Every year, all BMO employees must complete our Ethics, Legal and Compliance Training (ELCT), which covers a range of topics including ethical conduct, information security and anti-corruption. We reinforce that training with ongoing communication to help ensure there’s a shared understanding of our collective responsibility to do what’s right, and to speak up candidly when we have questions or concerns. The Code is reviewed annually and updated at least biennially.

One of the key premises of our ethical culture requires employees to be alert and report any behavior they witness that violates our Code. The channels available for reporting concerns are outlined in the Code, internal documents and our annual ELCT program. Among the channels is our external “Speak Up” service, an anonymity-assured resource. We make it clear that we will not tolerate retaliation against anyone who reports a concern or participates in an investigation.

Our Supplier Code of Conduct sets out specific expectations related to supplier integrity, fair dealing and sustainability. It is updated every two years to address evolving trends, issues and legislative requirements.