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
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