Outside Business Activity Pre-Hire Attestation

Bank of America recognizes the importance of complying with laws and regulations applicable to a contractor’s
Outside Business Activities (OBAs) and the need to manage actual or potential conflicts of interest or risks as a
result of such activities. The purpose of this form is to provide notice of prohibitions and disclosure requirements
with regards to OBAs prior to contract assignment with Bank of America Corporation and its Enterprise
Subsidiaries.

OBAs are broadly defined as any role, external to your Bank of America assignment, which is either compensated
or provides access to, and some level of control over, that organization’s governance, finances, or accounts. This
includes:

 Serving in a capacity as a director, officer, general partner, managing member, board member, observer,
committee member, or other like service;
 Any role with government or government related entities;
 Roles that grant access to, or control over, the finances or securities of an outside organization;
 Being employed, compensated, or having the reasonable expectation of compensation by any person,
entity, or organization other than their vendor employer that is contracted with Bank of America;
 Ownership in a business or organization if you are actively participating in the business, or where your
ownership stake is 25% or greater, and;
 Political activities such as fundraising, campaigning, lobbying, volunteering on or with government
agencies, political appointments and running for and holding any elected office.

Within ten (10) days of your assignment start date with Bank of America, you may be required to disclose all OBAs
covered by the Enterprise OBA Policy, which will then be subject to review and approval by your assignment
manager , and in some cases the Associate Investment Monitoring (AIM) Compliance & Operational Risk (C&OR)
Group. The activity will be subject to conditions of approval. All regulated or associated contractors are required to
follow the disclosure and approval requirements set forth for all new and existing OBAs. Contractors registered or
associated with Financial Industry Regulatory Authority (FINRA) may be subject to additional review and may be
required to provide additional documentation to the Registration and Licensing team.

Prohibitions
Bank of America prohibits outside business activities that involve:

 A Financial Institution1, other than Bank of America or its subsidiaries (this includes Non-Profit Financial
Institutions and Community Development Financial Institutions (CDFIs);
 Activities in financial services (i.e., accounting, tax preparation unless on behalf of immediate family
members on an uncompensated basis, financial planning, credit consulting, selling, or issuing investments
not offered by Bank of America, authoring financial or investment related publications, credit
piggybacking);
 Companies that operate within the sector/industry a contractor covers during their assignment at Bank of
America (sector coverage is based on S&P’s Global Industry Classification Standard);
 Receipt of compensation for referral of clients to business services away from Bank of America;
 The utilization of a real estate license to facilitate real estate purchases/sales for third parties outside of
the contractor’s immediate family (i.e., spouse, domestic partner, child (including by adoption), parent,
sibling, parent-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law of the contractor or
contractor’s spouse or domestic partner, as well as step relationships of the foregoing);

1
Financial Institution means a company engaged in the business of dealing with financial and monetary transactions such as deposits, loans,
investments, and currency exchange. Examples of Financial Institutions include depository institutions, credit unions, trust companies,
brokerage-dealers, mortgage companies, credit card companies and other lenders, insurance companies (inclusive of Life and Health), FinTech
companies, mutual funds, hedge funds, private equity groups, venture capital funds, title companies, Special Purpose Acquisition Companies
(SPACs), and other companies offering or providing financial services regardless of where or how formed or incorporated.

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  The practice of law (including but not limited to providing an opinion, preparing, or assisting in the
preparation of documents), unless the use relates to personal matters of the contractor or the
contractor’s immediate family (i.e., spouse, domestic partner, child (including by adoption), parent,
sibling, parent-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law of the contractor or
contractor’s spouse or domestic partner, as well as step relationships of the foregoing);
 Activities with businesses restricted under the Bank of America Environmental and Social Risk Policy
Framework (such as firearm manufacturing, adult entertainment);
 Engaging in any OBA with a client. A client is considered any individual for which the contractor 1) is
currently assigned to the client relationship in any manner (e.g., Financial Advisor, Business Banker, Loan
Officer), or 2) has serviced or received compensation from the client relationship in the past 12 months.
The only exemption to this prohibition is clients who are family members of the associate;
 Serving in a federal, state, or provincial legislative position;
 Board roles with Political Action Committees;
 Treasurer roles associated with a political campaign or committee, government entity, or government-
owned entity (GOE);
 Roles that include oversight of the Outside Organization’s relationships with Bank of America;
 Roles that include control of or authorization over the Outside Organization’s investment accounts;
 Any crypto mining activities (i.e., the process of creating new digital “coins”); or
 Directorships with public companies.

Additional prohibitions for contractors in the Merrill Lynch Wealth Management or Consumer & Small
Business Lines of Business:
 If you are assuming an assignment in the Consumer & Small Business organization, a real estate
license is strictly prohibited with no allowable exceptions.
 If you are assuming an assignment in Merrill Lynch Wealth Management, fiduciary roles are only
allowed if they involve immediate family members (i.e., spouse, domestic partner, child (including
by adoption), parent, sibling, parent-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-
in-law of the contractor or contractor’s spouse or domestic partner, as well as step relationships of
the foregoing).

NOTE: If you are currently participating in any of the prohibited activities above, please alert
your supplier as soon as possible, as you must cease these activities prior to your assignment
starting at Bank of America.

Conflicts and Risks

Contractors should not engage in activities which compete with the Bank’s interests or presents perceived or
potential conflicts of interest. The best interests of the client should always govern the actions of the Bank and the
contractor. Failure to identify and appropriately manage conflicts of interest expose the Bank to financial losses,
civil or criminal liability and regulatory criticism. Additionally, mismanagement of actual, potential, or perceived
conflicts of interest can negatively impact the Bank’s reputation by jeopardizing the public’s trust in the Bank and
its dealings with clients.

While this is not an exhaustive list, the below represents potential conflicts and risks that could be associated with
Outside Business Activities and should be evaluated. Any activity that presents a conflict will not be permitted.

 The devotion of such time or effort as to negatively affect the satisfactory performance of the contractor’s
assignment at Bank of America;
 Roles that are inherently similar to the contract assignment with Bank of America;
 Roles with a current or likely competitor, third party, client or prospect that could cause divided loyalty
between the Outside Organization and Bank of America;

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  Potential compromise of an opportunity due to competing interests between the Outside Organization
and Bank of America;
 Personal activities with an Outside Organization in which Bank of America has an equity investment,
including membership shares, such that the contractor could be perceived to be acting on behalf of Bank
of America;
 The activity could raise regulatory issues or involve other potential conflicts of interest;
 The activity could pose legal or regulatory risk that cannot be appropriately mitigated;
 It involves oversight of an Outside Organization’s finances or investments;
 It requires the use of professional financial licensing or designations (e.g., real estate licenses, insurance
licenses, securities licenses, Certified Public Accountant, etc.).
*Some professional licenses (e.g., insurance, mortgage/NMLS, and notary) may be held; however, they may be subject to
additional restrictions, and only permitted to be used as they relate to the scope of your contract assignment with Bank of
America.

**Individual lines of business may prohibit or severely restrict the holding of professional licenses.

Conditions of Approval

The following conditions must also be acknowledged and followed:

 After a board seat has been approved, you may not serve for any additional terms as a member of a
company’s board unless you submit a request and receive additional approval;
 If the outside entity in which you are on the board is private and then determines it will go public, you
must immediately notify AIM;
 In the event a dispute arises between Bank of America and the outside entity, you will recuse yourself
from discussions regarding Bank of America’s strategy, or attempting to resolve the dispute;
 While participating in an OBA with the outside entity, you will not provide to Bank of America, any
proprietary business, confidential non-public information, or material non-public information (CI/MNPI)
that may be acquired while participating in the OBA, nor provide the outside entity with any CI/MNPI of
Bank of America
 You must not explicitly recommend securities issued by the outside entity, their products or services to
any Bank of America client or employee;
 In the event you acquire any information related to the outside entity that may conflict with your duties
and responsibilities to Bank of America, you must immediately discuss with Bank of America’s Legal
and/or Compliance departments;
 You acknowledge a separation of duties between the outside entity and Bank of America;
 You agree that any directorship is in your individual capacity and not as an agent or representative of
Bank of America;
 You must refrain from making any statement, either in writing or orally at a conference or other forum
that explicitly or implicitly appears to be a Bank of America endorsement of the outside entity, its
products, or services;
 You must not participate in any discussions concerning an existing or potential future business
relationship between an outside entity and Bank of America.

Access to an outside entity’s monetary accounts presents heightened risk, and therefore requires your
acknowledgment of the following conditions of approval. This does not apply to organizations where you and/or
your family holds sole ownership.
 You are not permitted to have control or authorization over the Outside Business Activity Organization’s
investment accounts now or in the future;
 At least one other member of the organization should also have access to the account or account
information.

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Bank of America has the authority to deny or rescind any OBA at any time. If an OBA is denied by Bank of America,
the individual is expected to cease participation at that time, or at an agreed upon time determined by their
assignment manager, in consultation with Global Compliance and Operational Risk (GC&OR).

Critical Information for Merrill Lynch Contractors

Contractors of Merrill Lynch and their immediate family members are not permitted to fill fiduciary roles for
anyone who is not an immediate family member, or be named as beneficiaries on client accounts, given the
conflicts of interest associated with these roles. Fiduciary roles include but are not limited to acting as an
executor/personal representative/administrator, trustee, guardian/conservator, and agent/attorney-in-fact
under a Power of Attorney. These roles must be dissolved prior to onboarding to Bank of America/Merrill
Lynch. If you are onboarded with a fiduciary role that is not permitted, you will be required to resign from that
role immediately. Additionally, outside business activities with clients who are not immediate family members
are generally not permitted and should be reviewed with your hiring manager.

You acknowledge that you understand and will abide by the expectations set forth herein. You agree to cease
involvement in all prohibited activities prior to your contract assignment with Bank of America and agree not to
participate in a prohibited activity while contracted at the bank. If you do not cease your involvement with a
prohibited activity, you may be released from assignment.

Name Vlad Popa

Signature

Date 05.06.2024

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