BNY
Mellon
ETF
Trust
ANNUAL
REPORT
October
31,
2022
BNY
Mellon
Sustainable
International
Equity
ETF
Contents
The
Fund
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The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
•
Not
Bank-Guaranteed
•
May
Lose
Value
Discussion
of
Fund
Performance
3
Fund
Performance
7
Understanding
Your
Fund’s
Expenses
8
Statement
of
Investments
9
Statement
of
Assets
and
Liabilities
12
Statement
of
Operations
13
Statement
of
Changes
in
Net
Assets
14
Financial
Highlights
15
Notes
to
Financial
Statements
16
Report
of
Independent
Registered
Public
Accounting
Firm
25
Important
Tax
Information
26
Liquidity
Risk
Management
Program
27
Board
Members
Information
29
Officers
of
the
Trust
31
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
December
14,
2021,
the
fund’s
inception,
through
October
31,
2022,
as
provided
by
Paul
Markham
and
Nick
Pope,
Portfolio
Managers
employed
by
the
fund’s
sub-adviser,
Newton
Investment
Management
Limited.
Market
and
Fund
Performance
Overview
For
the
period
from
December
14,
2021,
the
fund’s
inception,
through
October
31,
2022,
the
BNY
Mellon
Sustainable
International
Equity
ETF
(the
“fund”)
produced
a
total
return
of
−27.57%
at
net
asset
value.
1
In
comparison,
the
fund’s
benchmark,
the
MSCI
EAFE
®
Index
(the
“Index”),
produced
a
total
return
of
−19.24%
for
the
same
period.
2
International
equities
declined
during
the
reporting
period
under
pressure
from
increasing
inflation,
tightening
central
bank
policies
and
uncertainties
related
to
Russia’s
invasion
of
Ukraine.
The
fund
underperformed
the
Index
largely
due
to
the
fund’s
allocations
to
the
energy
and
information
technology
sectors,
and
stocks
selections
in
health
care,
financials
and
consumer
staples.
The
Fund’s
Investment
Approach
The
fund
seeks
long-term
capital
appreciation.
To
pursue
its
goal,
the
fund
normally
invests
at
least
80%
of
its
net
assets
(plus
the
amount
of
any
borrowings
for
investment
purposes)
in
equity
securities
of
foreign
companies
that
demonstrate
attractive
investment
attributes
and
sustainable
business
practices.
The
fund
considers
a
foreign
company
to
be
a
company
organized
or
with
its
principal
place
of
business
in,
or
that
has
a
majority
of
its
assets
or
business
in,
or
whose
securities
are
primarily
listed
or
traded
on
exchanges
in,
a
country
outside
the
United
States.
The
fund’s
sub-adviser,
Newton
Investment
Management
Limited
(Newton),
an
affiliate
of
the
BNY
Mellon
ETF
Investment
Adviser,
LLC,
considers
a
company
to
be
engaged
in
“sustainable
business
practices”
if
the
company
engages
in
such
practices
in
an
economic
sense
(i.e.,
the
company's
strategy,
operations
and
finances
are
stable
and
durable),
and
takes
appropriate
measures
to
manage
any
material
consequences
or
impact
of
its
policies
and
operations
in
relation
to
environmental,
social
and
governance
(ESG)
matters
(e.g.,
the
company’s
environmental
footprint,
labor
standards,
board
structure,
etc.).
Companies
engaged
in
sustainable
business
practices
also
may
include
companies
that
have
committed
explicitly
to
improving
their
environmental
and/or
social
impacts
that
will
lead
to
a
transformation
of
their
business
models.
Mounting
Inflation
Drives
Markets
Lower
While
international
equities
moved
higher
over
the
end
of
December
2021,
the
start
of
2022
represented
the
most
challenging
period
faced
by
equity
investors
since
the
outbreak
of
the
COVID-19
pandemic.
Russia’s
invasion
of
Ukraine
was
the
defining
geopolitical
and
economic
event
contributing
to
equity
market
weakness
during
the
period.
However,
by
the
time
the
invasion
took
place
in
February
2022,
equity
indices
had
already
come
under
considerable
pressure.
The
proximate
cause
was
the
U.S.
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
Federal
Reserve
(the
“Fed”)
turning
more
hawkish,
and
the
growing
expectations
that
it
was
poised
to
hike
rates
more
aggressively
than
previously
expected,
potentially
complemented
with
quantitative
tightening.
Weakness
in
China
also
weighed
on
investor
sentiment,
given
the
implications
for
economic
growth
and
supply
chains.
These
forces
drove
government
bond
yields
steeply
higher
and
put
acute
pressure
on
higher-multiple
equities.
Stocks
in
energy
producers
surged
along
with
oil
and
gas
prices.
Many
other
commodity
producer
stocks
climbed
as
well,
while
sectors
seen
as
“defensive,”
such
as
utilities
and
consumer
staples,
proved
relatively
resilient.
However,
growth-oriented
shares
suffered
as
political
instability
and
the
threat
of
rising
interest
rates
caused
investors
to
question
the
relative
value
of
future
earnings.
The
risk
of
recession
loomed
toward
the
end
of
June
amid
concerns
regarding
aggressive,
global
monetary
tightening
in
response
to
rising
inflation.
However,
stock
markets
started
the
third
quarter
on
a
firmer
footing,
bolstered,
in
part,
by
a
quarterly
corporate
reporting
season
that
proved
better
than
feared.
Additional
positive
momentum
was
generated
when
investors
discerned
a
less
hawkish
tone
from
Fed
Chair
Powell
as
he
announced
a
0.75%
increase
in
U.S.
interest
rates
in
July.
However,
a
subsequent
Powell
speech
just
a
month
later
disabused
markets
of
any
nascent
hopes
that
a
dovish
policy
pivot
might
materialize
in
the
near
future.
September
inflation
numbers
came
in
higher
than
expected,
underscoring
the
argument
in
favor
of
maintaining
tight
U.S.
monetary
conditions.
These
factors
placed
downward
pressure
on
risk
assets,
exacerbated
by
Russia’s
actions
to
cut
flows
of
natural
gas
to
Europe
ahead
of
winter.
International
equities
moved
higher
in
October
on
hopes
of
easing
monetary
policy,
although
the
risk
of
recession
remained
a
real
concern.
China-linked
equities
declined
as
Xi
Jinping,
the
country’s
president,
revealed
a
new
leadership
team
that
demonstrated
his
tightening
grip
on
power,
while
data
showed
the
Chinese
economy
falling
short
of
Beijing’s
growth
target.
Allocations
and
Stock
Selections
Detract
Commodity-related
shares
exhibiting
strong
performance
against
the
backdrop
of
war
in
Ukraine
and
rising
inflation
lacked
characteristics
consistent
with
the
portfolio’s
sustainable
mandate.
In
particular,
the
fund’s
zero
exposure
to
the
energy
sector
undermined
returns
relative
to
the
Index.
At
the
same
time,
the
market’s
shift
from
favoring
growth-oriented
shares
to
favoring
value-oriented
shares
also
raised
significant
headwinds
for
the
fund,
given
the
growth
bias
often
inherent
in
names
supported
by
sustainable
themes.
Overweight
exposure
to
information
technology
detracted
as
investors
reappraised
tech-related
valuations
in
the
face
of
surging
inflation,
tighter
monetary
policy
and
geopolitical
uncertainty.
Disappointing
returns
from
several
individual
stock
selections
further
hampered
performance,
particularly
in
the
health
care,
financials
and
consumer
staples
sectors.
Among
notably
underperforming
holdings,
shares
in
Taiwan
Semiconductor
Manufacturing
fell
victim
to
demand
worries
and
the
outlook
for
the
semiconductor
industry
as
a
whole.
The
stock
of
Japanese
human-resources
company
Recruit
was
hit
by
a
market
rotation
out
of
higher-multiple
5
names;
we
sold
the
fund’s
position
late
in
the
period,
cognizant
of
the
negative
impact
that
a
recession
could
have
on
the
recruitment
market
in
the
United
States
and
Japan.
Shares
in
UK-based
insurer
Prudential
struggled
as
lockdown
measures
implemented
in
China
suggested
a
further
delay
to
a
recovery
in
sales
in
the
region.
However,
we
view
this
as
a
temporary
issue
and
remain
positive
on
the
stock’s
long-term
opportunity.
On
the
positive
side,
underweight
consumer
discretionary
exposure
contributed
positively
to
performance.
Stock
picking
in
information
technology
aided
relative
performance
as
well,
despite
the
detrimental
impact
of
overweight
sector
exposure.
Top-performing
individual
holdings
included
UK-based
equipment
leasing
firm
Ashtead
Group
and
Switzerland-based
Zurich
Insurance.
Ashtead
Group
shares
benefited
from
management’s
confident
tone
on
the
outlook
for
U.S.
construction,
and
from
strong
quarterly
results
from
Ashtead
Group
and
its
competitors.
Zurich
Insurance
shares
benefited
from
a
favorable
backdrop
for
commercial
insurance
pricing
and
the
company’s
positive
leverage
to
rising
yields.
The
quality
of
the
business
and
its
defensive
attributes
also
resonated
with
investors,
as
did
a
favorable
outlook
for
pricing
power
in
the
face
of
claims
inflation
for
the
remainder
of
the
year,
as
well
as
a
share
buyback,
announced
sooner
than
expected
to
offset
the
expected
earnings
dilution
from
the
company’s
life
insurance
back-book
sale
in
Germany.
Maintaining
the
Fund’s
Long-Term
Focus
As
of
October
31,
2022,
international
equity
markets
continue
to
face
now-familiar
headwinds:
rising
inflation,
more
hawkish
policies
from
global
central
banks,
political
uncertainty
and
growing
concern
regarding
the
possibility
of
a
recession.
These
challenges
are
likely
to
remain
in
place
over
the
shorter
term
although,
as
we
reflect
on
the
extent
to
which
equities
have
now
derated,
the
focus
may
soon
turn
to
earnings
resilience
in
a
weakening
economic
environment,
with
both
revenues
and
margins
subject
to
vulnerability.
In
light
of
this
environment,
we
continue
to
consider
adjustments
to
the
fund’s
positions
with
these
dynamics
in
mind,
while
remaining
wary
of
those
businesses
that
may
prove
vulnerable
to
a
higher
interest-rate
environment.
Given
the
high
degree
of
uncertainty
and
wide
dispersion
of
views
within
the
market,
we
continue
to
focus
the
fund’s
assets
in
highly
sustainable
businesses
that
we
believe
will
be
long-term
winners,
and
that
can
prove
resilient
in
a
wide
range
of
outcomes.
Currently,
the
fund
holds
its
largest
overweight
position
in
information
technology
in
the
belief
that
the
fundamental
business-model
strength
and
growth
prospects
of
our
holdings
will
reassert
in
time.
Conversely,
the
fund
holds
underweight
exposure
to
consumer
discretionary,
given
the
growing
intensity
of
the
squeeze
on
incomes
and
likely
headwinds
for
the
consumer
over
the
coming
months.
November
15,
2022
1
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
ETFs
are
bought
and
sold
at
market
prices,
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
6
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
2
Source:
Lipper
Inc.
—
The
MSCI
EAFE
®
Index
(Europe,
Australasia,
Far
East)
is
a
free
float-adjusted,
market
capitalization-weighted
index
that
is
designed
to
measure
the
equity
market
performance
of
developed
markets,
excluding
the
U.S.
and
Canada.
It
reflects
reinvestment
of
net
dividends
and,
where
applicable,
capital
gain
distributions.
Investors
cannot
invest
directly
in
any
index.
Please
note:
the
position
in
any
security
highlighted
with
italicized
typeface
was
sold
during
the
reporting
period.
ETFs
trade
like
stocks,
are
subject
to
investment
risk,
including
possible
loss
of
principal.
ETF
shares
are
listed
on
an
exchange,
and
shares
are
generally
purchased
and
sold
in
the
secondary
market
at
market
price.
At
times,
the
market
price
may
be
at
a
premium
or
discount
to
the
ETF’s
per
share
NAV.
In
addition,
ETFs
are
subject
to
the
risk
that
an
active
trading
market
for
an
ETF’s
shares
may
not
develop
or
be
maintained.
Buying
or
selling
ETF
shares
on
an
exchange
may
require
payment
of
brokerage
commissions.
The
fund
may,
but
is
not
required
to,
use
derivative
instruments.
A
small
investment
in
derivatives
could
have
a
potentially
large
impact
on
the
fund’s
performance.
The
use
of
derivatives
involves
risks
different
from,
or
possibly
greater
than,
the
risks
associated
with
investing
directly
in
the
underlying
assets.
Equities
are
subject
generally
to
market,
market
sector,
market
liquidity,
issuer
and
investment
style
risks,
among
other
factors,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
Recent
market
risks
include
pandemic
risks
related
to
COVID-19.
The
effects
of
COVID-19
have
contributed
to
increased
volatility
in
global
markets
and
will
likely
affect
certain
countries,
companies,
industries
and
market
sectors
more
dramatically
than
others.
To
the
extent
the
fund
may
overweight
its
investments
in
certain
countries,
companies,
industries
or
market
sectors,
such
positions
will
increase
the
fund's
exposure
to
risk
of
loss
from
adverse
developments
affecting
those
countries,
companies,
industries
or
sectors.
Investing
internationally
involves
special
risks,
including
changes
in
currency
exchange
rates,
political,
economic
and
social
instability,
a
lack
of
comprehensive
company
information,
differing
auditing
and
legal
standards
and
less
market
liquidity.
These
risks
generally
are
greater
with
emerging-markets
countries
than
with
more
economically
and
politically
established
foreign
countries.
Environmental,
social
and
governance
(ESG)
managers
may
take
into
consideration
factors
beyond
traditional
financial
information
to
select
securities,
which
could
result
in
relative
investment
performance
deviating
from
other
strategies
or
broad
market
benchmarks,
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
Further,
ESG
strategies
may
rely
on
certain
values-based
criteria
to
eliminate
exposures
found
in
similar
strategies
or
broad
market
benchmarks,
which
could
also
result
in
relative
investment
performance
deviating.
FUND
PERFORMANCE
(Unaudited)
7
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Sustainable
International
Equity
ETF
with
a
hypothetical
investment
of
$10,000
in
the
MSCI
EAFE
®
Index
(the
“Index”).
†
Source:
Lipper
Inc.
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Sustainable
International
Equity
ETF
on
12/14/21
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
Index
(Europe,
Australasia,
Far
East)
is
a
free
float-adjusted,
market
capitalization-weighted
index
that
is
designed
to
measure
the
equity
market
performance
of
developed
markets,
excluding
the
U.S.
and
Canada.
It
reflects
reinvestment
of
net
dividends
and,
where
applicable,
capital
gain
distributions.
Investors
cannot
invest
directly
in
any
index.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
Average
Annual
Total
Returns
as
of
October
31,
2022
Inception
Date
From
Inception
BNY
Mellon
Sustainable
International
Equity
ETF
Net
Asset
Value
Return
12/14/21
(27.57)%
Market
Price
Return
12/14/21
(27.36)%
MSCI
EAFE
®
Index
12/14/21
(19.24)%
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
8
As
a
shareholder
of
the
fund,
you
pay
ongoing
expenses,
such
as
management
fees
and
other
expenses.
Using
the
information
below,
you
can
estimate
how
these
expenses
affect
your
investment
and
compare
them
with
the
expenses
of
other
funds.
For
more
information,
see
your
fund’s
prospectus
or
talk
to
your
financial
adviser.
Actual
Expenses
The
information
under
each
column
in
the
table
below
entitled
“Actual”
provides
information
about
on
how
much
a
$1,000
investment
would
be
worth
at
the
close
of
the
period,
assuming
net
asset
value
total
returns
and
actual
expenses.
You
may
use
the
information
in
these
columns,
together
with
the
amount
you
invested,
to
estimate
the
expenses
that
you
paid
over
the
period.
Simply
divide
your
account
value
by
$1,000
(for
example,
an
$8,600
account
value
divided
by
$1,000
=
8.6),
then
multiply
the
result
by
the
number
for
the
fund
under
the
heading
entitled
“Expenses
paid
for
the
period”
to
estimate
the
expenses
you
paid
on
your
account
during
this
period.
Hypothetical
Example
For
Comparison
Purposes
The
Securities
and
Exchange
Commission
(“SEC”)
has
established
guidelines
to
help
investors
assess
fund
expenses.
The
information
under
each
column
in
the
table
entitled
“Hypothetical”
provides
information
about
hypothetical
account
values
and
hypothetical
expenses
based
on
the
fund’s
actual
expense
ratio
and
assuming
a
hypothetical
5%
annualized
return,
which
is
not
the
fund’s
actual
return.
The
hypothetical
account
values
and
expenses
may
not
be
used
to
estimate
the
actual
ending
account
balance
or
expenses
you
paid
for
the
period.
You
may
use
this
information
to
compare
the
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
To
do
so,
compare
this
5%
hypothetical
example
with
the
5%
hypothetical
examples
that
appear
in
the
shareholder
reports
of
the
other
funds.
Please
note
that
the
expenses
shown
in
the
table
are
meant
to
highlight
your
ongoing
costs
only
and
do
not
reflect
any
transactional
costs,
such
as
brokerage
commissions
paid
on
purchases
and
sales
of
fund
shares.
Therefore,
the
ending
account
values
and
expenses
paid
for
the
period
in
the
table
are
useful
in
comparing
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
In
addition,
if
these
transactional
costs
were
included,
your
costs
would
have
been
higher.
For
the
six
months
ended
October
31,
2022
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
six-month
period
ended
October
31,
2022.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
184/365.
Beginning
account
value
($)
Ending
account
value($)
Expense
paid
for
the
period
($)
Annualized
expense
ratios
for
the
period
(%)
Actual
Hypothetical
Actual
Hypothetical
Actual
(a)
Hypothetical
(a)
1,000.00
1,000.00
843.20
1,021.68
3.25
3.57
0.70
STATEMENT
OF
INVESTMENTS
October
31,
2022
9
Description
Shares
Value
($)
Common
Stocks
–
96.3%
Australia
–
1.3%
Dexus
(a)
18,925
93,938
China
–
1.3%
Ping
An
Insurance
Group
Co.
of
China
Ltd.,
Class
H
23,000
92,004
Denmark
–
4.7%
CHR
Hansen
Holding
A/S
3,193
177,316
Orsted
A/S
(b)
1,991
164,210
341,526
France
–
10.5%
Bureau
Veritas
SA
5,335
132,177
Legrand
SA
2,293
174,804
L'Oreal
SA
827
259,977
Sanofi
2,278
196,600
763,558
Germany
–
6.1%
Infineon
Technologies
AG
6,313
153,725
RWE
AG
1,826
70,359
SAP
SE
2,240
216,210
440,294
Hong
Kong
–
5.2%
AIA
Group
Ltd.
27,804
210,576
Prudential
PLC
17,809
165,593
376,169
India
–
3.1%
HDFC
Bank
Ltd.
12,502
226,049
Indonesia
–
2.3%
Bank
Rakyat
Indonesia
(Persero)
Tbk
PT
549,200
163,730
Ireland
–
1.8%
Smurfit
Kappa
Group
PLC
3,845
126,728
Japan
–
13.1%
M3,
Inc.
3,700
110,630
Seven
&
i
Holdings
Co.
Ltd.
4,500
168,082
Sony
Group
Corp.
2,900
194,796
Sugi
Holdings
Co.
Ltd.
1,600
64,239
Suntory
Beverage
&
Food
Ltd.
4,500
150,711
Topcon
Corp.
12,200
133,819
Toyota
Industries
Corp.
2,400
123,636
945,913
Netherlands
–
7.6%
ASML
Holding
NV
397
187,536
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Shares
Value
($)
Common
Stocks
–
96.3%
(continued)
Netherlands
–
7.6%
(continued)
Universal
Music
Group
NV
7,221
141,667
Wolters
Kluwer
NV
2,099
223,095
552,298
Norway
–
2.2%
Mowi
ASA
10,858
161,938
South
Korea
–
3.1%
Samsung
SDI
Co.
Ltd.
432
223,514
Spain
–
2.5%
Industria
de
Diseno
Textil
SA
8,109
183,835
Switzerland
–
5.4%
Lonza
Group
AG
386
198,676
Zurich
Insurance
Group
AG
456
194,586
393,262
Taiwan
–
3.5%
Taiwan
Semiconductor
Manufacturing
Co.
Ltd.
21,004
254,219
United
Kingdom
–
16.1%
Ascential
PLC
(c)
23,043
50,737
Ashtead
Group
PLC
3,781
197,291
AstraZeneca
PLC
2,568
301,979
Croda
International
PLC
1,837
142,411
Genus
PLC
2,932
85,876
Informa
PLC
24,488
156,029
RELX
PLC
8,459
227,632
1,161,955
United
States
–
6.5%
CSL
Ltd.
920
165,057
Roche
Holding
AG
929
308,522
473,579
Total
Investments
(cost
$9,347,544)
96.3%
6,974,509
Cash
and
Receivables
(Net)
3.7%
264,955
Net
Assets
100.0%
7,239,464
(a)
Investment
in
a
real
estate
investment
trust.
(b)
Security
exempt
from
registration
pursuant
to
Rule
144A
under
the
Securities
Act
of
1933.
These
securities
may
be
resold
in
transactions
exempt
from
registration,
normally
to
qualified
institutional
buyers.
At
October
31,
2022,
these
securities
were
valued
at
$164,210
or
2.27%
of
net
assets.
(c)
Non-income
producing
security.
11
See
Notes
to
Financial
Statements
Portfolio
Summary
(Unaudited)
†
Value
(%)
Health
Care
18.8
Information
Technology
16.2
Industrials
14.8
Financials
14.6
Consumer
Staples
11.1
Materials
6.2
Consumer
Discretionary
5.2
Communication
Services
4.8
Utilities
3.3
Real
Estate
1.3
96.3
†
Based
on
net
assets.
STATEMENT
OF
ASSETS
AND
LIABILITIES
October
31,
2022
12
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
9,347,544
6,974,509‌
Cash
238,020‌
Cash
denominated
in
foreign
currency
16,181
15,794‌
Dividends
receivable
8,237‌
Tax
reclaim
receivable—Note
2(b)
7,132‌
7,243,692‌
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
4,228‌
4,228‌
Net
Assets
($)
7,239,464‌
Composition
of
Net
Assets
($):
Paid-in
capital
10,002,050‌
Total
distributable
earnings
(loss)
(2,762,586‌)
Net
Assets
($)
7,239,464‌
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
200,001‌
Net
asset
value
per
share
36.20‌
Market
price
per
share
36.30‌
STATEMENT
OF
OPERATIONS
For
the
Period
from
December
15,
2021
(commencement
of
operations)
to
October
31,
2022
13
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends
(net
of
$18,482
foreign
taxes
withheld
at
source):
Unaffiliated
issuers
134,628‌
Total
Income
134,628‌
Expenses:
Management
fee—Note
3(a)
52,214‌
Total
Expenses
52,214‌
Net
Investment
Income
82,414‌
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
and
foreign
currency
transactions
(465,494‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
and
foreign
currency
transactions
(2,374,154‌)
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
(2,839,648‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
(2,757,234‌)
STATEMENT
OF
CHANGES
IN
NET
ASSETS
14
See
Notes
to
Financial
Statements
For
the
Period
from
December
15,
2021
(a)
to
October
31,
2022
Operations
($):
Net
investment
income
82,414‌
Net
realized
gain
(loss)
on
investments
(465,494‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
(2,374,154‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
(2,757,234‌)
Distributions
($):
Distributions
to
shareholders
(5,352‌)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
10,000,050‌
Transaction
fees—Note
5
2,000‌
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
10,002,050‌
Total
Increase
(Decrease)
in
Net
Assets
7,239,464‌
Net
Assets
($):
Beginning
of
Period
—‌
End
of
Period
7,239,464‌
Changes
in
Shares
Outstanding:
Shares
sold
200,001‌
Net
Increase
(Decrease)
in
Shares
Outstanding
200,001‌
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
15
The
following
table
describes
the
performance
for
the
fiscal
period
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
For
the
Period
from
December
15,
2021
(a)
to
October
31,
2022
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
50.00‌
Investment
Operations:
Net
investment
income
(b)
0.41‌
Net
realized
and
unrealized
gain
(loss)
on
investments
(14.19‌)
Total
from
Investment
Operations
(13.78‌)
Distributions:
Dividends
from
net
investment
income
(0.03‌)
Transaction
fees
(b)
0.01‌
Net
asset
value,
end
of
period
36.20‌
Market
price,
end
of
period
(c)
36.30‌
Net
Asset
Value
Total
Return
(%)
(d)
(27.57‌)
(e)
Market
Price
Total
Return
(%)
(d)
(27.36‌)
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.70‌
(f)
Ratio
of
net
investment
income
to
average
net
assets
1.10‌
(f)
Portfolio
Turnover
Rate
(g)
27.08‌
Net
Assets,
end
of
period
($
x
1,000)
7,239‌
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
The
mean
between
the
last
bid
and
ask
prices.
(d)
Net
asset
value
total
return
is
calculated
assuming
an
initial
investment
made
at
the
net
asset
value
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
net
asset
value
during
the
period,
and
redemption
at
net
asset
value
on
the
last
day
of
the
period.
Net
asset
value
total
return
includes
adjustments
in
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
and
as
such,
the
net
asset
value
for
financial
reporting
purposes
and
the
returns
based
upon
those
net
asset
values
may
differ
from
the
net
asset
value
and
returns
for
shareholder
transactions.
Market
price
total
return
is
calculated
assuming
an
initial
investment
made
at
the
market
price
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
market
price
during
the
period,
and
sale
at
the
market
price
on
the
last
day
of
the
period.
Total
investment
returns
calculated
for
a
period
of
less
than
one
year
are
not
annualized.
(e)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
(f)
Annualized.
(g)
Portfolio
turnover
rate
is
not
annualized
for
periods
less
than
one
year,
if
applicable,
and
does
not
include
securities
received
or
delivered
from
processing
creations
or
redemptions.
NOTES
TO
FINANCIAL
STATEMENTS
16
NOTE
1—Organization:
BNY
Mellon
Sustainable
International
Equity
ETF (the “fund”) is a
separate
non-
diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
fifteen
series,
including
the
fund.
The
fund
had
no
operations
until December
15,
2021
(commencement
of
operations),
other
than
matters
relating
to
its
organization
and
registration
under
the
Act.
The
investment
objective
of
the
fund
is
to
seek
long-term
capital
appreciation.
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
a
wholly-owned
subsidiary
of
The
Bank
of
New
York
Mellon
Corporation
(“BNY
Mellon”),
serves
as
the
fund’s
investment
adviser. Newton
Investment
Management
Limited (the
“Sub-Adviser”),
a
wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a
wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
NYSE
Arca,
Inc.
The
market
price
of
each
Share
may
differ
to
some
degree
from
the
fund’s
net
asset
value
(“NAV”).
Unlike
conventional
mutual
funds,
the
fund
issues
and
redeems
Shares
on
a
continuous
basis,
at
NAV,
only
in
a
large
specified
number
of
Shares,
each
called
a
“Creation
Unit.”
Creation
Units
are
issued
and
redeemed
principally
in
exchange
for
the
deposit
or
delivery
of
a
basket
of
securities.
Except
when
aggregated
in
Creation
Units
by
Authorized
Participants,
the
Shares
are
not
individually
redeemable
securities
of
the
fund.
Individual
fund
Shares
may
only
be
purchased
and
sold
on
the
NYSE
Arca,
Inc.,
other
national
securities
exchanges,
electronic
crossing
networks
and
other
alternative
trading
systems
through
your
broker-dealer
at
market
prices.
Because
fund
Shares
trade
at
market
prices
rather
than
at
NAV,
fund
Shares
may
trade
at
a
price
greater
than
NAV
(premium)
or
less
than
NAV
(discount).
When
buying
or
selling
Shares
in
the
secondary
market,
you
may
incur
costs
attributable
to
the
difference
between
the
highest
price
a
buyer
is
willing
to
pay
to
purchase
Shares
of
the
fund
(bid)
and
the
lowest
price
a
seller
is
willing
to
accept
for
Shares
of
the
fund
(ask). 
NOTE
2—Significant
Accounting
Policies: 
The
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standards
Codification
(“ASC”)
is
the
exclusive
reference
of
authoritative
U.S.
generally
accepted
accounting
principles
(“GAAP”)
recognized
by
the
FASB
to
be
applied
by
nongovernmental
entities.
Rules
and
interpretive
releases
of
the
SEC
under
authority
of
federal
laws
are
also
sources
of
authoritative
GAAP
for
SEC
registrants. The
fund
is an
investment
company
and
applies
the
accounting
and
reporting
guidance
17
of
the
FASB
ASC
Topic
946
Financial
Services-Investment
Companies. The
fund’s
financial
statements
are
prepared
in
accordance
with
GAAP,
which
may
require
the
use
of
management
estimates
and
assumptions.
Actual
results
could
differ
from
those
estimates.  
The
Trust
accounts
separately
for
the
assets,
liabilities
and
operations
of
each
series.
Expenses
directly
attributable
to
each
series
are
charged
to
that
series’
operations;
expenses
which
are
applicable
to
all
series
are
allocated
among
them
on
a
pro
rata
basis.
The
Trust
enters
into
contracts
that
contain
a
variety
of
indemnifications.
The
fund’s
maximum
exposure
under
these
arrangements
is
unknown.
The
fund
does
not
anticipate
recognizing
any
loss
related
to
these
arrangements. 
(a)
Portfolio
valuation:
The
fair
value
of
a
financial
instrument
is
the
amount
that
would
be
received
to
sell
an
asset
or
paid
to
transfer
a
liability
in
an
orderly
transaction
between
market
participants
at
the
measurement
date
(i.e.,
the
exit
price).
GAAP
establishes
a
fair
value
hierarchy
that
prioritizes
the
inputs
of
valuation
techniques
used
to
measure
fair
value.
This
hierarchy
gives
the
highest
priority
to
unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
(Level
1
measurements)
and
the
lowest
priority
to
unobservable
inputs
(Level
3
measurements).
Additionally,
GAAP
provides
guidance
on
determining
whether
the
volume
and
activity
in
a
market
has
decreased
significantly
and
whether
such
a
decrease
in
activity
results
in
transactions
that
are
not
orderly.
GAAP
requires
enhanced
disclosures
around
valuation
inputs
and
techniques
used
during
annual
and
interim
periods.
Various
inputs
are
used
in
determining
the
value
of
the
fund’s
investments
relating
to
fair
value
measurements.
These
inputs
are
summarized
in
the
three
broad
levels
listed
below:
Level
1
—
unadjusted
quoted
prices
in
active
markets
for
identical
investments.
Level
2
—
other
significant
observable
inputs
(including
quoted
prices
for
similar 
investments,
interest
rates,
prepayment
speeds,
credit
risk,
etc.).
Level
3
—
significant
unobservable
inputs
(including
the
fund’s
own
assumptions
in
determining
the
fair
value
of
investments).
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
18
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee,
effective
September
8,
2022, to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies)
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy. 
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they
are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
Investments
denominated
in
foreign
currencies
are
translated
to
U.S.
dollars
at
the
prevailing
rates
of
exchange.
The
table
below
summarizes
the
inputs
used
as
of October
31,
2022
in
valuing
the
fund’s
investments:
19
Fair
Value
Measurements
(b)
Foreign
currency
transactions:
The
fund
does
not
isolate
that
portion
of
the
results
of
operations
resulting
from
changes
in
foreign
exchange
rates
on
investments
from
the
fluctuations
arising
from
changes
in
the
market
prices
of
securities
held.
Such
fluctuations
are
included
with
the
net
realized
and
unrealized
gain
or
loss
on
investments.
Net
realized
foreign
exchange
gains
or
losses
arise
from
sales
of
foreign
currencies,
currency
gains
or
losses
realized
on
securities
transactions
between
trade
and
settlement
date,
and
the
difference
between
the
amounts
of
dividends,
interest
and
foreign
withholding
taxes
recorded
on
the
fund’s
books
and
the
U.S.
dollar
equivalent
of
the
amounts
actually
received
or
paid.
Net
unrealized
foreign
exchange
gains
and
losses
arise
from
changes
in
the
value
of
assets
and
liabilities
other
than
investments
resulting
from
changes
in
exchange
rates.
Foreign
currency
gains
and
losses
on
foreign
currency
transactions
are
also
included
with
net
realized
and
unrealized
gain
or
loss
on
investments.
Foreign
Taxes:
The
fund
may
be
subject
to
foreign
taxes
(a
portion
of
which
may
be
reclaimable)
on
income,
stock
dividends,
realized
and
unrealized
capital
gains
on
investments
or
certain
foreign
currency
transactions.
Foreign
taxes
are
recorded
in
accordance
with
the
applicable
foreign
tax
regulations
and
rates
that
exist
in
the
foreign
jurisdictions
in
which
the
fund
invests.
These
foreign
taxes,
if
any,
are
paid
by
the
fund
and
are
reflected
in
the
Statement
of
Operations,
if
applicable.
Foreign
taxes
payable
or
deferred
or
those
subject
to
reclaims
as
of
October
31,
2022,
if
any,
are
disclosed
in
the
fund’s
Statement
of
Assets
and
Liabilities.
(c) Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-
dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
(d)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
are
defined
as
“affiliated”
under
the
Act. 
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
6,974,509
—
—
6,974,509
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
20
(e)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
The
value
of
a
security
may
also
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
company
or
industry,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
the
general
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates,
changes
to
inflation,
adverse
changes
to
credit
markets
or
adverse
investor
sentiment
generally.
In
addition,
turbulence
in
financial
markets
and
reduced
liquidity
in
equity,
credit
and/or
fixed
income
markets
may
negatively
affect
many
issuers,
which
could
adversely
affect
the
fund.
Global
economies
and
financial
markets
are
becoming
increasingly
interconnected,
and
conditions
and
events
in
one
country,
region
or
financial
market
may
adversely
impact
issuers
in
a
different
country,
region
or
financial
market.
These
risks
may
be
magnified
if
certain
events
or
developments
adversely
interrupt
the
global
supply
chain;
in
these
and
other
circumstances,
such
risks
might
affect
companies
world-wide.
Recent
examples
include
pandemic
risks
related
to
COVID-19
and
aggressive
measures
taken
world-wide
in
response
by
governments,
including
closing
borders,
restricting
international
and
domestic
travel,
and
the
imposition
of
prolonged
quarantines
of
large
populations,
and
by
businesses,
including
changes
to
operations
and
reducing
staff.
Foreign
Investment
Risk:
To
the
extent
the
fund
invests
in
foreign
securities,
the
fund’s
performance
will
be
influenced
by
political,
social
and
economic
factors
affecting
investments
in
foreign
issuers.
Special
risk
associated
with
investments
in
foreign
issuers
include
exposure
to
currency
fluctuations,
less
liquidity,
less
developed
or
less
efficient
trading
markets,
lack
of
comprehensive
company
information,
political
and
economic
instability
and
differing
auditing
and
legal
standards.
Non-Diversification
Risk:
The
fund
is
non-diversified,
which
means
that
the
fund
may
invest
a
relatively
high
percentage
of
its
assets
in
a
limited
number
of
issuers.
Therefore,
the
fund’s
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
(f)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
and
dividends
from net
realized
capital
gains,
if
any,
are
normally
declared
and
paid
annually,
but
the
fund
may
make
distributions
on
a
more
frequent
basis
to
comply
with
the
distribution
requirements
of
the
Internal
Revenue
Code
of
1986,
as
amended
(the
“Code”).
To
the
extent
that
net
realized
capital
gains
can
be
offset
by
capital
loss
carryovers
of
a
fund,
it
is
the
policy
of
the
fund
not
to
distribute
such
gains.
Income
and
capital
gain
distributions
are
determined
in
accordance
with
income
tax
regulations,
which
may
differ
from
GAAP.
21
(g)
Federal
income
taxes:
It
is
the
policy
of
the
fund
to
continue
to qualify
as
a
regulated
investment
company,
if
such
qualification
is
in
the
best
interests
of
its
shareholders,
by
complying
with
the
applicable
provisions
of
the
Code,
and
to
make
distributions
of
taxable
income
and
net
realized
capital
gain sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
As
of
and
during
the period
ended October
31,
2022,
the
fund
did
not
have
any
liabilities
for
any
uncertain
tax
positions.
The
fund
recognizes
interest
and
penalties,
if
any,
related
to
uncertain
tax
positions
as
income
tax
expense
in
the
Statement
of
Operations.
During
the period
ended October
31,
2022,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
year
in
the
period
ended
October
31,
2022 remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
At October
31,
2022,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
undistributed
ordinary
income
$70,461,
accumulated
capital
losses
$458,893, and
unrealized depreciation
$2,374,154.
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
October
31,
2022.
The
fund
has
$458,893
of
short-term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
year
ended
October
31,
2022
were
as
follows:
ordinary
income
$5,352.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.70%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expenses,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
22
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
October
31,
2022,
there
was
no
reduction
in
expenses
pursuant
to
the
undertaking.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
percentage
of
the
value
of
the
fund's
average
daily
net
assets.
The
Adviser
has
obtained
an
exemptive
order
from
the
SEC
(the
“Order”),
upon
which
the
fund
may
rely,
to
use
a
manager
of
managers
approach
that
permits
the
Adviser,
subject
to
certain
conditions
and
approval
by
the
Board,
to
enter
into
and
materially
amend
sub-investment
advisory
agreements
with
one
or
more
sub-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-advisory
fee
payable
by
the
Adviser
separately
to
a
Sub-Adviser
that
is
a
wholly-owned
subsidiary
(as
defined
in
the
1940
Act)
of
BNY
Mellon
in
documents
filed
with
the
SEC
and
provided
to
shareholders;
such
fees
are
to
be
aggregated
with
fees
payable
to
the
Adviser.
The
Adviser
has
ultimate
responsibility
(subject
to
oversight
by
the
Board)
to
supervise
any
Sub-Adviser
and
recommend
the
hiring,
termination,
and
replacement
of
any
Sub-Adviser
to
the
Board.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.35%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
(b)
The
fund
has
an
arrangement
with
The
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, whereby
the
fund
will
receive
interest
income
or
be
charged
overdraft
fees
when
cash
balances
are
maintained.
For
financial
reporting
purposes,
the
fund
includes
this
interest
income
and
overdraft
fees,
if
any,
as
interest
income
in
the
Statement
of
Operations.
The
components
of
“Due
to
BNY
Mellon
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $4,228.
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Trust
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds.
23
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
during
the
period
ended
October
31,
2022, amounted
to $3,334,887
and
$2,218,908,
respectively.
At October
31,
2022,
the
cost
of
investments
for
federal
income
tax
purposes
was
$9,348,663;
accordingly,
accumulated
net
unrealized
depreciation on
investments
for
federal
income
tax
purposes was
$2,374,154,
consisting
of
gross
appreciation
of
$49,801
and
gross
depreciation
of
$2,423,955.
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
24
In-kind
Redemptions:
For
financial
reporting
purposes,
in-kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
year
ended
October
31,
2022,
the
fund
had
in-kind
transactions
associated
with
creations
of
$8,690,458
and
redemptions
of
$0.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
25
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Sustainable
International
Equity
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Sustainable
International
Equity
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
October
31,
2022,
and
the
related
statements
of
operations,
changes
in
net
assets,
and
the
financial
highlights
for
the
period
from
December
15,
2021
(commencement
of
operations)
through
October
31,
2022
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
October
31,
2022,
the
results
of
its
operations,
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
period
from
December
15,
2021
(commencement
of
operations)
through
October
31,
2022,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audit.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
("PCAOB")
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audit
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audit,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audit
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
October
31,
2022,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audit
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audit
provides
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
December
21,
2022
IMPORTANT
TAX
INFORMATION
(Unaudited)
26
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended October
31,
2022:
For
federal
tax
purposes
the
fund
hereby
reports
100.00%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
October
31,
2022 as
qualified
dividend
income.
The
fund
intends
to
elect
to
pass
through
to
shareholders
the
credit
for
taxes
paid
to
foreign
countries.
The
fund
received foreign
source
income
of $153,114
and
paid
foreign
taxes
of
$18,482.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
27
The
funds
have
adopted
a
liquidity
risk
management
program
(the
“Program”)
pursuant
to
the
requirements
of
Rule
22e-4
under
the
Investment
Company
Act
of
1940,
as
amended.
Rule
22e-4
requires
registered
open-end
funds,
including
exchange-traded
funds,
to
establish
liquidity
risk
management
programs
in
order
to
effectively
manage
fund
liquidity
and
shareholder
redemptions.
The
rule
is
designed
to
mitigate
the
risk
that
a
fund
could
not
meet
redemption
requests
without
significantly
diluting
the
interests
of
remaining
investors.
The
Board
has
appointed
BNY
Mellon
ETF
Investment
Adviser,
LLC,
the
investment
adviser
to
the
funds,
as
the
Program
Administrator.
The
rule
requires
each
fund
to
assess,
manage
and
review
its
liquidity
risk
at
least
annually,
considering
applicable
factors
such
as
investment
strategy
and
liquidity
during
normal
and
reasonably
foreseeable
stressed
conditions,
including
whether
the
strategy
is
appropriate
for
an
open-end
fund
and
whether
the
fund
has
a
relatively
concentrated
portfolio
or
large
positions
in
particular
issuers.
Each
fund
must
also
assess
its
use
of
borrowings
and
derivatives,
short-
term
and
long-term
cash
flow
projections
in
normal
and
reasonably
foreseeable
stressed
conditions,
holdings
of
cash
and
cash
equivalents,
and
borrowing
arrangements
and
other
funding
sources.
In
addition,
with
respect
to
an
exchange-traded
fund,
a
fund
must
assess
the
relationship
between
the
fund’s
portfolio
liquidity
and
the
way
in
which,
and
the
prices
and
spreads
at
which,
the
fund’s
shares
trade,
and
the
effect
of
the
composition
of
baskets
on
the
overall
liquidity
of
the
fund’s
portfolio.
The
rule
also
generally
requires
funds
to
classify
each
of
their
investments
as
highly
liquid,
moderately
liquid,
less
liquid
or
illiquid
based
on
the
number
of
days
the
fund
expects
it
would
take
to
liquidate
the
investment,
and
to
review
these
classifications
at
least
monthly
or
more
often
under
certain
conditions.
Illiquid
investments
are
those
a
fund
does
not
expect
to
be
able
to
sell
or
dispose
of
within
seven
calendar
days
without
the
sale
or
disposition
significantly
changing
the
market
value
of
the
investment.
A
fund
is
prohibited
from
acquiring
an
investment
if,
after
the
acquisition,
its
holdings
of
illiquid
assets
will
exceed
15%
of
its
net
assets.
In
addition,
if
a
fund
permits
redemptions
in-kind,
the
rule
requires
the
fund
to
establish
redemption
in-kind
policies
and
procedures
governing
how
and
when
it
will
engage
in
such
redemptions.
Pursuant
to
the
rule’s
requirements,
the
Program
has
been
reviewed
and
approved
by
the
Board.
Furthermore,
at
its
October
2022
meeting,
the
Board
received
a
written
report
prepared
by
the
Program
Administrator,
for
the
period
October
1,
2021
to
September
30,
2022,
addressing
the
operation
of
the
Program,
assessing
the
Program’s
adequacy
and
effectiveness
and
describing
any
material
changes
made
to
the
Program.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
(continued)
28
Assessment
of
Program
In
the
opinion
of
the
Program
Administrator,
the
Program
approved
by
the
Board
continues
to
be
adequate
for
the
funds
and
the
Program
has
been
implemented
effectively.
The
Program
Administrator
has
monitored
each
fund’s
liquidity
risk
and
the
liquidity
classification
of
the
securities
held
by
the
funds
and
has
determined
that
the
Program
is
operating
effectively.
During
the
period
from
October
31,
2021
to
September
30,
2022,
there
were
no
material
changes
to
the
Program
and
no
material
liquidity
events
that
impacted
the
funds.
During
the
period,
each
fund
held
sufficient
highly
liquid
assets
to
meet
fund
redemptions.
Under
normal
expected
foreseeable
fund
redemption
forecasts
and
foreseeable
stressed
fund
redemption
forecasts,
the
Program
Administrator
believes
that
each
fund
maintains
sufficient
highly
liquid
assets
to
meet
expected
fund
redemptions.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
29
J.
Charles
Cardona
(66)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY
Mellon
ETF
Trust,
Chairman
and
Trustee
(2020-Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004-Present)
and
Chairman
(2019-2021)
No.
of
Portfolios
for
which
Board
Member
Serves:
38,
including
23
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(62)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017).
No.
of
Portfolios
for
which
Board
Member
Serves:
15
F.
Jack
Liebau,
Jr.
(59)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
–
Present;
Chairman
of
Board
2016
–
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
15
Jill
I.
Mavro
(50)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
CapWGlobal,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
15
30
BOARD
MEMBERS
INFORMATION
(Unaudited)
(continued)
INDEPENDENT
BOARD
MEMBERS
Kevin
W.
Quinn
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
15
Stacy
L.
Schaus
(62)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
15
The
address
of
the
Board
Members
and
Officers
is
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC,
240
Greenwich
Street,
New
York,
New
York
10286.
Additional
information
about
each
Board
Member
is
available
in
the
fund’s
Statement
of
Additional
Information
which
can
be
obtained
from
the
Adviser
free
of
charge
by
calling
this
toll
free
number:
1-833-383-2696.
OFFICERS
OF
THE
TRUST
(Unaudited)
31
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
(“BNYM
Investment
Adviser”)
since
February
2021;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
since
January
2018;
and
Director
of
Product
Strategy,
BNY
Mellon
Investment
Management
from
January
2016
to
December
2017.
He
is
an
officer
of
55
investment
companies
(comprised
of
109
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
44
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005.
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNYM
Investment
Advisor
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Vice
President
of
BNYM
Investment
Adviser
since
September
2020;
and
Director-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
64
years
old
and
has
been
an
employee
of
the
Adviser
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021;
and
Senior
Counsel
of
BNY
Mellon
from
March
2013
to
December
2017.
She
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
47
years
old
and
has
been
an
employee
of
the
Adviser
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNYM
Investment
Adviser.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
February
2016
to
August
2018.
She
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
the
Adviser
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
57
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services
from
September
2018
to
May
2019;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
April
2015
to
August
2018.
She
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
37
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2019.
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
32
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Product,
BNY
Mellon
Investment
Management
since
January
2018;
Co-Head
of
Product
Management,
Development
&
Oversight
of
North
America
Product,
BNYM
Investment
Management
from
January
2010
to
January
2018;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
since
2010.
He
is
an
officer
of
55
investment
companies
(comprised
of
109
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
53
years
old
and
has
been
an
employee
of
BNY
Mellon
Securities
Corporation
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Head
of
Product
Management
of
North
America
Product,
BNYM
Investment
Management
since
January
2018;
Director
of
Product
Research
and
Analytics
of
North
America
Product,
BNYM
Investment
Management
from
January
2010
to
January
2018;
and
Senior
Vice
President
of
North
America
Product,
BNYM
Investment
Management
since
2010.
He
is
an
officer
of
55
investment
companies
(comprised
of
109
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
46
years
old
and
has
been
an
employee
of
BNY
Mellon
Securities
Corporation
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
56
investment
companies
(comprised
of
130
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Chief
Compliance
Officer
since
August
2021
and
Vice
President
and
Assistant
Secretary
since
February
2020
of
BNY
Mellon
ETF
Trust;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNYM
Investment
Adviser
from
April
2018
to
August
2021.
She
is
an
officer
of
55
investment
companies
(comprised
of
129
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
37
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
48
investment
companies
(comprised
of
122
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2022
BNY
Mellon
Securities
Corporation
4860AR1022
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
(inside
the
U.S.
only)
Mail
BNY
Mellon
ETF
Trust,
240
Greenwich
Street,
New
York,
New
York
10286
E-Mail
Send
your
request
to
[email protected]
Internet
Information
can
be
viewed
online
or
downloaded
at
www.im.bnymellon.
com
BNY
Mellon
ETF
Trust
discloses,
at
www.im.bnymellon.com
,
the
identities
and
quantities
of
the
securities
held
by
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
“
SEC
”
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
’
s
Forms
N-PORT
are
available
on
the
SEC
’
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
fund
’
s
complete
schedule
of
portfolio
holdings,
as
filed
on
Form
N-PORT,
can
also
be
obtained
without
charge,
upon
request,
by
calling
1-833-383-2696.
A
description
of
the
policies
and
procedures
that
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
fund
voted
these
proxies
for
the
most
recent
12-month
period
ended
June
30
is
available
at
www.im.bnymellon.
com
and
on
the
SEC’s
website
at
www.sec.gov
.
The
description
of
the
policies
and
procedures
is
also
available
without
charge,
upon
request,
by
calling
1-833-383-2696.
BNY
Mellon
ETF
Trust
Custodian
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC
240
Greenwich
Street
New
York,
NY
10286
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Adviser
Transfer
Agent
&
Dividend
Disbursing
Agent
BNY
Mellon
ETF
Investment
Adviser,
LLC
201
Washington
Street
Boston,
MA
02108
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Sub-Adviser
Distributor
Newton
Investment
Management
Limited
160
Queen
Victoria
Street
London,
EC4V,
4LA,
UK
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Sustainable
International
Equity
ETF
BKIS
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