OVERVIEW

1. Background

Toronto Centre is committed to conducting its business in accordance with applicable laws, rules, and regulations and to the highest ethical standards. Toronto Centre does not engage in business that would trigger the application of Canadian anti-money laundering / terrorist financing laws and Toronto Centre is not a “reporting entity” as defined under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). As such, Toronto Centre is not subject to the oversight of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). However, Toronto Centre has undertaken to adopt a written financial crime compliance policy designed to:

1. contribute to the prevention of money laundering and terrorist financing;
2. ensure compliance with suppression of terrorism and sanctions laws; and
3. ensure compliance with anti-bribery or anti-corruption laws.

2. Scope

This Policy applies to every Toronto Centre employee, including senior executive and financial officers, members of our Board of Directors, and program leaders (collectively referred to as Toronto Centre personnel). The Policy reflects the standards to which Toronto Centre expects its business associates, partners, agents, contractors, and consultants to adhere to when acting on Toronto Centre’s behalf. This Policy is intended to supplement all applicable laws, rules, and other corporate policies. It is not intended to supplant any local laws.

ANTI-MONEY LAUNDERING / ANTI-TERRORIST FINANCING

3. What is Money Laundering?

The United Nations defines money laundering as “any act or attempted act to disguise the source of money or assets derived from criminal activity.” Money laundering is the process whereby “dirty money” (money generated through criminal activity) is transformed into “clean money,” the criminal origin of which is difficult to trace. There are three recognized stages in the money laundering process:

1. Placement
   
   The first stage involves placing the proceeds of crime into the financial system. This is also referred to as the “physical disposal” of cash proceeds derived from illegal activity. For example, placement can be as simple as a cash payment into a bank account where the funds are then used to purchase money orders, drafts, wire transfers, etc. Placement is the stage where the criminal is most at risk and where financial institutions are most likely to successfully detect money-laundering activities.
   
   
2. Layering
   
   The second stage separates illicit proceeds from their source through complex layers of financial transactions designed to disguise the source and ownership of funds. Most layering is carried out using monetary instruments and electronic funds transfers. For example, one layer might be the purchase and subsequent sale of stocks, bearer bonds, commodities, or other property. Another layer is created using the proceeds from the sale to buy some other asset, or to deposit money orders or drafts from another financial institution, issuing multiple cheques or drafts from newly deposited account funds.
   
   
3. Integration
   
   The third stage adds apparent legitimacy to criminally derived wealth. This typically consists of a complex web of transactions designed to make tracing the original source nearly impossible. If the layering process succeeds, integration places the laundered proceeds back into the economy in such a way that the funds appear to be normal proceeds of business. For example, layered funds can be used to purchase a legitimate business, and the income and capital appreciation from that business can be used to support commercial loans.

These stages may occur one after another or at the same time. There are no hard and fast rules as to how money laundering occurs. The only rule is that the money laundering process is continuous, and new dirty money is constantly being introduced into the financial system. The only real limitations are the launderer’s imagination and his or her perception of the risks of being caught.

4. What is Terrorist Financing?

Terrorist financing is the collection or provision of funds, either directly or indirectly, for the purposes of carrying out terrorist activities or for the use or benefit of a terrorist organization. Terrorist financing is an offence in Canada under the Criminal Code.

Terrorist financing provides the funds required to support terrorist activity. The principal focus of terrorist activity is to intimidate a population and/or compel governments to act in a particular way. This is accomplished through intentionally killing, harming, or endangering people; causing significant property damage; or interfering with essential services, facilities or systems.

Terrorist organizations need financial support to carry out their illicit activities and achieve their goals. Thus the basic aim of terrorist financing is to obtain resources to support terrorist activities. A successful terrorist group, much like a criminal organization, is one that is able to build and maintain an effective financial infrastructure. It must therefore develop sources of funding and effective means of hiding the links between those sources and the activities the funds support.

5. Methods of Terrorist Financing

There are two primary sources of financing for terrorist organizations:

1. Financial Support
   
   Terrorist organizations may receive financial sponsorship from like-minded countries or sympathetic governments. However, state support may be replaced by support from other sources, such as individuals with sufficient financial means.
   
   
2. Revenue Generation
   
   The revenue-generating activities of terrorist organizations typically involve criminal activities and therefore often resemble the activities of criminal organizations. Kidnapping and extortion serve the dual purpose of providing much-needed financial resources, while furthering the main terrorist objective of intimidating the target population. In addition, terrorist organizations may use smuggling, fraud, theft, robbery, and narcotics trafficking to generate funds.

Financing for terrorist organizations may also include legitimately earned income. This might include membership dues and subscriptions, sale of publications, speaking tours, cultural and social events, as well as direct solicitation and appeals within the community. This fundraising might be in the name of organizations with charitable status, leading donors to believe they are donating to a legitimate cause.

6. Laundering of Terrorist-Related Funds

The methods used by terrorist organizations to generate funds from illegal sources are often similar to those used by more “traditional” criminal organizations. Like criminal organizations, terrorist organizations must continually find ways to launder illicit funds to use them without attracting suspicion. For this reason, transactions related to terrorist financing may look similar to those related to money laundering. Therefore, strong, comprehensive anti-money laundering policies and procedures are critical for tracking the financial activities of terrorist organizations.

SUPPRESSION OF TERRORISM AND SANCTIONS

7. Canadian Legislation

While Toronto Centre is not a reporting entity under the PCMLTFA, it is subject to certain requirements of Canadian sanctions laws and generally subject to the Criminal Code (Canada). For the purposes of this Policy, the following Canadian statutes and regulations are defined as suppression of terrorism and Canadian sanctions (STCS) legislation:

• Criminal Code (Canada)
• United Nations Act (Canada) and Regulations
• Freezing Assets of Corrupt Foreign Public Officials Act (Canada) and Regulations
• Justice for Victims of Corrupt Foreign Officials Act and Regulations
• Special Economic Measures Act (Canada) and Regulations

8. Designated Persons, Designated Entities and Sanctioned Jurisdictions

Toronto Centre requires its clients to run the names of all staff participating in a training and capacity-building program against various lists maintained under the STCS Legislation to determine whether Toronto Centre could possess or control property of a person or entity designated on a list.

1. Identification of Designated Person or Designated Entity
   
   If a client or Toronto Centre identifies a participant on a list, Toronto Centre will not allow the participant to attend a training or capacity-building program or accept further instructions from the relevant client or person. Toronto Centre will take any further action as required by applicable laws.
   
   
2. Additional Prohibitions under Economic Sanctions
   
   Certain STCS Legislation includes prohibitions against providing, financing, or assisting any person in the sanctioned jurisdiction to obtain, manufacture, or use a list of specified products. If an address provided or obtained in the course of Toronto Centre’ identity verification procedures is in a sanctioned jurisdiction, the CEO (or designate) should be consulted before accepting a mandate with or funds from the client associated with that address. Toronto Centre may decline potential mandates under such circumstances

9. Freezing and Reporting of Terrorist Group Funds

If a current client of Toronto Centre is identified as a designated person or designated entity during reviews of the STCS Legislation lists, Toronto Centre will immediately freeze all of the client’s funds that are, directly or indirectly, under Toronto Centre’s control. Such freezing of funds includes the cessation of all applicable debits, entitlements, or any other applicable credits.

Toronto Centre is required to immediately report all such terrorist group property to the Royal Canadian Mounted Police and/or the CSIS Financing Unit. It is an offence under the STCS Legislation to tip off a current or prospective client that a Terrorist Property Report has been made and/or disclose the contents of the report, and such disclosure by Toronto Centre employees is strictly prohibited. The CCO is the only individual authorized to file Terrorist Property Reports on behalf of Toronto Centre and should be advised immediately by any employee who believes Toronto Centre possesses terrorist group property.

10. Ministerial Directives

From time to time, the Minister of Finance will issue additional directives pertaining to STCS requirements. The CEO (or designate) will ensure that the Policies, Procedures and Risk Assessment are updated accordingly. This may include introducing new processes to comply with directives and test the effectiveness of compliance measures. The CEO (or designate) will maintain an awareness of such directives.

ANTI-BRIBERY AND ANTI-CORRUPTION

11. Purpose

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate Toronto Centre’s commitment to full compliance by it, and its officers, directors, employees, contractors, and agents with Canada’s Corruption of Foreign Public Officials Act (CFPOA) and any applicable local anti-bribery or anti-corruption laws.

For the purposes of this Policy, a contractor or third-party service provider is defined as an entity or individual who provides, and receives payment for, services or goods related to any aspect of a Toronto Centre project. This includes program leaders and subcontractors.

12. What is Bribery and Corruption?

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, entertainment, or other inducement to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including providing or accepting:

• Cash payments
• Phony jobs or “consulting” relationships
• Kickbacks
• Political contributions
• Charitable contributions
• Social benefits
• Gifts, travel, hospitality, and reimbursement of expenses.

13. Improper Payment Activity

Toronto Centre personnel and agents are strictly prohibited from offering, paying, promising, or authorizing any payment or other thing of value, to any person, directly or indirectly through or to a third party, for the purpose of (or in exchange for):

1. causing the person to act or fail to act in violation of a legal duty
2. causing the person to abuse or misuse their position
3. securing an improper advantage, contract or concession for Toronto Centre or any other party.

Such activity is defined as Improper Payment Activity.

To promote compliance with anti-corruption laws in Canada and other applicable jurisdictions, no Toronto Centre personnel shall undertake any Improper Payment Activity related to a foreign official, a domestic official, or a person doing business in the private sector.

In addition, Toronto Centre’s books and records must ensure a reasonable relationship between the substance of a transaction and how it is described in its books and records.

Toronto Centre has in place standards and procedures for:

1. Sponsoring travel of government or government officials
2. Direct and in-kind support for government or government officials
3. Retaining third parties, including those who may interact with the government on Toronto Centre’s behalf
4. Contracting with state-owned entities
5. Meals, gifts, and entertainment for government officials
6. Facilitating payments.

GENERAL

14. Financial Crime Compliance Program

The CEO is Toronto Centre’s designated compliance officer for the purposes of this Policy. The CEO may designate another officer of Toronto Centre to fulfill the CEO’s administrative obligations under this policy.

15. Effectiveness Review

The CEO (or designate) will review the effectiveness of and, if necessary, update the procedures set out in this Policy at least every two years, and more often when there are changes to Canadian legislation, the services offered by Toronto Centre, or its internal controls.  Any updates will be reviewed and approved by the board of directors.

16. Waiver

Any deviations from this Policy must be documented by the CEO (or designate).

17. Discipline

Any board member or employee who violates the terms of this Policy will be subject to disciplinary action. Any board member or employee who has direct knowledge of potential violations of this Policy but fails to report them to Toronto Centre management will be subject to disciplinary action. Any board member or employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action. In all cases, disciplinary action may include termination of board appointment or employment.

Any third-party agents may have their contracts re-evaluated or terminated if they violate the terms of this Policy; if they know of and fail to report potential violations of this Policy to Toronto Centre management; or if they mislead investigators making inquiries into potential violations of this Policy. Any employee or third-party agent with knowledge of potential violations of this Policy shall report same to the Chief Executive Officer or designate.

18. Effective Date and Administration of the Policy.

The Policy is effective as of November 29, 2023.

Requests for additional guidance or interpretation regarding this Policy can be directed to the Chief Executive Officer or designate.

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 0 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 0, 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.

Toronto Centre recognizes environmental protection and the potential threats of environmental change, including climate change, as key components of sound business practice. We are committed to conducting our business in a manner that ensures a safe and healthy workplace for our employees and minimizes our impact on the environment. We will operate in compliance with relevant federal, provincial, and municipal environmental legislation, and we will strive to use environmental best practices in all we do.

Toronto Centre will:

• Incorporate environmental concerns and impacts into all of our decision-making and activities;
• Promote environmental awareness among our employees and partners and encourage them to work in an environmentally responsible manner;
• Train, educate, and inform our employees and partners about environmental issues that may affect their work;
• Reduce waste by initiating recycling programs within the office including the recycling of paper, cardboard, plastics, electronics and other materials that are accepted by a recycling provider;
• Reduce consumption by reducing printing and promoting “going green” at all ourprograms;
• Purchase environmentally responsible products and use environmentally responsible modes of transportation;
• Promote efficient use of resources throughout our facility including water and energy;
• Avoid unnecessary use of hazardous materials and seek alternatives whenever feasible;
• Regularly communicate our environmental program to our clients, customers, and the public and encourage their support;
• Strive to continually improve our environmental performance by periodically reviewing our environmental policy in planning our current and future activities

Rationale

Toronto Centre’s mission is to enhance the capacity of financial regulators from around the world to help improve their agencies’ crisis preparedness and to promote change that will lead to sound and inclusive financial systems. Toronto Centre recognizes that sustainable economic growth and poverty reduction would be more optimally achieved with the full participation of women in the financial sector. Women play a central role as income earners in lifting themselves, their families, and their communities out of poverty; many women face barriers to full participation in financial institutions due to legal, social, regulatory, and cultural factors.

Even as overall financial inclusion increases, gender gaps persist. Globally, women disproportionately face barriers to financial access that prevent them from participating in the economy and from improving their lives. Many women who are excluded from formal financial systems are building financial independence through informal microfinance and microinsurance channels; an enabling regulatory environment and effective supervision are critical to the success and sustainability of these sectors.

Toronto Centre also recognizes that although women compose a large percentage of the workforce in financial institutions, in many countries women hold fewer leadership and decision-making positions.

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

Objectives

• To support women’s access to financial services which support women’s economic empowerment, employment, entrepreneurship and poverty reduction by promoting more inclusive and effective financial regulation and supervision around the globe, and to increase the participation of women in decision-making in the financial services industry.
• To promote women’s full access to and use of high-quality financial services to support poverty reduction and economic growth which benefits women and men.
• To contribute to a gender-sensitive financial services industry which supports women in leadership and decision-making by building capacity of senior leaders—men and women.
• Core Commitments
• To analyse and address the relevant gender dimensions of financial regulation and supervision in all capacity development programs, where appropriate.
• To encourage gender balance in participation in all capacity development programs.
• To support women’s participation in senior leadership and decision-making through leadership training and change management.
• To strengthen the promotion and protection of women’s legal rights to financial services through training and policy dialogue.
• To act as a role model in global financial supervision in promoting employment equity and gender equality.
• To communicate Toronto Centre’s commitment to gender equality to partners and participants (regulators and supervisors) through policy dialogue and communications.
• To create a workplace and learning environment in which staff and consultants treat others with respect, and that promotes equality and diversity.

Effective Date and Administration of Policy

The policy is effective as of May 20, 2016.

Requests for additional guidance or interpretation regarding this Policy can be directed to the Chief Executive Officer or designate.

 

Toronto Centre’s Code of Conduct outlines our ongoing commitment to our values of integrity, respect and accountability. Toronto Centre is committed to maintaining a respectful and positive work environment.

All board members, advisors, employees, contractors and program leaders are expected to treat one another and Toronto Centre’s program partners and program participants with courtesy, dignity and respect, without discrimination or harassment.

Harassment and Sexual Harassment

Harassment is behaviour that is physically or verbally abusive, creating a hostile or intimidating work environment. Objective performance reviews and changes in job assignments do not constitute harassment. Supervisors are responsible to give appropriate constructive performance feedback, including performance improvement plans, and to make appropriate decisions on job assignments based upon an objective assessment of an employee’s performance. Occasional rudeness or rudeness that is not personally demeaning is not considered harassment.

Sexual harassment is any behavior of a sexual nature that is unwelcome, offensive or embarrassing to the individual(s) exposed to the behaviour. Sexual harassment includes unwanted physical contact, sexually suggestive conduct, offensive remarks, visual displays of degrading sexual images, requests for sexual favours and sexual assault. The most obvious form of sexual harassment in the work place is a direct or implied promise of career advancement in exchange for sexual favours. Sexual harassment does not include comments on clothing or appearance that most people would find reasonable.

Reporting

All individuals included in the scope of this policy should report instances of harassment. Reporting incidences helps Toronto Centre to maintain our commitment to a high level of integrity and ethics.

All reports of harassment will be taken seriously and investigated discreetly in a timely manner. The Compliance Officer will keep the person who reported the incident informed of the status of the investigation. There will be no negative repercussions to anyone who reports an incident of harassment in good faith.

Violation of the Harassment Policy by board members, advisors, employees, consultants and program leaders will result in disciplinary action, up to and including termination of employment or contractual services. Violation of a law may result in criminal or civil proceedings.

Headquarters (Toronto)

All incidents and suspected incidents of harassment should be reported for investigation to the Compliance Officer (Director of Finance), the President & CEO if the Compliance Officer is in a conflict position or the Chair of the Board if the President & CEO is in a conflict position.

Outside of Headquarters

Toronto Centre provides capacity development and technical training on an international stage, particularly in emerging markets and developing economies. As most training is provided on site in the host country, program personnel are still bound by the Harassment Policy and should not harass any other member of the program team, program participants or country agency officials. The program director should also be sensitive to any potential problems caused by behaviour of the program participants or country agency officials that could constitute harassment. Interaction outside of the program between the program team and program participants and/or country agency officials should be limited if there are any concerns.

Members of the program team should report any incidents to the program director or to the Compliance Officer (Director of Finance) for investigation.

Introduction

Toronto Leadership Centre (“Toronto Centre” or “we”, “our” or “us”) values our members and associates (“you”); we respect your privacy. We only collect personal information about you with your consent. This privacy policy (the “Policy”) describes the kinds of personal information we collect about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. You may require us to change, amend or delete the personal information that you have provided to us at any time. If you do not agree to the terms of this Policy, please do not use our services, including our website.

If this Policy changes in the future, we will post an updated version on our website at www.torontocentre.org (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy.

Information we collect

When you sign up for a Toronto Centre program, register to receive our email newsletter or to become a member of our Toronto Centre Website and online community, you voluntarily give us certain personal information including your name, e-mail address, and organization. In addition, when you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “Our Use of Cookies and Log Files.”

If you make a payment to attend a course, we collect information necessary to complete the transaction, but will not retain such information longer than necessary to complete the sale. We call this personal information “Sales Information.”

Using information we collect

We use the personal information you have agreed to provide to us in order to: communicate with you for the purposes you have separately indicated when you registered for a program or to become a member of Toronto Centre’s Website and online community.

Disclosing information we collect

We will not share, sell, or rent your personal information in personally identifiable form with any third party, except if, and to the extent necessary, in our good faith judgment, doing so is required to: comply with laws or regulations; respond to a valid subpoena, order, or government request; establish or exercise the Company’s legal rights or defend against legal claims; investigate, detect, suppress, prevent, or take action regarding illegal or prohibited activities, suspected fraud, or situations involving potential threats to the reputation or physical safety of any person; or as otherwise required by law.

We may remove personal identifiers from your information and maintain and use it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with our funders, but we will not disclose your personally identifiable information unless we receive your express consent to do so.

We use the Sales Information in order to process the payment for your course registration.

If we have disclosed your personal information to a third party in accordance with this Policy, we will only give the information needed to them to perform the services required and we do not authorize them to use or disclose the information for their own marketing or other purposes.

Storing information

We will retain your personal information only for a time and to the extent necessary for the purposes for which it was collected as described in this Policy and for reasonable backup, archival, audit, or other similar purposes.

Your decisions about your personal information

At any time you can contact us to: stop receiving e-mails from us; review the personal information held by Toronto Centre in connection with your membership; withdraw your consent for our use and disclosure of your information; request a list of third parties to which Toronto Centre may have provided your personal information; and amend your personal information on Toronto Centre member Website. You can always unsubscribe from receiving e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every e-mail from us.

If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use, and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.

Our use of cookies and log files

We use browser tracking cookies (or “cookies”), which are small text files that are placed on the hard disk of a computer by a website. Cookies are uniquely assigned to you, and can only be read by a website or web server that issued the cookie to you. We also use browser “log files” which record certain information when you visit a website, including your internet protocol (IP) address. To improve your experience on our Website, we use cookies and logs files to: recognize you when you return to our Website; keep track of activity on our Website and remember what items you have clicked on or viewed; study how you navigate through our Website and which products you request in site searches so that we can improve the design, content and function of our Website. We call this “Browsing Data”. We may hire third-party service providers to assist us in the collection and analysis of this Browsing Data collected through cookies, but none of your personal information is disclosed to these third-party service providers.

You have the ability to accept or decline our use of cookies by changing the settings in your web browser. You can refuse cookies by turning them off or blocking them in your internet browser. If you decide to turn off or block cookies, our Website might not function correctly.

Security

We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that while we try to create a secure and reliable Website for members, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed.

We limit access to your personal information within Toronto Centre to individuals on a need-to-know basis.

Your personal information may be transferred, processed, and retained on servers in countries outside of Canada, including the United States, and may therefore be subject to laws that do not offer the same degree of protection as Canadian law, although the Company will ensure that contractual protections, at least equal to its own standards, are put in place with those owning or managing servers located outside Canada. While we undertake to protect your personal information when it is transferred to other jurisdictions, the laws of other jurisdictions may require the disclosure of your personal information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Policy.

Links to other sites

We provide links on our Website to other, third party sites we think you will enjoy. These sites operate independently of us and have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is provided directly to that third party and subject to that third party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

Children’s online privacy protection

The Website is not intended for use by children under the age of 18. Company does not knowingly collect or use any personal information from any children under the age of 13. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

Questions or comments

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by clicking info@torontocentre.org or by delivery in person, by courier, or by the mail to us at 2 Toronto Street, Suite 200, Toronto, Ontario, M5C 2B5 or by calling us at 416-943-9300. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.

Effective Date: December 1, 2014

Introduction

Workplace diversity and inclusion is a significant driver of organizational success and
competitive advantage. Very simply, it is a moral imperative and makes good business sense.
Individual and organizational reputations can be irreparably damaged by even the smallest
missteps.

Workplace diversity requires understanding, accepting and valuing the differences between
people. These differences encompass sex, gender, age, race, ethnicity, national origin, sexual
orientation, and disability. The result of true inclusiveness is a workforce that has different
educations, personalities, skill sets, experiences, and knowledge bases – in brief, a formula for
organizational success.

Policy Statement

Toronto Centre (TC) is committed to fostering and creating a diverse and inclusive organization
in the boardroom, workplace, classroom environment, and in its capacity building and training
programs.

This means a commitment to fostering fairness and respect and providing a workplace and
classroom that are free of discrimination on the basis of sex, gender, age, race, ethnicity, national
origin, sexual orientation and disability.

This applies to the workplace or classroom environment, whether in Canada or delivered in
another country, virtually or in person.

TC strives to be an exemplary equal opportunity employer, with hiring practices that are free
from discrimination and bias.

This policy should be read in conjunction with TC’s policies on gender and harassment, and its
overall Code of Conduct.

Implementation

All board members, advisors, employees, contractors and program leaders are expected to be
aware of and adhere to this policy and its requirements when dealing with each other and with

TC’s program partners and program participants. Each has their role to play.

Roles and Accountabilities

• Board of Directors: Approves and oversees the application of the policy in the

  organization as a whole and to the board itself, including representatives of member

  organizations.

• CEO: Oversees the monitoring and implementation of the policy by ensuring the

  development of a plan.

• Compliance Officer: Develops a plan for approval and implements that plan, including

  monitoring mechanisms.

• Program Directors: Adhere to the policy and identify any potential problems caused by

  the behaviour of program leaders, program participants or country agency officials that

  might constitute a violation of the policy. They must deal promptly with any incidents or

  suspected incidents that may take place at TC programs. Program directors will notify the

  Compliance Officer and seek guidance as required from the Compliance Officer.

• Program Leaders: Adhere to the policy when preparing program materials, delivering

  presentations and dealing with program participants and representatives of partner

  agencies. Program leaders must report any incidents to the program director for

  investigation.

• Employees: Adhere to the policy and be aware of inappropriate behaviour. Employees

  must report any incidents to the Compliance Officer for investigation.

• Program Partners and Participants: All partners and participants will be provided with

  a copy of the policy. They should be aware of and demonstrate behaviour that is

  consistent with the policy. This includes all dealings with other program participants, TC

  personnel and staff members of host agencies. They should report any incidents or

  suspected incidents to the program director for investigation.

Incident Reporting

All incidents and suspected incidents of discrimination on the grounds mentioned above should
be reported for investigation to the Compliance Officer, or the President & CEO if the
Compliance Officer is in a conflict position, or the Chair of the Board of Directors if both the
Compliance Officer and the President & CEO are in conflict positions. As noted above, incidents
and suspected incidents that take place at TC programs should be dealt with promptly by the
program director who is leading the program. S/he may seek advice and guidance from the
Compliance Officer as needed. Reporting incidents helps TC to maintain its commitment to a
high level of integrity and ethics.

All reports of discrimination will be taken seriously and investigated in a timely manner. The
Compliance Officer will keep the person who reported the incident informed of the status of the
investigation. There will be no negative repercussions to anyone who reports an incident in good
faith.

Disciplinary Action

Violation of the Diversity and Inclusion Policy by board members, advisors, employees,
consultants, and program leaders could result in disciplinary action, up to and including
termination of employment or contractual services or removal from the Board of Directors.

Violation by program partners and participants may result in the termination of the program or
the dismissal of the participant from the program. TC may decline to work with a partner agency
in the future if they do not adhere to the policy.

Policy Review and Reporting

The Policy will be reviewed at least every three years and updated if needed to ensure that it
remains current with industry practices.

Annually, management will submit a Diversity Report to the Board of Directors. The Diversity
Report will include information on the status of the implementation of the Diversity Policy and
incident reporting.

Definitions

Accessibility means the degree of ease that something (e.g., device, service, physical
environment and information) can be accessed, used and enjoyed by persons with disabilities.
Something that is accessible does not have obstacles for people with disabilities – something that
can easily be reached or obtained, a facility that can easily be entered, or information that is easy
to access.

Disability means
(a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by
bodily injury, birth defect or illness and, without limiting the generality of the foregoing,
includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack
of physical co-ordination, blindness or visual impediment, deafness or hearing impediment,
muteness or speech impediment, or physical reliance on a guide dog or other animal or on a
wheelchair or other remedial appliance or device,
(b) a condition of mental impairment or a developmental disability,
(c) a learning disability, or a dysfunction in one or more of the processes involved in
understanding or using symbols or spoken language,
(d) a mental disorder, or
(e) an injury or disability for which benefits were claimed or received under the insurance plan
established under the Workplace Safety and Insurance Act, 1997
Diversity means the presence of a wide range of human qualities and attributes within an
individual, group or organization. Diversity includes such factors as age, sex, race, ethnicity,
physical and intellectual ability, religion, sexual orientation, educational background and
expertise.

Sex means the different biological and physiological characteristics of females and males.
Gender means refers to the characteristics of women, men, girls and boys that are socially
constructed. This includes norms, behaviours and roles associated with being a woman, man, girl
or boy, as well as relationships with each other. As a social construct, gender varies from society
to society and can change over time.

Racism includes ideas, beliefs, practices and erroneous assumptions that establish, maintain or
perpetuate the racial superiority of one group over another. It may be evident in organizational or
institutional structures and programs as well as in the thought or behaviour patterns of
individuals.

Discrimination means the unjust (or illegal) or prejudicial treatment of different categories of
people or things, especially on the grounds of race, ethnicity, age, gender, sexual orientation,
national origin, or disability.

Contact Information

TC’s Compliance Officer may be reached at cmaclean@torontocentre.org
TC’s President & CEO may be reached at babak@torontocentre.org