BANK OF MONTREAL /CAN/

The Bank’s Code of Conduct (“Code”) is a principles-based foundational document that outlines the Bank’s expectation around business conduct and ethical behaviour. It is applicable to every director and employee of the Bank. In fiscal 2024 the Bank completed a refresh of the Code, primarily intended to increase accessibility and ensure content is relevant and aligned with evolving business and regulatory expectations. The content of the prior Code was simplified and enhanced. The most significant changes include: (1) a shift from 5 principles to 5 new commitments; (2) new content and expanded topics including, diversity, equity and inclusion, human rights, responsible use of artificial intelligence, reputation risk, and approved channels for business communications; and (3) other general enhancements including new Chair and Chief Executive Officer messages and the addition of more references and resource links. In addition to these changes, certain other technical, administrative, or non-substantive amendments were made to the Code. The amended version of the Code was furnished to the Commission on Form 6-K on March 4, 2024. The Code is available on the Bank’s website

www.bmo.com/main/about-bmo

under “Learn more about us” and is available in print without charge to any shareholder upon request. Unless and to the extent specifically referred to herein, the information on the Bank’s website shall not be deemed to be incorporated by reference in this annual report on Form 40-F.