Case study: How BMO promotes ethical business behaviour
As one of the largest banks in North America, providing a wide range of personal and commercial banking, wealth management and investment banking services and products to over 12 million customers around the globe, BMO strives to earn and maintain stakeholder trust by operating fairly, openly and responsibly. Tweet This!
This case study is based on the 2016 Environmental, Social and Governance Report and Public Accountability Statement by BMO published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
Abstract
As a highly diversified financial services provider, with total assets of $688 billion and over 45,000 employees, adhering to the highest standards of integrity and ethical conduct is a top priority for BMO. In order to promote ethical business behaviour BMO took action to:
- implement a Code of Conduct
- provide ethics training
- enable employees to report ethical concerns
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With this case study you will see:
- Which are the most important impacts (material issues) BMO has identified;
- How BMO proceeded with stakeholder engagement, and
- What actions were taken by BMO to promote ethical business behaviour
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What are the material issues the company has identified?
In its 2016 Environmental, Social and Governance Report and Public Accountability Statement BMO identified a range of material issues, such as privacy and data security, consumer protection and transparency, corporate governance, learning and development. Among these, promoting ethical business behaviour stands out as a key material issue for BMO.
Stakeholder engagement in accordance with the GRI Standards
The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:
Stakeholders must be consulted in the process s of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.
Key stakeholder groups BMO engages with:
| Stakeholder Group | Method of engagement |
| Customers
| · Advisory panels · Complaints management process (including BMO’s Ombudsman Office) · Correspondence (by letter and email) · Dedicated mailboxes · Focus groups · Meetings (in person and by phone) · Net Promoter Score surveys (by phone and online) · Social media · Stakeholder impact surveys |
| Employees
| · Dedicated mailboxes · Employee affinity groups · Senior leader internal blogs · Stakeholder impact surveys · Surveys (annual employee survey) · Town halls |
| Shareholder & Investor Community
| · Annual general meeting · Correspondence (by letter and email) · Disclosure of interim and annual financial results · Investor conferences · Investor days · Meetings (in person and by phone) · News releases, corporate website and industry conferences · Stakeholder impact surveys |
| Government & Regulators | · Correspondence (by letter and email) · Meetings (in person and by phone) |
| Civil Society
| · Correspondence (by letter and email) · Interviews · Meetings (in person and by phone) · Questionnaires · Research papers (on key issues for the industry) · Stakeholder impact surveys · Surveys |
How stakeholder engagement was made to identify material issues
To identify and prioritize material issues BMO carried out, in 2016, targeted online surveys and organized ESG-specific panels with regional stakeholders from North America, Europe and Asia. Stakeholders engaged by BMO were asked to rank material issues and propose new ones. They included thought leaders, research analysts, investors, employees, industry peers, academics, community partners and civil society organizations.
What actions were taken by BMO to promote ethical business behaviour?
In its 2016 Environmental, Social and Governance Report and Public Accountability Statement BMO reports that it took the following actions for promoting ethical business behaviour:
- Implementing a Code of Conduct
- BMO’s expectations and guidelines for employees’ ethical behaviour are outlined in its Code of Conduct. Moreover, in 2016 BMO:
- refreshed the Code of Conduct, to make it easier to understand
- launched a new Supplier Code of Conduct, outlining principles BMO’s suppliers are expected to comply with
- updated its Statement on Human Rights to ensure it aligns with the refreshed Code of Conduct and the new Supplier Code of Conduct
- updated its Anti-Corruption policy, to incorporate principles and updates relating to hiring practices, gifts and sponsorships
- Providing ethics training
- To promote awareness of the Code of Conduct, BMO provides employees with formal and informal training. Every year, all BMO employees (including contract and temporary employees) have to complete BMO’s Ethics, Legal & Compliance Training program. Through the training employees are, among others, offered guidance on effective risk management.
- Enabling employees to report ethical concerns
- BMO provides various channels for employees to raise, confidentially and without fear of retaliation, concerns regarding accounting, internal controls over financial reporting and auditing matters, or the Code of Conduct. These channels include a third-party whistleblower reporting service, for BMO employees and other stakeholders to report such concerns to BMO’s Ombudsman.
Which GRI indicators/Standards have been addressed?
The GRI indicators/Standards addressed in this case are:
1) G4-56: Describe the organization’s values, principles, standards and norms of behavior such as codes of conduct and codes of ethics – the updated GRI Standard is: Disclosure 102-16 Values, principles, standards, and norms of behavior
2) G4-57: Report the internal and external mechanisms for seeking advice on ethical and lawful behavior, and matters related to organizational integrity, such as helplines or advice lines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
3) G4-58: Report the internal and external mechanisms for reporting concerns about unethical or unlawful behavior, and matters related to organizational integrity, such as escalation through line management, whistleblowing mechanisms or hotlines – the updated GRI Standard is: Disclosure 102-17 Mechanisms for advice and concerns about ethics
4) G4-SO4: Communication and training on anti-corruption policies and procedures – the updated GRI Standard is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures
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References:
1) This case study is based on published information by BMO, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:
http://database.globalreporting.org/
2) http://www.fbrh.co.uk/en/global-reporting-initiative-gri-g4-guidelines-download-page
3) https://g4.globalreporting.org/Pages/default.aspx
4) https://www.globalreporting.org/standards/gri-standards-download-center/
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