The case for CSR/ Sustainability Reporting Done Responsibly


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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.

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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

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:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

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 
  • Advisory boards and idea-sharing conferences 
  • Direct conversations 
  • Satisfaction and engagement surveys 
  • Social media feedback 
  • Thought leadership collaborations
  • Annual and quarterly reports 
  • Annual Meeting of Stockholders 
  • Financial services conferences 
  • Proxy voting 
  • Webcasts and conference calls
  • Conversations with managers 
  • Employee groups 
  • Engagement surveys 
  • Materiality analysis interviews 
  • Performance management and development programmes
  • Town Hall meetings
  • Employee volunteering and giving-related relationships with community organisations 
  • Meetings with local leaders and advocacy groups
  • Nonprofit board memberships and financial support partnerships (grants and sponsorships)

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:

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

FBRH GRI Standards Certified, IEMA & CIM recognised Sustainability Course | Venue: London LSE

By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



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: 


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