TCFD Entity Disclosure

The Bank of New York Mellon, London Branch

The Bank of New York Mellon, London Branch alignment with 2.2 ESG TCFD reporting requirements

Introduction and context

The Bank of New York Mellon is a banking corporation organized pursuant to the laws of the State of New York, whose registered office is at 240 Greenwich St, NY, NY 10286, USA. The Bank of New York Mellon is supervised and regulated by the New York State Department of Financial Services and the US Federal Reserve and is authorized by the Prudential Regulation Authority (PRA) (Firm Reference Number: 122467). The Bank of New York Mellon also operates in the UK through its London branch (FC005522 and BR000818) and is subject to regulation by the Financial Conduct Authority (FCA) and limited regulation by the PRA at The Bank of England.

The Bank of New York Mellon, London Branch (BNY) makes this disclosure in accordance with Chapter 2 of the FCA Environmental, Social and Governance (‘ESG’) Sourcebook. Chapter 2 of the ESG Sourcebook requires in-scope firms to prepare entity disclosures consistent with the Task Force on Climate-Related Financial Disclosures (‘TCFD’). This includes all firms that undertake portfolio management (“In-Scope Business”) and meet a prescribed assets under management threshold.

BNY In-Scope Business

BNY’s securities finance business undertakes limited investment decision-making on behalf of its clients, with such limited decisions only being made as part of its agency securities lending and related cash reinvestment programmes. The disclosure requirements relate to the limited portfolio management activities of BNY’s securities finance business (“BNY In-Scope Business”).

As with all services provided to clients, BNY considers a broad range of risks when making these limited investment decisions on behalf of clients; BNY does not provide investment advice to clients within the agency lending programme. Given the role of BNY as agent, implementing the investment guidelines set by clients themselves and given the limited discretionary authority vested in BNY, as described above, BNY does not currently expressly consider sustainability risks or the adverse impacts of investments decisions on sustainability factors, when making investments on behalf of clients in relation to its agency lending programme. However, more broadly across the group, climate-related risks and opportunities are considered as applicable. Accordingly, we believe that the climate-related disclosures made at the group level are relevant and we have cross-referenced to the climate related financial disclosure contained within the group disclosures (see table below).

Compliance statement

The disclosures in the report, including any group disclosures cross-referenced in it, comply with the requirements set out in ‘ESG 2.2 TCFD entity report’ and other relevant sections of the FCA ESG Sourcebook.

Ioanna Thomson
Global Markets Risk & Control Framework Lead
June, 2026

References to BNY Group Disclosures:

TCFD Pillar	Recommended Disclosures	Report Section(s)	Subsection(s)
Governance	a. Describe the board’s oversight of climate-related risks and opportunities.	Governance (pg. 2)	Board of Directors (pg. 2)
Governance	b. Describe management’s role in assessing and managing climate-related risks and opportunities.	Governance (pg. 2)	Management (pg. 2)
Strategy	a. Describe the climate-related risks and opportunities the organization has identified over the short, medium, and long term.	Strategy (pg. 3-4)	Climate Opportunities (pg.4)
		Risk Management (pg. 5-6)	Risk Management Time Horizons (pg. 5); Risk Measurement (pg. 5-6)
	b. Describe the impact of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning.	Strategy (pg. 3-4)	Global Climate Strategy (pg. 3-4)
		Climate Risk Management (pg. 5-6)	Risk Measurement (pg. 5-6)
	c. Describe the resilience of the organization's strategy, taking into consideration different climate-related scenarios, including a 2° C or lower.	Risk Management (pg. 5-6)	Climate Scenario Analysis (pg. 6)
		Risk Management (pg. 5-6)	Enterprise Resiliency (pg. 6)
Risk Management	a. Describe the organization’s processes for identifying and assessing climate-related risks.	Risk Management (pg. 5-6)	Approach to Climate-Related Risk (pg. 5); Risk Identification, Assessment, and Materiality (pg. 5); Risk Measurement (pg. 5-6)
	b. Describe the organization’s processes for managing climate-related risks.		Controls and Mitigation (pg. 6)
	c. Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organization’s overall risk management.		Approach to Climate-Related Risk (pg. 5); Risk Identification, Assessment and Materiality (pg. 5); Controls and Mitigation (pg. 6)
Metrics & Targets	a. Disclose the metrics used by the organization to assess climate-related risks and opportunities in line with its strategy and risk management process.	Metrics and Targets (pg. 9-13)	Operational Emissions (pg. 9-12); Financed Emissions (pg. 13)
	b. Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 greenhouse gas (GHG) emissions and the related risks.
	c. Describe the targets used by the organization to manage climate-related risks and opportunities and performance against targets.

Disclaimer

BNY is the corporate brand of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various subsidiaries generally. This material and any products and services mentioned may be issued or provided in various countries by duly authorized and regulated subsidiaries, affiliates, and joint ventures of BNY. This material does not constitute a recommendation by BNY of any kind. The information herein is not intended to provide tax, legal, investment, accounting, financial or other professional advice on any matter, and should not be used or relied upon as such. BNY assumes no direct or consequential liability for any errors in or reliance upon this material.

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