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Driving our Ethical Culture Reinforcing our Foundation. Learnings from 2012 & Actions for 2013 Ethics and Business Conduct Office. Increased communications drove slight improvement in each category over 2011 Still below benchmark in key 3 areas due to inability to reach line associates.

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Driving our Ethical CultureReinforcing our Foundation

Learnings from 2012

&

Actions for 2013

Ethics and Business Conduct Office


Increased communications drove slight improvement in each category over 2011

Still below benchmark in key 3 areas due to inability to reach line associates

Attorney Client Privileged


Slight increase in total reported cases with a category over 2011

16% drop in total substantiated cases over 2011

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Compliance Cases by Disposition 2012 vs. 2011


Higher total per capital volume due to distributed work force/accessibility issues

Attorney Client Privileged

Per Capita by Business 2012 vs. 2011


Need to leverage multiple communication channels to reach front line associates

  • VOA Conclusions

    • 2012 communication efforts marginally effective at impacting front line associates

    • Most front line associates have no access to:

      • “ethics” training (as compared to BSC and Managers)

      • communications from Ethics Office

  • 2013 Plan

    • Enhance communication and training:

      • Redesigned the Code of Conduct

        • Distributed to all associates with CEO video message

        • Tailored content to audience utilizing SVM fact based examples

      • Cascade monthly “ethics messages” from CEO to all associates

        • Short “Know the Code” topics integrated into monthly staff meetings & monthly “meeting in the box”

      • Implement 2013 code of conduct training for all associates (4Q 2013)

    • Include “Ethics / Integrity” in performance management

Attorney Client Privileged


Redesigned code of ethical business conduct
Redesigned Code of Ethical Business Conduct front line associates

  • Published December 2012

  • Printed & distributed to branches February

  • Accompanied by monthly “Know the Code” talking points for Managers

    • Cascaded from CEO

    • No “tracking” required

    • Part of the “meeting in the box”


Questions
Questions front line associates

  • What are some expected trends in 2013?

  • When should we involve the ethics office?

  • When is it appropriate to communicate with management & others re: an investigation?


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