BMO Financial Group is driven by enduring corporate values. These values represent our core beliefs. They stand as our collective commitment – to our colleagues, to our customers, to our shareholders and to the communities of which we are a part. These values live in the way we work, in the solutions we offer, in the employment environment we provide and in the way we partner with the community.
Code of Conduct
Read
BMO's Code of Conduct, called
FirstPrinciples
| Case Study: Conflict of Interest |
Scenario:
Keith is an Investment Advisor at BMO Nesbitt Burns. A new offering of a public company's shares has just been announced. The offering is attracting a lot of interest. Keith has been allocated 5,000 shares to meet the demand of his clients. Keith has several clients whose combined interest in the offering exceeds the allocation he has received. One client, Marie, is sure she can make a quick profit on the re-sale of the shares and would therefore like to acquire as many of them as she can. In a conversation with Marie, Keith relates how he has promised his wife a European vacation but the cost of taking a trip like that is beyond his means. Marie offers Keith the use of her vacation home in France for two weeks if he allots the entire 5,000 shares to her.
|
Question:
Should Keith accept the offer of the use of a client's vacation home in exchange
for the full allotment? |
Answer:
No. By accepting Marie's offer on these terms, Keith would be misusing his
position and accepting an improper gift or benefit. Keith's personal
interests should not be a consideration. He must fairly allocate the
shares among his clients based on BMO's best interests and the suitability
of the investment to his clients. For example, it might be appropriate
to allocate more of the new issue to a client who has provided more significant
amounts of business to BMO. |
What is it?
FirstPrinciples is our code of business conduct and ethics. It reflects our commitment to doing what is fair, legal and right.
Who
does the Code of Conduct Apply to?
FirstPrinciples applies to all BMO Financial Group directors, officers
and employees. We also make our major suppliers aware of our code of conduct.
Code of Conduct Training
Every year, all active, permanent full-time and
permanent part-time BMO employees, directors and officers must read FirstPrinciples and complete an online questionnaire that demonstrates their understanding
and relevance of the Code.
How often is the Code of Conduct updated?
Each year, our Corporate Compliance department conducts a rigorous review of FirstPrinciples, benchmarking our code of conduct against best practices within the global financial services industry and regulatory environment, before presenting it to our Board for review and approval. BMO’s Board of Directors approved the most recent version of FirstPrinciples in November 2007.
How is the Code of Conduct made available?
FirstPrinciples is published in both English and French on various internal sites and on bmo.com. BMO’s intranet contains information for managers and employees on how to apply FirstPrinciples in their daily work and lists key contacts for those seeking guidance on specific issues relating to the Code.
Exceptions and Escalation
Exceptions to FirstPrinciples are not typical, nor are they encouraged. Any
exception for a director, officer or employee must be approved by the Audit
Committee of the Board of Directors. When required by applicable law, rule
or regulation, exceptions shall be disclosed to the appropriate regulatory
bodies.
Protecting Whistleblowers
We encourage any BMO employee who has concerns relating to a breach or potential
breach of either FirstPrinciples or any law, regulation or BMO policy to
immediately report the concern to one of the appropriate persons and departments
listed
on our FirstPrinciples web site.
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Corporate Responsibility Governance
At BMO, the notion of corporate responsibility is embedded throughout the organization – it just makes sense. Various areas are responsible for the specific economic, social, and environmental policies and programs that comprise corporate responsibility. Our Corporate Responsibility Unit is responsible for identifying best practices and emerging issues in corporate responsibility, and determining their applicability to the organization.
Our Corporate Responsibility Policy outlines management’s approach for dealing with social and environmental issues. The policy is reviewed and approved by the Risk Review Committee of the Board of Directors.
We also have a Corporate Responsibility Committee, which is comprised of executives
from across the organization and serves as a forum to discuss various corporate
responsibility issues and their impact on the bank.
At BMO, we have well-developed and long-standing corporate policies on social
and ethical issues. As part of our framework for ethical decision-making,
we have enterprise-wide policies covering:
- anti-money laundering and terrorist financing
- business continuity management
- corruption and bribery
- confidentiality of information
- conflicts of interest
- equal opportunity and harassment
- financial governance
- health and safety
- human resources management
- market disclosure
- privacy of personal information
- operation of our compliance framework
- relationships with external auditors
- securities trading by employees
- whistleblower protection
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