FirstPrinciples - Bank of Montreal EN.pdf · national or ethnic origin, age, ... she sends a communication across Canada in English ... with FirstPrinciples. BMO FINANCIAL GROUP •

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FirstPrinciplesOUR CODE OF BUSINESS CONDUCT AND ETHICS

®

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Message from the CEO ...................................................... 3

BMO – Our Values ............................................................... 4

FirstPrinciples ................................................ 5

Principle 1

Maintain your personal integrity ..................................... 6

Principle 2

Follow both the letter and spirit of the law ........................ 7

Principle 3Report concerns promptly .............................................. 9

Principle 4

Protect information, systems and other assets ................. 11

Principle 5

Avoid conflicts of interest ............................................. 14

Principle 6Ensure personal activities do not harm BMO .................... 16

Principle 7Ensure personal trading complies with law and policy ....... 18

Conclusion ....................................................................... 19

Report your concerns ...................................................... 20

Important resources ........................................................ 20

BMO FINANCIAL GROUPFirst Principles - Our Code of Business Conduct and Ethics

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FirstPrinciples was created to clearly and concisely identify the accountabilities we share as employees of this company. It is the responsibility of each one of us to:

• hold ourselves to the highest standard of integrity;

• follow both the letter and the spirit of the law;

• act as guardians of BMO’s reputation by promptly

bringing forward concerns we may have about possible

breaches of our code;

• protect the information entrusted to us;

• never use our position to promote our personal

interests over those of the company;

• ensure that our personal activities do not harm BMO;

and, finally,

• never use non-public information for personal gain.

FirstPrinciplesWe take pride in the fact that people choose

to bank with BMO because we make money

make sense. As bankers we know we enjoy

that opportunity because we first earned

their respect.

When your business is helping people manage

their money, perhaps more than any other

profession, it is not only what you do for

customers, but also how you do it that matters

to them.

BMO is known for integrity and responsibility

– it’s a long-established reputation that we’ve

nurtured and built upon for almost 200 years.

Today, 47,000 of us are the stewards of that

vital element of our brand.

And so, the jobs we hold bring with them

responsibilities that shape the way we do

our daily tasks and goals. Individually and

collectively we are BMO – in the eyes of our

customers, our regulators, the law and each

other – this is why we have FirstPrinciples:

Our Code of Business Conduct and Ethics.

There is one more responsibility we all share –

to know thoroughly the principles contained in

this booklet and apply them in our work every

day. This booklet makes that task easy. In these

pages you’ll find our FirstPrinciples described in

precise, plain language.

Review these principles every now and then.

Take the time to think about the code and how

it applies to you and your work. Our customers’

success defines our success – and that begins

with our most basic responsibility: knowing

what’s right.

Bill Downe

President and Chief Executive Officer


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OUR VALUES

Take Pride In what we do and where we work.

Keep Your Word Never waver from our commitments to our customers and each other.

Embrace Diversity Gain strength through our people and our perspectives.

Do the Right Thing Demonstrate respect for all and earn trust through integrity of our actions.

Have Courage to Win Focus on what makes us successful.

Our Way and Our Values are at the heart of the BMO culture. Our Values represent what we stand for and Our Way is how we put those values into practice. FirstPrinciples, Our Code of Business Conduct and Ethics provides us with a set of rules to guide that behaviour in everything we do at BMO, ensuring that we really do practise what we preach.


OUR WAY

• Works Collaboratively

• Delivers Results

• Makes Things Happen

• Leads Us Higher

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Context and DirectionThis is our code of business conduct and ethics,

called FirstPrinciples. It sets out rules and

principles that help us do the right thing when

dealing with our clients, suppliers, other

stakeholders and each other. It reflects our

commitment to high standards of business

conduct and ethics, and builds on our proud

tradition of doing what is fair, right and legal.

All our Corporate Policies, Corporate Standards,

Operating Procedures, subsidiary policies,

and other codes or guidance documents

must follow and be consistent with the Code.

In the event of any inconsistency, the Code

will prevail.

FirstPrinciples is very important and we all need

to follow its seven principles – our reputation

depends on it. We are judged on our integrity,

as well as our competence.

Read the Code and Seek Advice We all want to foster a working environment

that upholds the highest ethical standards.

So it is essential to read and understand

FirstPrinciples, as well as the Corporate Policies,

Corporate Standards, Operating Procedures

and Subsidiary Policies that give further

guidance on how to interpret and apply it.

Together, they help us to do our jobs effectively

while conducting ourselves fairly and ethically.

Retaliation is not tolerated. We are committed

to maintaining a culture of integrity and ethical

behaviour, and it’s important to us to foster a

work environment where everyone feels secure

voicing their concerns.

If you have concerns or are unsure about the

legal, ethical or reputational implications of

a situation, consult your manager, or any of

the people or departments in FirstPrinciples

Contacts and Useful Links on the Ethics Office

website.

You should feel comfortable reporting any

possible violation of our Code of Conduct. We

prohibit retaliation against anyone who reports

concerns in good faith or participates in any

related review, investigation or proceeding.

Any act of retaliation is a violation of the Code.

Reports or complaints made in bad faith are

also viewed as violations of the Code and may

result in disciplinary action, up to and including

dismissal of the complainant.

Not Following FirstPrinciples Can Have Serious ConsequencesIf you don’t follow FirstPrinciples our

reputation could suffer damage and we

might lose business. Conduct inconsistent

with FirstPrinciples is very serious and may

lead to discipline, ranging from counselling

to suspension or termination of employment.

It may also mean lower compensation.

Similar consequences may result from failing

to co-operate in an investigation relating

to FirstPrinciples or from retaliating against

someone who reports a concern under

FirstPrinciples.

We may also sue anyone who harms BMO by

not following FirstPrinciples and may contact

outside authorities if laws are broken.

FirstPrinciplesOUR CODE OF BUSINESS CONDUCT AND ETHICS


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“ BMO is committed to high standards of business conduct and ethics. Ethical business practices are critical to BMO’s success. Our customers, our shareholders, the communities in which we operate and our fellow employees expect each of us to be honest, fair and legal in all that we do. FirstPrinciples, our Code of Conduct, helps to guide us in continuing to operate honestly, fairly and within the law.”

Blair Morrison Senior Vice-President , Deputy General Counsel

and Chief Compliance Officer BMO Financial Group

Principle 1Maintain your personal integrity

Be honest and fair in all your decisions and actions.

1. Follow the highest ethical standards to earn and keep the trust and respect of your

colleagues and our stakeholders – including customers, suppliers, shareholders and

the public.

2. Keep workplace relationships professional and free of discrimination and harassment.

• Discrimination – includes all forms of discrimination based on race, colour, religion,

national or ethnic origin, age, gender, gender identity or expression, sexual

orientation, marital status, military or veteran status, physical or mental disability,

or a criminal offence for which a pardon has been granted.

• Harassment – includes displays of offensive, unwelcome, intimidating or

humiliating behaviour – intentional or otherwise – that could reasonably be

interpreted as demeaning others and undermining efforts to maintain a safe,

comfortable and productive workplace.

3. Never retaliate against any other employee for raising ethical concerns.

4. Avoid personal behaviour that harms your reputation and ours, including:

• Alcohol and substance abuse that impairs work performance or calls our ethical

standards into question. Alcohol is prohibited on BMO premises – except at sanctioned

and supervised BMO events. If you drink at these events, do so responsibly.

• Gambling that impairs work performance.


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Principle 2Follow both the letter and spirit of the law

We must comply with laws, as written and for their intended purpose.

1. Comply with all government and legal requirements and industry standards everywhere we

operate. Meet all your contractual and legal obligations.

2. Make sure you understand all BMO policies.

3. Base business decisions on a thorough knowledge of our customers, products and services.

Ensure that your business relationships and actions serve our customers well.

4. Understand that the environmental, social and governance choices we make as a corporation

affect the lives of our shareholders, customers, employees and communities. Operate our

business ethically, honestly, transparently and with full accountability.

5. Deal only with customers who meet our ethical standards. Do not deal with people who try

to use our services or products illegally or unethically. Verify the identity of our customers

and report suspicious activities to BMO management and outside authorities.

6. Follow laws about marketplace competition, including marketing and advertising. Do not use

confidential information improperly. Do not arrange with others to lessen competition. Do not

use tied-selling practices, deceptive telemarketing or other improper marketing practices.

7. Communicate with customers, employees and other parties in the official language of their

choice. Try to communicate in the language that our customers prefer.

Veronica is a new BMO employee. As part of her corporate duties, she sends a communication across Canada in English only. An employee replies to the communication, reminding Veronica that all materials to Quebec customers and employees must be in French or bilingual and sent at the same time. What should Veronica do? a. Veronica takes immediate corrective action, ensuring

the communication is properly translated using BMO-approved translation suppliers and resends the bilingual document – with an apology

b. Veronica ensures that the bilingual translation - using BMO- approved translation suppliers and ordered through BMO Buying Online - is part of her planning process moving forward

c. Veronica takes a moment to review P&P Topic 735-07 regarding Quebec language laws and BMO translation policies

d. All of the above

The correct answer is (d). Veronica needs to take correctiveaction and resend the bilingual communication oncetranslated. She also needs to become familiar withBMO policy on communicating to employees and customersin Quebec and make translation, using BMO Buying Online, part of her project-planning process going forward.

SCENARIO:


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Principle 2continued

8. Avoid fraud and misappropriation – including embezzlement, kiting, float creation or

other improper conversions of funds, property or other assets. Do not help others do

these things.

9. Do not accept or offer bribes, payoffs or kickbacks, or engage in other corrupt

practices, and report others who engage in them. Try to prevent these activities

and report others who engage in them. Be careful about giving gifts to government

officials, making payments to an election campaign, or giving to political or

social causes.

10. Comply with all laws on money laundering and terrorist financing, and report

suspicious activities to BMO management and outside authorities.

11. Co-operate fully with investigations, audits, examinations and reviews by our

internal corporate support groups or by any government, regulatory or law

enforcement agency. Do not frustrate or circumvent their inquiries or make

any false or misleading statements. Refer all information requests by external

investigators, regulators and auditors to the right people – use the directory on

the Ethics Office website if a specific person is not identified in the request. Do not

retaliate (or threaten to retaliate) against anyone for cooperating with, or giving

information to, such investigations, audits, examinations or reviews.

BMO’s policies are designed to adhere and comply with legal and regulatory requirements so we’re always doing the right thing.If we fail to meet our legal obligations, we risk damaging BMO’s reputation as well as exposing BMO to legal or regulatory action.Violations are taken very seriously and can result in disciplinary action, up to and including dismissal, and may also affect compensation.

Additionally, we may sue anyone who harms BMO by not following FirstPrinciples and contact outside authorities if laws are broken.

REMEMBER…


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Principle 3Report concerns promptly

Be alert to possible violations of any laws, regulations or FirstPrinciples. Immediately report your concerns to the right people or department.

1. Maintain BMO’s high ethical standards. If you learn of anything that may conflict with

FirstPrinciples – or any laws, rules, regulations or BMO policy – speak up. If you are a

manager, take any concerns you receive seriously. Never make anyone feel that they were

wrong to raise a concern.

2. To raise a concern, consult your manager or compliance department, or check the

FirstPrinciples Contacts and Useful Links on the Ethics Office website. Report concerns about

accounting, internal control over financial reporting or auditing matters to management in the

appropriate finance department.

3. If you are not satisfied after raising a concern, contact BMO’s Ombudsman – an impartial

official who resolves concerns fairly and promptly. The Chief Executive Officer, Chief Financial

Officer, Chief Accountant and people who perform other similar functions should report any

such concerns to the Chair of the Audit and Conduct Review Committee.

4. We will protect anyone who raises legitimate concerns related to FirstPrinciples

from retaliation.

Dos: • Do speak up and report concerns immediately to

management if you suspect something unethical is happening.

• Do take concerns you don’t feel are being dealt with properly to the Ombudsman.

• Do report any concerns about accounting, internal control over financial reporting and auditing matters to the appropriate finance department or the Ombudsman.

Don’ts: • Don’t be afraid to report concerns of any kind.• Don’t ever make anyone feel it was inappropriate

to raise a concern. • Don’t ever retaliate against anyone raising

a concern.


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Doing the right thing

Q: What are the possible consequences of a violation of BMO’s FirstPrinciples?

A: Violations are taken very seriously and may lead to disciplinary action, even legal action where necessary. This could involve corrective action, suspension or termination of employment. Violations may also affect compensation decisions. We may also sue anyone who harms BMO by not following FirstPrinciples and may contact outside authorities if laws are broken. BMO protects you from retaliation when you raise legitimate concerns under this code. Retaliating against anyone reporting an ethical concern or assisting or participating in a review, investigation or proceeding is inconsistent with FirstPrinciples.

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Principle 4Protect information, systems and other assets

Keep non-public information confidential – including non-public information about our customers, suppliers and employees. Protect our systems and other assets from improper use.

1. Protecting information – protect the confidential information of our customers, suppliers and

fellow employees (past, present and prospective). Confidential information is all information

that isn’t public. Comply with laws that restrict using, disclosing, keeping and allowing access

to confidential information.

2. Meet these specific requirements:

• Protecting personal information – obey privacy laws and BMO policies on using or

disclosing customer and employee personal information. If in doubt, get advice from a

manager or the appropriate person identified on the Ethics Office website before sharing

any personal information.

• Using and disclosing customer and employee information – use and disclose this

information only for the specific purpose or transaction for which it was given or collected.

Do not disclose it without the consent of the person unless the law requires its disclosure.

Follow BMO policy on using or disclosing customer or employee personal information. If in

doubt, get advice from a manager or the appropriate person identified on the Ethics Office

website before disclosing any information.

• Accessing customer and employee information – access customer and employee

information in BMO systems or other media only for legitimate business purposes. Keep

employee and customer information strictly confidential and use or disclose it only under

the terms of our policies and procedures.

Dos: • Do create passwords that are at least eight characters

in length, consist of a mixture of UPPER CASE and lower case letters and numbers, and are not obvious words or dates (especially those that have personal associations such as birthdays, names of pets or family names).

• Do install all updates from Office Connect, Harris Connect and/or Pathway Connect.

• Do shred all confidential or highly sensitive documents using the secure disposal bins.

• Do remember that the Internet is in the public domain, so that anyone, anywhere can potentially see what you post online.

Don’ts: • Don’t use unapproved hardware – it could cause

BMO equipment to fail.• Don’t dispose of any hardware or software on a BMO

computer without first obtaining the appropriate authorization.

• Don’t post information online on behalf of BMO unless you are a member of an authorized team mandated to do so.

• Don’t disclose client information without verifying the identity of the person making the request.


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• Disclosing BMO information – do not disclose non-public information to anyone

except under the terms of BMO’s Disclosure Policy. Only certain spokespeople

are authorized to disclose material information about BMO. Ask the authorized

spokespeople to respond to any inquiries you receive, including those from the

investment community or media. Authorized spokespeople must ensure that public

disclosure of BMO information is full, fair, timely, factual, accurate, understandable,

objective, relevant, broadly disseminated, and consistent with legal requirements

and BMO’s Disclosure Policy. Communicate all developments, facts or changes that

could reasonably be material to BMO through the escalation processes established in

BMO’s Disclosure Policy.

• Ensuring information security – be alert to external security threats to information

entrusted to us; don’t put such information at risk. Follow BMO policy on safeguarding

information when dealing with media, including social networking sites.

• Managing information – comply with BMO policies to ensure the accuracy,

completeness and proper maintenance of records, data and information that we own,

create, collect, use and manage – in all types of media. This includes (a) knowing

how long to keep records, especially those related to any pending, threatened or

foreseeable investigation, audit, regulatory examination or legal proceeding and

(b) remembering that others may review any record you create, including email.

We may monitor BMO systems and applications that store and transmit information

(servers, networks, email, etc.) as well as personal mobile devices approved for business

use to ensure that confidential information is protected and handled in compliance with

legal requirements and FirstPrinciples.



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3. Protect BMO systems and other assets, and those of our suppliers, from improper use,

and respect intellectual and other property rights.

4. Use BMO property (such as telephones, voicemail, faxes, computer networks,

email, instant and text messaging, personal digital assistants and remote access

capabilities) only for legitimate business purposes. Keep personal use of such property

reasonable and consistent with BMO policy, including FirstPrinciples.

5. Do not use BMO property to generate, transmit, view, print, retrieve, download or store

communications that are discriminatory, defamatory, obscene, damaging (such as

computer viruses), threatening, or harassing. Do not use material inappropriate for a

business environment (such as sexually-oriented content and chain letters).

6. Respect property rights. Do not duplicate copyrighted material without the written

consent of the copyright holders. This includes software; printed, recorded or broadcast

materials; and digital media.


François is a very busy financial adviser. He distributes his personal mobile number so clients can reach him even when he’s out of the office. He doesn’t have a bank-issued BlackBerry, so he stores customer information in his own phone so he can easily retrieve it wherever he is.

Although François likes being accessible outside the office, his manager has not approved a bank-issued mobile device. François’s own mobile phone doesn’t offer the security needed to protect confidential customer information. He should not be storing any of this information outside the bank.

SCENARIO:


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Principle 5Avoid conflicts of interest

Ensure that your personal and business affairs do not conflict – or appear to conflict – with our interests or the interests of our current or prospective customers and suppliers.

1. Do not let personal interests impair – or even appear to impair – your judgment, loyalty,

objectivity or impartiality in dealing with us, or with prospective or current customers or

suppliers. Be alert to potential conflicts between BMO’s interests and those of our customers

and suppliers, and use good judgment in these cases. If you learn of a potential or actual

conflict of interest involving you, another employee or BMO, report it promptly to

management. The following examples show where some conflicts of interest may arise.

• Misuse of position – do not use your position or connection with us to benefit yourself or

people you are connected to, such as family members, business associates or colleagues.

Do not use your position to harm our customers’ interests. Do not use your access to BMO

information or other assets to benefit yourself personally.

• Gifts, entertainment, other benefits and payments – do not offer, give or receive gifts,

entertainment or similar types of benefits that compromise – or appear to compromise – the

recipient’s or donor’s judgment or honest performance of their duties. Accept gifts and

entertainment of more than nominal value only if the law permits, the gifts are consistent

with industry standards and their disclosure would not harm our reputation, our employees

or the recipient.

• Outside business activities – if you engage in outside activities such as a second job, a

personal business or a directorship, ensure that they do not harm our interests, our reputation

or our customers. For example, do not compete with us. Before taking on outside activities,

follow the procedures found in the Conflict of Interest and Outside Business Activities

Corporate Standard. Follow any regulations that may restrict or prohibit your outside

business activities.

Staff members at a downtown branch each received a $25 gift card for a local coffee shop from a regular customer. Since the yearly gift limit is $100, the employees didn’t think there was anything wrong with accepting the gift cards. Their manager pointed out that gift cards are considered to be cash and under no circumstances can cash be accepted as a gift from a customer. The employees were instructed to return the gift cards.

Other gifts that cannot be accepted include:• Travel arrangements, meals or accommodation for

non-business purposes. • Discounts or rebates on merchandise or services

not available to the public. Example - A local roofer offers you a discount on fixing your roof, if you approve his business loan.

Acceptable gifts include:• Gifts of nominal value for holiday or religious celebrations

such as a gift basket during the festive season.• Tickets of nominal value to local events. • Advertising or promotional material with a token value.

Examples - pens, notepads, golf umbrellas, calendars, etc.• Benefits from civic, charitable, educational or religious

organizations for service acting on behalf of BMO, such as a complimentary meal at an awards banquet.


SCENARIO:

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We valuehonesty

Q: What are the consequences of violating the personal trading principle?

A: In some cases, a trade may be reversed or restrictions may be imposed on trading. If a trade is reversed, the person who authorized the trade will be responsible for any losses and must forfeit any profits from the trade. If an investigation reveals that the individual(s) in question engaged in activities prohibited by regulatory requirements, outside authorities will be contacted. The employee(s) will be disciplined, and this can include termination of employment.

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Principle 6Ensure personal activities do not harm BMO

Ensure that your personal pursuits, involvement in the community and political activities do not harm BMO’s interests or reputation.

1. Avoid personal interests and activities that could conflict with BMO’s interests or harm

BMO’s reputation. Make it clear that BMO is not associated with your personal activities.

Some examples include:

• Community service – BMO and its employees enjoy a long, honourable and very active

tradition of community service. In some cases, we can support your involvement in such

activities. If you take on roles in religious, educational, cultural, social and charitable or

other non-profit entities, promptly identify and manage any actual or potential conflicts

with BMO’s interests that these roles create (for example, if you become a director of a

charity that banks with us).

• Political participation – if you run for public office, support others running for office or back

a cause, make it clear that your activity is personal and that BMO is not associated with your

political views or allegiances. Observe all applicable laws, restrictions and prohibitions on

corporate or individual contributions to political parties, public officials, candidates or causes.

• Public expression of personal views – if you express personal views, make it clear that

you are not speaking for BMO. Before publicly expressing views on matters that could

affect BMO, consult management and, if appropriate, Media and Public Relations or

Corporate Communications. This is especially important for branch or community banking

managers who have a public profile as a spokesperson. When offering personal opinions

in a public forum, use common sense – don’t make statements that might discredit BMO

or our competitors.

Recently, Peter joined the campaign team for a woman running for mayor in his hometown. Peter is now looking for places to host a car wash and barbecue for the candidate, so he asks the manager of the town’s BMO branch. The branch manager tells him she can’t offer him space on BMO grounds to host the car wash and barbecue since it would appear that BMO was a supporter of this particular candidate and, therefore, it would be a violation of the personal activity principle.


SCENARIO:

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• Written, published material and social media – if you write books, articles or

letters, run a personal website or blog, or share personal information on a social

media website, do not harm BMO’s interests or reputation. Follow our policy

on social media and laws that may apply before posting entries in blogs, wikis,

Internet forums or social networks. At a minimum, make it clear that BMO is not

associated with your activity. Do not use or refer to customer information, BMO

proprietary information or BMO brand assets such as our name, logo, and other

trademarked and copyrighted material in any form, unless you have permission

from management.


Social Media: What’s Appropriate?

There is a significant difference between speaking on behalf of BMO and about BMO. Unless you are an approved Social Media Representative you must not indicate, imply or create the impression that you have authority to speak on behalf of BMO.

You may disclose on your social media profile(s) that you work for BMO. If you do so, then you must include a disclaimer on that profile that any views expressed are your own and are not made on behalf of BMO.

Do not mention, refer to in any way, nor give any advice or recommendations about any products or services offered or otherwise made available by BMO.

Only approved Social Media Representatives may refer to products and services offered by BMO, including any products, services or securities offered by BMO Private Client Group and BMO Capital Markets.

SCENARIO:


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Principle 7Ensure personal trading complies withlaw and policy

Do not engage in trading activities – personal or professional – that abuse or undermine the integrity of the markets. Do not use inside information.

1. Do not trade securities based on material non-public information. Material non-public

information means information that, if it were publicly known, would reasonably be

expected to have a significant effect on the market value of a company’s securities. Do not

share such information with other people. Use of material non-public information when

trading securities (including BMO securities) violates both the law and FirstPrinciples.

2. Do not spread rumours to manipulate a security price or engage in market timing of

mutual funds.

“ The relationships we have with our customers, our shareholders, our communities and each other are built on the expectation that we will be honest, fair and legal in all that we do. FirstPrinciples, our Code of Conduct, is aligned with our BMO Financial Group vision, culture and values. As a company, we are committed to great customer experience and to an internal culture where employees are encouraged to explore their potential and contribute at their

fullest.” Mark F. Furlong

President and CEO Personal and Commercial Banking U.S. BMO Financial Group


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Conclusion

We are dedicated to responsibility and

fairness, reflected in our longstanding

reputation as a company with integrity. Each

of us is responsible for upholding BMO’s core

values. We expect our employees to do the

right thing. FirstPrinciples provides a clear

overview of our standards and beliefs.

Familiarize yourself with FirstPrinciples,

and know them well. We are committed

to holding ourselves to the highest ethical

standards – and that commitment is the key

to our continued success.

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Do the Right Thing

Demonstrate respect for all and earn trust through the integrity of our actions.


Report your concerns:BMO wants all employees to be comfortable escalating concerns.

Employees are encouraged to speak with their manager first, followed by their

Responsible Executive or Compliance Office. If you have spoken with your

manager, Responsible Executive or Compliance Office and feel that the matter

needs to be taken further, stop and consider the type of concern you’re dealing

with. From here you’ll know whether you should speak to the Human Resources

Centre – Employee Relations or the Ombudsman Office.

Concerns regarding harassment, employee compensation, personnel policies and

other HR matters should be directed to the Human Resources Centre – Employee

Relations.

The Ombudsman Office is a confidential and, if desired, anonymous resource

for employees worldwide to report any concerns related to FirstPrinciples,

Anti-Corruption Policy, accounting, internal control over financial reporting

and/or auditing matters.

Important ResourcesCode of Conduct http://www.bmo.com/home/about/banking/

corporate-information/codeofconduct

Annual Report http://www.bmo.com/home/about/banking/investor-relations/

annual-reports-proxy-circulars

Corporate Governance http://www.bmo.com/home/about/banking/

corporate-governance

Corporate Responsibility Report http://www.bmo.com/home/about/banking/

corporate-responsibility/home

Ombudsman Office http://www.bmo.com/home/popups/global/ombudsman/

ombudsman-details

®

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www.bmo.com/home/about/banking/corporate-information/codeofconduct

http://www.bmo.com/home/about/banking/investor-relations/annual-reports-proxy-circulars

http://www.bmo.com/home/about/banking/corporate-governance

http://www.bmo.com/home/about/banking/corporate-responsibility/home

www.bmo.com/home/popups/global/ombudsman/ombudsman-details

Documents

FirstPrinciples - Bank of Montreal EN.pdf · national or ethnic origin, age, ... she sends a communication across Canada in English ... with FirstPrinciples. BMO FINANCIAL GROUP •