Principles and Policies
Financial service companies, perhaps more than any other
business, depend on confidence and trust. As a global organization,
RBC respects and complies with laws and regulations that govern
our businesses in the jurisdictions in which we operate.
RBC has enterprise-wide policies and processes to support
the assessment and management of risks, including policies
to address issues such as the environment, privacy, money
laundering, terrorism financing, economic sanctions, lending
to political parties, and fiduciary risk. We regularly review
policies and controls to ensure continued effectiveness and
alignment with relevant laws and regulations. We also adhere
to a number of other principles, codes and policies to ensure
we operate with integrity, including our Code of Conduct,
which governs the behaviour of our employees and informs how
we conduct all our businesses operations. This section covers
key principles, codes and policies, including:
Code of Conduct
All RBC employees worldwide are governed by our Code of Conduct,
which was established more than 20 years ago. We review the
Code regularly and update it as needed to ensure it covers
all aspects of our activities and is clear and easy for our
employees to understand and follow. RBC requires all employees
to successfully complete a web-based learning program and
test or to follow an alternative process approved by our Human
Resources Advisory Service, so that they know and understand
the Code's principles and compliance elements. Employees must
review the Code and acknowledge adherence to it at least once
every two years. In addition, the company's most senior officers
and select others must complete the acknowledgement annually.
RBC's Code of Conduct includes the following principles:
- Upholding the law
- Confidentiality
- Fairness
- Corporate responsibility
- Honouring our trust in you
- Objectivity
- Integrity
- Individual responsibility
Privacy
We have had a formal Privacy policy since 1991 to ensure
that the personal and financial information of our clients
and employees is protected.
For more information, see Marketplace-Consumer
Protection.
Know your client (client due
diligence)
RBC has long recognized the importance of implementing and
maintaining adequate controls and procedures to ensure that
on a reasonable and practicable basis, we know with whom we
are conducting business. We perform due diligence on new and
existing clients, and comply with applicable regulatory guidance
concerning anti-money laundering, anti-terrorism and economic
sanctions, as well as with suitability requirements that protect
our clients.
Fiduciary risk
RBC businesses and subsidiaries are expected to identify,
assess, manage and mitigate any fiduciary risk inherent in
our business and operations or arising from our specific activities
and relationships with clients.
Employees engaged in fiduciary relationships must have the
appropriate level of knowledge and training necessary to discharge
their fiduciary duties and must meet all regulatory licensing
or registration requirements. Client communication campaigns
and marketing materials sent to clients in relation to fiduciary
duties must be reviewed and approved from a fiduciary risk
perspective.
The environment
RBC first adopted a formal environmental policy in 1991,
and we update it regularly. Our policy applies to all of RBC's
operations, including:
- Environmental impacts of products and services
- Suppliers and service providers (e.g., contractors)
- Other key business partners (e.g., non-managed operations,
joint venture partners, etc.).
Our environmental policy incorporates a number of components
that are drafted, implemented and updated regularly. For instance,
our Code of Conduct addresses the behaviour we expect of our
employees with regard to the environment. We ask vendors to
supply us with their own environmental policies and practices,
which we consider in the supplier selection process. We also
have specific environmental risk management policies for various
businesses including agricultural businesses, residential
mortgages, business and commercial markets and project finance.
In 2007, we launched the RBC Environmental Blueprint™,
which covers our policy, priorities and objectives. The blueprint
is overseen by a Corporate Environmental Affairs group that
works with executives and staff in business and functional
units.
Development
of products and services
RBC has a formal policy that sets out a defined, rigorous
process for launching any new product or significantly changing
an existing one. We evaluate products for a range of risks
and ensure they align with client needs, our Code of Conduct,
laws and regulations, and voluntary consumer protection codes
that we have signed. Approval levels within RBC correspond
to the level of risk identified for a particular product or
service.
Anti-Corruption,
Anti-Bribery
RBC's Code of Conduct includes broad principles that address
anti-bribery and anti-corruption concerns, and prohibits employees
from making improper political contributions. To supplement
our Code of Conduct, and to enhance understanding of regulations
as well as the specific requirements of the U.S. Foreign Corrupt
Practices Act, RBC launched a new Anti-Corruption and Anti-Bribery
eLearning training program in April 2009. This training is
mandatory for certain employees based on the nature of the
business activities they perform for RBC and/or the geographic
regions in which they conduct their business
Anti-money laundering
RBC companies are required by various regulators to apply
appropriate scrutiny and monitoring measures to clients in
order to monitor for possible money laundering, especially
for 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 (AML)
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, to ensure that we are effective in our reporting of
prescribed transactions. To enhance our anti-money laundering
capabilities, we have implemented robust software systems
to detect, track and analyze transactions for suspicious activities.
RBC promotes employee awareness and compliance with anti-money
laundering and anti-terrorist financing controls through web-based
training, presentations, employee communications vehicles
(newsletters, websites, meetings, etc.) and conferences. Annual
anti-money laundering training is mandatory for all employees
including senior executives.
Learn
more
Anti-terrorism
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.
In order to effectively meet these requirements, we have implemented
automated systems for scanning client names against various
terrorist and control lists daily, as well as scanning of
payments against government control lists, as per terrorist
financing regulations.
Tax havens
RBC operates in 50 countries. RBC supports the laws enacted
by Canada and the other jurisdictions where we operate that
are designed to deter tax evasion, tax fraud, money laundering
and other criminal activities. RBC, our subsidiaries and employees
are expected to comply with all laws and regulations that
govern our businesses in the various jurisdictions in which
we operate. While complying with applicable laws, we arrange
our business affairs in a manner that best meets the needs
of our stakeholders. We also contribute to the effort to eliminate
abuses of the global financial system by practising "Know
Your Client" rules, implementing throughout our global
network a robust anti-money laundering compliance regime,
adhering to a Code of Conduct, and working with international
organizations to enhance policies and rules that govern the
global financial system.
Economic sanctions
RBC businesses, and all our units globally, as well as our
directors, officers, and employees will not knowingly conduct
business with states, entities, organizations and individuals
targeted by the economic sanctions of the jurisdictions where
we are located or where we 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.
- 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.
Reporting
suspected irregularities
RBC employees around the world have the duty to report suspected
breaches of our Code of Conduct, other irregularities and
dishonesty. We have long-established processes that enable
employees to do so, and our Code of Conduct protects employees
from retaliation for any report made in good faith. Specific
to financial reporting practices, the RBC Reporting Hotline
was established so employees and third parties around the
world can report suspected irregularities or wrongdoing relating
to accounting, auditing or internal accounting controls directly
to the RBC Ombudsman, anonymously, confidentially and without
fear of retaliation.
Political
contributions and lobbying
RBC's policy on political donations is outlined in our Code
of Conduct as follows:
[RBC] 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. …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 does not make 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 and/ or internal policy. Our 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, RBC does not provide political donations
to any party at any level of government, or PACs (Political
Action Committees). However, our U.S. employees are personally
permitted to raise monies through federal and state PACs for
individual 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 to ensure that all requests are treated
in a fair, consistent and equitable manner, while freeing
us from perceived political bias and resultant reputation
risk. Certain employees who lobby on behalf of RBC must register
with the Office of the Commissioner of Lobbying of Canada,
under the Lobbying Act. A list of all registered lobbyists
in Canada is publicly available, including RBC lobbyists.
In addition, RBC employees who have conversations with senior
federal public office holders with respect to legislative
proposals, bills, resolutions, regulations, policies, programs
or grants, contributions or other financial benefits must
report these conversations to the Lobbyists Registry on a
monthly basis.
Voluntary codes
We have signed and adhere to a number of voluntary codes
of conduct in the area of consumer protection. Voluntary codes
of conduct are non-legislated commitments, voluntarily made
by companies, associations and other organizations used as
a form of consumer protection in place of government legislation.
For more information, see rbc.com/voluntary-codes-public-commitments
External
principles, charters and initiatives
RBC subscribes to or participates in a number of externally
developed economic, environmental and social principles, charters
and initiatives. They include:
- The Equator Principles
- The United Nations Environment Programme Finance Initiative
- The Universal Declaration of Human Rights
- The International Chamber of Commerce Business Charter
for Sustainable Development
- OECD Guidelines for Multinational Enterprises
- The Canadian Human Rights Act
- The Global Reporting Initiative
- Imagine, a Canadian initiative to encourage corporate
philanthropy and volunteerism (RBC is a founding member)
- The Canadian Standards Association's Strategic Steering
Committee on Business Management and Sustainability.
