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Business Ethics
and Compliance

At Discover, we share a proud commitment to “Doing the right thing.” That means we act with honesty and with integrity, comply with all laws and regulations applicable to Discover, and perform to the highest ethical standards. It also means we are accountable for our actions and for the results we deliver.

Ethics and Compliance Policies and Procedures

To reinforce our Core Values and to help our employees navigate a variety of circumstances, we have several policies and procedures in place that inform our actions and provide further guidance on specific ethics and compliance areas. These include:

Code of Ethics and Business Conduct

Our Code of Ethics and Business Conduct (Code of Conduct) applies to all Directors, employees, and our subsidiaries and affiliates. It helps us make the right decisions by providing guidance on the ethical and legal responsibilities we share, whether on or off Discover’s premises or on or off duty. On an annual basis, Discover's Code of Conduct and related policies are reviewed and refreshed as appropriate. The Code of Conduct and related policies are presented to the HR Risk Committee, the Risk Committee, and the Board for approval.

All employees are required to take (and acknowledge their taking of) Code of Conduct training annually. Employee performance is assessed against Discover’s Behaviors bi-annually, and non-compliance with Discover’s Code of Conduct can result in corrective action up to and including termination of employment.

Key Principles of Our Code of Ethics and Business Conduct

Treat Everyone Equally and With Respect

We foster and maintain a work environment in which all individuals are treated with dignity and respect and are offered equal opportunities without discrimination or harassment.

Earn and Keep Trust

We protect all confidential information and do not misuse inside information or company assets.

Operate Transparently
and Fairly

We deal fairly with consumers, the public, competitors, suppliers, and one another, and we accurately and completely disclose information and maintain books and records.

Conduct Business Legally and Ethically

We are responsible for understanding the laws that apply to our job and locations and complying in both letter and spirit.

Maintain a Safe and Professional Work Environment

We expressly prohibit threats and acts of violence; behavior that is disruptive, threatening or intimidating; and forced labor and human trafficking within our business and supply chain.

See Something,
Say Something

We report any behavior that is illegal, unethical, or improper and ensure that all employees can do so without fear of retaliation.

Anti-Bribery and Anti-Corruption

Discover has zero tolerance for bribery and corruption. These activities are illegal and against our Core Values; bribery and corrupt behavior violate earned trust and put our company at risk.

Our Anti-Bribery and Anti-Corruption (ABAC) Policy establishes principles that govern the conduct of all employees with respect to compliance with the letter and spirit of the Foreign Corrupt Practices Act (FCPA), Bank Bribery Act, Travel Act, United Kingdom Bribery Act (UKBA), and similar local laws and regulations wherever Discover conducts business. The ABAC Policy prohibits both public and private sector bribery in all forms, generally prohibits “facilitation payments," and is intended to promote ethical conduct to prevent bribery and other corrupt practices.

We have a global ABA Compliance Program that is reasonably designed to implement our ABAC-related policies and procedures. Key components of the ABAC Compliance Program include an ABAC Standard that details the Program’s requirements; a dedicated ABAC team within our Compliance Department; periodic assessments of bribery and corruption risks and the effectiveness of internal controls; and risk-based due diligence and ongoing monitoring of relevant business, employee, and third-party activities to prevent, identify, manage, mitigate, and, when necessary, report bribery and corruption risks.

Employees are also required to participate in annual ABAC training. Our policies, procedures, and training provide guidance on several channels for reporting ethical issues promptly, including through anonymous reports to our Integrity Hotline.

Anti-Money Laundering and Sanctions

Our Anti-Money Laundering (AML) Policy defines our risk-based approach to ensuring our products and services are prevented from being used to launder money, finance terrorism, or violate economic sanctions. It is our policy to aid law enforcement through reporting of suspicious activity.

All employees are trained annually on the AML Policy, U.S. and Canadian AML laws, and Discover’s processes, including specifically how to identify and report transactions associated with money laundering, terrorist financing, and human trafficking.

We undertake customer and partner due diligence to understand the risks associated with maintaining certain relationships and take steps to mitigate those risks, including, but not limited to risks associated with partners operating in certain industries and customers or partners located in certain jurisdictions. This further helps us avoid doing business with any sanctioned entities or money launderers.

Our AML annual training helps employees analyze customer and partner geographic location, products, and services, and expected activities to identify unusual transactions outside of that customer’s or partner's expected pattern of
activity, thus reducing exposure to fraud,
identity theft, and financial crimes.

Upholding Human Rights

Wherever we do business, we respect and protect human rights. As outlined in our annual Modern Slavery Act and Transparency Statements, we prohibit any violations relating to, but not limited to, child labor, forced labor, elder abuse, slavery and human trafficking. Our Code of Ethics and Business Conduct includes an obligation to report any suspicion of non‑compliant and/or unethical behavior, either by Discover or by any of our suppliers, third parties or partners.

One way we hold ourselves accountable for upholding human rights is by performing compliance checks on all new employees and contractors and by training employees on underlying principles and policies of the code annually. We remain committed to transparency of our procurement practices and partnerships and communicating enhancements to our policies and due diligence process as they relate to modern slavery.

Discover’s EthicsPoint Hotline:

Voicing Concerns

Discover is committed to an environment where open, honest communications are the expectation, not the exception. We work hard to cultivate a culture where employees feel comfortable in approaching management to report concerns relating to ethical or business conduct matters, including accounting, internal accounting controls, or auditing matters. However, employees can also report any concerns anonymously (where allowed by local law) through our hotline, EthicsPoint, which is managed by a third party. Discover prohibits retaliation against any employee for reporting concerns in good faith, and we promise our employees that their concerns will be heard.

Consumers can file complaints through the Consumer Financial Protection Bureau’s (CFPB) Consumer Complaint Database, which is a collection of complaints about consumer financial products and services that is then sent on to companies for response.