Corporate Governance at Block

Block has formed a cross-functional working group from multiple business areas that serves as the central coordinating body for our corporate responsibility efforts. An ESG Lead oversees this team and the broader ESG program, connects key stakeholders across the company, and reports up to senior leadership and the Nominating and Corporate Governance Committee.

The Nominating and Corporate Governance Committee is responsible for overseeing ESG and corporate responsibility matters of significance to Block and receives quarterly reports on these matters from our ESG Lead. The Nominating and Corporate Governance Committee also receives quarterly Inclusion & Diversity reports from our People Lead and Inclusion & Diversity Lead.

Our Board recognizes the oversight of risk management as one of its primary responsibilities and central to maintaining an effective, risk-aware, and accountable organization. This includes the oversight of our Enterprise Risk Assessment (ERA) framework, which is supported and enabled by our Audit and Risk Committee. While our Board maintains ultimate responsibility for the oversight of risk, it implements a multilayered approach. This approach involves delegating certain responsibilities to the appropriate board committees to ensure that primary areas of focus are thoroughly discussed and that a pervasive understanding of such focus areas is obtained. These primary risk focus areas are defined by the Board, senior leadership, and leaders of our ERA as strategic, operational, people, financial, and compliance and legal, and consist of risks such as cybersecurity, financial reporting, and competition. Our Board promotes an appropriate culture of risk management to set the right “tone at the top,” while our senior leadership is responsible for the day-to-day management of risk within Block.

Given the regulated industries in which we operate, our Board believes in robust oversight of compliance with laws and regulations. The Chief Compliance Officer has dotted line reporting to the Audit and Risk Committee, provides a quarterly update to the Audit and Risk Committee, and conducts an annual compliance training for our Board. Our employees also receive annual compliance training. We conduct an annual independent assessment of the company’s global Anti-Money Laundering/Counter Terrorist Financing and Sanctions Compliance programs.

We are dedicated to fostering and maintaining high ethical standards and integrity in all our operations, in every country in which we operate or have business connections. We maintain a Code of Business Conduct and Ethics (the Employee Code) and a Supplier Code of Business Conduct and Ethics (the Supplier Code, and together with the Employee Code, the Codes of Conduct). The Employee Code holds each of our directors, executive officers, and all other employees accountable to approach their work lawfully, honestly, ethically, and in the best interest of Block. The Supplier Code encourages all Block suppliers to approach business lawfully, ethically, and with integrity, good judgment, and fairness. The Codes of Conduct serve as guides for such conduct, and the policies and procedures within show our respective employees and suppliers how to uphold the Codes of Conduct in their day-to-day activities. We continually evaluate the Codes of Conduct and make updates when needed.