FOSTERING A SAFE ENVIRONMENT TO RAISE CONCERNS
TRAINING AND AWARENESS
Training is a crucial aspect of our ethics-based culture that provides our team members with knowledge to understand their responsibilities to act with integrity and in compliance with regulatory requirements. Our ethics program sets out mandatory training requirements for our team members and hosts a periodic Ethics Week to shine a spotlight on ethics- related topics and practices. Training requirements address a wide range of topics, including anti-money laundering and anti-terrorist financing, ethics awareness, fraud awareness, operational risk management, economic sanctions laws, workplace harassment and violence prevention, material non-public information and insider training.
Our ethics program provides avenues for our team members and contractors to raise serious ethical questions and concerns, through multiple levels of intervention, including confidential interaction with our embedded Ethics Officers or an anonymous Ethics Hotline, which is managed by a third-party service provider. We protect individuals who raise ethical concerns and retaliation against a person for reporting an issue or participating in an investigation is a serious violation of our Code of Conduct. A summary report of all concerns raised or identified is provided to the Ethics Committee and the GCR Committee on a quarterly basis.
EMBEDDING ETHICAL BEHAVIOUR WITHIN COMPENSATION
Team member performance management and compensation are directly aligned to ethical decision-making and risk management. A significant portion of every team member’s performance rating is based on performance drivers, which include acting with integrity and in line with our values. Further, if an individual at the level of Assistant Vice President, a mid-level management role, or above engages in job-related fraud, ethical misconduct, or a serious violation of CWB policies, the HR Committee may exercise its discretion to recoup previously paid variable cash compensation, require forfeiture of vested and unvested equity-based variable compensation or recoup any realized gains on previously exercised equity-based compensation.
16 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
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