Our Commitment

BMO Financial Group is driven by enduring corporate values. These values represent our core beliefs. They stand as our collective commitment – to our colleagues, to our customers, to our shareholders and to the communities of which we are a part. These values live in the way we work, in the solutions we offer, in the employment environment we provide and in the way we partner with the community.

• Our Values
• Code of Conduct
• Corporate Sustainability Governance
• BMO on the Issues

Our Vision

"We know how important it is to recognize and respect customer values –and to embody them in our own values and the way we do business."

Bill Downe President and Chief Executive Officer BMO Financial Group

To be the bank that defines great customer experience.

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.

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Code of Conduct

What is it?
FirstPrinciples is our code of business conduct and ethics. It reflects our commitment to doing what is fair, legal and right.

Who does the Code of Conduct apply to?
FirstPrinciples applies to all BMO Financial Group directors, officers and employees. We also make our major suppliers aware of our Code of Conduct. All BMO Financial Group directors, officers and employees acknowledge annually that they have read, understand and complied with the code.

Ethics and legal compliance training
Directors, officers and employees must annually complete online training modules designed to assess awareness, understanding and compliance with key ethical, legal and regulatory requirements. In 2010, we adopted a centralized process for the design and development of regulatory and policy mandated training programs. Further enhancements were introduced for 2011, including an expanded repertoire of both enterprise-wide and more targeted training modules.

Enterprise-wide training include:

• Code of Conduct
• Information, security and privacy matters
• Anti-corruption
• Anti-money laundering & anti-terrorist financing

How often is the Code of Conduct updated?
Each year, our Corporate Compliance department conducts a rigorous review of FirstPrinciples, benchmarking our Code of Conduct against best practices within the global financial services industry and regulatory environment, before presenting it to our Board of Directors for review and approval.

How is the Code of Conduct made available?
FirstPrinciples is published in both English and French on various internal sites and on bmo.com. Our intranet contains information for managers and employees on how to apply FirstPrinciples in their daily work and lists key contacts for those seeking guidance on specific issues relating to the Code.

Exceptions and escalation
Exceptions to FirstPrinciples are not typical, nor are they encouraged. Any exception for a director, officer or employee must be approved by the Audit Committee of the Board of Directors. When required by applicable law, rule or regulation, exceptions shall be disclosed to the appropriate regulatory bodies.

Protecting whistleblowers
We encourage any BMO employee who has concerns relating to a breach or potential breach of either FirstPrinciples or any law, regulation or BMO policy to immediately report the concern to one of the appropriate persons and departments listed on our FirstPrinciples website.

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Corporate Sustainability Governance

Corporate sustainability is embedded in every facet of our organization – not only because it’s the right thing to do but because it’s integral to our success.

Our business is built on trust, so we constantly review and refine our governance standards to ensure we are maintaining the highest standards for ethics and transparency.

BMO’s Corporate Responsibility & Sustainability Policy outlines BMO management’s approach to dealing with social and environmental issues. The Policy is approved by the Board of Directors and is supported by a number of related policies covering:

• anti-money laundering and terrorist financing
• code of conduct
• conflicts of interest
• corruption and bribery
• equal opportunity and harassment
• financial governance
• health and safety
• human resources management
• market disclosure
• privacy and confidentiality of personal information
• operation of our compliance framework
• relationships with external auditors
• securities trading by employees
• whistleblower protection

Our Corporate Responsibility & Sustainability Group is responsible for identifying, understanding and addressing the wide-ranging implications of sustainability issues that impact our business, and collaborating with various areas of the bank to address them. The group is closely aligned with our Environmental Sustainability Group, whose mandate is to design and implement programs for BMO to reduce its operational impact on the environment.

Our Sustainability Council provides guidance and oversight for environmental and social issues. Members are senior leaders representing the bank’s various business and corporate areas. The Council meets quarterly and the chair reports directly to the CEO, who is a member of the Board of Directors.

Financial services companies must deal with a range of sustainability issues. BMO’s board committee structure is designed to help the Board of Directors fulfill their oversight and governance responsibilities. Sustainability issues are addressed in the mandates of the various committees and as required, items are forwarded to the Board for further consideration.

Board Oversight of Sustainability Issues (24 KB)

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BMO on the issues

We think it’s important to be clear about where we stand on the issues that affect our business. The documents listed here summarize our views on issues ranging from anti-corruption to collective bargaining to human rights.

Our views are based on our code of conduct and internal guidelines, and comply with laws in all jurisdictions where we operate. They apply to Bank of Montreal and its subsidiaries, wherever we do business.

1. Anti-corruption (PDF, 30 KB)
2. Anti-money laundering and terrorist financing (PDF, 31 KB)
3. Freedom of association and collective bargaining (PDF, 33 KB)
4. Human rights (PDF, 29 KB)
5. Political contributions and lobbying (PDF, 29 KB)

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