Reporting Concerns Mechanisms
We are committed to carrying out our business activities ethically and in accordance with all applicable laws. Accordingly, we maintain appropriate mechanisms for our stakeholders to report or raise concerns should they suspect or witness unethical or unlawful behaviour.
Mechanisms to report or raise concerns over unlawful or unethical behaviour are formalized through our Code of Business Conduct and Ethics, Third Party Code of Conduct and Accounting Complaints Handling Procedures. These documents outline the processes in place for Directors, officers, employees and third parties to promptly report any suspected violation of our Codes and policies, or of any law, rule or regulation, including possible concerns regarding accounting, internal accounting controls or auditing matters.
Additional reporting mechanisms are also described in other internal policies, such as our Global Anti-Bribery Policy and our Disclosure Policy, which provide for an obligation to report any suspected breach thereof. The Respectful Workplace Policy also outlines the procedures and mechanisms that are available for anyone believing they have been subject to or have witnessed any behaviour which is contrary to the policy, including a reporting hotline and web portal operated by a third-party provider which is available 24 hours a day, 365 days a year.
Unless otherwise specified in a particular policy or procedure, concerns can be reported to Power Financial's Vice-President and General Counsel.
Each Director, officer and employee is provided with a copy of our various policies and procedures, which are available in French and English. Furthermore, as part of our Code of Business Conduct and Ethics training sessions, we educate our employees on the application of our policies and procedures, including the various mechanisms available to report concerns.
All reports are taken seriously and treated with the utmost confidentiality and anonymity. We have processes in place to ensure reports are promptly investigated and addressed.
The Corporation will not take any reprisal or retaliation measures, including any adverse employment measures, against any Director, officer, employee and/or third party who in good faith brings forward actual or potential violations or other concerns.
The Vice-President and General Counsel is responsible for ensuring that the mechanisms for reporting concerns are made readily available, and reports are appropriately reviewed, investigated, and addressed.
Our Subsidiaries’ Commitments
Power Financial supports the reporting mechanisms established by its wholly owned operating subsidiaries. Many of our subsidiaries have put in place similar processes for their stakeholders, including their clients, to report concerns, as defined in their respective Codes of Business Conduct and Ethics.
For example, Great-West Life has put in place Customer Complaint Handling Procedures, which outline various mechanisms for a customer to raise concerns. These Procedures include an Ombudsman Office – a channel for clients to raise concerns on the company’s products or services.
IGM Financial has a policy regarding reporting concerns that outlines a confidential process for raising concerns, including a 24/7 whistleblower hotline and website, and a detailed process for comprehensive investigation, where warranted. IGM Financial’s operating companies have formal procedures in place to handle written or verbal complaints from clients. They are guided by principles of fairness, timeliness and reasonability in their assessment of each issue. A client’s first point of resolution is through their financial advisor. Call centres at each company also assist with routine inquiries and complaints. When problems are escalated, the resolution process includes a thorough examination of the complaint by an investigator who contacts the client and engages in a personalized review of the client’s concern.