Our business practices

Client focus

We want to be a company that people want to do business with. Throughout our lines of businesses, we look for ways to better serve our clients needs in a way that upholds the highest ethical standards. Some highlights include:

Consumer Bank

Strengthening our company culture involves the full commitment and engagement of our managers and leaders as well as front-line associates. Our Customer Engagement PlayBook outlines the core behaviors and expectations of our financial center associates and enables our leaders to manage and coach them based on business needs, staffing models, and local market conditions. When core behaviors and expectations are consistently met, we show our customers how we’re committed to being better, one connection at a time.

The content covers essential elements, such as how we engage customers, build relationships, and solve problems, and it describes foundational expectations and behaviors. Employees are asked to make a personal pledge to embrace the Customer Experience Commitments:

  • Make interactions easier by making it simple for customers to do business with us.
  • Make expertise more accessible by partnering with our experts as one team to help our customers.
  • Make relationships more human by caring for customers and treating them with respect.
  • Share our success by doing the right thing for customers, teammates, and the community.

To enable us to meet our customer satisfaction goals, we publish and use a series of job aids, which help employees understand how to more fully connect and interact with customers:

  • Our Client Experience & Commitments Job Aid provides details on behaviors that contribute to our unique customer experience.
  • Our Client Experience Playbook is designed to help managers and leaders demonstrate and coach associates to achieve better connections with our customers and improve performance in key areas impacting customer experience.

Additionally, in 2016, we introduced the Client Management Process and Client Management Center.

The Client Management Process (CMP) is a client-centric way for us to identify client priorities and deliver solutions and expertise in a way that meets our clients' expectations. The CMP helps financial center teammates and leaders deliver the themes outlined in the Client Experience Playbook.

The Client Management Center is a relationship management tool that complements our Client Management Process and enables delivering as One Team. This integrated sales desktop tool offers the following:

  • Provides consumer and small business client information to enable teams to manage their financial center’s portfolio
  • Enables documentation of individual client opportunities and contact strategies
  • Provides a centralized location for tracking all client interactions
  • Enables leadership coaching on CMP execution

Global Wealth & Investment Management

Our financial advisors help our clients prioritize which goals matter most to them—whether that's transitioning to the next generation, customizing financial strategies that help clients pursue desired outcomes, or simply providing advice and guidance to help clients stay informed.

Our financial advisors serve clients in the following ways:

  • Transparency to fees, risks and potential outcomes, including confirmation of fees associated with each offering and explanation of risks associated with each investment strategy
  • Guidance customized with a discipline wealth and investment process, including evaluation of clients’ financial situations and help prioritizing what clients hope to achieve
  • Responsible service personalized to your preferences, including explanation of all available services
  • A team of advisors that understands clients’ needs and goals

Read more about how our financial advisors responsibly serve clients.

Global Banking and Markets

Throughout our sales and trading practices, we’ve taken steps to mitigate risk through preventive and detective measures. Senior managers are engaged in the implementation and oversight of practices and controls to ensure that employees uphold the company’s conduct expectations. Salient aspects of the control framework are outlined below:

  • Enhanced routines to hold employees and managers accountable for conduct incidents which may result in outcomes ranging from verbal coaching up to termination of employment and/or claw-back of compensation in the most serious cases.
  • Business and desk heads have conducted multiple conduct-focused training sessions across the globe for all sales and trading employees, emphasizing our culture of compliance; additionally, new-hire orientation and newly promoted employee sessions focus on conduct and culture expectations.
  • Business Controls and Compliance teams have conducted specific line-of-business training covering acceptable versus unacceptable employee market conduct.
  • Access to customer order information and potential resulting conflicts have been further limited through information-security controls designed to restrict access to only those who need to know the information for legitimate business purposes.
  • Multi-user chats have been prohibited for two or more banks and/or dealers, are limited to those who have a business purpose, and are closely monitored.
  • E-communication reviews have been significantly enhanced, and efforts continue to correlate trading behavior to e-communications.
  • Sales, trading, investment banking and research supervisors are required to review their employee’s e-communications, including chats, and escalate potentially problematic communications.
  • Supervisory and surveillance capabilities have been improved and continue to be enhanced, and additional compliance testing reviews have been recently added to complement traditional surveillance capabilities.
  • A conduct goal is included in goal setting for all GBAM employees, and year-end performance documentation contains guiding questions for managers to assess individuals’ conduct.
  • The GBAM 360, a multi-rater feedback tool, was refreshed in 2015, such that 25% of questions are risk or conduct related.
  • Conduct expectations have been explicitly included in promotion criteria for all title levels, and communicated broadly.
  • In 2015, GBAM established the Market Misconduct Council, which is responsible for providing a consistent perspective and direction on all potential market misconduct incidents globally, including disciplinary outcome and direction on regulatory reporting activity.

Additionally, conduct incidents including policy violations, unprofessional and problematic e-communications and matters identified through supervisory, compliance, human resources, and risk management processes are aggregated globally and incorporated into performance management and compensation decisions. In addition, conduct incidents are reviewed by the Conduct Review Forum, which includes senior business, compliance, human resources, and risk managers to determine if heightened supervisory requirements should be imposed.


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