BMO Whistleblower Hotline

Misconduct is behaviour that falls short of legal, professional, internal conduct or ethical standards. Misconduct conflicts with the Code and could harm BMO’s reputation, employees or others. 

If you suspect someone working at BMO or providing a service on behalf of BMO is engaging, planning to engage, or already engaged in misconduct, you need to Speak Up! and report your concern. 

Examples of misconduct that you should report include:

• Concerns about financial fraud, accounting irregularities, internal controls over financial reporting or auditing matters 
• Violations of BMO policy or procedure 
• Disregarding or failing to comply with legal or regulatory requirements 
• Illegal conduct, such as theft, violence, or threats 
• Offering or accepting a bribe, kickback, or facilitation payment 
• Conflicts of Interest 
• Insider trading 
• Failing to safeguard or inappropriately accessing confidential information 
• Taking advantage of, coercing, imposing excessive or persistent pressure on any BMO customer or member of the public 
• Violations of voluntary codes of conduct and public commitments that BMO has agreed to (see Voluntary Codes of Conduct and Public Commitments) 
• Harassment or discrimination 
• Actual or suspected retaliation against a person who has reported misconduct 

The Speak Up! Service facilitates secure, confidential, and anonymous reporting 24 hours a day, 7 days a week, in multiple languages. 

Online

Report a concern online through the ClearView Connects™ website (go to www.clearviewconnects.com, click “Submit a Report’ and enter BMO in the “Let’s Get Started” search box)

Phone

Call ClearView Connects^™ at BMO’s dedicated Speak Up! number 1-844-783-9209 (Canada/USA).

If you are outside of Canada/USA, please report your concern by phone using the international toll-free numbers below or call collect at 1-647-426-7281. 

Email

ethics@bmo.com

Mail

BMO Ethics Office, Attention: Chief Ethics Officer 

1 First Canadian Place P.O. Box 150 

Toronto, ON M5X 1H3 

Government

Although you are encouraged to report your concerns to BMO, you are not required to report to BMO and may choose to report externally to applicable regulators, governmental agencies, law enforcement agencies, or self-regulatory authorities in your jurisdiction. 

Keep your concerns factual. Include as much detailed information as possible so that your report can be investigated. Useful details include:

• date, time, and location  
• names of person(s) involved, roles and their business group  
• the general nature of your concern  
• how you became aware of the issue  
• possible witnesses  
• any other information you believe supports your report. You can take out your name and any identifiable information if you prefer to remain anonymous  

Do not upload or attach any potentially sensitive or confidential data from BMO’s systems with your report (for example, customer personal and financial information, employee personnel records, proprietary system and project documentation, strategic plans or unannounced financial results). This may violate BMO’s Data Loss Prevention rules and trigger an alert that will be sent to your manager. We can obtain internal information that relates to your report directly from BMO’s systems. 

Every year our Ethics Office receives a small number of reports that can’t be actioned or fully reviewed because limited information is provided. By sharing more information, you will help us to better assist you and investigate the concern. 

The three key steps of the process are:

1) Triage:  

The Ethics Office reviews and categorizes every report received to determine if it is reporting misconduct for review through BMO’s Whistleblower Process or raising concerns or inquiries that are out of scope of the Whistleblower Process. The Ethics Office may provide information or direct out of scope concerns and Inquires to other teams or contacts as appropriate. 

The Ethics Office acknowledges all reports regardless of categorization and may ask questions to get more information, clarify or better understand your concerns.

2)  Investigation: 

The Ethics Office will engage appropriate stakeholders to investigate misconduct reports. While the scope and length of time it takes to complete an investigation will vary based on the nature and complexity of the concern, all investigations will: 

• Be handled in a sensitive and impartial manner. 
• Conducted as quickly and efficiently as the circumstances permit. 
• Determine if there is enough evidence to substantiate the allegations; and 
• Result in consequences when a violation is found. 

No further action is required from you unless you are contacted for more information. 

The Ethics Office may decide not to open a file, or to close a file during the investigation process if: 

• the matter is being handled by lawyers on behalf of you or BMO; 
• the matter is before the courts or another regulatory or administrative body or tribunal (e.g., the Human Rights Commission); or 
• the Ethics Office believes the matter is being pursued in a frivolous or vexatious manner. 

3)  Follow up:

The Ethics Office will not close an investigation file until they impartially review the investigation findings to ensure your concerns are reviewed, and appropriate action is taken. If you share your contact information and/or communicate with Ethics through the Speak Up! Service, you will receive a follow up advising when the investigation file is closed, however for privacy reasons, you will not be provided with specific details of an investigation, including the outcome. 

There are consequences for those that engage in misconduct, up to and including termination. BMO may also take additional steps to address violations, including developing enhanced training, increasing communication to employees, or changing policies and procedures.

When you raise a concern through the Speak Up! Service you have the option to provide your name and contact information, or you can raise your concern anonymously through the Speak Up! Service. You are encouraged to report in the way you feel most comfortable, however you should be aware that it can be more difficult to investigate anonymous allegations, especially if your report is general, vague or includes limited information. 

Whenever possible, the Ethics Office will redact or restrict the disclosure of any identifiable information in your report if you would like to remain anonymous. However, please be aware that it may be difficult to maintain your anonymity if:

• you were the only person that was present or witnessed the behaviour. 
• you were the only recipient of the information; or 
• you are the only person that was aware of the situation. 

If you provide your name and contact information, it will only be shared with your consent within BMO as required to investigate the matter, or if BMO is legally obligated to disclose your identity. This would include if BMO receives a court order, subpoena, or regulatory request pursuant to applicable legislation.

Retaliation

Retaliation can be any action that deters or punishes someone for speaking up to report suspected misconduct. It includes terminating employment, demoting, harassing, disciplining, discriminating against, taking adverse job action, terminating a contractual relationship or any other behaviour that threatens or punishes someone who in good faith: 

• Reports actual or suspected misconduct, either internally or externally; 
• Provides information or otherwise assists in any investigation or proceeding regarding a concern; 
• Questions whether something is ethical or right; 
• Refuses or intends on refusing to engage in misconduct; 
• Prevents or intends on preventing misconduct from being committed; or 
• Encourages or supports someone to report a concern. 

BMO has zero tolerance for retaliation. 

If you have experienced retaliation because you reported misconduct to BMO, please report it to BMO’s Ethics Office using the Speak Up! Service.