Approved on July 19, 2011
This Code of Conduct provides guidance on how you conduct your professional duties and outlines your responsibilities. The Code is related to the policies of Rockglen-Killdeer Credit Union (“the credit union”), its board, and federal and provincial laws and regulations. Referring to the Code and corporate or board policy should help you recognize the right thing to do when faced with an ethical situation.
If unsure, it is important that you ask before you act. Employees are encouraged to discuss any questions about Code of Conduct related matters with their manager or supervisor. Directors may obtain further information from the Conduct Review Committee.
This Code of Conduct is not a comprehensive manual that covers every situation that might be encountered. Each employee and director should apply this Code with common sense and the attitude of seeking full compliance with the letter and spirit of the guidelines presented.
Adherence to the Code is mandatory for all employees and directors. Your choices in applying this Code shape the ethical culture and conduct of the credit union. Each of us has a personal responsibility to maintain the trust of our stakeholders and protect the credit union’s reputation in the industry.
Questions to Consider
Some of the questions to consider when deciding how to act could include:
Is it in accordance with the credit union’s values and standards?
Is it legal?
Will it reflect negatively on your image or the credit union’s if it became publicly known?
Who else could be affected by this action?
Is there an alternative action that would not create an ethical problem?
How would it look if printed in the newspaper?
Additional Information and References
Specific policies and procedures exist for harassment, violence, bullying, security, information technology, conflict of interest, and privacy. Additional information is available in the credit union’s Human Resources Policy Guide and Privacy Code or the Board of Directors Policy Manual.
Note: Copies of this Code are available in hard copy and electronic form.
1. Abiding by the Law
Laws and Regulations
Legislation and regulations apply to many aspects of credit union and subsidiary business, including the kinds of services offered and the way in which they are offered. Employees and directors must comply with the letter and spirit of all applicable laws, regulations and standards.
You are not to take any action that violates any applicable law, regulation or standard, or instruct anyone else to do so.
You are required to comply with credit union policies, procedures and practices, and use credit union forms because these have been developed with legal requirements in mind.
In order to protect members and customers, the requirements of the Market Code (acceptable sales practices, employee qualifications and licensing, disclosure, privacy and complaint resolution) are to be adhered to.
Management officers must be aware of all legal requirements pertinent to their activities, ensure that these requirements are communicated to their staff and manage and supervise their staff with the objective of ensuring that the law and credit union policies and procedures are followed.
To avoid legal difficulties, obtain a legal opinion when clarification is required.
Most printed material, software and trademarks are protected by proprietary rights.
You are expected to honour the proprietary rights of others and obtain any prior approval requests required.
You are required to follow the terms of the licensing agreement for any software program used in the course of business or on a company owned computer.
Installation or use of any software not licensed for use by the credit union on any company owned computer requires permission (contact General Manager or Office Supervisor).
Integrity of Records
The books and records of the credit union are to be maintained with the utmost integrity and are to accurately reflect all business dealings. Full co-operation with credit union regulators and internal and external auditors is mandatory.
All employees play a part in ensuring accuracy and integrity. You are to ensure that all transactions, documents, agreements and dealings are recorded and maintained in an accurate and timely manner. You are not to bypass an internal control procedure even if you think this is harmless or will save time.
You are to preserve the integrity of the record-keeping and reporting systems by being aware of and complying with all current applicable record retention policies and procedures. Destroy or alter records only after ensuring that they can be destroyed or changed.
All transactions must be authorized and handled in accordance with credit union policies and procedures and must meet applicable standards for knowing your member or customer. You are not to undertake or participate in transactions that could be considered improper or suspect. Be alert to any illegal, suspicious or unusual activity in accounts.
Employees and directors should evaluate all communications for which they are responsible and ensure information is true and does not mislead the public, either directly or indirectly.
You are to tell the truth in all communications, making every reasonable effort to provide full, fair, accurate, timely, and understandable disclosure in reports, documents and communications, and to avoid errors, omissions or misunderstandings in communications issued on behalf of the credit union.
Open, honest and timely communication is expected in dealing with employees, members, customers, associates, communities, government, suppliers, contractors and competitors.
All facts relating to the credit union’s services or transactions will be disclosed to ensure members and customers are informed of their costs and benefits.
The cornerstone of financial services is trust. The credit union requires employees and directors with high ethical standards who demonstrate and practice responsible business behaviour.
Respecting privacy is a requirement of all employees and directors. Employees and directors are expected to be familiar with the credit union’s Privacy Code and to treat all personal information in accordance with the Privacy Code and confidentiality guidelines.
You are to comply with the Privacy Code and respect the confidentiality of information at all times.
Any requests for employee information, including those concerning former employees, are to be handled in accordance with the Privacy Code.
You are required to protect the confidentiality and security of member and customer information when it is collected, used and retained and also when it is disposed of or destroyed.
Information Shared With Third Parties
In the course of regular business activities, the credit union frequently enters into contracts with a variety of third parties, including vendors, suppliers and service providers, often resulting in the exchange of information.
You are to share information only with third parties who have undertaken in writing to keep the information confidential in accordance with the Privacy Code. You may share only that information which is needed to satisfy the conditions of the contract and only with those who need to know.
All information and work product (e.g. computer or electronic files, paper records, project deliverables), including any information or work product produced in the course of employment with the credit union, are the property of the credit union and classified as proprietary and confidential.
Do not disclose confidential information without the proper authorization. Any request for confidential information is to be referred to the department responsible.
The credit union owns all proprietary rights to intellectual property and work that you develop, or contribute to developing, during the course of your employment or term.
At the end of your employment or term, you are obliged to protect the confidentiality of the credit union’s business indefinitely, unless a specific corporate authorization has been granted. Specific member or customer information, including names, lists, profiles and data, is not to be used in subsequent employment situations.
The credit union supports the highest standards of fairness and equitable opportunity in all matters of hiring, supervision, compensation, promotion and termination and in dealing with members and customers. Discrimination is not acceptable. All people will be treated with dignity, respect and fairness consistent with human rights legislation which prohibits discrimination on various grounds (e.g. age, race, color, religion or creed, gender, marital status, sexual orientation, disability or pregnancy/childbirth).
Do not engage in discriminatory practices that are contrary to the principles established for the credit union. Ensure that you are respectful of differing beliefs and personal values.
Do not discriminate against members or customers on the basis of race, religion, age, pregnancy, marital status, gender, sexual orientation, ethnic or social origin, disability, color, ethics, belief, culture, language or birth, except to the extent that a distinction is required or justified by any law or to the extent that the factor has commercial implications or if a special product or service offering is designed for all members of a particular target market group.
In recognition of the importance of access to basic banking services, you are to take reasonable measures to ensure access to a basic bank account for interested persons. Access cannot be refused because a person is unemployed or has been bankrupt.
Illegal or Anti-Competitive Sales Practices
Credit union services, products, sales programs, cross-selling programs and discretionary pricing policies are developed carefully to comply with lawful competition practices. Employees who work in a sales function should familiarize themselves with the Market Code and policy on coercive tied selling.
You are to use fair and honest sales and negotiating methods. Avoid any sales practices that could be misconstrued as an attempt to impose undue pressure on or coerce a member or customer into obtaining a product or service as a condition of closing a sale. Note: this does not include authorized relationship pricing practices.
Carefully follow credit union policies and practices pertaining to insurance products.
Ensure that all comparisons to competitors and their products and services are accurate and not misleading. You may not engage in illegal or unethical activities to obtain proprietary information.
Do not collude or co-operate with any other financial services provider in anti-competitive activities. Note: this does not include syndicated loan arrangements or certain government lending programs.
Suppliers, Contractors and Competitors
The credit union is committed to dealing with its suppliers, contractors and competitors in a legal and ethical manner. The credit union does not engage in practices that attempt to influence a competitor’s reputation or that lessen competition through unethical behaviour.
You are not to take bribes, kickbacks or any other kind of payoff from suppliers or contractors in exchange for favourable treatment or consideration. Ensure suppliers are fully informed of requirements and use fair and honest sales and negotiation methods. Provide equitable opportunity for suppliers to demonstrate their quality, reliability, price and service.
Select suppliers and contractors which satisfy our quality standards by considering price, specifications, technology, reliability, safety, service and delivery. Periodically review quality, reliability, price and service regardless of the length of the relationship.
5. Corporate Responsibility
The credit union may make political contributions to support and encourage the democratic process.
You are not to make political contributions in the name of the credit union unless you are explicitly directed to do so by the company.
Involvement in political activity must be undertaken responsibly. You are not to use your affiliation with the credit union in a marketing fashion or to gain improper advantage or purchase favours.
Employees are encouraged to participate in general political processes such as school board, municipal, provincial and federal elections.
Community involvement is a manifestation of our values as a co-operative organization. The credit union is responsible and accountable for the social and economic effects of its business actions and decisions.
You need to conscientiously consider these factors when you make business decisions. If in doubt, seek the assistance or advice of senior executive.
Individuals are encouraged to engage in charitable, educational and community service.
The credit union is committed to managing its business to meet all required environmental standards, and will work to protect human welfare through sound economic growth and maintenance of a healthy environment.
Your personal contribution will vary depending on your role, but you are expected to participate in the environmental programs that are put in place at the credit union.
6. Individual Responsibility
Harassment and Bullying
Employees and directors have a right to work in an environment that is free from harassment and bullying. Harassment and bullying involve conduct that interferes with a climate of understanding and mutual respect for the dignity and worth of each person. Examples include, but are not limited to:
- verbal abuse or threats or relentless criticism, belittling, rumours or raging
- unwelcome remarks or jokes
- innuendo or taunting about something an individual could consider offensive (e.g. an individual’s body, race, color, attire, age, gender, sexual orientation, ethnic origin or religion)
- leering or other gestures
- displaying pornographic, racist or other offensive or derogatory pictures or material
- practical jokes which cause awkwardness or embarrassment
- unwelcome invitations or requests, whether indirect or explicit
- threat of loss of one’s job or other forms of reprisal if one does not comply with a request for sexual favours
- abuse of power of authority
Harassment and bullying is not tolerated in the credit union. Complaints are thoroughly investigated and the credit union will take whatever measures it deems appropriate and necessary to deal with those parties found to have engaged in such conduct.