Bread Financial 2021 ESG Report: Ethics & Integrity

Ethics and Integrity

Integrity, ethical decision-making and compliance with all applicable laws and regulations governing our business drive our global growth and long-term success. We know that the way to earn stakeholders' trust and foster long-term success is through our business conduct — by what we do, not just what we say. In a world of competing demands and rising expectations, having a strong ethical culture is essential to protecting our reputation and preparing for whatever challenges come our way. Our Board of Directors and executive leaders set the tone at the top and take responsibility for fostering a culture of integrity, ethical business practices and accountability.

Code of Ethics

Our comprehensive Code of Ethics outlines the values and principles we agree to embody, maintain and protect, and provides guidance to help us consistently make sound decisions and perform our duties ethically and responsibly. Every decision we make — and each of our daily actions — reflects our values, beliefs and behaviors. Individually and collectively, we are focused on driving business performance and protecting our reputation as a responsible and compliance-centric organization.

Associates must certify annually that they have read, agree to and adhere to the Code of Ethics (99.6% of associates completed the Code of Ethics training in 2021); and every two years, they complete a more in-depth online Code of Ethics training, which addresses a variety of topics included in the Code. Additional training is provided to associates on a regular basis covering topics such as global anti-corruption, insider trading, harassment and discrimination, retaliation, conflicts of interest and antitrust.

We also maintain supplementary codes of ethics for our Board of Directors and senior financial officers, which address additional standards and guidance applicable to their roles.

The Nominating & Corporate Governance Committee of our Board of Directors is responsible for monitoring compliance with and enforcement of the provisions of the Code of Ethics, and together with management, reviewing the Code periodically and recommending updates to the Board. Our Ethics Office provides quarterly ethics reports to the Nominating & Corporate Governance Committee to keep the committee apprised of ethics-related complaints and investigations and help them assess and understand the company’s culture. Significant ethics-related complaints are also reported to the Audit Committee.

We value and respect the opinions and insights of our associates and encourage them to speak up if they have a concern or suspect unethical conduct. If an associate recognizes a potential Code of Ethics or other Bread Financial policy violation, they have a responsibility to report it to their immediate supervisor or a manager, a Human Resources representative, the Legal department, the Ethics Office or via the Ethics Helpline. The Ethics Helpline is available 24 hours a day, 7 days a week. Reports to the Ethics Helpline can be made by phone (877-217-6218) or online (www.breadfinancial.ethicspoint.com) and may be made anonymously.

Stockholders and other interested parties may also submit questions or comments to the Board through our Ethics Office by email at CorporateEthics@breadfinancial.com or, on an anonymous basis if desired, through the Ethics Helpline.

FOSTERING A CULTURE OF INTEGRITY AND ACCOUNTABILITY

In our 2021 Annual Associate Engagement Survey:

• 75% answered that Bread Financial is open and honest in communication with associates
• 81% answered that they have trust and confidence in senior leadership
• 84% answered that Bread Financial shows a commitment to ethical business decisions and conduct

Protecting Human Rights

Bread Financial is committed to promoting and protecting human rights throughout our business operations and engagement with our associates, customers, clients, suppliers and the communities we serve. This commitment is embodied in our company values and culture, which includes treating everyone with respect, being authentic and embracing our differences. We value and strive to operate our business in a manner consistent with human rights principles such as those contained in the United Nations Universal Declaration of Human Rights.

Our Human Rights Statement, which we published in 2021, outlines our commitment as well as the actions we take to honor this commitment.

Participating Responsibly in Political Matters

Engaging in political and legislative matters is important to the success of the company. We have adopted a Political Contributions and Activity Policy, which outlines how the company and our associates may engage in political activities.

Our public policy strategy includes a variety of activities aligned around defending our business interests while also balancing what is right for the greater good. We manage issues that most directly affect our operations and have the greatest potential to impact the company’s overall performance and ability to do business optimally. Our priority legislative and regulatory issues include consumer and data privacy and other protections, cybersecurity, tax, consumer finance and bank regulation. We engage in the public policy process through trade associations, industry coalitions and lobbying activity.

In 2021, designated associate representatives had 35 lobbying contacts with government agencies, members of Congress and their staffs. We also participated in industry meetings and events as corporate members of the American Bankers Association, Card Coalition and National Association of Industrial Bankers. Eligible associates may also participate in our nonpartisan, issues-focused political action committee (PAC). In 2021, the Bread Financial Holdings, Inc. PAC, which is governed by an associate-led board, disbursed $6,400 to three distinct federal candidate committees and raised $70,961.73 from 38 contributors.

All political contributions and activities comply with applicable laws and are reported publicly as required by law,

KEY PAC ISSUES

• Consumer Protection, including Privacy
• Bank Regulation – Consumer Finance
• Tax Regulations

CURRENT LOBBYISTS OF RECORD

• Capitol Legislative Strategies (Washington, D.C.)
• Polaris Government Relations (Washington, D.C.)
• CGCN (Washington, D.C.)
• Kallner and Associates (Columbus, Ohio)

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