Your participation in the BNY Mellon Wellbeing Program (the "Wellbeing Program") is voluntary. The Wellbeing Program is available to all eligible employees and their eligible family members. The Wellbeing Program is administered according to Federal rules permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990, the Genetic Information Nondiscrimination Act of 2008, and the Health Insurance Portability and Accountability Act, as applicable, among others.

If you choose to participate in the Wellbeing Program, you have the option to complete a voluntary Wellbeing Assessment ("WBA") that asks a series of questions about your health-related activities, behaviors and history. You may also complete a voluntary biometric screening, which will include a blood test for cholesterol and blood glucose levels. You are not required to complete the WBA or to participate in the biometric screening or any other medical examinations. If you think you might be unable to meet a standard or activity for an incentive under this Program, you might qualify for an opportunity to earn the same incentive by different means. Contact WebMD at 1-888-258-9275 and they will work with you (and, if you wish, with your physician) to find an alternative means for you to earn the same incentive.

None of the vendor program partners will provide your personal health data, including WBA and biometric screening input or results, or other personal information, to BNY Mellon, except as permitted by law. BNY Mellon will receive only anonymous, aggregate data to be used for the purpose of evaluating the success of the Wellbeing Program and for designing programs that meet your health and wellness needs.

Individual participation will be reported to BNY Mellon and vendor partners for purposes of Wellbeing Program incentive administration. Vendor partners (but not BNY Mellon) may receive individual medical and pharmacy information in order to provide you with tools and services under this Wellbeing Program. Although BNY Mellon may receive aggregated data from vendor partners for estimating overall plan costs, it will not receive any of your personal health data under any circumstance.

The programs and services provided by vendor partners, including, but not limited to, Premise Health, The Ayco Company, L.P., Beacon Health Options, WebMD Health Services, Castlight, CVS Caremark, Virgin Pulse, Voya, Best Doctors, Aetna, and United Healthcare, are completely confidential. Your health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the programs, and you will not be asked or required to waive the confidentiality of your health information as a condition of participating in the Wellbeing Program or receiving any incentive.

In addition, all medical information obtained through the programs will be maintained separate from your personnel records, information stored electronically will be encrypted, and no information you provide as part of the Wellbeing Program will be used in making any employment decision. Appropriate precautions will be taken to avoid any data breach, and in the event a data breach occurs involving information you provide in connection with the Wellbeing Program, we will notify you immediately.

You may not be discriminated against in employment because of the medical information you provide as part of participating in the Wellbeing Program, nor may you be subjected to retaliation if you choose not to participate. If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact the BNY Mellon Health Information Privacy Officer at:

BNY Mellon
Employee Benefits Department
500 Grant Street, AIM: 151-3118
Pittsburgh, PA 15258