Code of Conduct

Toronto Centre’s vision

A world where financial systems are stable and accessible to all.

Toronto Centre’s mission

To provide high quality capacity building programs for financial supervisors and regulators.

Toronto Centre’s values and guidelines

To achieve our vision and mission, Toronto Centre expects all employees, board members, program leaders, and consultants who work for us to observe high standards of business ethics and to exercise sound professional judgment.

We have a responsibility to ensure that Toronto Centre maintains the strong ethical culture, good governance practices, and high level of integrity that our funders and stakeholders rely on. Since we are custodians of resources our funders entrust to us, we are expected to act in an ethical and responsible manner.

The values and guidelines that embody Toronto Centre’s Code of Conduct are:

• Act with integrity
• Be accountable
• Be respectful
• Protect confidential information
• Avoid conflicts of interest
• Follow laws and policies

Purpose

The purpose of the Code of Conduct (“Code”) is to make clear the values and expected behaviors that relate to business practices and personal conduct for Toronto Centre.

The majority of Toronto Centre’s funding and support is from government-funded departments and agencies that are in turn funded by taxpayer dollars. Our funders and donors, both private and public, entrust us to prudently utilize the resources provided to us to carry out our important mission.

In addition, Toronto Centre’s teaching materials and methodology are paramount to our success, and like any copyrighted material, should be protected against misuse or unauthorized use.

By committing to the values and expected behaviors in the Code, Toronto Centre will ensure it maintains the strong ethical culture, good governance practices, and high level of integrity that our funders and stakeholders rely on and will protect the intellectual assets critical to our success.

Applying the Code

The Code of Conduct (“Code”) applies to Toronto Centre’s employees, board members, consultants, program leaders, and others who may be hired to act on Toronto Centre’s behalf.

The intention of the Code is to provide clear guidance to help those subject to the code to make sound choices and exercise good judgment. Recognizing that you may sometimes face difficult choices that are not straight-forward, the Code seeks to provide as much detail as possible. A few basic common sense questions that can be a useful guide include:

• Is it legal?
• Is it in accordance with Toronto Centre policies and procedures?
• Will it reflect positively or negatively on Toronto Centre or me?
• How would I feel if my action is reported in the media or to my peers?
• Would I approve of the decision if I were a co-worker, program participant, or taxpayer?
• Would I be embarrassed if others knew I took this action?
• Is there another action that is more appropriate?

If still unsure after considering these questions, you should first seek the guidance of your supervisor. If you and your supervisor are unclear you should then seek guidance from the President and CEO before taking any further action.

Reporting Breaches & Action

It is important that if you feel you may have breached the Code or believe that someone else has breached the Code, you must promptly inform your supervisor, the President and CEO, or the Chair of the Board, depending upon to whom you report. Reporting misconduct and breaches of the Code helps us maintain our commitment to high standards of ethics and integrity.

All reports of breaches or suspected breaches will be taken seriously and investigated discreetly. There will be no negative repercussions to anyone who reports a potential breach in good faith. If you feel you breached the Code and self-report, there will be no repercussions for self-reporting and if, following an investigation, it is determined that a breach did occur, your self-reporting will be taken into consideration in determining the consequences.

Violation of the Code by employees and consultants may result in disciplinary action, including in extreme cases, termination of employment or contract services. Violation of a law may result in criminal or civil proceedings.

Example

What happens when I report a suspected violation?

All suspected violations will be taken seriously and will be investigated anonymously by your supervisor. If you feel it has not been dealt with appropriately you must raise the item with the President and CEO or Chair of the Board.

Act with Integrity

Integrity encompasses honesty, probity, loyalty, and trustworthiness.

You are expected to act with integrity in all of your duties for Toronto Centre and to avoid behavior that would bring the Centre into disrepute. You should avoid expressing any views or opinions in the public sphere that would reflect negatively on Toronto Centre, and you should not speak publicly about or on behalf of Toronto Centre unless you are authorized to do so.

You are expected to provide accurate and complete information to Toronto Centre for programs, personnel matters, expense claims, regulatory filings, and financial statement presentation.

Do not use Toronto Centre resources for personal benefit

Toronto Centre receives generous support from its funders and has an obligation to ensure these funds are used prudently towards fulfilling our mission.

You are expected to ensure that Toronto Centre resources are used for official business only and to carry out the required Toronto Centre activities for which you receive compensation. Resources should not be used for personal benefit or shared with other organizations outside of normal business activities such as joint programs.

Example

I have a personal blog. Can I blog about my work at Toronto Centre?

Toronto Centre supports the use of Toronto Centre’s official social media platforms (Linked In, Twitter) when you are authorized to speak about Toronto Centre as part of duties. You should not speak about Toronto Centre’s business in any public communication, or on any social media site or to the press unless authorized to do so. Speaking positively about Toronto Centre to stakeholders in programs or courses is welcome.

Be Accountable

Staff should act within the scope of their position and responsibilities at all times. If you delegate duties to others you must communicate the requirements of those duties to them and ensure they understand by giving them the opportunity to ask questions. You are still accountable to exercise control and supervision over tasks that you delegate. You are responsible to ensure that the activities are carried out appropriately.

Example

I travel a lot in my duties for Toronto Centre. Can I delegate the approval of a program leader’s program expenses to my administrator?

Although you may delegate the administrator to review the expenses you are ultimately accountable for the approval of expenses. It is important that you provide the administrator with all of the information necessary to complete the expense report review such as travel dates, personal side trips or extra vacation days, and meal arrangements while at the program.

Be respectful

Staff, program leaders, and consultants should always treat others with courtesy and respect, without harassment, hostility, or intimidation. (see Harassment Policy)

Toronto Centre provides training on an international stage and you are expected to act respectfully and impartiality towards others’ cultures and backgrounds.

Example

One of my colleagues emails jokes that I consider to be offensive to women and people of certain nationalities and sexual orientation. Should I report this?

Yes, this behavior violates the Code. First, you should ask your colleague to stop sending such emails. If he or she persists, you should report the emails to your supervisor. In addition to not being respectful, sending emails of this nature is not an appropriate use of Toronto Centre resources.

Protect confidential information

You are responsible to protect the security of any confidential information provided to or generated by Toronto Centre. This includes, but is not limited to, teaching materials (case studies, slides and presentations) and methodologies, partnership and funding agreements, business contacts, suppliers, program participant information, business plans, and financial and personnel information.

You must not disclose any such confidential information to anyone and must not use it for your own advantage such as your own private business dealings, regardless of whether or not you continue to work on behalf of Toronto Centre.

Our teaching materials and methodologies are proprietary information and protected under copyright laws and must not be disclosed or shared with other organizations other than in the normal course of business such as joint teaching programs.

Our programs are conducted under the “Chatham House Rule” which means everyone at a program is free to make use of key lessons arising from the information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other participant, may be revealed. And, to the extent that confidential information relating to specific financial institutions is referred to during our programs, that information must also remain confidential and not be referred to outside of the program. Course participants should always feel comfortable discussing and sharing their professional experiences during programs without any concerns that the information will be used inappropriately.

Examples

I developed a number of presentations and case studies while working for Toronto Centre that I would like to use for another client, is this permissible?

No, the teaching materials and methodologies that were developed and paid for by Toronto Centre are proprietary information of Toronto Centre and you must not use them for other work assignments.

I developed a case study for Toronto Centre a number of years ago for which I assigned copyright to Toronto Centre. I would like to update and expand this case study to use in my consulting business. Do I require permission from Toronto Centre to do so?

As Toronto Centre owns the copyright for the case study, the case study is the property of Toronto Centre and permission would not be granted to update or expand the case for non-Toronto Centre purposes.

A course participant from “Country X” discussed a challenging experience she is having with supervising “Bank A.” Can I write a paper on this topic for publication?

No, the information discussed at Toronto Centre programs by participants is confidential and details must not be disclosed to anyone. One of Toronto Centre’s key success factors is that participants feel they are in a safe and trustworthy environment and openly share professional experiences for the benefits of all attending the programs.

Avoid conflicts of interest

You should avoid situations involving a conflict, or the appearance of a conflict, between the performance of your duties and your personal interests. You should always act in the best interest of Toronto Centre to the exclusion of any personal advantage or advantage of your family or close, personal friends. Perceived conflicts include business dealings with family members and close, personal friends.

If a perceived or potential conflict exists, you should disclose it immediately to your supervisor to determine if you should be removed from the situation.

For example, business dealings with family and close, personal friends would be a perceived or potential conflict and should be disclosed to your supervisor to determine if you should be removed from the awarding of the contract or hiring decision. If the family member or close, personal friend is the best qualified to do the work you should not directly supervise their work; it should be overseen by someone else.

Example

May I hire my sister to do some work for Toronto Centre if she is the best qualified and offers competitive rates for the services?

This situation would be perceived as a conflict of interest even if your sister is the best qualified for the contract. Toronto Centre requires the disclosure of your relationship and conflict to your supervisor and you should be removed from participating in the hiring decision. If your supervisor determines that your sister should be awarded the contract, approval should be obtained from the CEO. You may work with your sister, but your sister’s work should not be supervised by you.

Engaging in outside charitable activities or business dealings

Toronto Centre staff are encouraged to be involved with outside charitable activities and board members, program leaders, and consultants may have business dealings with other organizations. It is important that your involvement in external activities does not create or appear to create a conflict of interest or interfere with your responsibilities at Toronto Centre. To reduce the possibility of a conflict of interest, you should discuss your involvement with your supervisor or the President and CEO if you believe there could be a conflict or a perceived conflict.

Toronto Centre resources or information are copyright and must not be used or shared in any of your outside charitable activities or business dealings, without prior consent of the CEO.

Example

I have been requested by a university to be a guest lecturer on financial regulation in developing countries for one of its courses. I would not receive any fees for my lecture. A Toronto Centre presentation and case study would be the perfect material for my lecture. Can I accept the invitation and use Toronto Centre materials?

Toronto Centre encourages charitable activities but if you are employed directly by Toronto Centre, it is important that it does not conflict with your work with us. You should discuss this opportunity with your supervisor and obtain approval before accepting the invitation. Approval from Toronto Centre is not required for program leaders, board members, or consultants to accept invitations from other organizations. All materials developed and paid for by Toronto Centre are the property of Toronto Centre and must not be used for other purposes without the approval of the President and CEO.

Accepting and giving of gifts

Toronto Centre recognizes and is very grateful that many individuals or organizations donate their time and services to us as in-kind contributions by serving as or providing staff as program leaders or speakers. To recognize an individual’s contribution it is acceptable to provide a nominal (less than $100 in value) thank-you gift for their services as long as it does not breach the policies of the organization that the individual works for. It is prudent to check with the speaker’s supervisor prior to giving such a gift.

Toronto Centre employees shall not solicit gifts or accept any gifts from suppliers or potential suppliers that could influence or appear to influence the employee’s judgment in awarding business or contracts. It is acceptable for Toronto Centre to accept a nominal gift from a supplier that can be shared amongst all employees such as a holiday gift basket.

If in doubt, an employee should always decline an offer.

Toronto Centre recognizes that working lunches and dinners serve a legitimate business purpose. Employees can accept or offer such lunches and dinners where there is a business reason to do so. The lunch or dinner should not take place if it could be construed by an objective observer to create a sense of obligation or bias to the host, or could compromise or appear to compromise objectivity and integrity in business decisions.

Example

OSFI has provided a staff member to serve as a program leader in Jakarta. In addition to the time spent instructing at the program, the individual has spent time before the program preparing his presentation material. OSFI policies prohibit any payment to the individual, however the individual wants to stop in Australia en route to the program for a personal vacation. The cost of this stop over is only $750, and it is much less than the actual monetary value of the generous work the OSFI employee has done for our benefit, if could have paid him or her a fee. Can I authorize this expenditure?

No, this would be a gift greater than a nominal amount. It is also is in breach of both Toronto Centre and OSFI policies. Toronto Centre’s Standard Terms and Conditions for Program Leaders require the program leader to pay for all personal trips and Toronto Centre Travel Policy requires any exception to the policy to be approved by the CEO.

Follow laws and policies

As Toronto Centre operates on an international stage, it is not reasonable to expect individuals to be aware of all applicable international laws and regulations but you are expected to comply with any laws and regulations that our program partners make us aware of as well as applicable Canadian laws and regulations that one should be aware of to the best of his or her knowledge. If in doubt, consult with your supervisor or the President and CEO.

You are expected to read and comply with all Toronto Centre policies and procedures of which some key provisions are highlighted below:

• Anti-Bribery and Anti-Corruption Policy
  • As outlined in our Anti-bribery and Anti-Corruption Policy, Toronto Centre prohibits the direct or indirect use of bribery, kickbacks, payoffs, or other corrupt practices by employees, or other parties acting on our behalf
• Purchasing Policy
  • Responsibility to obtain competitive quotes
  • Remove yourself if there is a conflict or perceived conflict of interest
  • Do not accept gifts, meals, or entertainment that might directly or indirectly influence a business decision or give the appearance of impropriety
• Travel Policy
  • Documentation for reimbursement based upon our funders’ requirements
• Program Leader Letter of Agreement and Standard Terms and Conditions
  • Copyright
    • Assignment of copyright of materials to Toronto Centre
  • Anti-Terrorism
    • As required in our funding agreement with the Department of Foreign Affairs, Trade and Development (DFATD) Toronto Centre guarantees that the funding we receive will not knowingly be used to benefit terrorist groups as defined in the Criminal Code, or individuals of those groups. You should speak to your supervisor or the President and CEO if they believe funding is being used for such purposes.

Internal controls and maintaining books and records

All staff, board members, program leaders, and consultants participate in Toronto Centre’s internal control framework. Internal controls help us achieve our business objectives, mitigate risks, and meet our ethical obligations to our funders and other stakeholders. Toronto Centre’s internal controls are designed to provide reasonable assurance that:

• our operations are effective and efficient
• our financial reporting is reliable
• we comply with laws and regulations

Toronto Centre is required to maintain accurate, reliable and complete records to appropriately manage its affairs and comply with funders’ legal, regulatory, and financial obligations.

Our financial statements, books, and records should accurately reflect all business transactions. Failing to disclose or record revenues, expenses, assets, or liabilities is prohibited.

You are responsible to submit accurate information for the completion of our financial statements and for regulatory requirements such as tax filings.

Example

On a recent program, one of the dinners was provided by the program host. Can I claim the meal per diem for the dinner?

No, as the meal was provided it is not an eligible expense. It would be fraudulent to claim the meal per diem.