Doing What's Right
BMO's success and reputation are built on the trust we've earned from the people we work with and the customers we serve. Our reputation is our greatest asset. It is maintained by everyone associated with BMO Financial Group. We are sensitive to the impact our business decisions have on our stakeholders and the communities where we do business, and we are committed to doing the right thing - always. This commitment to corporate citizenship and long-term sustainability is part of who we are, and it is as important to our brand as the products and services we offer.
BMO's Code of Conduct applies to BMO's Board of Directors, to the directors of the boards of BMO's subsidiaries and to all employees of BMO Financial Group and its direct and indirect subsidiaries around the world.
The approach outlined in this Code of Conduct is not something we aspire to: it is the performance standard we commit to every day. It is our enduring ethical guide — its principles are extremely important, and they are not negotiable.
- 2016 BMO's Code of Conduct (3.24 MB - PDF)
Maintain integrity, empathy and responsibility in all our decisions and actions.
Our values guide us beyond the easy thing to do to the right thing to do. They ensure we act with integrity with all of BMO’s customers, employees, suppliers and competitors, as well as any other third party or business partner.
We must uphold high standards for how we operate. We must all consider the environmental and social impacts of our decisions. It’s an essential part of upholding our commitment to corporate responsibility.
We must be inclusive. Welcome and support individuals from diverse backgrounds, perspectives and communities. All of our communications and interactions with our colleagues in the workplace should 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
- Discrimination includes any legally protected status and all forms of making a distinction in favor of or against a person based on gender, race, ethnicity, sexual orientation, age, disability, and/or work style.
- Harassment includes bullying and offensive or inappropriate language, as well as unwelcome, intimidating or humiliating behavior — intentional or not — that could reasonably be seen as demeaning to others and that undermines a safe, comfortable and productive workplace.
Be alert to possible violations of laws, regulations or the Code. Report concerns immediately to the appropriate people or department.
Maintain our high ethical standards
If you learn of anything that may conflict with the Code, or with any laws, rules, regulations, or BMO policy or procedure, speak up, and be candid. You do not have to be 100% certain of an issue before speaking up.
You have the right to disclose any information that is protected under whistleblower laws, when you are reporting possible violations of laws or regulations or responding to inquiries from, or testifying before, any regulatory authority, any governmental agency or self-regulating authority, all without notice to, or consent from, BMO.
To raise a concern, consult your manager or the department listed on the Code of Conduct website.
Here are some resources that can help employees with concerns related to the Code:
- the Ethics Office
- the Anti Corruption Office
- the AML Office
- Employee Relations
- the Human Resources Center
- Center Investigative & Security Services
- Legal & Compliance Groups
- the Privacy Office
- BMO’s Ombudsman
If you want to anonymously report a possible violation, or you are not satisfied after raising a concern under the Code, report it to BMO’s Ombudsman through BMO’s external whistleblowing service ClearView Connects™.
Report concerns about accounting, internal controls over financial reporting, or auditing matters to BMO’s Ombudsman through the ClearView Connects™ whistleblowing service.
Never retaliate against anyone who raises a concern related to the Code. Take concerns you receive seriously. Never make anyone feel they were wrong to raise a concern. If you feel you have been retaliated against for raising a concern, report it through the ClearView Connects™ whistleblowing service.
ClearView Connects is a registered trademark of ClearView Strategic Partners Inc.
Always follow both the letter and the spirit of the law.
If following the Code would cause you to violate local law, follow local law. However, if a conflict arises between local custom and the Code, follow the Code. If your business unit or location has policies that are more restrictive than the Code, follow the more restrictive policies.
Anti-corruption and anti-bribery requirements
- Do not accept or offer bribes or payoffs, and do not engage in other corrupt practices.
- Follow BMO’s procurement ethics and outsourcing policy practices as part of any sourcing and supplier relationship management activities.
- Follow BMO’s Anti-Corruption Corporate Standard on offering, giving or receiving gifts, business entertainment or similar types of benefits.
- Promptly report all suspected corrupt activities, as described in BMO’s Anti-Corruption Corporate Standard.
Anti-money laundering and anti-terrorist financing requirements
- Comply with regulatory and AML Program requirements on anti-money laundering, anti-terrorist financing and sanctions measures.
- Collect all required customer information
- Do not provide financial services or advice contrary to law and AML Program requirements, and do not help customers evade these requirements.
- Report unusual activities, as described in BMO’s Anti-Money Laundering, Anti-Terrorist Financing and Sanctions Measures Program. Customers must not be told that their activities are being reported.
- Understand and comply with Corporate Policies, Corporate Standards, subsidiary policies and Operating Procedures or Directives.
- Collect all of the required information to know your customer.
- Understand our products and services and the rules that apply when you sell them.
- Consider only the interests of our customers and provide them with the information needed to make financial decisions that are right for them.
Government and legal requirements
- Comply with governmental, legal and regulatory requirements and industry standards for each place BMO operates.
- Meet all of our contractual, legal and regulatory obligations.
- Do not engage in financial crime or misappropriation — including embezzlement, kiting, float creation, forgery or other improper use of funds, property or other assets. Do not help others do these things.
Investigations, audits and examinations
- Refer requests for information from external investigators, regulators and auditors to the right people. Use the directory on the Code of Conduct website if the request doesn’t identify a specific person.
- Cooperate fully with investigations, audits, examinations and reviews by BMO, governments, regulators and law enforcement agencies.
- Do not frustrate, circumvent inquiries or make false or misleading statements.
- Comply with any notice to preserve records — that is, written requests with instructions to keep records that may be needed for an investigation or legal action.
- Do not retaliate (or threaten to retaliate) against anyone for cooperating with, or giving information to, investigations, audits, examinations or reviews.
- Follow laws about marketplace competition, including marketing and advertising practices.
- Do not send electronic solicitation messages to customers without their consent
- Do not use tied selling practices, deceptive telemarketing or other improper marketing practices.
- Never take unfair advantage of anyone through manipulation, concealment, misuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.
- Do not use confidential information improperly.
- Do not arrange with others to lessen competition.
Personal trading in securities
- Do not engage in trading activities that abuse or undermine the integrity of the capital markets.
- Do not use inside information or share it with others. Do not trade securities (including BMO securities) based on material, non public information - that is, information which could have a significant effect on the market price or value of a security. These actions violate securities regulations, as well as our Code of Conduct.
- Do not spread rumors to manipulate a security price. Do not engage in market timing of securities and mutual funds.
- Comply with BMO’s internal trading policies that apply to you.
Respect intellectual and other property rights
- Respect laws governing intellectual property (i.e. patents, trademarks, copyright, domain names and trade secrets) and other third party rights (i.e. personality/publicity rights). Only use BMO’s brand name, logos and trademarks if you have authority to do so.
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 use.
Protect confidential information
- Protect the confidential information of BMO’s customers, suppliers, and fellow employees (past, present and prospective). Confidential information means all information that isn’t public. Comply with all laws that restrict using, disclosing, keeping, and allowing access to confidential information.
- BMO may monitor personal banking, investment and loan accounts, systems and applications that store and transmit information (servers, networks, email, etc.), as well as personal mobile devices approved for business to identify inappropriate behavior or activity.
Meet these requirements
- Protect personal information — obey all privacy laws and BMO policies on customer and employee personal information.
- Protect confidential commercial information – ensure that information that is protected by contractual terms and confidentiality or non-disclosure agreements is managed appropriately.
- Using and disclosing customer and employee information — use and disclose this information only for the specific purpose for which it was given or collected. Unless BMO already has an individual’s consent or the law requires disclosure, always get consent before disclosing an individual’s information. Always follow BMO policy on using or disclosing customer or employee personal information.
- Accessing customer and employee information — access customer and employee information in BMO systems or other media only for legitimate business purposes. Keep customer and employee information strictly confidential and use or disclose it only under the terms of BMO’s policies and procedures.
- Disclosing BMO Information — do not disclose non public information to anyone except under the terms of BMO’s Disclosure Corporate Policy. Only certain spokespersons are authorized to disclose material information about BMO. Ask authorized spokespersons to respond to any inquiries you receive, including those from the investment community or media.
Authorized spokespersons must ensure that every public disclosure is full, factual, accurate, understandable, timely, objective, relevant, broadly disseminated, and consistent with BMO’s Disclosure Corporate Policy, as well as any legal requirements.
- Reporting material BMO information — Communicate all developments, facts or changes you are aware of that could reasonably be material to public disclosures of BMO information by following the escalation processes detailed in BMO’s Disclosure Corporate Policy.
- Ensuring information security — be alert to external security threats to BMO information and information entrusted to us. Don’t put this information at risk. Maintain information security in our workplace and when working off-site. When using the web, browse safely to protect yourself and BMO against criminals seeking to breach our security. Use email encryption to keep confidential and highly sensitive information secure (i.e., add [PROTECT] to the subject line) and retain and dispose of information in the correct manner. Follow BMO policy on safeguarding information.
- Managing information — comply with our policies and procedures in order to ensure the accuracy, completeness and proper maintenance of records, data and information BMO owns, creates, collects, uses and manages, in all types of media. You must:
- Know how long to keep records, especially those for any pending, threatened or foreseeable investigation, audit, regulatory examination or legal proceeding.
- Remember that others may review any record you create, including email messages.
Protect BMO systems
- Protect BMO systems and other assets against improper use, as well as those of BMO’s suppliers.
Respect BMO property
- 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).
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.
A potential conflict of interest may exist:
- when your personal interests impair — or appear to impair — your judgment, loyalty, objectivity or impartiality in dealing with BMO or with prospective or current clients, customers, counterparties or suppliers.
- where BMO’s interests may be materially opposed to the interests of its clients, customers or counterparties.
Be aware of potential conflicts and use good judgment to avoid them.
In addition to information barriers that exist to prevent the inappropriate disclosure of information within and across business groups, employees must ensure that they follow BMO procedures respecting the clear, timely and effective disclosure of potential conflicts of interest. For more information, consult the Managing Conflicts of Interest Operating Directive.
The following examples show how some conflicts of interest may arise.
- Gifts, business entertainment, other benefits and payments — do not offer, give or receive gifts, business entertainment, improper payments or other benefits intended to improperly influence a business decision or that 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 greater than nominal value to a Public Official. If you have a question or a concern, 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. use of the preferred exchange rate when you are travelling is acceptable, while use of 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.
- Not disclosing important information — follow BMO procedures respecting the clear, timely and effective disclosure of potential, perceived, or actual conflicts of interest. Take action to manage the possible effects of any conflict.
Outside activities — Before engaging in an activity outside of BMO, such as an ongoing volunteer role, a second job, a personal business, or a treasurer or director position, ensure it does not harm our reputation or our customers ( e.g. ensure the activity does not compete with BMO). Your manager is responsible for reviewing and making a decision on all outside activities, as described in the Operating Directive: Managing Conflicts of Interest Operating Directive.
Some examples of outside activities include:
- Community service — BMO and its employees enjoy a long, honourable tradition of active community service. If you take on a role in a religious, educational, cultural, social, charitable or other non profit entity, you must promptly identify and manage any potential, perceived or actual conflicts with BMO’s interests (for example, if you are a director of a charity that banks with BMO).
- Political participation — if you run for public office, support a candidate who is running for office, or actively advocate for a cause, you must make it clear that the activity is personal and that BMO is not associated with your political views or allegiances. Follow all laws and restrictions on corporate and individual contributions to political parties, public officials, candidates or causes.
- Public expression of personal views — when expressing personal views, make it clear that you are not speaking for BMO. This is especially important for employees who have a public profile as spokespersons for BMO. When offering personal opinions in a public forum, don’t make statements that might discredit BMO or our competitors.
- Serving as a trustee or an executor, or in a similar role, for a non-family member — do not agree to serve (personally) as an executor, administrator, holder of power of attorney, guardian of an estate, conservator, trust protector, investment adviser or trustee of an estate or trust, or in another fiduciary role for a customer or former customer, unless that customer or former customer is a “relative” or “close personal friend”, as defined in the Operating Directive: Managing Conflicts of Interest Operating Directive.
- Written, published material and social media — if you write books, articles or letters for publication; run a personal website or blog; or share information on social media, you must make it clear that your views and opinions are your own. Familiarize yourself with BMO’s policy on social media and any applicable laws before posting on a social media network, forum, blog, wiki or another digital platform.