Our business practices

Client focus

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

Consumer Bank

We continue to strengthen our client-centric culture by improving the ways we connect internally and externally. We are transforming the way we listen to our clients and our employees through our innovative approach to collecting feedback and utilizing it to improve. We know our clients expect exceptional experiences however they choose to interact with us, and we are investing in our people so that they can continue to deliver.

To enable our employees, we have created The Academy, a best-in-class training and career development organization that equips employees with the skills and behaviors needed to deliver the best client care and to succeed and grow through their entire career. The Academy provides learning that is more high-touch and personal including the Lifestage Navigation curriculum. This curriculum helps employees understand the various life stages of our clients and demonstrate empathy and understanding as they assist them to self-evaluate their preparedness for each stage of life.

Our employees are aligned to our purpose; and our commitments remain unchanged:

  • 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

We continue to build momentum and excitement through our recognition programs for exceptional client experience and advocacy.

Additionally, we use the Client Management Process and Client Management Center to ensure we remain connected with our clients and their Life Priorities.

The Client Management Process (CMP) helps us to deliver on our purpose – to help make financial lives better through the power of every connection – through a client-centric, repeatable process that entails:

  • Working together as One Team to develop a Client Engagement Plan, and proactively inviting clients to visit us based on our seasonal focus and their particular needs
  • Delivering a more personalized, caring experience for our clients by preparing for conversations that enable us to get to know them and their Life Priorities better
  • Listening to clients to understand their needs, life events and life priorities so that we can help make their financial lives better
  • Ensuring client needs have been met while building trusting, loyal relationships — taking ownership of their experience by managing referrals and completing next steps

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

  • Provides consumer and small business client information to enable teams to manage their financial center’s client 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 disciplined 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.

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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