Anti-Corruption Policies
RBC's Code
of Conduct is a comprehensive document, covering topics
including corruption and bribery. In addition, RBC has policies,
programs and procedures in place to combat corruption, including:
These policies were reviewed in 2006 to reflect changes
in RBC's standards as well as the regulatory and industry
environments. The policies are reviewed annually to ensure
continued compliance.
RBC companies and employees are subject to the laws, rules
and regulations of all countries in which they operate. These
laws include, but are not limited to, banking laws, securities
laws and regulations, laws prohibiting the dealing with corrupt
foreign officials, as well as employment legislation. RBC
complies with all regulations in the jurisdictions in which
it conducts business.
Internally, we have formal committees on process and technology
solutions to address risks. In addition, the Office of the
Superintendent of Financial Institutions (OSFI), Canada's
primary banking regulator, audits our compliance with Canada's
Proceeds of Crime (Money Laundering) and Terrorist Financing
Act, which demonstrates the government's commitment to
fight money laundering and contributes to international efforts
to detect, deter and prevent money laundering and seize criminal
and terrorist funds.
RBC provides ongoing training for employees with respect
to money laundering and terrorism financing through web based
training, presentations, employee communications vehicles
(newsletters, websites, meetings etc.) and conferences.
Anti-Money Laundering Policy
RBC Financial Group companies are required to apply appropriate
scrutiny and monitoring measures to high-risk clients whose
business activities are known to be susceptible to criminal
activity or have been designated as high risk for money laundering.
Our Global Anti-Money Laundering Compliance Group is dedicated
to the continuous development and maintenance of policies,
guidelines, training and risk assessment tools and models
to help our employees deal with ever-evolving money laundering
and terrorism financing risks.
RBC actively participates in global industry groups dealing
with Anti-Money Laundering and Anti-Terrorist Financing. We
consult with Canada's national financial intelligence unit,
the Financial Transactions and Reports Analysis Centre of
Canada (FinTRAC) to ensure that we are effective in our reporting
of prescribed transactions. To enhance our anti-money laundering
capabilities, we implemented an enhanced software system to
detect, track and analyze transactions for suspicious activities.
In 2007, every RBC employee worldwide, regardless of their
role in the organization, took an anti-money laundering/anti-terrorism
financing course and exam. The course was tailored for each
business, function and geography with material specific to
the laws of 38 countries and jurisdictions in which we operate.
Our Global Anti-Money Laundering Compliance Group develops
and maintains policies, guidelines, training and risk assessment
tools and models and other controls to help our employees
protect RBC and our clients, and to ensure we are managing
ever-evolving money laundering and terrorism financing risks.
Our controls in this area incorporate Know Your Client rules
established by various regulators to ensure we properly identify
our clients and protect against the illegal use of our products
and services.
Learn about our anti-money
laundering certifications.
Anti-Terrorism Policy
As part of the global fight against Terrorist Financing Activities,
countries around the world have enacted regulations aimed
at combating terrorism that typically prohibit dealings with
certain entities and individuals, and require financial institutions
to file reports with regulators and other authorities as required.
RBC units and their directors, officers, and employees will
not knowingly enter into transactions with, or provide or
assist in providing, directly or indirectly, financial services
to, or for the benefit of, states, entities, organizations
and individuals targeted by applicable anti-terrorism measures.
Failure to comply with applicable anti-terrorism measures
can result in fines against RBC and/or its directors, officers
and employees, possible imprisonment for individuals and severe
reputational consequences for RBC.
In order to effectively meet these requirements, RBC has
implemented automated systems for scanning client names against
various terrorist and control lists daily, including scanning
of payments against OFAC and other control lists, as per Terrorist
Financing regulations.
In 2007, every RBC employee worldwide, regardless of their
role in the organization, took an anti-money laundering/anti-terrorism
financing course and exam. The course was tailored for each
business, function and geography with material specific to
the laws of 38 countries and jurisdictions in which we operate.
Know Your Client Policy (Client Due Diligence)
Financial institutions around the world are increasingly
recognizing the importance of implementing and maintaining
adequate controls and procedures to ensure that on a reasonable
and practicable basis they know with whom they are conducting
business.
RBC businesses must perform adequate due diligence on new
and existing clients to understand with whom we are dealing
and to comply with applicable anti-money laundering, anti-terrorism
and economic sanctions legislation regulatory guidance, suitability
regulations and related policies.
The consequences of any lack of vigilance in this area can
be severe. Facilitating a financial transaction while willfully
or recklessly disregarding the source of a client's assets
or the nature of a client's transaction can result in criminal
and/or civil liability for the employee and/or RBC. Consequently,
conduct inconsistent with this Policy may subject the employee
involved to corrective action, up to and including termination
of employment, as well as possible civil and criminal penalties.
Economic Sanctions Policy
RBC companies, and all their units globally, as well as their
directors, officers, and employees will not knowingly conduct
business with states, entities, organizations and individuals
targeted by the economic sanctions of the jurisdictions where
they are located or where they operate. In addition:
- We will not knowingly conduct business with states, entities,
organizations and individuals targeted by the economic sanctions
of other jurisdictions that are applicable to them by reason
of their country of incorporation or of citizenship, to
the extent provided by such economic sanctions; and
- We will not knowingly do anything that causes, assists,
or promotes, or is intended to cause, assist or promote,
any act which they would be prohibited from doing directly.
Position on Tax Havens
RBC supports the laws enacted by Canada and the other jurisdictions
where it carries on business that are designed to deter tax
evasion, tax fraud, money laundering and other criminal activities.
RBC and our employees are expected to comply with all laws
and regulations that govern our businesses in the various
jurisdictions in which we operate. We also contribute to the
effort to eliminate abuses by working with international organizations
to enhance policies and rules that govern the global financial
system.
Political Contributions and Lobbying
RBC's policy on political donations is built into our Code
of Conduct as follows:
RBC companies will make only those contributions permitted
by law to a political party, candidate, or campaign and only
as an expression of responsible citizenship - not to "purchase"
favours or to gain improper advantage. Contributions to political
parties, riding associations, and candidates are not included
in the corporate philanthropy program. Head Office decides
on and reports such contributions separately for RBC companies.
Employees are encouraged to take their citizenship seriously
and to participate in general political processes such as
school board, municipal, provincial and/or federal elections,
etc.
RBC Financial Group no longer makes corporate donations to
federal political parties through any part of our company
in Canada. RBC makes political donations to provincial parties,
to the extent permitted by law or internal policy. RBC' s
participation in provincial political donations is limited
and restricted depending upon the respective province and
territory. Political donations to municipal politicians are
not permitted.
In the United States, we do not provide political donations
to any party at any level of government. Neither is the corporation
permitted to donate to PACs (Political Action Committees).
In the United States, our employees are permitted to raise
monies through federal and state Political Action Committees
for candidates. Funds donated by employees are reported to
the Federal Election Commission and to appropriate state regulators,
such as the North Carolina Board of Elections.
RBC has a credit policy relative to lending to political
parties or candidates, in order to ensure all requests are
treated in a fair, consistent and equitable manner, while
freeing the bank from perceived political bias and resultant
reputation risk.
Anyone who lobbies on behalf of RBC must register with the
Office of the Registrar of Lobbyists (federal government),
under the Lobbiest Registration Act. A list of all registered
lobbyists in Canada is publicly available, including RBC lobbyists.
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