Overview
Manage our impact responsibly
03
54
04
55
Message from the President and Chief Executive Officer
Social and environmental risk management
57
05 06 07 07 08 08
Climate related disclosures
About this report
71
Environmental impact of our operations
About us
72
Responsible procurement
Our values
Strategic direction
Our approach to sustainability
Supplemental reporting
73
Materiality assessment and stakeholder engagement Overview of our sustainability performance
74 78
Public Accountability Statement
09
SASB index
10
Maintain a foundation of trust
Appendices and Glossary
84
11
84 85
Corporate governance
How we listen to our stakeholders
16 18
Business ethics and integrity
Independent practitioner’s limited assurance report
Human rights
88 89
Forward-looking statements
Glossary
22
Obsessed with your success
23 27 32 41 49 53
Client experience
Financial inclusion
Team member experience
Diversity and inclusion
Community investment
Sustainable finance and products
2 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Overview
IN THIS SECTION
• Message from the President and Chief Executive Officer • About this report • About us • Overview of our sustainability performance
3 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
To be the best full-service bank for business owners in Canada, our approach to sustainability ensures we will continue to deliver on this commitment in an increasingly complex world. The economic backdrop was challenged last year through monetary policy actions to curb persistent inflation while Canadians also faced significant wildfires during the warmest summer on record. We deeply understand the businesses of our clients and the evolving risks they face, and that’s why our clients continue to choose us as a trusted advisor and their banking provider. We are committed to managing our approach to sustainability to focus on the areas that are most important to our clients, people, investors and communities, guided by our values, culture and strategy. Our 2023 Sustainability Report highlights our progress against this commitment. We maintain a foundation of trust under the stewardship of our diverse and experienced Board of Directors whose mandate includes our strategy, risk appetite and culture. In 2023 the Board continued to oversee our climate strategy, approach to social matters and governance structure, and reviewed our sustainability report and key ESG initiatives. Our ESG Steering Committee provided leadership and oversight of the design and execution of our approach to sustainability, ensuring intentional focus on our strategy. We are obsessed with the success of our clients and strive to deliver an unrivaled client experience with a focus on personalized and differentiated advice, and efficient and convenient transactional processing through our enhanced digital platforms. In 2023 we migrated our retail and small business clients to cwb.digital TM , along with continued enhancements to functionality. We maintain an accessible and inclusive environment where our clients with diverse needs and backgrounds see CWB as a great place to bank, and continued to expand our wealth management relationships with Indigenous communities. We are committed to building on our inclusive culture and creating opportunities and growth for our team members in an organization where skill and performance is recognized, rewarded, and celebrated. Our 11 Employee Represented Groups (ERGs) continued to provide a sense of belonging to equity-seeking groups who are often impacted by systemic Message from the President and Chief Executive Officer
Chris Fowler, President and CEO CWB Financial Group
barriers, with over one-third of our people belonging to at least one ERG. Our values and culture inspire our teams to continue to go above and beyond for our clients in challenging environments by rapidly adapting to changing conditions. I am proud of our team’s achievements as we were recognized as one of the Best Workplaces TM in Canada for the fourth consecutive year and placed in the top 25 for the second year in a row. We were also recognized by Waterstone Human Capital as having one of Canada’s Most Admired Corporate Cultures TM for the fourth time, earning a place in their hall of fame. We recognize that we have a part to play in Canada’s transition to net-zero emissions by managing our direct and indirect climate impact, and in 2023 we took decisive steps towards this goal. We developed an absolute Scope 1 and 2 GHG emissions reduction target of 42% by 2030, leveraging the guidance provided by the Science-Based Targets initiative (SBTi). We also disclosed initial estimates of Scope 3 financed emissions related to our residential mortgages and oil and gas extraction lending portfolios, and intend to expand the scope of our disclosures in future years. We also developed a climate risk heat map as an initial step to increase our understanding of the impact of physical and transition risks to key industries within our loan portfolio. I am proud of our progress this year, and confident in our ability to drive responsible, sustainable growth as we navigate the evolving landscape in front of us. I would like to express my gratitude to our clients for the opportunity to be a trusted partner in their success, and our team members for the care, dedication and integrity they have demonstrated in a challenging environment. Through their efforts we have built a strong, resilient full-service bank and are well positioned to create value for all our stakeholders going forward.
4 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
About this report This Sustainability Report includes information about Canadian Western Bank and its subsidiaries (collectively, CWB) and outlines our activity and performance related to environmental, social and governance (ESG) factors that are most important to our stakeholders (refer to Our approach to sustainability ). Unless otherwise stated, the information contained within this report pertains to our fiscal year ended October 31, 2023, and all amounts are reported in Canadian dollars.
Reporting to the Chief Financial Officer (CFO), our Sustainability team is responsible for the development of this report, which was reviewed by our ESG Steering Committee, Disclosure Committee and Board of Directors prior to its release.
PUBLIC ACCOUNTABILITY STATEMENT
This report includes our Public Accountability Statement, which describes the contributions we made to the Canadian economy and society in fiscal 2023, in alignment with the regulatory requirements outlined in section 627.996 of the Bank Act . Refer to page 74 for further details.
REPORTING STANDARDS AND FRAMEWORKS
We provide transparent disclosures on our approach to sustainability, supported by a phased adoption of several voluntary reporting frameworks, including the: – Task Force on Climate-related Financial Disclosures (TCFD) recommendations (refer to page 57 ); and, – Sustainability Accounting Standards Board (SASB) standards (refer to page 78 ). We will continue to enhance our disclosures as we advance our approach to sustainability and as related reporting regulations and stakeholder expectations evolve.
We publish a range of materials with information about our approach to sustainability and relevant ESG factors. The following publications are referenced throughout this report and can be found on CWB.com :
INDEPENDENT LIMITED ASSURANCE
We obtained limited assurance from KPMG LLP (KPMG) on our Scope 1 and 2 greenhouse gas (GHG) emissions figures disclosed on pages 9, 68 and 69 . Refer to page 85 for KPMG’s Independent Limited Assurance Report .
• ESG data pack • Annual Report • Equity Report Narrative • Management Proxy Circular Our previous Sustainability Reports can be found at www.cwb.com/en/ sustainability-reports.
WAYS TO REACH US
We welcome your feedback on this report. Please direct your questions and comments to sustainability@cwbank.com .
5 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
About us CWB is the only full-service bank in Canada with a strategic focus to meet the unique financial needs of businesses and their owners. We provide our nationwide clients with full-service business and personal banking, specialized financing, comprehensive wealth management offerings, and trust services. Clients choose CWB for a differentiated level of service through specialized expertise, customized solutions, and faster response times relative to the competition. Our people take the time to understand our clients and their business, and work as a united team to provide holistic solutions and advice. We are firmly committed to the responsible creation of value for all our stakeholders and our approach to sustainability will support our continued success. Learn more at www.cwb.com .
OUR FOOTPRINT AND IMPACT
Our national footprint
Our people
Our clients
55 retail and corporate locations Including 39 banking centres
Authorized ~ $ 38 billion (2) business financing
Employed ~2,700 (1) people
Produced 5,800 tCO 2 e Scope 1 and 2 GHG emissions (3)
Estimated 59,516 tCO 2 e Scope 3 financed GHG emissions in residential mortgages (3) Estimated 47,476 tCO 2 e Scope 3 financed GHG emissions in oil & gas extraction (3)
Estimated 794 tCO 2 e Scope 3 GHG emissions from business travel (3)
Our environmental footprint
(1) Headcount of full-time and part-time employees as reported in our Public Accountability Statement on page 76 . Full-time equivalent employees at October 31, 2023 – 2,505 (2022: 2712). (2) Total Canadian business financing as reported in our Public Accountability Statement on page 77 . (3) Refer to page 69 for more information about our GHG emissions.
6 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
Our values Our culture is who we are and how we show up – as individuals and as a team – to accomplish our strategy. We have great people who care about our clients and each other. It’s what makes us different. Our values are guideposts for how we deliver on our brand promise: Obsessed with your success.
PEOPLE FIRST
RELATIONSHIPS GET RESULTS
EMBRACE THE NEW
THE HOW MATTERS
INCLUSION HAS POWER
Change is everywhere. We seek out new ideas and are committed to continuous learning. We know that better is always possible.
How we do things is as important as
Diverse teams unleash new ideas and perspectives. We are aware of our own biases. We are proud of who we are, and we are allies for those around us.
Caring people are the key to our success. We work as a team and support one another. We always treat each other with respect and have the courage to be candid.
Clients choose CWB for the best experience. We build relationships proactively, with intention and consistency. Our results depend on it.
what we do. We take ownership, and move with urgency and efficiency. We always
act with integrity, and balance risk and reward.
OUR VISION
OUR STRATEGIC DIRECTION
Provide an unrivaled client experience tailored for business owners and their families.
Offer an engaging employee experience and culture for our inclusive and performance-driven teams.
Deliver an efficient and resilient business that drives sustained growth of our profitability.
7 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Our approach to sustainability Our values, culture and strategy guide our approach to sustainability, which addresses the ESG factors that are most important to our clients, people, investors and communities. We remain committed to long-term value creation for all our stakeholders and the sustainable growth of our business.
MAINTAIN A FOUNDATION OF TRUST Ensure the highest standards of governance, ethics and integrity to maintain the trust of our stakeholders Priority Topics* • Corporate governance • Business ethics and integrity • Human rights • Data privacy and cybersecurity
OBSESSED WITH YOUR SUCCESS Contribute to the success of our clients and their families, our people, and their communities in pursuit of a sustainable and inclusive future Priority Topics* • Client experience • Financial inclusion • Team member experience • Diversity and inclusion • Community investment • Sustainable finance and products
MANAGE OUR IMPACT RESPONSIBLY Responsibly manage our social and environmental impact, and support Canada’s transition to net-zero emissions Priority Topics* • Climate change • Environmental impact of our operations • Social and environmental risk management • Responsible procurement
*Topics identified through 2022 Materiality Analysis (see box below), not listed in priority order.
Moving forward, we will continue to embed sustainable practices that are aligned with our strategic priorities and prudent approach to risk management to help us meet the expectations of our stakeholders and regulators. By continuing to engage our people across the organization, we will advance a collective sense of purpose and amplify our impact. We are committed to provide our stakeholders with transparent reporting on our progress and performance as our approach evolves.
MATERIALITY ASSESSMENT AND STAKEHOLDER ENGAGEMENT Our sustainability strategy and priority topics incorporate feedback from internal and external stakeholders to ensure that our business activities align with the evolving needs of our diverse stakeholders. We listen to our stakeholders through ongoing engagement, as outlined in the How we listen to our stakeholders section of this report, as well as the comprehensive materiality assessment that was completed in 2022 to identify and prioritize our most significant ESG factors. Our 2022 assessment was supported by an independent consulting firm and completed based on the Global Reporting Initiative (GRI) approach, which is a commonly used framework. Further information can be found on pages 8-9 of our 2022 Sustainability Report . These priority topics will continue to be assessed regularly to ensure they continue to meet the expectations of our stakeholders.
8 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
Overview of our sustainability performance
Page reference
2023
2022
Maintain a foundation of trust
11
Women on the Board of Directors (1)
60%
55%
11
Independent Directors (1)
90%
91%
Directors who self-identify as a Black, Indigenous or racialized person (1)
11
20%
18%
Obsessed with your success
Time spent on learning and development activities (hours) (2)
35
37,647
48,302
37
76%
82%
Team member Trust Index score (3)
48
Women in senior leadership positions (4)
27%
28%
48
Black, Indigenous or racialized persons in our workforce
41%
33%
Manage our impact responsibly
Scope 1 GHG emissions (Tonnes of carbon dioxide (tCO 2 e)) Scope 2 GHG emissions (Tonnes of carbon dioxide (tCO 2 e))
69
2,229
2,339 (5)
69
3,571
3,614 (5)
69
Annual reduction in Scope 1 and 2 GHG emissions
2.6%
N/A (6)
KPMG provided limited assurance of this figure. Refer to page 85 for KPMG’s 2023 Independent Limited Assurance Report.
(1) Figures may differ from our Management Proxy Circulars , which include the slate of directors proposed for election at the next Annual General Meeting. (2) Based on hours spent completing online learning within Teal Academy and LinkedIn ® Learning. Additional time spent on learning and development activities outside of Teal Academy is not included within this figure. Methodology to determine time spent on learning and development activities was updated in 2023. (3) Measures employee engagement by averaging the scores of 60 standard statements that assess feelings of pride, camaraderie, fairness, respect and credibility, in accordance with the methodology administered by our independent third-party service provider, Great Place to Work ® . (4) Senior leadership positions comprise Executives and Senior Management. (5) KPMG previously provided assurance over our baseline 2022 Scope 1 and Scope 2 emissions. KPMG’s assurance opinion on our 2022 baseline can be found in page 74 of our 2022 Sustainability Report . In 2023, KPMG was not engaged to perform assurance procedures on our baseline 2022 Scope 1 and Scope 2 emissions and therefore have not expressed a conclusion on this information in 2023.
(6) Not reported in 2022.
9 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Ensure the highest standards of governance, ethics and integrity to maintain the trust of our stakeholders. Maintain a foundation of trust
IN THIS SECTION
2023 HIGHLIGHTS
• Corporate governance • Business ethics and integrity • Human rights • Data privacy and cybersecurity
• Continued to integrate ESG oversight into the mandates of the Board of Directors and its Committees. • 60% of Board directors are women, including our Board Chair, and 20% identify as Black, Indigenous or racialized persons, achieving our diversity targets well ahead of schedule. • Continued to enhance our cybersecurity program and security solutions for our clients, including multifactor authentication.
10 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
Corporate governance
We maintain the trust of our stakeholders through strong corporate governance practices supported by a Board of Directors with diverse experiences and perspectives. Our policies and practices foster ethical conduct, promote responsible business practices, and ensure CWB is governed with a focus to build long-term value for our stakeholders.
CORPORATE GOVERNANCE SNAPSHOT
Overview of board composition (1)
As at October 31, 2023 As at October 31, 2022
Number of Directors
10
11
Independent Directors
90%
91%
Women on the Board of Directors, including Chair (Target: 40%)
60%
55%
Directors who self-identify as a Black, Indigenous or racialized person (Target: 5%)
20%
18%
Women Committee Chairs
75%
50%
Average tenure of Directors
7.1 years
9 years
(1) Figures may differ from our Management Proxy Circulars , which include the directors proposed for election at the next Annual General Meeting.
Summary of key elements of our governance practices:
Formal mandate for Board, Board committees and Board Chair
P
Separate Chair and CEO positions
P (2)
Annually elect directors
P
Elect directors individually (not by slate)
P
Majority voting policy for directors
P
Share ownership requirements for directors P Formal mandates for the independent Chair of the Board and committee Chairs, and position description for the CEO P Retirement age for directors 75 Code of business conduct and ethics program for directors P Orientation and continuing education program for directors P Annual advisory vote on executive compensation P Formal assessment process for the Board, Chair of the Board and committee Chairs P Shareholder engagement program P
(2) Under the Bank Act, the CEO is required to serve as a director of CWB. The Chair of the Board is an independent director. Separating the roles of CEO and Chair of the Board allows the Board to effectively oversee management, enhance accountability, and avoid potential conflicts of interest.
11 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
ABOUT OUR BOARD OF DIRECTORS
With current director nominees, if elected, 56% (1) of the Board will be comprised of women, surpassing the targets for women in both our Corporate Governance policy (target of 40%) and the 30% Club. Further, 11% (1) of Board directors identify as Black, Indigenous or racialized persons, surpassing the targets in our Corporate Governance policy (target of 5%) and our BlackNorth CEO Pledge commitment, well in advance of the 2025 deadline.
Our Board’s primary responsibilities include oversight of CWB’s risk appetite, culture, strategy, capital plans and key policies, and to provide challenge, advice and guidance to senior management. To fulfill its mandate, certain responsibilities are delegated to its standing committees, which include the Audit, Governance and Conduct Review (GCR), Human Resources (HR), and Risk Committees (collectively, the Committees). Effective Board composition Our Board is composed of independent directors and our Chief Executive Officer (CEO), who have diverse backgrounds and complementary experience and expertise to ensure robust oversight. During director recruitment and succession planning, the GCR Committee seeks out suitable candidates and assesses the potential candidate’s experience and expertise against the needs of the Board and its Committees. The GCR Committee uses an expertise and skills matrix to assess our directors and regularly analyzes whether the Board has the appropriate composition. Board diversity commitments On behalf of CWB, the Chair of the Board and the President and CEO have signed on as members of the 30% Club Canada, an organization that supports the goal of having 30% of corporate board positions held by women. In 2020, the President and CEO signed the BlackNorth CEO Pledge, committing CWB to specific actions and targets designed to end anti-Black systemic racism.
(1) Refer to our most recent Management Proxy Circular for more information on the election process.
Strong governance practices Our Board works closely with management to ensure our governance approach incorporates evolving industry trends, regulatory expectations and global best practices. We ensure our governance policies meet or exceed the requirements of our regulators. We consider, and where appropriate adopt, new corporate governance best practices put forward by governance institutions, industry groups, and groups that represent the interests of our shareholders and other stakeholders.
Refer to our most recent Management Proxy Circular for more information about our approach to corporate governance. Formal mandates for the Board and its Committees can be found on our website at: www.cwb.com/corporate-governance .
Our Board continues to provide strong governance of CWB’s business and our winning strategy to be the best full-service bank for business owners in Canada. We provide close oversight of CWB’s risk appetite and risk management framework and remain focused on CWB’s evolving approach to address social and environmental risk, including climate risk. CWB continues to prioritize the ongoing success of our clients and remains committed to long-term value creation for all stakeholders and sustainable growth of our business. We are proud of the progress we have made to-date and are committed to support and engage with management as they continue to develop and implement CWB’s approach to sustainability.”
- Sarah Morgan-Silvester Chair of the Board
12 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
SUSTAINABILITY GOVERNANCE
Sustainability governance framework Our Board and management oversight frameworks support the advancement of our approach to sustainability.
Board Oversight
Board of Directors
Provides oversight of our risk appetite, culture and strategy, including the development and execution of our approach to sustainability and related public disclosures in the Sustainability Report and Public Accountability Statement.
Risk Committee
Audit Committee
HR Committee
GCR Committee
Provide oversight of ESG factors that are specific to Committee mandates.
Management Oversight
Executive Team
Responsible for the development and implementation of our strategic direction, including our approach to sustainability.
ESG Steering Committee
Executive Risk Committee (including subcommittees)
Provides oversight of risks that arise in executing our strategy, including direct social and environmental risks, and the indirect impact of these factors on other risk types.
Provides oversight of the development and implementation of our approach to sustainability, with integration to our broader corporate strategy.
Group Disclosure Committee
Provides oversight of public disclosures, including the Sustainability Report.
Execution and Socialization
Business units and corporate teams, cross-functional committees and working groups
Sustainability team, Environmental and Social Risk Management team
13 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
ESG oversight mandates The mandates of the Board and its Committees reflect specific responsibilities related to relevant ESG factors.
Committee ESG mandate
2023 highlights
Board of Directors
Responsibilities include oversight of our strategy, risk appetite and culture. Oversees our climate strategy, our enterprise approach to social matters, and our governance structure, as well as related ESG reporting.
• Received reporting on sustainability topics, including: – updates to our Sustainability Roadmap, including our evolving approach to climate change; – operational Scope 1 and 2 emissions and progress on estimation of financed Scope 3 GHG emissions; – current and emerging trends related to climate change, which could impact our business or the businesses of our clients; – the evolving regulatory and government policy landscape and potential downstream impacts; and, – stakeholders focus and engagement. • Reviewed our 2022 Sustainability Report. • Received educational material focused on Scope 3 GHG emissions. • Reviewed and recommended Board approval of the Enterprise Risk Management policy, which was updated in 2022 to include social and environmental risk in our risk universe. • Received quarterly reporting on emerged and emerging risks, including climate risk. • Reviewed management’s planned approach to continue to enhance CWB’s ESG disclosures and reporting. • Reviewed and recommended Board approval of climate disclosures in the Social and Environmental Risk section of our 2023 MD&A. • Reviewed the Environmental Protection and Social Responsibility section of our 2023 AIF. • Reviewed CWB’s Great Place to Work Canada ® engagement and trust survey results and management’s action plan. • Reviewed CWB’s updated hybrid work approach and requirements. • Reviewed CWB’s transition to a new flexible benefits program for all employees. • Reviewed progress and plans with respect to employment equity, diversity and inclusion. • Reviewed employment and workplace federal and provincial legislative developments and management’s compliance plans, including CWB’s plans and progress towards compliance with 2024 federal pay equity requirements. • Reviewed Board composition, diversity, and director succession planning. • Received educational material focused on Corporate Governance matters.
Risk Committee
Oversees our approach to principal risks and the continued integration of material social and environmental risk factors within the Risk Management framework. Oversees our financial reporting, including disclosures related to material ESG factors incorporated into the annual financial statements, annual Management’s Discussion and Analysis (MD&A) and Annual Information Form (AIF). Oversees our human capital management strategy and aspects of workplace culture, including diversity, equity and inclusion, and employee health, safety and well-being.
Audit Committee
HR Committee
GCR Committee
Oversees our corporate governance policies, practices and standards that promote ethical conduct throughout our organization as well as the allocation of sustainability oversight across the Committees.
14 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
Board responsibilities Our Board is responsible for overseeing the development and execution of our approach to sustainability and related disclosures included within our Sustainability Report and Public Accountability Statement. Our Directors have experience in sustainability matters, including environmental and social issues, and corporate governance principles and practices. Management responsibilities Our ESG Steering Committee oversees the design and execution of our approach to sustainability. The ESG Steering Committee consists of each member of our Executive team, and is supported by our Sustainability team, who engages with internal and external stakeholders and works closely with our business units and corporate teams to establish appropriate working groups tasked with the development of various components of our approach to sustainability. Our Executive Risk Committee provides oversight of our developing approach to identify, assess, monitor, and report on social and environmental risks. In addition to their participation in the ESG Steering Committee and Executive Risk Committee, members of our Executive team have specific accountabilities related to our approach to sustainability. For example, our Chief People & Culture Officer is accountable for our approach to diversity, equity and inclusion and our Chief Information Officer is responsible for cybersecurity programs.
Embedding sustainability within executive compensation
Our executive compensation philosophy aims to attract and retain a team focused on developing and executing our strategic direction, and delivering strong outcomes for our clients, people, investors and communities. A component of executive variable pay is linked to key ESG factors, such as client satisfaction, team member engagement, and diversity and inclusion across the organization. The ongoing development and execution of our approach to sustainability, including a climate transition plan, is included in the performance criteria of the performance share units (PSUs) granted under our executive long-term incentive plan (LTIP). As our approach to sustainability evolves, we will continue to explore further integration of ESG factors and targets into our compensation programs.
Refer to our most recent Management Proxy Circular for further information about our executive compensation program.
CWB Executive Committee members
Refer to our Climate related disclosures on page 57 for further information on Board and management oversight responsibilities specifically related to our approach to climate change.
15 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Business ethics and integrity
Our culture is based on the principles of integrity and accountability. Our commitment to ethical business practices is foundational to our reputation and ability to build and maintain strong relationships with our clients, people, investors and communities.
OUR APPROACH
Refer to our Code of Conduct to learn more about our approach to business ethics and integrity.
The GCR Committee oversees our ethics program, which is managed by an internal Ethics Committee comprised of senior leadership and chaired by the Chief Ethics Officer. All directors, officers and team members are held to a high ethical standard and are required to attest to our Code of Conduct on an annual basis. Our Code of Conduct proactively integrates our corporate values into our activities so that each team member contributes to an organization where we are all proud to work, where clients want to do business, and where shareholders are confident to invest.
OUR CODE OF CONDUCT
Our Code of Conduct, which is reviewed and approved annually by the Chief Ethics Officer and the Ethics Committee and approved by the Board of Directors, sets out clear expectations for our team members related to:
– Demonstrate personal integrity. – Support an inclusive work environment free of discrimination and harassment. – Promote a safe and healthy work environment.
Living our values at work
– Avoid conflicts of interest and disclose potential conflicts of interest. – Avoid gifts and entertainment that may impact business decision-making. – Maintain complete and accurate information in our documents. – Exercise responsible sales practices to deal fairly and honestly with our clients and act in their best interests. – Comply with anti-bribery and anti-corruption laws and policies. – Comply with anti-money laundering, terrorist financing and economic sanctions laws and policies. Our Know Your Customer (KYC) laws, policies, standards and practices are an essential risk management tool, and we comply with all regulatory requirements during our due diligence processes.
Living our values in business
– Use company assets and resources appropriately. – Safeguard the confidential information of our clients and team members.
Living our values for our investors
– Protect material non-public information and adhere to share trading restriction policies. – Adhere to workplace policies related to communications and social media as well as email, Internet and information systems use.
Living our values in our communities
– Avoid political contributions and political involvement on CWB’s behalf. – Adhere to specific requirements related to lobbying activities.
16 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
FOSTERING A SAFE ENVIRONMENT TO RAISE CONCERNS
Our ethics program provides avenues for our team members, contingent workers, and third parties 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 provider. We protect individuals who raise ethical concerns and prohibit retaliation against a person for reporting in good faith an issue or participating in an investigation as this 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.
TRAINING AND AWARENESS
Training is a crucial element of our ethics-based culture as it provides our team members with the knowledge required 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 periodically highlights ethics-related topics and practices to the broader organization. These 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.
of active employees (1) completed annual Code of Conduct attestations and Ethics Awareness training
(1) Active employees are defined as full-time and part-time employees as at February 24, 2024.
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. If an individual engages in job-related fraud, ethical misconduct, or a serious violation of CWB policies, our internal Human Resources (HR) function or the HR Committee of the Board may exercise its discretion to recommend disciplinary actions. For individuals at mid-level management roles or above who participate in the LTIP, actions may include recoupment of previously paid variable cash compensation, forfeiture of vested and unvested equity-based variable compensation or recoupment of any realized gains on previously exercised equity-based compensation.
17 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Human rights
Protecting human rights is crucial to building a more equitable, inclusive and sustainable society. In alignment with our culture and values, we support and respect the protection of human rights throughout our operations and across our business.
AN INTEGRATED APPROACH
To support awareness of commitments and responsibilities, our team members are required to complete training on human rights topics, including workplace harassment and violence prevention and our accessibility program, upon hire and on a regular basis thereafter. Our Ethics program provides multiple avenues for our team members and contractors to raise human rights questions and concerns, including confidential interaction with our embedded Ethics Officers and an anonymous Ethics Hotline.
We operate solely in Canada and comply with all federal, provincial and territorial human rights laws and standards, including the Canadian Human Rights Act and the Canada Labour Code. – Code of Conduct: We are guided by our values and Code of Conduct to promote an inclusive and safe work environment that is free of discrimination and harassment based on race, colour, ancestry, national or ethnic origin, pardoned criminal conviction, religious beliefs, gender, age, disability, marital status, family status, source of income, gender identity or expression, genetic characteristics or sexual orientation. – Recruitment and talent management practices: We are an equitable employer and follow a merit-based approach in all areas of employment, including recruitment, hiring, career advancement, and access to benefits and opportunities. – Accessibility program: Under our Accessibility program, we strive to create an environment where all our team members and clients have access to the support and resources they need to succeed. This includes tailored communication strategies, barrier-free access at our locations, and individualized accommodation plans to remove barriers that may affect our team members’ performance or access to training and development opportunities. – Supplier Code of Conduct: In 2023, we finalized the development of our Supplier Code of Conduct and communicated the content to our suppliers. The principles of our Supplier Code of Conduct align with our internal Code of Conduct and set out our expectations for our suppliers to act in an ethical manner and in compliance with applicable laws, including employment, labour, non-discrimination and human rights legislation (refer to Responsible Procurement for more information).
Refer to the Business ethics and integrity , Financial inclusion , Diversity and inclusion and Responsible procurement sections to learn more.
18 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
DATA PRIVACY Our approach Our comprehensive Privacy Compliance framework establishes the principles of our organization-wide privacy management program to protect the personal information of our clients and comply with applicable legal and regulatory requirements. Our Chief Privacy Officer oversees our privacy management program and is responsible to set and monitor the effectiveness of related policies and procedures. The Governance and Conduct Review (GCR) Committee of the Board oversees privacy risk management and receives regular reporting as part of its oversight responsibilities. Incidents involving suspected or actual breaches of privacy are documented and investigated by our Privacy Office. If a privacy breach has occurred, our teams follow established procedures to limit its impact, understand the root cause of the incident, ensure that the issue is remediated and take preventative steps to avoid recurrence. Where appropriate, we notify applicable regulators and impacted individuals.
Our privacy management program extends to third-party service providers, and we assess their privacy management practices and controls prior to providing them with any personal information of our clients. Once satisfied with the service provider’s procedures and safeguards, we will only provide them with the personal information required to deliver contracted services. Training and awareness We make privacy a key focus for our team members and take steps to ensure they are aware of privacy-related regulatory obligations relevant to their role, know how to comply with those obligations, and are accountable to achieve effective compliance. All team members are required to undergo privacy training as part of their onboarding experience, and on an annual basis thereafter. Privacy principles, such as only accessing information for legitimate business purposes, are also embedded in our Code of Conduct, which applies to all our directors, officers and team members.
Refer to our Privacy Statement and Online Privacy and Interest-Based Advertising Statement to learn more about our privacy management practices, including an overview of how we collect, use and disclose personal information, and the choices clients may exercise in this regard.
19 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
CYBERSECURITY Our approach
evaluate key performance indicators and metrics, such as incident response times and threat resolution effectiveness. These measures are crucial for understanding our program’s contribution to the organization’s resilience. Our program is managed by a team of technical and cybersecurity professionals dedicated to proactive identification, containment, and eradication of cybersecurity threats. We have a comprehensive control framework that is continually assessed for effectiveness using well-established threat intelligence and risk management programs. Innovation is at the heart of our cybersecurity strategy. We leverage AI-driven threat detection systems and invest in technologies that not only enhance security but also align with our environmental commitments. The CISO has a dedicated Security Operations Centre (SOC) responsible for the management of cyber incident handling, detection, response and recovery. This specialized team executes on containment strategies and recovery support in the event of a cybersecurity incident in accordance with CWB’s protocols. We proactively conduct regular threat analysis activities to identify vulnerabilities in technology and operational processes, and opportunities for remediation. Vulnerabilities are assessed across all technologies and services, and we have defined timeframes around remediation, based on the criticality of the affected service and impact or likelihood of exploitation. We maintain insurance coverage to help mitigate against certain potential losses associated with cyber incidents. Recognizing the importance of the entire supply chain to our security posture, we have a mature third-party security risk management program. This program assesses the cybersecurity practices of our vendors, ensuring they uphold the required standards.
Our cybersecurity program is a mature practice, influenced by well-recognized industry security frameworks. Guided by the National Institute of Standards and Technology (NIST) framework and aligned to industry standards like COBIT 5 and ISO/IEC 27001, we manage information security with precision and foresight. These frameworks not only bolster our defenses but also echo our dedication to responsible information technology governance and management. Our cybersecurity governance is robust, with the Chief Information Security Officer (CISO) at the helm, reporting to the Chief Information Officer, and ultimately to our Board of Directors. This governance structure ensures accountability and strategic alignment with our sustainability goals. Our Board provides oversight and receives quarterly reports, which include updates on the ongoing maturation of our program and our proactive measures for risk management. Within our three lines of defence model, our Information Security team is responsible for execution of our cybersecurity risk management program, with second and third-line oversight provided by the Risk Management and Internal Audit teams. Our Board of Directors provides oversight of our cybersecurity risk management program and receives quarterly reporting on key activities and the ongoing maturation of our program. We are committed to continuous advancement in our cybersecurity efforts. By regularly updating our practices and investing in the currency of our technology, we enhance our ability to respond to emerging threats. To demonstrate the impact of our cybersecurity initiatives, we regularly
2023 HIGHLIGHTS
• Continued to prioritize IT governance and data protection by investing in our people, processes, technology and governance programs to ensure our clients’ information remains secure in an evolving threat landscape;
• Focused on the protection of client information through enhanced data security safeguards as we continue to advance our digital banking and payments capabilities;
• Continued to enhance key knowledge and capabilities within our Cybersecurity Incident Response team to advance our understanding of the rapidly changing landscape and respond to cyber incidents; and,
• Provided Board and executive education sessions, with support from external experts, focused on elevated cybersecurity risks and the development of a cybersecurity risk appetite statement.
20 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Appendices and Glossary
Overview
Training and awareness Our cybersecurity training program is transparent and inclusive, engaging with the community and stakeholders to foster a shared culture of security. We conduct employee training and public awareness initiatives that emphasize the importance of cybersecurity in achieving sustainable development goals. The program includes mandatory monthly employee training requirements, with shifting areas of focus based on current and emerging threats, and simulation tests to assess the effectiveness of our training programs. Areas within the organization that require more focused training are assessed on a regular basis to ensure our team members within higher-risk job functions understand their responsibilities to protect our systems and information. Each October, we also complete an organization-wide cybersecurity awareness campaign in association with National Cybersecurity Awareness month.
In 2023 our “Step up your cyber fitness” Cybersecurity Awareness Month campaign featured: • A webinar on the most common cyber threats and tools for online safety; • Articles on how to avoid social engineering scams and why Multifactor Authentication is an essential cybersecurity defence tool; • Resources and a quiz on cyber fitness.
Information Security Oce
Supporting our clients With the launch of our retail and small business digital platform in 2023, we released cyber and fraud awareness communications and enabled Multifactor Authentication for these clients.
21 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Team Teal members partner with the Christmas Bureau of Edmonton to pack food hampers for families in need
Obsessed with your success
Contribute to the success of our clients and their families, our people, and their communities in pursuit of a sustainable and inclusive future.
IN THIS SECTION • Client experience • Financial inclusion • Team member experience
HIGHLIGHTS
• Migrated our retail and small business clients to cwb.digital TM . • Launched a suite of business credit cards, in partnership with Brim Financial. • Recognized as one of the Best Workplaces TM in Canada by Great Place to Work Canada ® for the fourth consecutive year and by Waterstone Human Capital as having one of Canada’s Most Admired Corporate Cultures TM for the fourth time, earning a place in their hall of fame. • Our diverse workforce included 59% women, 41% Black, Indigenous or racialized persons, 7% Persons with Disabilities and 2% persons who self-identify as 2SLGBTQIA+. • Invested over 37,000 hours in learning and development activities. • Over $1.7 million invested in community organizations.
• Diversity and inclusion • Community investment • Sustainable finance and products
22 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Page 74 Page 75 Page 76 Page 77 Page 78 Page 79 Page 80 Page 81 Page 82 Page 83 Page 84 Page 85 Page 86 Page 87 Page 88 Page 89 Page 90 Page 91 Page 92Powered by FlippingBook