Bristol-Myers Squibb Co

Our Board considers environmental, social, and governance (ESG) risks and opportunities as a part of our broader strategy for doing business around the world. Our governance profile includes oversight by our Board, with primary responsibility for ESG risks, assessment and disclosure assigned to the Board's Committee on Directors and Corporate Governance (CDCG). Oversight by this committee strengthens our ability to operate with the highest levels of quality, integrity, and ethics, which are foundational to our business. The Board's Compensation and Management Development Committee (CMDC) provides oversight and input into integration of ESG with incentive programs and management of human capital. The Board's other committees may also provide oversight on certain topics consistent with their respective charter responsibilities. Our Board members discuss pertinent climate and ESG topics multiple times a year, including details about external and emerging trends and weighing internal performance against predetermined objectives and opportunities. [...] The ESG Council is responsible for identifying and prioritizing ESG risks and opportunities and is composed of senior executives across the Company. The Council serves as the Company's primary governance body for all ESG matters and is led by the Vice President of Purpose, ESG, and Health Equity. Group members bring expertise from their respective areas and help raise awareness and alignment on both managing risks and activating opportunities related to ESG priorities. The Council, which meets at least quarterly, operates under a formalized process and protocols, ensuring that climate-related risks and opportunities, among other ESG topics, are being managed effectively and are aligned with our overall business objectives. The efforts of the Council are reported to the CEO, the BMSLT, and the CDCG. [...] The Environmental Working Group (EWG) is a key component of our governance structure, with sponsors and leaders from various business units including Global Procurement, Legal, ESG, and Global Product Development and Supply (GPS). The EWG, which meets monthly, is pivotal in fostering cross-functional collaboration and ensuring that our climate initiatives are integrated enterprise-wide. A sub-group of the EWG, the Climate-Related Financial Disclosure group is critical in ensuring that our financial disclosures accurately reflect our climate-related risks and opportunities. The Climate-Related Financial Disclosure group includes Corporate Financial Reporting, Internal Audit, ESG, Legal, and Environmental Sustainability and meets four to six times annually.

Disclosure Regarding Political Activities

We provide semi-annual disclosure on our website at the link below of all political contributions to political committees, parties or candidates on both state and federal levels that are made by our employee political action committee, as well as annual disclosure of the portion of our dues or other payments made to trade associations to which we give $50,000 or more that can be attributed to lobbying expenditures. Please see the company's website at: https://www.bms.com/aboutus/sustainability/economic-responsibility/political-contributions.html under ''Political Contributions.''

### Governance and compliance

The Board of Directors of Bristol Myers Squibb has delegated responsibility for oversight of our political activities to our Committee on Directors and Corporate Governance. The Committee semi-annually reviews political contributions made by the company and the BMS PAC, and annually reviews the lobbying expenditures reported by certain U.S. trade associations of which we are members. In addition, we have implemented internal and external controls to promote compliance with our political contributions policy and all applicable lobbying and political contribution laws, rules and regulations, including requiring all Bristol Myers Squibb employees to undergo training on our Principles of Integrity: BMS Standards of Business Conduct and Ethics (PDF), requiring that all federal contributions from corporate funds be approved by our Head of Federal Government Affairs, and all state contributions from corporate funds be approved by our Executive Director, State Government Affairs, and requiring that all payments by the BMS PAC be approved by its Board of Directors comprised of up to fifteen representatives from various organizational units.

Bristol Myers Squibb and its subsidiaries are committed to conducting our lobbying activities in compliance with applicable federal, state and local laws and regulations, and in a manner that is consistent with the Company's values and ethical standards. Therefore, under the federal Lobbying Disclosure Act (LDA), in-house federal lobbyists acting on behalf of Bristol Myers Squibb are required to register with the Secretary of the Senate and Clerk of the House of Representatives to provide full disclosure and full public knowledge and awareness of any lobbyist activities and gift and travel provisions. Additionally, payments made for any outside lobbying services must be disclosed by the lobbyists we retain. All of these reports are publicly available on the U.S. House of Representatives Office of the Clerk website and on the U.S. Senate Office of Public Records website. A summary of our corporate policy on disclosure of our federal lobbying activities may be found here. We file similar periodic reports with state agencies reflecting state lobbying activities which are also publicly available.

Disclosure Regarding Political Activities We provide semi-annual disclosure on our website at the link below of all political contributions to political committees, parties or candidates on both state and federal levels that are made by our employee political action committee, as well as annual disclosure of the portion of our dues or other payments made to trade associations to which we give $50,000 or more that can be attributed to lobbying expenditures. Please see the company's website at: https://www.bms.com/aboutus/sustainability/economic-responsibility/political-contributions.html under 'Political Contributions.'

Disclosure Regarding Political Activities

We provide semi-annual disclosure on our website at the link below of all political contributions to political committees, parties or candidates on both state and federal levels that are made by our employee political action committee, as well as annual disclosure of the portion of our dues or other payments made to trade associations to which we give $50,000 or more that can be attributed to lobbying expenditures.

Please see the company's website at: **https://www.bms.com/about-us/sustainability/economic-responsibility/political-** **contributions.html under "Political Contributions."** [...] The Committee on Directors and Corporate Governance continually reviews corporate governance topics, trends, and is responsible for identifying and recommending the adoption of corporate governance initiatives. In addition, our Compensation and Management Development Committee regularly reviews our compensation policies and procedures and, when appropriate, recommends changes that strengthen our compensation practices. [...] Committee on Directors and Corporate Governance

Focuses on risks associated with corporate governance, Board refreshment, Board succession planning and regularly considers and makes recommendations to the Board concerning the appropriate size, function and needs of the Board; determines the criteria for Board membership; provides oversight of our corporate governance affairs and reviews corporate governance practices and policies to manage related risks. Identifies and oversees monitoring and management of risks related to the company's political activities; environmental, social and governance strategy and reporting and the impact on the company's employees and shareholders.

Disclosure Regarding Political Activities

We provide semi-annual disclosure on our website at the link below of all political contributions to political committees, parties or candidates on both state and federal levels that are made by our employee political action committee, as well as annual disclosure of the portion of our dues or other payments made to trade associations to which we give $50,000 or more that can be attributed to lobbying expenditures. Please see the company's website at: https://www.bms.com/about-us/sustainability/economic-responsibility/political-contributions.html under 'Political Contributions.'

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes