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FirstPrinciplesOUR CODE OF BUSINESS CONDUCT AND ETHICS
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Message from the CEO ...................................................... 3
BMO – Our Values ............................................................... 4
FirstPrinciples ................................................ 5
Principle 1
Maintain your personal integrity ..................................... 6
Principle 2
Follow both the letter and spirit of the law ........................ 7
Principle 3Report concerns promptly .............................................. 9
Principle 4
Protect information, systems and other assets ................. 11
Principle 5
Avoid conflicts of interest ............................................. 14
Principle 6Ensure personal activities do not harm BMO .................... 16
Principle 7Ensure personal trading complies with law and policy ....... 18
Conclusion ....................................................................... 19
Report your concerns ...................................................... 20
Important resources ........................................................ 20
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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FirstPrinciples was created to clearly and concisely identify the accountabilities we share as employees of this company. It is the responsibility of each one of us to:
• hold ourselves to the highest standard of integrity;
• follow both the letter and the spirit of the law;
• act as guardians of BMO’s reputation by promptly
bringing forward concerns we may have about possible
breaches of our code;
• protect the information entrusted to us;
• never use our position to promote our personal
interests over those of the company;
• ensure that our personal activities do not harm BMO;
and, finally,
• never use non-public information for personal gain.
FirstPrinciplesWe take pride in the fact that people choose
to bank with BMO because we make money
make sense. As bankers we know we enjoy
that opportunity because we first earned
their respect.
When your business is helping people manage
their money, perhaps more than any other
profession, it is not only what you do for
customers, but also how you do it that matters
to them.
BMO is known for integrity and responsibility
– it’s a long-established reputation that we’ve
nurtured and built upon for almost 200 years.
Today, 47,000 of us are the stewards of that
vital element of our brand.
And so, the jobs we hold bring with them
responsibilities that shape the way we do
our daily tasks and goals. Individually and
collectively we are BMO – in the eyes of our
customers, our regulators, the law and each
other – this is why we have FirstPrinciples:
Our Code of Business Conduct and Ethics.
There is one more responsibility we all share –
to know thoroughly the principles contained in
this booklet and apply them in our work every
day. This booklet makes that task easy. In these
pages you’ll find our FirstPrinciples described in
precise, plain language.
Review these principles every now and then.
Take the time to think about the code and how
it applies to you and your work. Our customers’
success defines our success – and that begins
with our most basic responsibility: knowing
what’s right.
Bill Downe
President and Chief Executive Officer
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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OUR VALUES
Take Pride In what we do and where we work.
Keep Your Word Never waver from our commitments to our customers and each other.
Embrace Diversity Gain strength through our people and our perspectives.
Do the Right Thing Demonstrate respect for all and earn trust through integrity of our actions.
Have Courage to Win Focus on what makes us successful.
Our Way and Our Values are at the heart of the BMO culture. Our Values represent what we stand for and Our Way is how we put those values into practice. FirstPrinciples, Our Code of Business Conduct and Ethics provides us with a set of rules to guide that behaviour in everything we do at BMO, ensuring that we really do practise what we preach.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
OUR WAY
• Works Collaboratively
• Delivers Results
• Makes Things Happen
• Leads Us Higher
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Context and DirectionThis is our code of business conduct and ethics,
called FirstPrinciples. It sets out rules and
principles that help us do the right thing when
dealing with our clients, suppliers, other
stakeholders and each other. It reflects our
commitment to high standards of business
conduct and ethics, and builds on our proud
tradition of doing what is fair, right and legal.
All our Corporate Policies, Corporate Standards,
Operating Procedures, subsidiary policies,
and other codes or guidance documents
must follow and be consistent with the Code.
In the event of any inconsistency, the Code
will prevail.
FirstPrinciples is very important and we all need
to follow its seven principles – our reputation
depends on it. We are judged on our integrity,
as well as our competence.
Read the Code and Seek Advice We all want to foster a working environment
that upholds the highest ethical standards.
So it is essential to read and understand
FirstPrinciples, as well as the Corporate Policies,
Corporate Standards, Operating Procedures
and Subsidiary Policies that give further
guidance on how to interpret and apply it.
Together, they help us to do our jobs effectively
while conducting ourselves fairly and ethically.
Retaliation is not tolerated. We are committed
to maintaining a culture of integrity and ethical
behaviour, and it’s important to us to foster a
work environment where everyone feels secure
voicing their concerns.
If you have concerns or are unsure about the
legal, ethical or reputational implications of
a situation, consult your manager, or any of
the people or departments in FirstPrinciples
Contacts and Useful Links on the Ethics Office
website.
You should feel comfortable reporting any
possible violation of our Code of Conduct. We
prohibit retaliation against anyone who reports
concerns in good faith or participates in any
related review, investigation or proceeding.
Any act of retaliation is a violation of the Code.
Reports or complaints made in bad faith are
also viewed as violations of the Code and may
result in disciplinary action, up to and including
dismissal of the complainant.
Not Following FirstPrinciples Can Have Serious ConsequencesIf you don’t follow FirstPrinciples our
reputation could suffer damage and we
might lose business. Conduct inconsistent
with FirstPrinciples is very serious and may
lead to discipline, ranging from counselling
to suspension or termination of employment.
It may also mean lower compensation.
Similar consequences may result from failing
to co-operate in an investigation relating
to FirstPrinciples or from retaliating against
someone who reports a concern under
FirstPrinciples.
We may also sue anyone who harms BMO by
not following FirstPrinciples and may contact
outside authorities if laws are broken.
FirstPrinciplesOUR CODE OF BUSINESS CONDUCT AND ETHICS
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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“ BMO is committed to high standards of business conduct and ethics. Ethical business practices are critical to BMO’s success. Our customers, our shareholders, the communities in which we operate and our fellow employees expect each of us to be honest, fair and legal in all that we do. FirstPrinciples, our Code of Conduct, helps to guide us in continuing to operate honestly, fairly and within the law.”
Blair Morrison Senior Vice-President , Deputy General Counsel
and Chief Compliance Officer BMO Financial Group
Principle 1Maintain your personal integrity
Be honest and fair in all your decisions and actions.
1. Follow the highest ethical standards to earn and keep the trust and respect of your
colleagues and our stakeholders – including customers, suppliers, shareholders and
the public.
2. Keep workplace relationships professional and free of discrimination and harassment.
• Discrimination – includes all forms of discrimination based on race, colour, religion,
national or ethnic origin, age, gender, gender identity or expression, sexual
orientation, marital status, military or veteran status, physical or mental disability,
or a criminal offence for which a pardon has been granted.
• Harassment – includes displays of offensive, unwelcome, intimidating or
humiliating behaviour – intentional or otherwise – that could reasonably be
interpreted as demeaning others and undermining efforts to maintain a safe,
comfortable and productive workplace.
3. Never retaliate against any other employee for raising ethical concerns.
4. Avoid personal behaviour that harms your reputation and ours, including:
• Alcohol and substance abuse that impairs work performance or calls our ethical
standards into question. Alcohol is prohibited on BMO premises – except at sanctioned
and supervised BMO events. If you drink at these events, do so responsibly.
• Gambling that impairs work performance.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Principle 2Follow both the letter and spirit of the law
We must comply with laws, as written and for their intended purpose.
1. Comply with all government and legal requirements and industry standards everywhere we
operate. Meet all your contractual and legal obligations.
2. Make sure you understand all BMO policies.
3. Base business decisions on a thorough knowledge of our customers, products and services.
Ensure that your business relationships and actions serve our customers well.
4. Understand that the environmental, social and governance choices we make as a corporation
affect the lives of our shareholders, customers, employees and communities. Operate our
business ethically, honestly, transparently and with full accountability.
5. Deal only with customers who meet our ethical standards. Do not deal with people who try
to use our services or products illegally or unethically. Verify the identity of our customers
and report suspicious activities to BMO management and outside authorities.
6. Follow laws about marketplace competition, including marketing and advertising. Do not use
confidential information improperly. Do not arrange with others to lessen competition. Do not
use tied-selling practices, deceptive telemarketing or other improper marketing practices.
7. Communicate with customers, employees and other parties in the official language of their
choice. Try to communicate in the language that our customers prefer.
Veronica is a new BMO employee. As part of her corporate duties, she sends a communication across Canada in English only. An employee replies to the communication, reminding Veronica that all materials to Quebec customers and employees must be in French or bilingual and sent at the same time. What should Veronica do? a. Veronica takes immediate corrective action, ensuring
the communication is properly translated using BMO-approved translation suppliers and resends the bilingual document – with an apology
b. Veronica ensures that the bilingual translation - using BMO- approved translation suppliers and ordered through BMO Buying Online - is part of her planning process moving forward
c. Veronica takes a moment to review P&P Topic 735-07 regarding Quebec language laws and BMO translation policies
d. All of the above
The correct answer is (d). Veronica needs to take correctiveaction and resend the bilingual communication oncetranslated. She also needs to become familiar withBMO policy on communicating to employees and customersin Quebec and make translation, using BMO Buying Online, part of her project-planning process going forward.
SCENARIO:
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Principle 2continued
8. Avoid fraud and misappropriation – including embezzlement, kiting, float creation or
other improper conversions of funds, property or other assets. Do not help others do
these things.
9. Do not accept or offer bribes, payoffs or kickbacks, or engage in other corrupt
practices, and report others who engage in them. Try to prevent these activities
and report others who engage in them. Be careful about giving gifts to government
officials, making payments to an election campaign, or giving to political or
social causes.
10. Comply with all laws on money laundering and terrorist financing, and report
suspicious activities to BMO management and outside authorities.
11. Co-operate fully with investigations, audits, examinations and reviews by our
internal corporate support groups or by any government, regulatory or law
enforcement agency. Do not frustrate or circumvent their inquiries or make
any false or misleading statements. Refer all information requests by external
investigators, regulators and auditors to the right people – use the directory on
the Ethics Office website if a specific person is not identified in the request. Do not
retaliate (or threaten to retaliate) against anyone for cooperating with, or giving
information to, such investigations, audits, examinations or reviews.
BMO’s policies are designed to adhere and comply with legal and regulatory requirements so we’re always doing the right thing.If we fail to meet our legal obligations, we risk damaging BMO’s reputation as well as exposing BMO to legal or regulatory action.Violations are taken very seriously and can result in disciplinary action, up to and including dismissal, and may also affect compensation.
Additionally, we may sue anyone who harms BMO by not following FirstPrinciples and contact outside authorities if laws are broken.
REMEMBER…
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Principle 3Report concerns promptly
Be alert to possible violations of any laws, regulations or FirstPrinciples. Immediately report your concerns to the right people or department.
1. Maintain BMO’s high ethical standards. If you learn of anything that may conflict with
FirstPrinciples – or any laws, rules, regulations or BMO policy – speak up. If you are a
manager, take any concerns you receive seriously. Never make anyone feel that they were
wrong to raise a concern.
2. To raise a concern, consult your manager or compliance department, or check the
FirstPrinciples Contacts and Useful Links on the Ethics Office website. Report concerns about
accounting, internal control over financial reporting or auditing matters to management in the
appropriate finance department.
3. If you are not satisfied after raising a concern, contact BMO’s Ombudsman – an impartial
official who resolves concerns fairly and promptly. The Chief Executive Officer, Chief Financial
Officer, Chief Accountant and people who perform other similar functions should report any
such concerns to the Chair of the Audit and Conduct Review Committee.
4. We will protect anyone who raises legitimate concerns related to FirstPrinciples
from retaliation.
Dos: • Do speak up and report concerns immediately to
management if you suspect something unethical is happening.
• Do take concerns you don’t feel are being dealt with properly to the Ombudsman.
• Do report any concerns about accounting, internal control over financial reporting and auditing matters to the appropriate finance department or the Ombudsman.
Don’ts: • Don’t be afraid to report concerns of any kind.• Don’t ever make anyone feel it was inappropriate
to raise a concern. • Don’t ever retaliate against anyone raising
a concern.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Doing the right thing
Q: What are the possible consequences of a violation of BMO’s FirstPrinciples?
A: Violations are taken very seriously and may lead to disciplinary action, even legal action where necessary. This could involve corrective action, suspension or termination of employment. Violations may also affect compensation decisions. We may also sue anyone who harms BMO by not following FirstPrinciples and may contact outside authorities if laws are broken. BMO protects you from retaliation when you raise legitimate concerns under this code. Retaliating against anyone reporting an ethical concern or assisting or participating in a review, investigation or proceeding is inconsistent with FirstPrinciples.
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BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Principle 4Protect information, systems and other assets
Keep non-public information confidential – including non-public information about our customers, suppliers and employees. Protect our systems and other assets from improper use.
1. Protecting information – protect the confidential information of our customers, suppliers and
fellow employees (past, present and prospective). Confidential information is all information
that isn’t public. Comply with laws that restrict using, disclosing, keeping and allowing access
to confidential information.
2. Meet these specific requirements:
• Protecting personal information – obey privacy laws and BMO policies on using or
disclosing customer and employee personal information. If in doubt, get advice from a
manager or the appropriate person identified on the Ethics Office website before sharing
any personal information.
• Using and disclosing customer and employee information – use and disclose this
information only for the specific purpose or transaction for which it was given or collected.
Do not disclose it without the consent of the person unless the law requires its disclosure.
Follow BMO policy on using or disclosing customer or employee personal information. If in
doubt, get advice from a manager or the appropriate person identified on the Ethics Office
website before disclosing any information.
• Accessing customer and employee information – access customer and employee
information in BMO systems or other media only for legitimate business purposes. Keep
employee and customer information strictly confidential and use or disclose it only under
the terms of our policies and procedures.
Dos: • Do create passwords that are at least eight characters
in length, consist of a mixture of UPPER CASE and lower case letters and numbers, and are not obvious words or dates (especially those that have personal associations such as birthdays, names of pets or family names).
• Do install all updates from Office Connect, Harris Connect and/or Pathway Connect.
• Do shred all confidential or highly sensitive documents using the secure disposal bins.
• Do remember that the Internet is in the public domain, so that anyone, anywhere can potentially see what you post online.
Don’ts: • Don’t use unapproved hardware – it could cause
BMO equipment to fail.• Don’t dispose of any hardware or software on a BMO
computer without first obtaining the appropriate authorization.
• Don’t post information online on behalf of BMO unless you are a member of an authorized team mandated to do so.
• Don’t disclose client information without verifying the identity of the person making the request.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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• Disclosing BMO information – do not disclose non-public information to anyone
except under the terms of BMO’s Disclosure Policy. Only certain spokespeople
are authorized to disclose material information about BMO. Ask the authorized
spokespeople to respond to any inquiries you receive, including those from the
investment community or media. Authorized spokespeople must ensure that public
disclosure of BMO information is full, fair, timely, factual, accurate, understandable,
objective, relevant, broadly disseminated, and consistent with legal requirements
and BMO’s Disclosure Policy. Communicate all developments, facts or changes that
could reasonably be material to BMO through the escalation processes established in
BMO’s Disclosure Policy.
• Ensuring information security – be alert to external security threats to information
entrusted to us; don’t put such information at risk. Follow BMO policy on safeguarding
information when dealing with media, including social networking sites.
• Managing information – comply with BMO policies to ensure the accuracy,
completeness and proper maintenance of records, data and information that we own,
create, collect, use and manage – in all types of media. This includes (a) knowing
how long to keep records, especially those related to any pending, threatened or
foreseeable investigation, audit, regulatory examination or legal proceeding and
(b) remembering that others may review any record you create, including email.
We may monitor BMO systems and applications that store and transmit information
(servers, networks, email, etc.) as well as personal mobile devices approved for business
use to ensure that confidential information is protected and handled in compliance with
legal requirements and FirstPrinciples.
Principle 4continued
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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3. Protect BMO systems and other assets, and those of our suppliers, from improper use,
and respect intellectual and other property rights.
4. Use BMO property (such as telephones, voicemail, faxes, computer networks,
email, instant and text messaging, personal digital assistants and remote access
capabilities) only for legitimate business purposes. Keep personal use of such property
reasonable and consistent with BMO policy, including FirstPrinciples.
5. Do not use BMO property to generate, transmit, view, print, retrieve, download or store
communications that are discriminatory, defamatory, obscene, damaging (such as
computer viruses), threatening, or harassing. Do not use material inappropriate for a
business environment (such as sexually-oriented content and chain letters).
6. Respect property rights. Do not duplicate copyrighted material without the written
consent of the copyright holders. This includes software; printed, recorded or broadcast
materials; and digital media.
Principle 4continued
François is a very busy financial adviser. He distributes his personal mobile number so clients can reach him even when he’s out of the office. He doesn’t have a bank-issued BlackBerry, so he stores customer information in his own phone so he can easily retrieve it wherever he is.
Although François likes being accessible outside the office, his manager has not approved a bank-issued mobile device. François’s own mobile phone doesn’t offer the security needed to protect confidential customer information. He should not be storing any of this information outside the bank.
SCENARIO:
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Principle 5Avoid conflicts of interest
Ensure that your personal and business affairs do not conflict – or appear to conflict – with our interests or the interests of our current or prospective customers and suppliers.
1. Do not let personal interests impair – or even appear to impair – your judgment, loyalty,
objectivity or impartiality in dealing with us, or with prospective or current customers or
suppliers. Be alert to potential conflicts between BMO’s interests and those of our customers
and suppliers, and use good judgment in these cases. If you learn of a potential or actual
conflict of interest involving you, another employee or BMO, report it promptly to
management. The following examples show where some conflicts of interest may arise.
• Misuse of position – do not use your position or connection with us to benefit yourself or
people you are connected to, such as family members, business associates or colleagues.
Do not use your position to harm our customers’ interests. Do not use your access to BMO
information or other assets to benefit yourself personally.
• Gifts, entertainment, other benefits and payments – do not offer, give or receive gifts,
entertainment or similar types of benefits that compromise – or appear to compromise – the
recipient’s or donor’s judgment or honest performance of their duties. Accept gifts and
entertainment of more than nominal value only if the law permits, the gifts are consistent
with industry standards and their disclosure would not harm our reputation, our employees
or the recipient.
• Outside business activities – if you engage in outside activities such as a second job, a
personal business or a directorship, ensure that they do not harm our interests, our reputation
or our customers. For example, do not compete with us. Before taking on outside activities,
follow the procedures found in the Conflict of Interest and Outside Business Activities
Corporate Standard. Follow any regulations that may restrict or prohibit your outside
business activities.
Staff members at a downtown branch each received a $25 gift card for a local coffee shop from a regular customer. Since the yearly gift limit is $100, the employees didn’t think there was anything wrong with accepting the gift cards. Their manager pointed out that gift cards are considered to be cash and under no circumstances can cash be accepted as a gift from a customer. The employees were instructed to return the gift cards.
Other gifts that cannot be accepted include:• Travel arrangements, meals or accommodation for
non-business purposes. • Discounts or rebates on merchandise or services
not available to the public. Example - A local roofer offers you a discount on fixing your roof, if you approve his business loan.
Acceptable gifts include:• Gifts of nominal value for holiday or religious celebrations
such as a gift basket during the festive season.• Tickets of nominal value to local events. • Advertising or promotional material with a token value.
Examples - pens, notepads, golf umbrellas, calendars, etc.• Benefits from civic, charitable, educational or religious
organizations for service acting on behalf of BMO, such as a complimentary meal at an awards banquet.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
SCENARIO:
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We valuehonesty
Q: What are the consequences of violating the personal trading principle?
A: In some cases, a trade may be reversed or restrictions may be imposed on trading. If a trade is reversed, the person who authorized the trade will be responsible for any losses and must forfeit any profits from the trade. If an investigation reveals that the individual(s) in question engaged in activities prohibited by regulatory requirements, outside authorities will be contacted. The employee(s) will be disciplined, and this can include termination of employment.
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BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Principle 6Ensure personal activities do not harm BMO
Ensure that your personal pursuits, involvement in the community and political activities do not harm BMO’s interests or reputation.
1. Avoid personal interests and activities that could conflict with BMO’s interests or harm
BMO’s reputation. Make it clear that BMO is not associated with your personal activities.
Some examples include:
• Community service – BMO and its employees enjoy a long, honourable and very active
tradition of community service. In some cases, we can support your involvement in such
activities. If you take on roles in religious, educational, cultural, social and charitable or
other non-profit entities, promptly identify and manage any actual or potential conflicts
with BMO’s interests that these roles create (for example, if you become a director of a
charity that banks with us).
• Political participation – if you run for public office, support others running for office or back
a cause, make it clear that your activity is personal and that BMO is not associated with your
political views or allegiances. Observe all applicable laws, restrictions and prohibitions on
corporate or individual contributions to political parties, public officials, candidates or causes.
• Public expression of personal views – if you express personal views, make it clear that
you are not speaking for BMO. Before publicly expressing views on matters that could
affect BMO, consult management and, if appropriate, Media and Public Relations or
Corporate Communications. This is especially important for branch or community banking
managers who have a public profile as a spokesperson. When offering personal opinions
in a public forum, use common sense – don’t make statements that might discredit BMO
or our competitors.
Recently, Peter joined the campaign team for a woman running for mayor in his hometown. Peter is now looking for places to host a car wash and barbecue for the candidate, so he asks the manager of the town’s BMO branch. The branch manager tells him she can’t offer him space on BMO grounds to host the car wash and barbecue since it would appear that BMO was a supporter of this particular candidate and, therefore, it would be a violation of the personal activity principle.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
SCENARIO:
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• Written, published material and social media – if you write books, articles or
letters, run a personal website or blog, or share personal information on a social
media website, do not harm BMO’s interests or reputation. Follow our policy
on social media and laws that may apply before posting entries in blogs, wikis,
Internet forums or social networks. At a minimum, make it clear that BMO is not
associated with your activity. Do not use or refer to customer information, BMO
proprietary information or BMO brand assets such as our name, logo, and other
trademarked and copyrighted material in any form, unless you have permission
from management.
Principle 6continued
Social Media: What’s Appropriate?
There is a significant difference between speaking on behalf of BMO and about BMO. Unless you are an approved Social Media Representative you must not indicate, imply or create the impression that you have authority to speak on behalf of BMO.
You may disclose on your social media profile(s) that you work for BMO. If you do so, then you must include a disclaimer on that profile that any views expressed are your own and are not made on behalf of BMO.
Do not mention, refer to in any way, nor give any advice or recommendations about any products or services offered or otherwise made available by BMO.
Only approved Social Media Representatives may refer to products and services offered by BMO, including any products, services or securities offered by BMO Private Client Group and BMO Capital Markets.
SCENARIO:
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Principle 7Ensure personal trading complies withlaw and policy
Do not engage in trading activities – personal or professional – that abuse or undermine the integrity of the markets. Do not use inside information.
1. Do not trade securities based on material non-public information. Material non-public
information means information that, if it were publicly known, would reasonably be
expected to have a significant effect on the market value of a company’s securities. Do not
share such information with other people. Use of material non-public information when
trading securities (including BMO securities) violates both the law and FirstPrinciples.
2. Do not spread rumours to manipulate a security price or engage in market timing of
mutual funds.
“ The relationships we have with our customers, our shareholders, our communities and each other are built on the expectation that we will be honest, fair and legal in all that we do. FirstPrinciples, our Code of Conduct, is aligned with our BMO Financial Group vision, culture and values. As a company, we are committed to great customer experience and to an internal culture where employees are encouraged to explore their potential and contribute at their
fullest.” Mark F. Furlong
President and CEO Personal and Commercial Banking U.S. BMO Financial Group
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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Conclusion
We are dedicated to responsibility and
fairness, reflected in our longstanding
reputation as a company with integrity. Each
of us is responsible for upholding BMO’s core
values. We expect our employees to do the
right thing. FirstPrinciples provides a clear
overview of our standards and beliefs.
Familiarize yourself with FirstPrinciples,
and know them well. We are committed
to holding ourselves to the highest ethical
standards – and that commitment is the key
to our continued success.
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Do the Right Thing
Demonstrate respect for all and earn trust through the integrity of our actions.
BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
Report your concerns:BMO wants all employees to be comfortable escalating concerns.
Employees are encouraged to speak with their manager first, followed by their
Responsible Executive or Compliance Office. If you have spoken with your
manager, Responsible Executive or Compliance Office and feel that the matter
needs to be taken further, stop and consider the type of concern you’re dealing
with. From here you’ll know whether you should speak to the Human Resources
Centre – Employee Relations or the Ombudsman Office.
Concerns regarding harassment, employee compensation, personnel policies and
other HR matters should be directed to the Human Resources Centre – Employee
Relations.
The Ombudsman Office is a confidential and, if desired, anonymous resource
for employees worldwide to report any concerns related to FirstPrinciples,
Anti-Corruption Policy, accounting, internal control over financial reporting
and/or auditing matters.
Important ResourcesCode of Conduct http://www.bmo.com/home/about/banking/
corporate-information/codeofconduct
Annual Report http://www.bmo.com/home/about/banking/investor-relations/
annual-reports-proxy-circulars
Corporate Governance http://www.bmo.com/home/about/banking/
corporate-governance
Corporate Responsibility Report http://www.bmo.com/home/about/banking/
corporate-responsibility/home
Ombudsman Office http://www.bmo.com/home/popups/global/ombudsman/
ombudsman-details
®
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BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics
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