Responsible procurement
To maintain strong ethical, social and environmental performance across our supply chain, we strive to work with partners and suppliers who operate in a manner that is aligned with our values and demonstrate responsible and sustainable business practices.
OUR SUPPLIER CODE OF CONDUCT
Our Procurement team governs our sourcing activities across a broad range of suppliers, and we continue to further integrate ESG considerations into our processes. Our Third-Party Risk Management program, with support from Business Lines, Subject Matter Experts, and suppliers, facilitates a risk-based due diligence process for all suppliers. As part of our due diligence processes for high-risk engagements, we assess the supplier’s approach to various ESG factors, including ethical business practices, policies and programs, corporate social governance, and other areas of reputational or legal concern. We also screen our suppliers for adverse media, sanctions, and watchlists.
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 related to: • Responsible business practices and business integrity including economic responsibility, social responsibility, ethics, employment practices and human rights, diversity and inclusion, health and safety, and environmental responsibility; and • Information and data management including information
access controls, privacy and information security, encryption, and data retention and destruction.
We are committed to working collaboratively with our suppliers through the implementation of our Supplier Code of Conduct to ensure adherence to our expectations.
2023 HIGHLIGHTS
• To support compliance with the updated OSFI Guideline B-10 on Third Party Risk Management, we have implemented enhancements to our third party risk management process to improve efficiency, ongoing monitoring and reporting capabilities. We expect our third party risk management processes to evolve and increase in sophistication as we move forward.
72 2023 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
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