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Peoples Group Whistleblowing Program
What you need to know
At Peoples Group we take pride in operating with integrity, honesty, diversity, and responsibility, as we have done throughout our 35-year history. These values are reflected in our internal Code of Conduct.
We highly value our relationships with employees, customers, and stakeholders and are aware of the impact our business decisions have on them. Our commitment is to always do the right thing.
As part of this ongoing commitment, we have established a confidential, anonymous, and secure reporting system to report any concerns about irregular business activities or behaviour. We continue to foster a culture where employees feel safe and are encouraged to speak up about any actual, suspected, or anticipated wrongdoing, without fear of retaliation or disadvantage.
What kind of wrongdoing can be reported?
Wrongdoing can come in many forms. It may be conducted by an individual or group and can lead to serious or negative implications to the public’s interest or the integrity of Peoples Group. Conduct to report could include dishonest, illegal, fraudulent, suspicious, or unethical behaviors or the unauthorized disclosure of confidential information.
Wrongdoing may include a contravention of: any provision of the Bank Act or its regulations; a voluntary code of conduct that Peoples Group has adopted or a public commitment that it has made; or a policy or procedure established by Peoples Group.
Who can report wrongdoing?
You can report wrongdoing if you are a current or former employee, contractor, or director of Peoples Group, or an employee of an affiliate or third party, representative, or other intermediaries of Peoples Group.
Customers concerned about how a product or service has been sold or offered should contact us through our complaint resolution process, not the whistleblowing program. Details are available at https://www.peoplestrust.com/en/about-us/resolving-your-concerns/
How can you report wrongdoing?
We have several internal channels for reporting wrongdoing. Employees can report wrongdoing to: the Appointed Employee, as defined in our Peoples Group Whistleblowing Policy; their People Leader; a member of Senior Management; or the Chief People Officer.
Alternatively, wrongdoing can be reported anonymously through an independent, third-party agency, ClearView ConnectsTM.
- Online through their secure website at: www.clearviewconnects.com
- Over the phone through a dedicated toll-free number: 1-866-865-3691
- By mail through the confidential post office box at: ClearView Connects P.O. Box 11017 Toronto, Ontario M1E 1N0
Reporting is available 24/7, in multiple languages.
You can also report wrongdoings directly to the Commissioner of the Financial Consumer Agency of Canada, the Office of the Superintendent of Financial Institutions, any other government agency or body that regulates or supervises financial institutions, or a law enforcement agency.
What protections apply to whistleblowers?
Employees who report wrongdoing based on a reasonable belief, are protected from disadvantage, reprisal, or retaliation.
If you report wrongdoing, all information received from you will be treated confidentially and sensitively. Your identity or information that could reasonably be expected to reveal your identity will only be disclosed to the appropriate regulatory body or law enforcement agency for purposes related to an investigation. If your identity is disclosed, we will make every reasonable effort to inform you of the disclosure.
How do we investigate whistleblowing?
An initial preliminary review will be conducted to determine whether the wrongdoing should be investigated. While not all wrongdoing reports will lead to an investigation, all reports will be assessed, and a decision made on whether to investigate.
All investigations will follow an objective and fair process. Investigations will be conducted in a timely manner, and all parties to an investigation will be treated fairly. Employees involved in the allegation of wrongdoing will be provided with an opportunity to respond before any adverse findings are made against them.
Employees who report wrongdoing should be aware that the findings and recommendations of any investigation are a confidential matter and may not be made available to them.
Ethical reporting covers several areas such as accounting or financial controls, acts of dishonesty or illegal activity, fraud, unauthorized disclosure of confidential information or conduct that appears suspicious or unethical.