Customers
Workplace
Environment
Communities
How We Operate
109
MATERIAL TOPIC
Ethics and Integrity
Context
• News of misdeeds in the financial industry continued to make headlines in 2013.
• For any business, reputation is a priceless asset earned over many years and it must be maintained and safeguarded by every employee.
Materiality and Strategy
While reaching our business goals is critical to TD’s success, equally important is the way we achieve them. TD is committed to conducting its affairs to the highest standards of ethics, integrity, honesty, fairness and professionalism – in every respect, without exception and at all times.
The actions of our employees are subject to a number of internal policies, standards and guidelines, including those that cover:
1. Our Code of Conduct and Ethics; 2. Anti-money laundering and anti- terrorist financing and sanctions;
3. Anti-bribery and anti-corruption; 4. Privacy compliance; 5. Security of information systems and premises; and 6. Fraud protection.
Promoting Responsible Conduct
The Code provides a framework for how we interact with one another, our sharehold- ers, customers, communities, suppliers and competitors. Employees understand clearly that any irregular business conduct, including bribery, corruption or insider trading, will not be tolerated. The document provides examples to illustrate acceptable and unacceptable behaviour.
The Code is reviewed annually and published in English and French. It applies to TD employees and Directors, who must attest annually that they understand the Code and comply with its provisions. The attestation includes a reminder of our whistleblower policy and hotline. A version of the Code applies to contract workers in North America.
In 2013 we updated the Code to assist in promoting ethical behaviour and enhancing TD’s culture of integrity by:
• Providing greater clarity about conduct that violates the Code and may result in criminal offences, including behaviour that constitutes forgery, conflicts of interest and nepotism.
• Protecting the privacy of employee information. Employees now have the privacy of employee information. Employees now have clearer information about their rights and what to do in an event that has led or may lead to a privacy issue.
• Promoting a deeper understanding of the Code through fact sheets to help employees make better decisions.
+ Code of Conduct and Ethics (PDF) TD 2013 Corporate Responsibility Report
Whistleblower Hotline
We encourage employees or any member of the public to report concerns relating to the integrity of TD accounting, internal account- ing controls or auditing matters; possible breaches of the Code of Conduct and Ethics; other ethical, legal or regulatory matters; or retaliation allegations through the TD Whistleblower Hotline. This independent, confidential and anonymous reporting channel allows TD to ask questions and allows the complainant to provide us with additional information and, where helpful, participate in an anonymous online chat.
TD employees and members of the public are protected against retaliation as a result of having made, in good faith, a complaint that the person reasonably believes to be valid or as a result of having otherwise assisted in the investigation of a complaint.
+ Whistleblower Hotline
Anti-Money Laundering/ Anti-Terrorist Financing/ Sanctions/Anti-Bribery
We are committed to taking all reasonable and appropriate steps to prevent people engaged in money laundering or terrorist financing from utilizing TD products or services and operating in full compliance with applicable anti-money laundering, anti-terrorist financing, sanctions and anti-bribery legal and regulatory require- ments, as well as our risk policies.
+ AML/ATL/Sanctions Policy Summary
+ Anti-Bribery, Anti-Corruption Policy Summary (PDF)
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107 |
Page 108 |
Page 109 |
Page 110 |
Page 111 |
Page 112 |
Page 113 |
Page 114 |
Page 115 |
Page 116 |
Page 117 |
Page 118