Case study: How BNY Mellon promotes ethical business behaviour
BNY Mellon is a leading investments company, providing investment management, investment services and wealth management that help institutions and individuals succeed in markets all over the world. BNY Mellon takes multiple approaches to educating employees on ethics, compliance and risk management, stressing their importance to the company’s success.
This case study is based on the 2019 Corporate Social Responsibility Report by BNY Mellon 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/ ESG/ 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.
BNY Mellon is committed to acting ethically and with integrity Tweet This!, empowering, through its governance framework and related corporate policies, employees and contractors to report and escalate concerns of unethical conduct. In order to promote ethical business behaviour BNY Mellon took action to:
- implement a Code of Conduct
- encourage employees to report ethical issues
- combat bribery and corruption
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With this case study you will see:
- Which are the most important impacts (material issues) BNY Mellon has identified;
- How BNY Mellon proceeded with stakeholder engagement, and
- What actions were taken by BNY Mellon to promote ethical business behaviour
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What are the material issues the company has identified?
In its 2019 Corporate Social Responsibility Report BNY Mellon identified a range of material issues, such as diversity & inclusion, environmental sustainability, employee engagement & wellbeing, ESG client solutions, human rights. Among these, promoting ethical business behaviour stands out as a key material issue for BNY Mellon.
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 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 BNY Mellon engages with:
| Stakeholder Group | Method of engagement |
| Clients |
|
| Investors |
|
| Employees |
|
| Communities |
|
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics BNY Mellon engaged with its stakeholders through a series of internal interviews.
What actions were taken by BNY Mellon to promote ethical business behaviour?
In its 2019 Corporate Social Responsibility Report BNY Mellon reports that it took the following actions for promoting ethical business behaviour:
- Implementing a Code of Conduct
- BNY Mellon’s Code of Conduct defines its high ethical standards. In 2019, 100% of active employees certified through BNY Mellon’s annual attestation programme that they read and understood all Code of Conduct provisions. BNY Mellon’s ongoing measures to reinforce these provisions and standards include:
- Annual employee training, which covers topics such as anti-corruption, protecting assets, business continuity, anti-money laundering and information risk. Targeted programmes cover regulations and best practices by region, business and other qualifiers.
- Regular, global communications through channels such as executive blogs, news stories and email newsletters, which highlight practices such as early risk identification and prompt escalation and reinforce risk ownership, ethical behaviour and putting clients first. A “Dear Ethics Officer” column introduces timely ethical situations, stresses appropriate actions, and reminds employees of resources.
- In 2020, BNY Mellon is simplifying the annual Code of Conduct certification and questionnaire, focusing on topics that pose the highest potential risk to the company. BNY Mellon is streamlining the number of questions asked of employees, consolidating related questions and clarifying the questions that remain. All employees will complete the same questionnaire and be asked questions focused on policy and conflict, providing better insights into policy adherence.
- Encouraging employees to report ethical issues
- BNY Mellon encourages employees at all levels to immediately report ethical issues and concerns to their managers and to BNY Mellon’s Compliance and Legal teams. BNY Mellon provides them with several ways to ask questions or make a report, including an Ethics Helpline, operated by the BNY Mellon Ethics Office, an Ethics Hotline, operated by independent administrator EthicsPoint, a desktop Incident Reporting System and Director’s Mailbox, a communication directed to an independent director of BNY Mellon’s Board. BNY Mellon urges all employees to ask questions and escalate issues until they are resolved, and prohibits retaliation against whistleblowers who raise concerns.
- Combating bribery and corruption
- BNY Mellon has a zero-tolerance policy on bribery and corruption. BNY Mellon’s Codes of Conduct for employees and the Board of Directors detail its expectations regarding anti-corruption compliance. BNY Mellon monitors potential conflicts through its anti-corruption compliance programme, which covers business dealings and relationships in countries where BNY Mellon, its subsidiaries and associates operate. The programme enforces compliance with both domestic and applicable foreign laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. It covers business activities and regulatory requirements, including gifts and entertainment, charitable contributions, hiring practices and third-party intermediary due diligence.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-1 Operations assessed for risks related to corruption
2) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by BNY Mellon, 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) https://www.globalreporting.org/standards/gri-standards-download-center/
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