Doing What's Right2018 BMO's Code of Conduct
(3.24 MB - PDF)
Principle 1 — Be honest and respectful
Maintain integrity, empathy and responsibility in all our decisions and actions.
We must be inclusive. Welcome and support individuals from diverse backgrounds, perspectives and communities. All of our behavior, communications and interactions with our colleagues in the workplace must be respectful, professional and in accordance with the Code. Workplace relationships must be kept free of discrimination and harassment. We must ensure all employees are valued, respected and heard.
Principle 2 — Be alert to behavior contrary to the Code
Be alert to possible violations of laws, regulations or the Code. Report concerns immediately to the appropriate people or department.
- the Ethics Office
- the Anti-Corruption Office
- Employee Relations
- Investigative & Security Services
- the Privacy Office
- BMO’s Office of the Ombudsman (Ombudsman)
* BMO's external Speak Up! service provider is ClearView ConnectsTM
Principle 3 — Be true to the letter and the spirit of the law
Always follow both the letter and the spirit of the law.
- Comply with legal, regulatory, and internal requirements for political participation, including use of corporate funds to support political candidates, campaigns, committees, or other political groups on behalf of BMO. Certain employees may be subject to additional limitations on personal political contributions.
Principle 4 — Be conscientious about security
Keep non-public information confidential — including non-public information about BMO’s customers, suppliers and employees. Protect BMO’s systems and other assets from improper access and use.
- Protect & respect BMO's intellectual property rights (patents, copyright, trademarks and trade secrets) which encompass everything you are hired to do and everything you create using BMO data, BMO confidential information, or BMO resources.
- Use BMO property (such as telephones, voicemail, faxes, computer networks, email and instant and text messaging) only for legitimate business purposes. Keep the nature and extent of any personal use of such property reasonable and consistent with BMO policies, including the Code. Do not install unauthorized software or storage devices on BMO-owned computers and devices.
- Do not use BMO property to transmit, view, generate, print, retrieve, download or store communications that are discriminatory, defamatory, obscene, damaging (such as computer viruses), threatening or harassing. Do not use or distribute material that is inappropriate in a business environment (such as sexually-oriented literature or chain letters).
- Protect BMO systems and other assets, as well as those of BMO's suppliers against improper use.
Principle 5 — Manage conflicts of interest
Ensure personal and business affairs do not conflict — or appear to conflict — with BMO’s interests or the interests of BMO’s current or prospective customers, counterparties and suppliers.
- Gifts, entertainment, other benefits and payments — do not offer, give or receive gifts, entertainment, improper payments or other benefits intended to improperly influence a business decision, gain unfair competitive advantage, obtain business or compromise (or appear to compromise) the recipient's or donor's judgment or honest performance of their duties. Do not directly or indirectly promise, approve, or offer anything of value to a public official or use an intermediary on your behalf without first seeking approval from the Anti-Corruption Office. If you have a question or a concern, review the Criminal Risk Corporate Standard, get advice from a manager or consult the Anti-Corruption Office.
- Misuse of position — do not use your position or connection with BMO to benefit yourself or people with whom you have a relationship, such as family members, business associates or colleagues. Do not use your employee banking privileges as a benefit for others or for personal profit; use them only for the purposes intended. (e.g. using the preferred exchange rate when you are travelling is acceptable, while using the preferred exchange rate to trade currency on financial markets is not). Do not use your position to harm our customers’ interests. Do not use access to BMO information or other assets to personally benefit yourself or people to whom you are connected.
- Outside activities — obtain approval before engaging in an activity outside of BMO, to ensure any potential, perceived or actual conflicts with BMO's interests are promptly identified and managed. The Managing Conflicts of Interest Operating Directive provides detailed guidance. Managers are responsible for reviewing and making a decision on all outside activities. Follow all laws, regulations, and internal procedures. Do not use company resources or BMO premises to engage in personal activities. Be clear any outside activity is personal and that BMO is not associated with it. Don't make statements that might discredit BMO or our competitors.
- Volunteering — BMO and its employees enjoy a long, honorable tradition of volunteering. Activities include roles in religious, educational, cultural, social, charitable or other non-profit entities (for example, a board director or treasurer of a non-profit entity that banks with BMO)
- Employment in addition to BMO
- Political Participation — including running for public office, supporting a candidate who is running for office, or actively advocating for a cause
- Outside business interests — including director roles at a for-profit, non-BMO company, or ownership interests in a for-profit business entity
- Public expression of personal views — this is especially important for employees who have a public profile as spokespersons for BMO
- Serving as a trustee or an executor, or in a similar role, for a current or former customer and non-family member
- Written, published material and social media — including writing books, articles for publication, running a personal website or blog, or sharing information on social media
- For additional examples see the Managing Conflicts of Interest Operating Directive