networking, and early talent program Wells Fargo’s learning platform — Develop You — recruiting and development programs . gives our employees access to relevant training Our University Programs (UP) team partners courses . This global platform uses a modern, with a number of diverse organizations, easy-to-navigate layout coupled with machine including HBCUs and HSIs, to source and learning and features that work together to help attract outstanding talent . College juniors employees complete assigned trainings more and seniors participate in a 10-week summer efficiently . What’s more, it also helps them internship program, which serves as a talent find development opportunities aligned with pipeline for the full-time analyst and associate the skills they need to grow their careers . programs . These programs range from

58 highly specialized technical training programs They discover how to weave coaching into to companywide development programs their leadership style and create a collaborative focused on the student’s transition from the coaching environment within their teams . campus to corporate environment . Community In addition, our Manager Excellence learning support and diversity, equity, and inclusion program is designed to provide new managers are key components of all Wells Fargo university with a consistent foundation and understanding programs . of what’s expected of them and the tools and Leadership and professional development resources available to them . The program helps build skills so that managers can focus Our leadership development training program on building high-performing and engaged contributes to the success of the Wells Fargo teams . The program’s components include: employee by partnering with them and leadership to drive learning that is strategic, measurable, and Independent learning effective . It’s our mission to contribute to the Social communities and networking growth and profitability of Wells Fargo by providing with peers employees with the tools and training necessary for job excellence and career advancement . On-the-job assignments

We provide leadership training opportunities Live webinars with internal subject matter through such programs as Leading Through experts in various subjects (e .g ., employee Change and Transition, Extraordinary Leader, relations and compensation) Coaching and Feedback in the Moment, and A preliminary study indicated that managers several Diverse Leaders programs . In 2020, who participated in these programs were more due to the challenges of COVID-19, the leadership likely to conduct monthly (or more frequent) and professional development program redirected performance check-ins . What’s more, their 12 of the courses from face-to-face delivery employees reported that they were more actively to virtual delivery . We also worked with vendors engaged in those performance discussions . and international leadership to convert additional courses to virtual delivery, to be implemented Competitive compensation in 2021 . Our compensation program is linked to The Coaching and Feedback in the Moment performance management and is designed (CFIM) program, which was converted to virtual to promote prudent risk management and delivery, aims to build the coaching capabilities reinforce our culture and operating standards . of managers at all levels, as well as individual Our compensation principles include: contributors who coach others in their roles . • Pay for performance ‒ Compensation Delivery of the course is through in-person is linked to company, line of business, or virtual classes, supported by online learning and individual performance, including activities . Leaders learn approaches for offering meeting regulatory expectations and feedback and coaching in ways that aim to evoke creating long-term value consistent insight and promote lasting behavior change . with the interests of shareholders .

59 • Promote effective risk management ‒ Incentive Compensation Risk Management Compensation promotes risk management Our compensation principles are supported by and discourages imprudent or excessive our Incentive Compensation Risk Management risk-taking . (ICRM) program, which establishes the • Attract and retain talent ‒ People are one expectations and requirements related to the of our competitive advantages; therefore, design and oversight of the incentive plans for compensation helps attract, motivate, employees . The program seeks to provide eligible and retain people with the skills, talent, employees with incentives that appropriately and experience to drive superior long-term balance risk and reward by establishing the company performance . governance framework, policies, risk management standards, and processes under which we manage To confirm that our pay is competitive in the incentive compensation risk . The program marketplace, jobs are assessed against our supports Wells Fargo’s Risk Management competitors at least annually . We look across Framework and accounts for the company’s industries because our competition for talent financial and non-financial risks and regulatory extends beyond the financial services sector . requirements . We invest significantly in salary increases and promotions for all roles at all levels across the As part of the enterprise incentive compensation company . For example, in addition to merit design process, the Incentive Compensation increases that result from annual performance Center of Excellence design team or business- reviews, each year we have averaged aligned compensation and performance approximately 42,500 employee promotions management teams are expected to: with salary increases . • Conduct an annual incentive compensation We aim to provide fair, competitive, and risk assessment for each existing incentive equitable compensation . In March 2020, we compensation arrangement, and an announced an increase in our U .S . minimum incentive compensation risk assessment hourly base pay in the majority of our markets . for each new incentive compensation Our minimum hourly pay range in the U .S . is arrangement or off-cycle revision $15 to $20, based on the cost of labor in each of an existing arrangement, prior to Wells Fargo market . We also reviewed and implementing the incentive adjusted the hourly pay for those whose pay compensation arrangement . was already at or close to the new minimum • Partner with appropriate enterprise hourly wage . functions to model plan measures for any new or materially revised formulaic incentive compensation arrangements before arrangements are finalized .

• Obtain appropriate stakeholder review and approval of the plan and verify that plan documents are distributed prior to the plan effective date .

60 • Evaluate whether the use of long-term full- and part-time employees (and their eligible incentives within a short-term incentive dependents, as applicable) with a comprehensive compensation arrangement (for example, set of benefits designed to protect their physical as a risk-balancing feature) is in accordance and financial health and to help them make the with policies, procedures, and companywide most of their financial future . U .S . employees guidance . may also take advantage of discounts on financial Please see our most recent Proxy Statement products, home mortgages, and more . and the Executive compensation section of this report for additional details . Health plans (medical, dental, vision) Across our global footprint, we offer Pay equity review comprehensive and competitive health benefits . Wells Fargo is committed to fair and equitable In the U .S ., we offer medical, dental, and vision compensation practices and we regularly review benefits to help employees achieve their health our compensation programs and practices for goals . Our medical plans offer comprehensive pay equity . Each year, we engage a third-party coverage, including preventive care services, consultant to conduct a thorough pay equity emergency care, mental health and substance review of employee compensation, which abuse services, and prescription drug coverage considers gender, race, and ethnicity . The results to help employees and their families improve or of our 2020 review, after accounting for factors maintain their health . such as role, tenure, and geography, show that We have invested $100 million toward making women at Wells Fargo continued to earn more health care more affordable for the majority than 99 cents for every $1 earned by their of our U .S .-based employees . Because of this, male peers . In addition, U .S . employees who are in 2021, about 60% of employees saw lower racially/ethnically diverse continue to earn more or no increases in premiums, and almost every than 99 cents for every $1 earned by Caucasian/ participant saw lower out-of-pocket health white peers . care costs due to plan changes . Our investment included a Health Savings Account (HSA) Employee benefits Performance trends can be contribution of up to $1,000 for employees At Wells Fargo, we value found in the at the lower range of our pay scale . In 2020, and support our people as a Wells Fargo Wells Fargo invested approximately $15,700 per competitive advantage . We ESG Goals and Performance employee in benefits programs . strive to attract, develop, Data (PDF) . engage, and retain the We also provide extensive health plan coverage best employees and we create an environment to our international employees and their that fosters collaboration across businesses dependents, in line with competitive market and functions, to serve our customers . We aim practices . In our international locations, we seek to be the employer of choice — a place where opportunities to help ensure we’re meeting the people feel included, valued, and supported; medical needs of our employees, which often where everyone is respected; and where we involves expanded coverage beyond traditional work as a team . That’s why we provide all eligible local market practices . Recent examples include expanded coverage for psychiatric treatment to support mental health in India, gender-affirming

61 surgery, and medical coverage for partners of the events and activities serving needs across our five same gender . Other examples include coverage dimensions of well-being of emotional, physical, for HIV/AIDS consultation, diagnostics, and financial, personal, and social . treatment in the Philippines . Work-life programs Behavioral health support We offer many benefits, programs, and work In addition to the mental health management arrangements intended to provide employees with benefits included in Wells Fargo’s health plans, flexibility and work-life balance . Examples of these Employee Assistance Consulting (EAC) is a proven options include flexible work arrangements to and trustworthy resource that helps employees help many employees define how and when work and their family members through difficult times . gets done . Employees have the right to request flexible or predictable work arrangements . Such In the U .S ., EAC is available for confidential arrangements may include: consultation and referral support on personal and work-related concerns . EAC also supports • Scheduling of hours worked ‒ This could employees affected by robberies, threats, mean a nontraditional start and end time, domestic violence, disasters, or critical incidents . flextime, or a compressed workweek . In addition, EAC consults with managers on • Number of hours worked ‒ This could behavioral health and risk concerns that may include part-time work and job shares . affect the workplace and provides Wells Fargo businesses with behavioral health products to • Location where work is done – This could maximize the emotional well-being and work include working from home or working at performance of employees . another Wells Fargo location . During COVID-19, we enabled more than 220,000 At our international locations, we offer free and employees to work remotely full-time . We also confidential assistance to employees and members offered specialized programs to assist working of their households . Services are available to parents with children participating in remote provide support, resources, and referrals regarding learning, additional backup care days, and a range of issues including stress management, assistance with finding caregivers for parents/ relationship problems, work-life balance, anxiety guardians impacted with school and daycare and depression, and financial problems . closures . We’re working to develop a new policy to Well-being programs better define and guide future work programs . In the U .S ., Wells Fargo offers an extensive Emergency aid range of well-being programs, including access Our internal We Care Fund grants emergency aid to health coaches, registered dietitians, and to employees facing disasters and other severe digital online behavior change and lifestyle financial hardships . This employee relief program improvement programs . is funded by Wells Fargo and employees who want Across international locations, well-being to help colleagues in need . teams have been established in locations with the largest numbers of employees, supporting our international regions by organizing virtual

62 Commuter benefits Employees and their immediate family members Employees in the U .S . who drive to work and pay also have access to free or discounted courses, for parking, or who take public transportation, webinars, and resources from participating are able to use pretax dollars deducted from their organizations or universities . In the U .S ., we paycheck to help cover monthly commuting costs . administer our Team Members’ Dependent Children Scholarship Program, which awards scholarships In certain international locations, Wells Fargo ranging from $1,000 to $3,000 for full-time provides government-supported cycle-to-work undergraduate or graduate study . benefits . In several countries, we also provide commuting plans and interest-free season ticket Family planning and dependent care loans to support employees using public transit . In the U .S ., Wells Fargo offers several family In addition, free busing is offered to employees in planning and dependent care benefits, including India and the Philippines, providing transportation paid leaves to provide employees with time away to and from work . from work to help care for loved ones, including: Time away from work • Parental leave – For U .S . employees to care At Wells Fargo, we understand that employees for a new child following birth or adoption, have busy lives and diverse needs . Our time away Wells Fargo provides up to 16 weeks of paid benefit provides a variety of competitive options parental leave for a primary caregiver and to accommodate diverse needs, including time up to four weeks for a parent who isn’t the off for vacation, illness, volunteering, the loss of a primary caregiver (available after one full family member, and other significant life events . year of service) . Wells Fargo offers leave for such civic duties as • Critical caregiving leave – One regularly voting, jury duty, and military leave . In the U .S ., scheduled workweek per year of paid critical more than 200 of our employees are on military caregiving leave is available to employees to leave at any given time . Across the globe, care for a spouse, partner, parent, or child Wells Fargo supports military leave and reservist with a certified serious health condition . options for employees . • Lactation support – We offer lactation Education benefits support for nursing mothers by providing Our education benefits help employees and their dedicated rooms in the workplace, access families attain their educational pursuits through to lactation consultants, and a breast milk accredited institutions . In the U .S ., Wells Fargo’s shipping program for nursing mothers tuition reimbursement benefit is available for traveling on business . eligible classes, required books, and certain fees • Adoption reimbursement – We provide up to $5,000 per calendar year for eligible regular up to $5,000 for eligible adoption- employees, and up to $2,500 per calendar year for related expenses through our Adoption part-time employees . The program is also available Reimbursement Program . in some of our international locations, reaching

approximately 80% of our international employees . • Insurance coverage for family planning – Through Wells Fargo’s medical insurance Reimbursement amounts are set at appropriate plans, employees can receive coverage for levels reflecting regional educational costs . fertility services and contraception .

63 • Support for dependent care – We offer Financial protection several options for dependent care support . Wells Fargo provides employees with a variety These include discounts with local child of employer-paid financial protection benefits care facilities, and financial support for aligning with local market practice, including backup child care and adult care . We also life insurance, critical illness insurance, paid offer referral services for child and elder sick leave, short-term and long-term disability, caregiving support . accidental death and dismemberment, and Across international locations, we provide a business travel accident insurance . In many range of leave and benefit programs specifically countries, Wells Fargo also provides additional designed to support employees with their top-up plans and flexible benefits options such as caregiver responsibilities, including access to critical illness and personal accident coverage . competitive maternity, parental, adoption, and paternity leave programs . In many countries, Employment security and responsible Wells Fargo provides child/elder and critical workforce restructuring caregiving leave, as well as the ability to buy We’re committed to managing our talent in additional time off, allowing employees to ways that support employment security and increase their level of time away if they need responsible workforce restructuring . We consider more leave to suit their individual needs and impacts on our people in our strategic planning personal circumstances . Where available and process and in our review of new business feasible, we also provide fully funded access initiatives . As we continue transforming our to emergency backup care programs for child and elder care support as well as child care business, we recognize that our employees may reimbursement programs . be impacted and we aim to provide transparent communication so that employees are aware Retirement income and planning of the programs and opportunities available to Wells Fargo provides a 401(k) plan to help eligible support them . We assess any adjustments we U .S . employees plan and save for retirement . make to our organizational structure based on We match employees’ contributions up to 6% of customer needs and business objectives to help eligible pay annually, after employees complete make sure we are adhering to local legislation and one year of service . In addition, Wells Fargo may regulatory requirements . make a discretionary contribution to eligible In some cases, restructurings result in employee employees’ 401(k) plan accounts . In 2021, we displacements or involuntary separations as added a nondiscretionary base contribution of a result of economic or operational factors . 1% for lower-paid employees to provide them a In the event of a workforce restructuring foundation to build their retirement savings . involving displacements in the U .S ., we support Across international locations, we offer programs our employees and provide tools to assist them to help employees save for retirement by providing with career transitions, including: market competitive contributions to retirement • Wells Fargo’s Displacement policy requires plans as well as access to alternative retirement that all displaced employees in the U .S . are savings plans, where feasible, such as the National provided a 60 day notice period, unless Pension System (NPS) accounts in India . otherwise required by business needs, federal, state, or local laws . Regardless of working or nonworking status, employees are still considered actively employed 64 during the entire notice period . • Employees are eligible for eight to 52 weeks • Implementation of an enterprise of severance pay, based on years of service . workforce planning strategy aimed at providing us with the necessary • We offer displaced employees Career resources to support business mandates . Transition Services (CTS) through an external vendor . CTS is a comprehensive program • Creation of programs that facilitate the that includes personalized career coaching, movement of talent across the enterprise, professional resume development, practice putting employees with complementary on interviewing techniques, and tailored job skills in the areas of greatest need and leads to connect employees with their next exposing them to other areas of the opportunity . company .

• Employees and their household family • Designing a new job architecture members can seek free, voluntary, to establish a defined competency confidential consultation and support for framework . The goal of this approach any concerns and challenges with Employee is to better enable employees to evaluate Assistance Consulting (EAC), a team of potential roles based on common behavioral health professionals . competencies and help them identify opportunities to advance their careers . • Employees also have access to the Live and Work Well website . This additional Safety and health online resource provides guides, articles, videos, and webinars to help employees We recognize the importance of providing through a displacement . a safe and healthy environment for all our employees, visitors, and customers . And we In countries where we operate outside of the design and implement programs across our U .S ., the practices of managing redundancies company to help reduce the frequency and or displacements and workforce restructuring severity of injuries and illnesses . We also make vary significantly based on legal and regulatory special accommodations available to help injured requirements and local market practices . employees return to work when they’re able . International support may include enhanced severance pay arrangements, employee assistance The COVID-19 pandemic has reinforced the programs, and career transition services . importance of safety and health as never before . For more information on how we have supported We also have multiple long-term initiatives our employees, customers, and communities underway that are intended to support employment security and responsible workforce during this unprecedented time, please see the restructuring, including: Continued response to the COVID-19 pandemic section of this report . • Development of the Human Capital Risk Program to help position us to effectively Governance and oversight hire, retain, manage, and appropriately We work to maintain a workplace environment compensate the talent we need to achieve that promotes and protects the safety and our business objectives in accordance with health of everyone who comes through our applicable laws and regulations . doors . The Wells Fargo Injury & Illness Prevention

65 Program (IIPP) outlines these responsibilities Employee safety and health training and the steps we take to promote safety and Newly hired employees are expected to complete health awareness . online safety and health training and certain Risk and Insurance Management is responsible for employee groups have quarterly refresher training establishing, implementing, and maintaining the requirements . Additionally, we expect managers IIPP . The IIPP describes employee responsibilities to provide training on job-specific hazards at the and safety and health practices that are designed time of an employee’s initial assignment and to to promote safety awareness, including: provide retraining whenever: • New substances, processes, procedures, Responsibility or equipment are introduced into the Communication workplace that represent a new hazard .

Hazard assessment • The manager is made aware of a new Accident/exposure investigations or previously unrecognized safety or health hazard . Hazard correction • An employee is given a new job assignment Training and instruction and hasn’t received training for that Record keeping assignment . Given the nature of our business, ergonomic Wells Fargo facilities are required to comply injuries and those resulting from slips, trips, with applicable, legally mandated standards for and falls are the most common workplace workplace safety and health in the countries and injuries . Training and awareness resources communities in which they operate . Employees on these and other topics are available on our are responsible for following safe work practices intranet . At some locations where cumulative and for reporting any unsafe working conditions . trauma injuries could have higher frequency rates, Risk and Insurance Management, in partnership our Site Ergonomic Coordinator Program provides with Wells Fargo’s Corporate Properties Group, access to on-site Wells Fargo employees trained in Legal, Enterprise Incident Management, Human hazard identification and basic office ergonomics . Resources, and lines of business, supports Site Ergonomic Coordinators are certified to adherence with the Occupational Safety and conduct internal ergonomic evaluations, providing Health Act (OSHA) and other regulatory valuable hands-on mitigation for the risk of injury requirements around workplace safety and health . to our employees . Additionally, they provide on- site hazard identification, which is designed to allow prompt remediation of identified workplace hazards, reducing the overall exposure to injury .

66 Separately, our Driver Safety Program provides Emergency preparedness and response periodic training to employees who drive Our Enterprise Incident Management regularly as a part of their work responsibilities . (EIM) team’s mission is to keep our employees, Among other things, this training supports and customers, and visitors safe . EIM has established emphasizes the importance of Wells Fargo’s companywide coordination, support, and distracted driving guidance which requires communication procedures for high-severity employees to minimize distracted driving incidents . Being ready for any emergency requires and to use good judgment in making sure the commitment of every employee . That’s that behavior supports our company, why we require employees to take Emergency policies, and expected conduct . Response and Violence Free Workplace training We celebrate safe work practices through on an annual basis . Wells Fargo locations are our companywide Shared Success® program, required to have procedures in place to deal which gives every employee the opportunity with a fire or other emergency that requires to recognize and celebrate accomplishments, evacuating or sheltering . We require the including safety leadership and employee well- Emergency and Security Procedures to be being . We also recognize safety leadership accessible to all employees as they include through our annual performance review information regarding: process . Unsafe work practices are expected What to do in an emergency to be promptly addressed and may be subject to corrective action, up to and including How to report an emergency termination . Where to go for shelter

How to evacuate

67 Dealing fairly and ethically with our suppliers

Wells Fargo engages numerous suppliers Third-Party Center of Excellence — companies that have direct contractual Wells Fargo Supply Chain Management relationships with our company — to provide and Third-Party Center of Excellence (TPCoE) various goods and services necessary to works with suppliers and business leaders across running our business . These relationships the enterprise to help deliver supply solutions don’t just enhance the value of the products with acceptable third-party risk consistent and services we offer our customers, they with Wells Fargo’s Enterprise Third-Party Risk create long-lasting collaborative relationships Management Policy and Third-Party Program within our communities . On some level, our Procedures . suppliers and their actions are an extension of our own actions and reputation . That’s The TPCoE is responsible for strategic sourcing, why we expect them to demonstrate strong negotiating commercial terms, procure-to-pay values and ethical practices . capabilities, supplier risk documentation and management, and timely supply chain analytics . Supplier Code of Conduct We also connect with our communities through Wells Fargo’s Supplier Code of Conduct supplier diversity outreach and by embedding (PDF) outlines our expectation that socially responsible strategies into our processes . suppliers not only comply with applicable Supplier diversity laws, regulations, and contract terms, but Performance trends can be also aspire to the highest standards of ethical We understand that our found in the business practices, environmental stewardship, success stems from diverse Wells Fargo ESG Goals and and community investment . It’s each supplier’s perspectives, and we Performance responsibility to make sure that its employees value diversity, equity, and Data (PDF) . and representatives maintain a thorough inclusion in our business . understanding of our expectations as Supplier diversity adds value to the organization set forth in the Supplier Code of Conduct . by ensuring that our supplier base mirrors the The Supplier Code of Conduct is subject to customers and communities we serve . To that same regular review and periodic revisions end, our Supply Chain Management group works as we continuously work to enhance our closely with all our lines of business, as well as internal business practices . and external stakeholders, to help grow relationships with certified minority, women, LGBTQ, veteran, disability-owned, and small businesses .

68 The following strategic approaches help Supplier development us develop strong relationships with our We invest in building capacity and expertise suppliers to achieve our supplier diversity for high-potential diverse suppliers . It’s an goals, while also striving to enhance the important effort aimed at strengthening value of the products and services we offer Wells Fargo’s supplier base and increasing our customers . the economic impact that our suppliers have on their communities . As part of this effort, Diverse spend growth we strive to work with organizations that align Wells Fargo supports strategic opportunities with our vision and provide diverse businesses that include diverse suppliers in competitive access to a broad range of tools and resources sourcing and procurement opportunities . that aim to help them: A key to successful supplier diversity outcomes is early engagement, which starts with our • Enhance their business and strategic plans . data-gathering process . We look at benchmark • Increase their ability to define and data, peer information, and diverse supplier communicate their strategic direction identification, which helps enable us to flag any and value . roadblocks that may limit diverse participation . The supplier diversity team provides input and • Retool their competitive position . reviews sourcing documents, to make sure • Strengthen their communications that they include language on our diversity effectiveness and executive presence . commitment, spend, and reporting that meets our supplier diversity goals and objectives . • Establish trusted relationships .

Further, at the beginning of each calendar year, • Model how to do business with targeted the supplier diversity team reviews Wells Fargo’s prospective clients . overall performance, including line of business • Improve innovation and scale . performance, supply chain category results,

and larger sourcing projects and initiatives . Outreach These data elements come together to shape We work with internal and external stakeholders our supplier diversity goals, both at the enterprise to deliver critical information to the diverse and line of business level, and these goals in turn supplier community . This outreach spans regional are actively supported by all levels of management and national organizations that share our and communicated to all employees and commitment to supplier development and that stakeholders . provide programs and services to strengthen Spend tracking and monitoring is also an diverse businesses within our communities . important tool in our diverse supplier efforts . We seek out and collaborate with partners who We track and report on our performance on a align with us on diverse supplier identification, quarterly basis and these reports include detailed certification, development, and engagement . information about our procurement spending .

69 Integrating ESG into Performance supplier selection trends can be found in the Wells Fargo’s 2020 CDP Supplier and engagement Wells Fargo ESG Goals and Engagement Ranking (SER) is A-. Considering ESG both during Performance The SER assesses performance supplier selection as well as Data (PDF) . on governance, targets, Scope 3 throughout the course of our emissions, and value chain engagement ongoing relationship is an important element in the CDP climate change questionnaire. of how we aim to optimize environmental Of the more than 5,000 companies that participated, Wells Fargo ranked in the and social principles across our value chain . top 15%. Wells Fargo seeks to build suppliers’ ESG We’re in the final stages of completing awareness and encourage them to support customized education support for our sustainable sourcing initiatives, enhance respect suppliers who received a score of B- for human rights, and embrace environmental or less from CDP. In 2020, we augmented sustainability . We also provide educational the training to address COVID-19’s impact opportunities to address environmental and the importance of business continuity challenges . planning for small and diverse-certified companies. Notably, ESG considerations are integrated into We’ve invited many of our key suppliers our sourcing process . We have implemented to participate in the CDP Climate Change a variety of sustainable sourcing initiatives survey; it’s one more way we back our in key areas/categories, including data centers, commitment to integrating environmental managed printing, office supplies, promotional sustainability throughout our supply chain. items, and additional areas within our facilities In addition to our involvement with CDP, Wells Fargo is a member of the Sustainable and operational scope . Purchasing Leadership Council.* We continuously engage with our suppliers This nonprofit organization offers on ESG topics . We’ve instituted guidance to support best practices in ESG and offers us the benefit of a collaborative supplier sustainability program working with a collaborative community that is designed to build awareness, create of companies, large and small, that are transparency, and drive best practices in our focused on the same ESG opportunities supply chain and operations . As part of this and challenges. program, we anticipate launching a sustainability learning series for relevant Wells Fargo suppliers .

We’re focused on fostering an inclusive, reach diverse neighborhoods in ways that advance sustainable future and strengthening the small business growth, housing affordability, resiliency of our communities and our planet financial health, and sustainability . for the long term . Working hand in hand with

nonprofits and other community stakeholders, Philanthropy Performance we’re combining our resources and expertise to Through our business and trends can be empower change in underserved communities found in the the Wells Fargo Foundation, Wells Fargo with a focus on creating greater racial equity we provide financial ESG Goals and and curbing climate change . donations, volunteers, Performance Data (PDF) . Community engagement is essential to and business expertise our overall approach to social impact and to a wide range of nonprofits and charitable sustainability, which includes four strategic organizations to actively support and positively priorities: impact communities and help address racial disparities, particularly around housing, small • Opening pathways to economic business, financial health, sustainability, and advancement . environmental justice . We prioritize funding • Championing safe, affordable homes . to philanthropic activities and programs that align with our four strategic priorities • Empowering small businesses to thrive . and organizations that can work with us on • Accelerating a just, low-carbon future . a broad level to tackle social, economic, and environmental challenges and drive innovation We believe in the importance of thriving at scale . To foster a truly inclusive economy, communities that offer people access to we’re also intentional about prioritizing the economic opportunity . Wells Fargo continues to needs of underserved communities and those accelerate positive change in local communities disproportionately impacted by systematic by collaborating with nonprofits, state and racial and economic inequities . city leaders, government agencies, and other public and private groups to help develop new Housing affordability opportunities for underserved communities . There is a global shortage of affordable housing This kind of multi-stakeholder collaboration for low- and moderate-income communities, and is a hallmark of our community engagement high housing costs have only amplified growing approach . It’s helped us build relationships that economic inequity . Our goal is to support solutions that allow people to have a safe and affordable place to call home, which is the foundation for wellness, dignity, and economic

71 opportunity . Our strategies are focused and help advance neighborhood stability by on keeping people in their homes, opening delivering down payment assistance to low- pathways to homeownership, increasing and moderate-income people to complete initiatives that drive supply of affordable homes, HUD-approved homebuyer education . and advancing innovation and transformation on the ground in local communities . These efforts Financial health help to advance racial equity to create a future An inclusive economy is one in which everyone where everyone should have a quality place to has a pathway to economic opportunity, live . In 2020, we helped keep more than 200,000 including the financial knowledge, skills, and people housed in the U .S . through efforts focused resources necessary to support themselves on advancing housing affordability solutions and their families . Wells Fargo aims to improve and relief . Since 2019, nearly $274 million has the financial stability of low- and moderate- been allocated toward our $1 billion housing income communities through programs that affordability commitment through 2025 . increase financial inclusion and access, reduce • In 2020, Wells Fargo and Enterprise debt, drive savings and wealth-building behavior, Community Partners launched and transform systems that provide a better a $20 million Housing Affordability context within which people lead their financial Breakthrough Challenge to uncover lives . Examples include: the most innovative, scalable, and viable • Reaching unbanked communities and ideas for increasing housing affordability . removing barriers to financial inclusion for The competition awarded six grants Black and African American, Hispanic, and across the U .S . of more than $2 million Native American/Alaska Native families each, in addition to providing two years through our Banking Inclusion Initiative . of technical assistance to help turn the grantees’ scalable concepts into reality . • Expanding access to cost-free, virtual financial coaching and counseling, direct • In collaboration with Habitat for cash assistance, and other financial Humanity and Rebuilding Together, resources to help people save money, we funded more than 400 home build reduce debt, and navigate other projects across the U .S . in 2020, enabling complex financial challenges through low- and moderate-income families to our collaboration with nonprofits such become first-time homeowners, making as Operation Hope, the National Disability repairs so seniors and veterans can Institute, and the National Foundation for safely stay in their homes, revitalizing Credit Counseling . neighborhoods, and championing advocacy work that helps people meet • Helping city and county governments basic shelter needs . improve banking access for residents through efforts with the nonprofit Cities • Through our NeighborhoodLIFT program, for Financial Empowerment Fund (CFE) . we collaborate with NeighborWorks® We also supported the launch of CFE America and local charitable organizations Fund’s new Financial Navigator initiative to to support sustainable homeownership help residents navigate the financial impacts of COVID-19 .

72 • Teaching people in all stages of life We voluntarily committed to donate about the basics of responsible money all of the gross processing fees received management, including how to create from PPP loans funded in 2020 . Through a budget, save and invest, borrow June 30, 2021, we donated approximately responsibly, buy a home, and establish $234 million of these processing fees a small business with Hands on Banking®, to nonprofit organizations that support or “El futuro en tus manos® .” small businesses .

Small business growth • Through Wells Fargo’s Diverse Community Capital program, a five-year, $175 million Small businesses are an important driving collaboration with Opportunity Finance force in job creation and thriving communities . Network, we have provided debt and We continue to intensify our efforts to provide philanthropic capital to support more than entrepreneurs with technical assistance and 90 CDFIs that provide access to capital and increased access to affordable sources of technical assistance to diverse small-business capital and training so they can grow, build owners in rural and urban communities . assets, and create local jobs . Examples of our commitment to support the small business Sustainability and environmental justice community include: Climate change is one of the most urgent • In July 2020, Wells Fargo established environmental and social issues of our time the Open for Business Fund . The Fund and we believe that collective action is needed provides grants for Community to accelerate a just transition to a low-carbon Development Financial Institutions economy and minimize the impact on vulnerable (CDFIs) and other nonprofit organizations communities . that serve diverse small businesses, • The Wells Fargo Innovation Incubator (IN2) including Black, African American, aims to accelerate the path to market for Hispanic, Asian American, Native promising clean technology, sustainable American, and other entrepreneurs . agriculture, and residential housing Through our Open for Business Fund, startups funded by the Wells Fargo we’re providing capital, technical support, Foundation and co-administered by the and long-term resiliency programs to U .S . Department of Energy’s National nonprofits that serve small businesses . Renewable Energy Laboratory (NREL) The first $250 million will go to nonprofit and the Donald Danforth Plant Science lenders or CDFIs who focus on minority- Center . Since 2014, IN2 has supported owned businesses that have been 46 companies that have each received disproportionately affected by the $250,000 in non-dilutive funding which pandemic . We deferred approximately led to an additional $568 million in funding $420 million of SBA processing fees in from external sources . 2020 that will be recognized as interest income over the terms of the loans . • We supported solar energy projects in tribal communities through the GRID Alternatives Tribal Solar Accelerator Fund, launched with seed funding from Wells Fargo .

73 Global philanthropy These include: Our global philanthropy strategy focuses on • In 2020, we held our first Month of Action, disaster response, local giving, and strategic during which we charted a new course in grants made to support housing affordability, employee engagement to inspire acts of small business growth, financial health, and kindness and virtual volunteerism globally sustainability . In 2020, funds supported and to kick off year-round giving . This organizations that are specifically focused new approach helped care for communities, on relief and recovery from the COVID-19 neighbors, and colleagues through pandemic . These funds were used for thousands of personal actions — which emergency food as well as hygiene, hospital, proved especially meaningful during the and medical supplies, among other needs . global pandemic .

• Through the Wells Fargo Foundation, Employee service Performance Community Care Grants help extend and impact trends can be found in the the impact of our employees’ donations . Part of what Wells Fargo Through personal giving or service activities, makes Wells Fargo’s ESG Goals and Performance employees may qualify for up to $2,000 in philanthropy program Data (PDF) . Community Care Grant funds that they can so robust is the generosity direct to approximately 1 million eligible of employees who multiply our community charities . impact, locally and collectively . Every year, eligible employees receive 16 hours of • Nearly 5,500 charities benefited from paid volunteer time to give back to local Wells Fargo employees sharing their communities where they live and work . leadership skills by serving as board In addition, employees are encouraged members of charitable organizations, to use their talents to get involved in making a meaningful impact in the causes they care about and volunteer . external communities where we live and work .

74 Understanding environmental and social impacts

The scale of our business enables us to have BSA/AML program significant impact through the products and Wells Fargo’s written BSA/AML compliance services we offer our customers . With that program is approved by the Wells Fargo’s Board comes the responsibility to acknowledge that of Directors (Board) and provides for the minimum business decisions made by Wells Fargo or our requirements, known as the ‘Four Pillars’ of a BSA/ customers may have adverse impacts on people AML compliance program,1 as follows: and the environment . To mitigate these impacts, we need to understand the inherent risk in our 1. Corporate BSA Officer: As appointed and financing decisions, and we must work hard directed by the Board, the Corporate BSA to detect, investigate, and report suspicious Officer is responsible for administering activity related to financial crimes and external and managing all aspects of the BSA/AML fraud . Our Global Financial Crimes Risk compliance program and for coordinating Management Program and Environmental and monitoring Wells Fargo’s overall adherence and Social Risk Management (ESRM) to the BSA and its implementing regulations . Framework help us navigate the evolving 2. System of Internal Controls: As mandated risk landscape associated with the potential by Wells Fargo’s size, structure, complexity, impacts of our clients . and risks, the BSA/AML Program maintains a strong system of internal controls, Global financial crimes risk management which includes a suite of preventive and detective controls designed to promote Wells Fargo maintains a financial crimes program a strong compliance culture and manage risk that is designed to assure compliance with transparently . Our financial crimes program applicable Bank Secrecy Act (BSA)/anti-money includes maintaining corporate BSA/AML, laundering (AML), counter-terrorist financing, Global Sanctions, and ABC policies; risk based global sanctions, and anti-bribery and corruption customer due diligence, or know your customer, (ABC) related laws, regulations, and regulatory processes inclusive of higher risk categories expectations, and to provide timely, actionable such as cash intensive businesses and politically intelligence to appropriate authorities that exposed persons; and monitoring, investigating, may be indicative of financial crimes in order and reporting of suspicious activity . to safeguard the company, its employees, our customers, our communities, other stakeholders, and the global financial system .

1 . While different regulators consider CDD a fifth pillar, the Wells Fargo BSA/AML and Global Sanctions Compliance Program includes it in the internal controls pillar to be consistent with the Office of the Comptroller of the Currency view of the four pillars . 75 3. Training: Wells Fargo provides Environmental Performance a comprehensive BSA/AML and trends can be and social risk found in the Global Sanctions training program, management Wells Fargo ESG Goals and to help make certain all employees receive As a provider of financial Performance adequate and appropriate training services for customers in Data (PDF) . to maintain compliance with BSA/AML, nearly every sector of the Global Sanctions, and ABC regulations economy and around the world, we must and expectations . consider the environmental and social impacts 4. Independent Testing: Internal Audit provides of our lending and investments, in addition independent testing of the BSA/AML to traditional financial risk . Our ESRM Framework compliance program . (PDF) and policies include due diligence requirements that help us identify, evaluate, and Global sanctions manage the environmental and social risks associated with our lending Under the direction of the Corporate BSA and investments . As our understanding of Officer, the Financial Crimes Risk Management these complex issues evolves, we aim to Global Sanctions Office provides oversight of update our ESRM requirements and strive the companywide Global Sanctions Compliance to adhere to global best practices for Program . The Global Sanctions Office leads the managing environmental and social risk . implementation of, content updates to, and compliance with the Global Sanctions Policy, Our stakeholder engagement helps us to better which is applicable companywide and outlines understand changing environmental and social Wells Fargo’s requirements for complying with expectations that can create risk in our business, economic sanctions laws in jurisdictions where and we apply what we learn to our policies and Wells Fargo operates . practices .

Anti-bribery and corruption Wells Fargo has zero tolerance for bribery and corruption in any form . The Financial Crimes Risk Management Anti-bribery and Corruption Governance team is responsible for companywide leadership, support, and independent oversight of Wells Fargo’s ABC Compliance Program . This includes developing and maintaining the ABC Policy, which is applicable ONLINE RESOURCES companywide and outlines Wells Fargo’s requirements for complying with applicable The ESRM webpage bribery and corruption laws and regulations . The ESRM Framework (PDF) ESG viewpoints

76 Sensitive industries Additional prohibitions related to clients, products, or business activities may exist at the We look at a full spectrum of risks and line of business level . Under these policies, any various other factors when we consider business or business activity that is illegal under financing any sector, company, or project- applicable law for the jurisdiction, including specific transaction . These factors include state or federal law, is prohibited, and we will credit risk, market conditions, reputation not knowingly finance or take deposits from risk, social and environmental considerations, individuals or businesses engaged in, or deriving and the potential volatility of policy and income from, illegal activities . Wells Fargo regulatory positions . Our ESRM policies are currently doesn’t directly or indirectly provide critical to our internal due diligence in such new financing, or is in the process of exiting, sensitive industries as oil and gas, coal and existing relationships or reducing our exposure metal mining, arms and armaments, consumer as contracts expire for the following activities or finance, and Equator Principles transactions . customers involved with them: Wells Fargo continues to evaluate its approach to environmental and social risk management • Coal industry, including companies deriving in an effort to expand our scope of due diligence profits from mountaintop removal coal and continuously assess emerging risks . operations, or any project associated with the expansion of an existing, or development Related to Human Rights, Wells Fargo of a new, coal mine or new coal-fired power continued its improvement efforts to address plant . modern slavery and published an updated Modern Slavery Statement (PDF) . In late 2020, • Equator Principles in-scope transactions Wells Fargo initiated a corporate-level Human in the Alaskan Arctic region . Rights Impact Assessment (HRIA) to determine • Modern slavery, servitude, forced or the current salient human rights risks across our compulsory labor (including child labor), value chain . The HRIA is being conducted by an and human trafficking . independent, external law firm, with expertise in the field of business and human rights . This • Private prison companies and immigrant assessment will help Wells Fargo improve its detention centers . governance related to managing human rights Additional due diligence issues companywide, and will enhance our dialogue with stakeholders . We are planning Through stakeholder engagement and industry to complete the HRIA in 2021 . expertise, we identify transaction types, customer activities, and crosscutting issues that carry Companywide policy restrictions a heightened risk of significant environmental and prohibitions and/or social impacts . If we believe such risks Wells Fargo has internal policies that prohibit and impacts are material to the long-term success lines of business from knowingly accepting of companies or could have material adverse or opening new accounts or relationships environmental or social impacts, we perform (or renewing existing accounts or relationships) client-, industry-, issue-, or transaction-specific with certain types of clients or industries . risk due diligence to evaluate a customer’s commitment, capacity, and track record as they relate to ESRM .

77 We use a proprietary ESRM due diligence Our ESRM Framework, policies, and statements methodology to quantitatively analyze require our customer relationship and investment environmental, social, and reputation risk . teams to engage the ESRM team for additional It includes triggers for additional due diligence, due diligence when a transaction is subject which may require follow-up questions or an to the Equator Principles . These requirements in-depth conversation with the customer . actually go beyond those of the Equator Principles . For companies that operate in the oil and gas, They include, for example, our expectation coal and metal mining, arms and armaments, for our customers to align with the objectives and consumer finance industries, and for and requirements of Free, Prior, and Informed Equator Principle in-scope transactions, Consent (PDF),* where it’s triggered in accordance we’ll apply up to three additional phases with International Finance Corporation (IFC) of due diligence to understand the environmental Performance Standard 7* and captured in and social risk and potential mitigation measures . Wells Fargo Indigenous Peoples Statement (PDF) . Each transaction receives an environmental and In 2018, our comprehensive risk management social risk rating — low, moderate, high, or critical . practices influenced our decision not to finance We add all transactions or clients with high Equator Principles in-scope transactions in the or critical risk rating to a corporate watch list . Alaskan Arctic region . We escalate any transaction internally rated as Stakeholder engagement and partnerships high or critical for senior leadership approval . Education and awareness-building are critically Equator Principles important to environmentally and socially Our primary ESRM commitment related responsible banking . As part of the ESRM to asset-specific financing aligns with the due diligence process, we consult with our Equator Principles* international risk customers to help them understand our management framework . The updated version requirements and commitment to responsible of the Equator Principles, EP4,* was released lending, as well as current risk management in November 2019 and implementation started best practices in their industries . Internally, on October 1, 2020 . This updated version includes we provide training for our banking teams and new amendments and commitments regarding other interested parties on ESRM policy, due human rights, climate change, Indigenous diligence and best practices, climate change, Peoples, and biodiversity . The scope of the and human rights topics . We also engage with framework has also been expanded to capture a wide variety of external stakeholders, including more project-related transactions . As a signatory NGOs, shareholders, advocacy groups, and to the Equator Principles, we’ll provide loans government officials, to share Wells Fargo’s and advisory services only to projects whose perspectives and our progress in managing borrowers can demonstrate their ability and environmental and social risk in sensitive willingness to comply, at a minimum, with industries . Examples include: the Equator Principles’ requirements for categorizing, assessing, and managing environmental and social risks .

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 78 • Serving as a Steering Committee member • Updating and developing human of the Equator Principles Association,* rights positions . where Wells Fargo supported the drafting • Exercising due diligence to enhance of the revised Principles framework (EP4) . our understanding of potential adverse We also played a lead role in drafting the impacts on the human rights of employees, corresponding guidance notes related non-employees, and our customers . to human rights and Indigenous Peoples . • Strengthening oversight of human rights • Providing financial support for the multi- issues in our supply chain . year development of global ESG standards in partnership with the IFC’s collaborative • Collaborating with external, cross-sectoral, global program to widely expand knowledge and industry-specific leadership groups . of ESG sustainability . Governance

Respecting human rights Wells Fargo’s human rights commitment is We recognize the role corporations play in society, explicitly approved at the senior-most level of and we understand Wells Fargo’s responsibility our company, as documented in the Wells Fargo to respect human rights in our operations and & Company Board of Directors Corporate through our business relationships . Many of the Responsibility Committee (CRC) charter (PDF) . actions we’ve taken to rebuild trust, strengthen Day-to-day management of human rights is led our culture, and reduce operational and conduct by our Environmental, Social, and Governance risk are critical components of a robust human Integration team . External stakeholders also rights risk management approach . help inform our understanding of business and human rights issues . Our external Stakeholder We publicly acknowledge our responsibility Advisory Council includes organizations that to respect and uphold human rights in our focus specifically on these issues . Human Rights Statement (PDF), which guides our efforts with key stakeholders, including Human rights due diligence employees, consumers, business customers, The Wells Fargo Environmental and Social Risk and suppliers . We recognize that this is an Management (ESRM) process includes ongoing effort, and we know we must regularly performance of human rights due diligence assess our practices and approaches in light and analysis of third-party environmental, of our changing world . social, and governance research across identified Deepening our understanding and management sensitive industries, as set forth in our ESRM of human rights issues relevant to our business, Framework (PDF) . When our research uncovers operations, and culture is an ongoing journey . allegations — or they are otherwise brought to In the spirit of continuous improvement, we’re our attention — we engage with our customers working throughout our value chain to improve to help understand their risk management our management of any actual or potential adverse approach and actively monitor developments impacts on human rights . To that end, we continue over time . When there are different viewpoints to work on: on an allegation, we document these views and

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 79 their sources and assess the situation . In cases document to better communicate our where we become uncomfortable with a commitment to Indigenous Peoples in general relationship — for financial, ethical, or other and, more specifically, to guide our decision- reasons — we seek opportunities to exit that making on projects in which Wells Fargo relationship . financing may potentially impact Native American, Alaska Native, or other Indigenous Human Rights Impact Assessment (HRIA) communities . The statement also outlines our In late 2020, Wells Fargo initiated a corporate approach to responsible finance . Specifically: Human Rights Impact Assessment to determine • We recognize that governments play the the current salient human rights risks across central role in the approval of policies or our value chain, including those related to racial projects that impact Indigenous Peoples, equity . This assessment will allow us to improve and we encourage our customers governance related to managing human rights to collaborate in meaningful ways issues companywide, update our Human Rights to manage the impacts and risks Statement to better align with the expectations of their activities on these communities . of companies under the United Nations Guiding Principles on Business and Human Rights, and • We conduct due diligence in sensitive enhance and inform our dialogue around human industries covered by the ESRM Framework rights with our various stakeholders . so that our customers have an opportunity to engage meaningfully and effectively Additional due diligence for vulnerable with critical stakeholders and commit to communities protecting community health, safety, and Beyond our Human Rights Statement, security; the environment; cultural identity; we recognize that several vulnerable groups and the sacred lands and heritage of have been historically disadvantaged . We dedicate affected Indigenous Peoples . extra attention to understanding and addressing We’ve supplemented this due diligence with their unique concerns and perspectives, as detailed a heightened focus on potentially impacted in the two examples below . Indigenous communities . We place special focus on whether they’ve had the opportunity Indigenous Peoples for informed consultation and participation . As a result of issues that arose during construction For certain transactions, we require escalated of the Dakota Access Pipeline — and following approval from senior leaders . specific assessment findings — we enhanced our ESRM due diligence to include more focused • If we don’t determine that a company can research into whether Indigenous communities effectively manage elevated environmental are affected and properly consulted . We’ve also and social risks in its operations, we will implemented an Indigenous Peoples Statement decline participation in the transaction . (PDF), which we developed in consultation • For projects where we can identify that the with tribal leaders, Indigenous stakeholders, use of proceeds may potentially impact and their representatives . We created this Indigenous Peoples — specifically for project

80 finance, project finance advisory services, We also seek to educate the banking project-related corporate loans, project- industry about the importance of engaging related refinance, and project-related tribal communities and going beyond legal acquisition finance opportunities — compliance . In January 2020, Wells Fargo we expect our customers to demonstrate convened a meeting of banks engaged in alignment with the objectives and project finance, and we brought in experts requirements of International Finance to help our peers at these banks to better Corporation Performance Standard 7 understand the issues and responsibilities on Indigenous Peoples, with particular associated with engaging U .S . tribal emphasis on circumstances requiring communities . Free, Prior, and Informed Consent . Modern slavery Wells Fargo respects Indigenous Peoples’ rights According to estimates by the antislavery to determine their own way of life on their own nonprofit Walk Free Foundation* and the lands, according to their time-honored cultures, International Labour Organization,* more traditions, and beliefs . We recognize their rights than 40 million people are trapped in to meaningful and appropriate consultation modern slavery worldwide . The trafficking regarding issues that affect their sacred lands and exploitation of women, children, and and natural resources — whether traditionally men is a highly lucrative global business that owned or otherwise occupied and used — today generates illegal profits of $150 billion a year . and for future generations . We believe the way We recognize Wells Fargo’s role in preventing these important policies came about illustrates modern slavery, including human trafficking, our commitment to listen to stakeholders who both in our operations and in our supply chain . may be impacted by our lending and investing . We have an internal companywide Modern And it demonstrates our commitment to Slavery Working Group that formalizes and adhere to recognized global best practices in reinforces our efforts in this area . Functional environmental and social risk management . business units whose work may be affected To help make sure that we keep abreast of by modern slavery risks participate in the these issues, we continue to engage stakeholders Modern Slavery Working Group . Such efforts who can help guide our approach . In 2018, and related activity are outlined in our Modern we carried out a tribal listening tour to enable Slavery Act statements . The Modern Slavery representatives from the ESRM team and those Working Group’s mandate is to: who provide banking services to tribal clients 1 . Look for ways to continuously to hear concerns from tribal members firsthand . improve our practices for assessing This was invaluable in informing and improving and addressing this risk . implementation of the commitments outlined in our Indigenous Peoples Statement (PDF) . 2 . Better coordinate companywide We remain engaged with these communities efforts to meet disclosure as issues arise . requirements under the UK Modern Slavery Act .

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 81 In 2020, we developed a steering committee Human rights training Performance can be for the Modern Slavery working group to drive trends Human rights training is found in the more robust governance around this topic . Wells Fargo an important part of our ESG Goals and Grievance mechanism overall ESRM training . Performance Each year, employees Data (PDF) . We know that even as we work to respect complete the first two human rights, adverse impacts sometimes modules of our diversity and inclusion occur . That’s why our internal reporting learning curriculum, which address aspects mechanisms are designed to allow for concerns of human rights as they relate to discrimination . to be raised and addressed . These include our We also provide a number of trainings on EthicsLine, a service that enables anonymous Modern Slavery . reporting of concerns and violations, including those related to human rights . Employees at any Collaborating with others and setting location in the world can reach the EthicsLine by human rights standards phone or online — 24 hours a day, seven days Many human rights challenges are systemic and a week . We encourage and expect our employees can’t be solved by any single actor . Therefore, to speak up and raise concerns via the confidential we have to work together in collaboration with EthicsLine, to their managers, or to our human others, both to learn from them and share what resources team . We also expect non-employees we do . For example, we participated in Business to speak up, raise concerns, and report any for Social Responsibility’s (BSR) Human Rights suspicions or evidence of human rights abuses, Working Group* — a cross-sector, collaborative via their employer, Wells Fargo supply chain initiative that helps more than 40 global management, Global Non-employee Program companies implement the United Nations Office, or the EthicsLine . In addition, we have Guiding Principles on Business and Human in place a Security Response Center — Rights (UNGPs) . We were previously part of a companywide service that employees the Thun Group of Banks . This informal group and non-employees around the world can of bank representatives works to understand contact on a 24/7 basis to report a range how the UNGPs can be practically implemented of security incidents . within the financial sector . Currently, we are part of the Financial Institutions Practitioners Cycle led by SHIFT, a group of human rights subject matter experts who discuss various human rights issues . We also participate on the Social Risk Working Group of the Equator Principles Association,* which facilitates dialogue on human rights and other

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 82 sustainability issues in the financial sector . In this capacity we co-led the development of the Human Rights Impact Assessment guidance document, and provided robust input into the Indigenous Peoples guidance document . Additionally, we are a Steering Committee member of the Equator Principles Association . In 2020, we helped finalize the most recent update of the EP4, which for the first time incorporates the UNGPs .

Promoting human rights

We work hard to respect, advance, and promote human rights . One of the most important ways we do that is by deploying financial and human capital to support economic development and improve quality of life in the communities where we operate . We have robust philanthropic and employee volunteerism programs around the world .

In addition, we participate in the United Nations (UN) Survivor Inclusion Initiative* (SII), which provides basic financial services — including checking and savings accounts and/or debit cards — to survivors of modern slavery and human trafficking . Members of our Global Financial Crimes Intelligence Group are our points of contact for the UN SII . They work with the UN and other financial institutions to learn best practices for offering these financial services . Further, they collaborate with survivors and NGOs that provide services to survivors, to help facilitate a smooth account opening process .

We’re embedding environmental sustainability throughout our products, services, operations, and culture in an effort to drive efficiencies and responsible resource use while creating comfortable, safe, and healthy workplaces for our stakeholders . We’re focused on our goal of reducing our energy consumption and greenhouse gas emissions, increasing our operational efficiency, and advancing clean technology and innovative solutions . We believe that climate change continues to be one of the most urgent environmental and social issues of our time, and we are working across our value chain to help accelerate the transition to a low-carbon economy and reduce the impacts of climate change on our business, communities, employees, and customers .

84 Climate commitment

Climate change is one of the most urgent threats Set and disclose targets for additional sectors we all face . We believe collective action is needed within a reasonable time after disclosing financed to transition to a low-carbon economy and emissions for those sectors. minimize the impact on our most vulnerable communities . That’s why we have committed to 4. Establishing an Institute for deploying $500 billion in sustainable financing by Sustainable Finance 2030 and have set a goal of net zero greenhouse Establish an institute that will work across the gas emissions — including financed emissions — enterprise to support clients in their climate by 2050 . In order to do this, we’ve outlined five transitions. areas of focus: Deploy an additional $500 billion in sustainable 1. Setting a goal to achieve net zero greenhouse finance by 2030, building on the approximately gas emissions by 2050 $157 billion provided since 2012.¹ Net zero goal includes Scope 1, Scope 2, and Support clients’ efforts to quantify their relevant Scope 3 emissions, including Scope emissions. 3 category 15 emissions from investments or financed emissions. Support science-based research to aid clients in their low-carbon transitions. Wells Fargo achieved carbon neutrality in our operations (Scope 1 and Scope 2) in 2019 Advocate for policy initiatives that support and again in 2020. clients’ low-carbon transitions as well as those that advance the U.S. meeting the goals of the 2. Committing to disclose Wells Fargo’s financed Paris Agreement. emissions measurement approach and provide more robust emissions data Work to support communities as they prepare for and adapt to increasing weather-related impacts Disclose our approach to measuring Scope 3 with a focus on low- and moderate-income and financed emissions by March 2022. other vulnerable communities that are being Enhance transparency and disclose financed disproportionally impacted by climate change. emissions for select carbon-intensive portfolios — 5. Further integrating climate considerations including the oil and gas sectors, and power into Risk Management Framework sector — no later than the end of 2022. Further integrate climate considerations into Expand disclosures to eventually include all our Risk Management Framework, eventually financed emissions as sufficiently reliable data utilizing sufficiently reliable data as it becomes becomes available. available, and use client carbon transition plans 3. Setting interim emission reduction targets in our decision-making processes. for select carbon-intensive portfolios, including oil and gas, and power

Set and disclose interim targets for select carbon- intensive portfolios — including the oil and gas sectors, and power sector — no later than the end of 2022.

1 . In 2018, Wells Fargo announced our $200 billion sustainable finance commitment and updated the methodology for how we track progress . The 2018-2020 results are not comparable to previously reported results for the “finance environmentally beneficial business opportunity” progress 85 statement . Wells Fargo’s current sustainable finance reporting methodology is available online . Climate-related disclosure In May 2021, we issued our first sustainability bond, named the Inclusive Communities and A critical element of a well-thought-out climate Climate Bond . This raised $1 billion in capital change strategy is the ability to transparently aimed toward projects that support housing and accurately provide climate-related financial affordability, socioeconomic advancement disclosures to our stakeholders, which helps and empowerment, and renewable energy . them to identify historical, current, and emerging The Inclusive Communities and Climate Bond risks and opportunities related to climate represents an important next step in delivering change and our business . As such, we published on Wells Fargo’s commitments to expand our our inaugural Task Force on Climate-related sustainable finance capabilities in support Financial Disclosures (TCFD) Report (PDF) in of an inclusive economic recovery and a just 2021, endorsed the recommendations of TCFD, transition to a low-carbon future . It also allows and continue to disclose our Scope 1 and Scope 2 us to contribute to the strong momentum we’re emissions as well as expand accounting, strategic seeing in the sustainability bond market and decisions, and disclosure on our Scope 3 financed help meet the growing demand for investment emissions . opportunities that deliver positive social and To learn more about our climate-related environmental outcomes . disclosures, please see our TCFD Report (PDF) and our ESG Goals and Performance Data (PDF) . Financing a low-carbon economy Wells Fargo is a leader in financing projects Sustainable finance Performance that aim to propel the U .S . toward a low-carbon trends can be A cumulative global investment economy . We contribute to the advancement of found in the of about $1 .6 trillion is needed Wells Fargo renewable energy and clean tech, serving a wide each year on average over the ESG Goals and variety of companies in these rapidly growing Performance next 30 years to achieve a net- Data (PDF) . sectors . We work with businesses around the zero economy .1 This equates world that manufacture, market, and develop to about 1% to 2% of GDP per clean technologies that enable sustainability year . We view this as a significant opportunity, and resource efficiency . Our customers include and in 2021, we launched the Institute for businesses that specialize in: Sustainable Finance to help deploy $500 billion Energy generation, including solar, wind, in financing to sustainable businesses and projects and biomass by 2030 to support science-based research on low-carbon solutions . The institute will also work Energy storage with communities as they prepare for and adapt Energy efficiency to changing weather-related impacts, and advocate for policies that enable client transactions . Water technologies

We published our Sustainable finance reporting Agricultural technologies methodology (PDF) on our corporate website ¹. Electric and low-emission vehicles

Smart grid applications

86 Wells Fargo renewable energy and clean tech that aims to speed the path to market for products include: technology startups focused on sustainability • Tax-equity investments and lease financing and resiliency in the built environment, as well – The Renewable Energy & Environmental as sustainable agriculture . IN² harnesses the Finance (REEF) team’s approach to project world-class expertise and facilities at NREL and finance is relationship based . We work with the Donald Danforth Plant Science Center* to leading, high-quality, trusted developers, and support promising startup technologies referred collaborate with them on multiple projects . through a network of channel partners . This network includes some of the nation’s foremost • Corporate banking – Offers loans (project clean technology and agriculture incubators, financing, loans, and letters of credit), accelerators, and university programs . capital markets (debt and equity), Companies selected to participate in the merger & acquisition advisory, and other program receive $250,000 non-dilutive grants financial services (derivatives and treasury to validate their technologies, and secure the management, among others) to renewable priceless benefit of business connections across power projects/companies and other the entire IN2 ecosystem . businesses focused on helping the transition of the energy value chain .

• Asset-based lending – Wells Fargo Capital As of March 31, 2021: Finance provides asset-based, revolving • 46 companies have participated lines of credit and term loans in support in the IN2 program of high-growth emerging businesses in the renewable energy and other clean tech • $568 million in external funding raised sectors looking to expand into the U .S . • 476 jobs created by these companies

The Wells Fargo Innovation Incubator • 9 have merged with or been In addition to providing sustainable finance acquired by other companies through our lines of business, we support clean technology innovation and entrepreneurship through strategic philanthropy and community The Center for Climate-Aligned Finance partnerships . The Wells Fargo Innovation The financial sector’s role in the global Incubator (IN²) is a $50 million collaboration sustainability agenda is a critical component with the United States Department of Energy’s that will help drive climate-aligned solutions with National Renewable Energy Laboratory (NREL) a growing focus on the implementation of the Paris Agreement in real economy sectors . In July 2020, Rocky Mountain Institute (RMI), a leading global clean energy nonproft, announced the launch of the Center for Climate-Aligned Finance in collaboration with Wells Fargo, Goldman Sachs, Bank of America, and JPMorgan Chase . The Center will be independently administered by RMI and

*We do not control this website . Wells Fargo has provided this link for your convenience, but does not endorse and is not responsible for the content, links, privacy policy, or security policy of this website . 87 will collaborate with the financial sector with the We are proud of our desire to change course goal of helping to develop integrated solutions when needed to achieve our operational efficiency and decision useful frameworks in partnership objectives . For example, in 2017, we realized that with industry clients in carbon-intensive sectors . our focus should be on total waste reduction — This work will support decarbonization, as well that is, using less resources overall — rather than as develop relevant metrics, tools, and means on waste diversion . We proactively changed our designed to track progress toward the net-zero goal from 65% waste diversion (a goal we were transition . on target to meet) to 50% total waste reduction, a far more difficult goal to achieve, but one we Operational efficiency Performance felt would help create more impactful change . trends can be This redirected focus helped drive our conversations To help provide healthy, found in the Wells Fargo with vendors and service providers on how to work safe, productive, and ESG Goals and to use less, design for reuse where possible, and environmentally responsible Performance return products back into the material stream spaces for our stakeholders, Data (PDF) . (core concepts in the creation of a circular economy) . we approach building operations through We’re working to integrate these circular economy the principles of leadership, learning, and ideas into our operations, and we strive to continue continuous improvement, additionality, sourcing and instituting more responsible options . and risk management . One success that we celebrate in this area is the Leadership, learning, and ongoing donation of used office furniture to continuous improvement hundreds of local nonprofits such as schools, civic Wells Fargo’s Corporate Properties Group organizations, and groups across the country, (CPG) oversees our real estate footprint . which serve diverse stakeholders in the CPG consistently seeks to adopt best practices communities that we serve . and is willing to learn, improve, and proactively innovate to do our part to address climate Additionality change directly . Wells Fargo strives to make decisions Over the years, we’ve set a number of operational regarding procurement and purchasing that goals, which have been focused on efficiencies will support additionality in building operations . across energy, water, greenhouse gas emissions, Additionality — particularly as it pertains to and waste . environmental sustainability — is a complex issue that continues to evolve over time . In the context Through our focus on continuous improvement, of buildings and building operations, additionality we added new goals, and increased many when refers to actions Wells Fargo can take that cause we met milestones early . By setting clear and a beneficial “additional” result that would not ambitious goals, our intent was not merely to have happened if Wells Fargo had not taken the achieve them, but to leverage them to drive activity or action . lasting, positive change .

88 An example of how supporting additionality is reflected in our building operations is our effort to meet 100% of our electricity consumption with renewable energy sources . In 2017, we achieved our goal of meeting 100% of Wells Fargo’s global electricity needs with renewable energy,¹ primarily WE APPROACH BUILDING OPERATIONS through the purchase of Green-e® certified THROUGH THE PRINCIPLES OF

renewable energy certificates (RECs) . These Leadership, learning, purchases were an important first step in our and continuous improvement renewable energy strategy . The second step in our renewable energy strategy has been to leverage our Additionality purchasing strength to encourage the development Risk management of new sources of green power through long-term agreements with renewable energy providers that build the renewable energy infrastructure needed to meet their contracts with Wells Fargo, thereby adding to the overall supply of renewable energy available in the electric grid .

Wells Fargo purchased carbon offsets to Risk management achieve carbon neutrality for Scope 1 and In the environmental sustainability arena, Scope 2 emissions for 2019 and 2020 operations . some areas of risk management may be readily Carbon neutrality, or having a net zero carbon apparent, such as environmental risk and footprint for Scope 1 and 2 GHG emissions is compliance — but Wells Fargo also considers the achieved first through continued improvement long-term impact of our decisions on the health in operations to shrink our GHG emissions, and well-being of stakeholders . For example, and then through the purchase of carbon Wells Fargo works with vendors and outside offsets . In addition to carbon neutrality experts to help optimize indoor air quality in for our operations, we also strive to utilize our spaces . Indoor air quality has been a key our carbon offset purchases to support projects priority for new, retrofitted, and existing spaces, that wouldn’t be viable without the financial and we take steps to proactively test indoor air support generated through the sale of carbon quality, which allows us to act on learnings to offsets and which create multiple co-benefits, improve indoor air quality . Likewise, our efforts beyond environmental benefits, for the local to provide greater access to daylight, clean water, community . a connection with nature, and opportunities for greater physical activity play a role in safeguarding the mental and physical health of our customers and employees .

1 . Renewable energy sources include on-site solar, long-term contracts that support net new sources of off-site renewable energy, and the purchase of renewable energy certificates . 89 Environmental risk and compliance Our Environmental Risk and Compliance program is managed by a team with deep subject matter expertise . This team is responsible for environmental due diligence in support of projects, as well as unplanned environmental issues that could impact the health and safety of employees or assets . This team oversees environmental assessments, tests, reports, identification of remediation requirements, and remediation oversight services for the following areas:

Indoor air quality

Refrigerant management

Underground storage tank management

Asbestos management

Environmental contractor management

90 Forward-looking statements

This Report contains forward-looking For more information about factors that could statements about the company’s future cause actual results to differ materially from activities, plans, objectives, and expectations . expectations, please refer to our reports filed with the Securities and Exchange Commission Forward-looking statements can be identified (SEC), including the discussion under “Forward- by words such as “anticipates,” “intends,” “plans,” Looking Statements” and “Risk Factors” in our “seeks,” “believes,” “estimates,” “expects,” 2020 Annual Report on Form 10-K and in our “target,” “projects,” “outlook,” “forecast,” “will,” 2021 Quarterly Reports on Form 10-Q, each as “may,” “could,” “should,” “can,” and similar filed with the SEC and available on its website at references to future periods . Forward-looking www .sec .gov *. statements are not based on historical facts, but instead represent our current expectations and assumptions regarding our business, the economy, and other future conditions . Because forward-looking statements relate to the future, Securities they are subject to inherent uncertainties, risks and changes in circumstances that are difficult and Exchange to predict . You are urged to not unduly rely on forward-looking statements, as actual results Commission could differ materially from expectations . filings Forward-looking statements speak only as of the date made, and we do not undertake to Our annual reports on Form 10-K, quarterly update them to reflect changes or events that reports on Form 10-Q, current reports on occur after that date . Form 8-K, and amendments to these reports are available free of charge on our website as soon as practical after they are electronically filed with or furnished to the SEC . These reports and amendments also are available free of charge on the SEC’s website at www .sec .gov *.

Corporate

Annual Report and Proxy Statement (https://www .wellsfargo .com/about/investor-relations/annual-reports/)

Board Committees and Charters (https://www .wellsfargo .com/about/corporate/governance/)

By-laws of Wells Fargo & Company (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate/governance-by-laws .pdf)

Code of Ethics and Business Conduct (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate/code-of-ethics .pdf)

Corporate Governance Guidelines (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate/governance-guidelines .pdf)

Government Relations and Public Policy (https://www .wellsfargo .com/about/corporate-responsibility/government-relations/)

History of Wells Fargo (https://www .wellsfargo .com/about/corporate/history/)

Leadership and Governance (https://www .wellsfargo .com/about/corporate/governance/)

Online Newsroom (https://newsroom .wf .com/)

Wells Fargo Stories (https://stories .wf .com/?cid=vty)

Wells Fargo Today Quarterly Fact Sheet (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate/wells-fargo-today .pdf)

92 Wells Fargo: Charting a New Future (PDF) (https://stories .wf .com/wp-content/uploads/New_Future8 .pdf)

Wells Fargo Stories: Wells Fargo’s New CEO: ‘We will get it done’ (https://stories .wf .com/wells-fargos-new-ceo-will-get-done)

Corporate responsibility

CDP: Wells Fargo & Company — Climate Change (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/climate- change-information-request .pdf)

Climate Change Issue Brief (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/climate- change-issue-brief .pdf)

Community Giving (https://www .wellsfargo .com/about/corporate-responsibility/community-giving/)

Community Reinvestment Act Performance Evaluation (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/community-reinvestment/ performance-evaluation .pdf)

Environmental, Social, and Governance (ESG) Goals and Performance Data (PDF) (https://www .wellsfargo .com/assets/pdf/about/corporate-responsibility/goals-performance- data .pdf)

Environmental Data Verification Statement – Apex Companies, LLC. (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/verification- statement .pdf)

Environmental and Social Risk Management (ESRM) Framework (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/esrm- framework .pdf)

Global Reporting Initiative (GRI) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/gri-index .pdf)

Sustainability Accounting Standards Board (SASB) Index (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/sasb-index .pdf)

Human Rights Statement (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/human- rights-statement .pdf/)

93 Innovation Incubator (IN²) (https://in2ecosystem .com/)

Indigenous Peoples Statement (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/indigenous- peoples-statement .pdf)

Modern Slavery Act Statement (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/corporate/modern-slavery-statement .pdf)

Sustainable Finance Reporting Methodology (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate-responsibility/sustainable- finance-methodology .pdf)

Task Force on Climate-related Financial Disclosures (TCFD) Report (PDF) (https://www .wellsfargo .com/assets/pdf/about/corporate-responsibility/climate-disclosure .pdf)

COVID-19 response

Resources and support for COVID-19 (https://www .wellsfargo .com/jump/enterprise/coronavirus-response)

Wells Fargo Stories: Wells Fargo responds to COVID-19 (https://stories .wf .com/series/wells-fargo-responds-covid-19/)

Employees

Careers at Wells Fargo (https://www .wellsfargo .com/about/careers)

Careers for Military Veterans (https://www .wellsfargo .com/about/careers/veterans/)

Diversity and Accessibility (https://www .wellsfargo .com/about/diversity/)

Wells Fargo Benefits (https://www .wellsfargo .com/about/careers/benefits/)

Wells Fargo Veterans Scholarship (https://learnmore .scholarsapply .org/wellsfargoveterans/)

94 Privacy and security

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Security Center (https://www .wellsfargo .com/privacy-security/fraud)

Wells Fargo Important information: Privacy (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/personal/privacy-security/privacycenter-important-information .pdf)

Products and services

CollegeSTEPS® (https://collegesteps .wf .com/)

Control Tower® (https://www .wellsfargo .com/online-banking/manage-accounts/control-tower/)

Diverse Community Capital program (https://www .wellsfargo .com/com/financing/real-estate/community-lending- investment/cdfi/)

Financial well-being (https://www .wellsfargo .com/financial-health)

Hands on Banking® (https://handsonbanking .org/)

Hands on Banking® for service members (https://handsonbanking .org/military/)

95 LGBTQ Resource Center (https://www .wellsfargo .com/lgbtq/)

Military Mortgage Services (https://www .benefits-mortgage .com/loans/mil0307/index-affinity .page)

Military Resource Center (https://www .wellsfargo .com/military/)

My FirstHomeSM Education Program (https://myfirsthome .wellsfargobank .com/index .html#bookmark/0/0/0/0)

NeighborhoodLIFT® (https://www .wellsfargo .com/mortgage/lift/)

Overdraft Rewind® (https://www .wellsfargo .com/checking/overdraft-services/)

The Private Bank – Social Impact Investing (https://www .wellsfargo .com/the-private-bank/solutions/social-impact-investing/)

Smarter CreditTM Center (https://www .wellsfargo .com/goals-credit/smarter-credit)

Wells Fargo AssistSM (https://www .wellsfargo .com/financial-assistance/)

Wells Fargo Investment Institute (https://www .wellsfargo .com/investment-institute)

Wells Fargo’s Lending and Servicing Principles for U.S. Residential Real Estate Products (https://www .wellsfargo .com/mortgage/principles/)

Wells Fargo’s Responsible Lending Principles for Consumer Credit (https://www .wellsfargo .com/help/consumer-credit-lending-principles/)

Wells Fargo Asset Management ESG Investing Library (https://www .wellsfargoassetmanagement .com/insights/esg-investing)

96 Wells Fargo Asset Management ESG Policy and Process (PDF) (https://www .wellsfargoassetmanagement .com/assets/public/pdf/legal/esg-policy- and-process .pdf)

Wells Fargo Works® for Small Business (https://wellsfargoworks .com/)

Suppliers

Supplier Code of Conduct (PDF) (https://www08 .wellsfargomedia .com/assets/pdf/about/corporate/supplier-code-of- conduct .pdf)

Supplier Diversity (https://www .wellsfargo .com/about/diversity/supplier-diversity/)