Report wrongdoing

The purpose of this policy is to establish an accessible and effective process to facilitate the reporting of wrongdoing without fear of reprisal for all employees and partners of the Bank and its subsidiaries.  

The Bank is committed, through its Code of Conduct and Ethics and various policies, to maintaining a culture of compliance and sound risk management, and this policy reinforces that commitment.

The policy is intended for: 

• all employees of National Bank and its subsidiaries, in Canada and abroad, 
• and to any other person interested in availing himself of it. 

Employees of third parties and our partners (i.e. anyone who offers products or services for the Bank or its subsidiaries) also have access to the mechanisms provided for in the policy while enjoying the same protections.  

Did you know that the policy considers it an employee, a contract worker for the Bank?  

If you believe that there has been wrongdoing in an institution other than National Bank and its subsidiaries, know that each institution is governed by the Bank Act. They must also implement this policy for their employees or any other person who distributes their products and services. We invite you to inquire with them to know how they work.

In order to promote reporting, the Bank shall: 

• ensures the confidentiality of the identity of employees and partners who report wrongdoing, as well as any information that may reveal it; 
• provides a fully anonymous reporting process; 
• takes measures to protect its employees who report wrongdoing against dismissal, suspension, demotion, harassment, discipline or loss of employment benefits, and partners who report wrongdoing against loss of benefits related to their contract. 

Please note that if your contribution is required for the purposes of the regulator's investigation, the Bank may be required to disclose your identity or any information that may reveal it: 

• to the Commissioner of FCAC; 
• the Superintendent of Financial Institutions; 
• a government agency or agency that regulates or supervises financial institutions; 
• to a law enforcement agency. 

If this is the case, the Bank will notify you of the upcoming disclosure of your identity for the purposes of the investigation. In addition, the competent authorities may also communicate with each other your identity or any information that may reveal it.

Report the wrongdoing to the Bank to: 

the Reporting Office

By form (confidential or anonymous) 

Reporting form

By phone (confidential or anonymous) 

1 877 390-7881 or 514 390-7881

By e-mail (confidential) 

reporting@nbc.ca

You can also report wrongdoing to an external body:
 

Financial Consumer Agency of Canada (FCAC)

427 Laurier Avenue West, 6th Floor  

Ottawa (Ontario) K1R 1B9 

             Telephone: 1-866-461-2232 

             Site Internet : acfc-fcac.gc.ca 

Office of the Superintendent of Financial Institutions Canada

            By email    

            information@osfi-bsif.gc.ca

            By phone 

            Phone: 1-800-385-8647 

            Services d'ATS : 1-800-465-7735 

            By fax 

            (613) 990-5591 

            By mail 

            Ottawa (Head Office) 

            255 Albert Street, 12th Floor 

            Ottawa (Ontario) 

            K1A 0H2 

any other government agency or agency that regulates or supervises financial institutions, 

to a law enforcement agency.

Upon receipt of your report, we will send you an acknowledgment of receipt that will confirm the start date of the review process, unless the report was made anonymously. 

As the Reporting Office is an independent and impartial team, a member will contact you to fully understand the situation and gather all the details. Subsequently, an analysis will begin and if the report is well-founded, action will be taken. 

It should be noted that it will not have any follow-up or feedback on: 

• the conduct of the investigation; 
• at the conclusion of the report. 

Each report will be dealt with in a timely, impartial, objective and fair manner, taking into account:   

• laws;  
  
• regulations;  
  
• bank standards and policies; 
  
• sound industry practices.
  

The example list of the following cases is not exhaustive and each example may fall into more than one category of breach. 
 

Some examples of wrongdoing that contravenes the Bank Act. 

• Offer products and services that are not suitable for a customer. 
  
• Provide incorrect information or fail to provide complete information about products and services. 
  
• Putting pressure on a customer to opt for our products and services. 
  
• Failing to disclose fees to a customer. 
  

Some examples of wrongdoing that goes against a voluntary code of conduct 

• Farea of advertising that is unclear, accurate or confusing.  
  
• Put pressure on our vulnerable customers to opt for our products and services. 
  
• Solicit, accept or offer rebates, secret commissions, bribes or other similar benefits. (Code of Ethics) 
  
• Participate, directly or indirectly, in activities that are illegal or likely to be perceived as such, even outside of our functions. 
  
• Communicate confidential information other than to persons who need it in the course of their duties and in a secure manner (e.g., discussing a file in a public place).) 
  
• Consult or use customer data without it being necessary to serve them or if we are not responsible for processing their file (e.g. consult the public figure profile). 
  
• False claim for representation expenses. 
  
• Refusal to grant a product to a customer based in particular on age, origin, religion, family status... 
  

Some examples of wrongdoing of the Bank's public engagement; 

• Sign a document from the Bank for the client. 

Commitment to provide mortgage security information 

• Do not provide a consumer wishing to take out a residential mortgage with information about the transfer or assignment of the mortgage guarantee to a new lender. 
  
• Do not provide information about borrowing additional funds or purging the mortgage guarantee in clear, simple and unconscrupulous language. 
  
• Do not make available to consumers in stores information about residential mortgages available in Canada. 
  

Commitment on Powers of Attorney and Joint Deposit Accounts 

• Impose the Bank's power of attorney model on clients. 
  
• Do not specify to the client, when the Bank offers its power of attorney model, that the client can obtain a power of attorney through other sources, including through legal advisors. 
  

Commitment to modify or replace existing products or services 

• If, within 90 days of the effective date of the new product or service that modified or replaced the previous product or service, the client contacts the Bank to indicate that he or she prefers an alternative and the Bank refuses to reimburse the client for the costs associated with the change. 
  

Some examples of wrongdoing in a Bank policy or procedure. 

• Do not protect portable equipment (e.g. laptop, tablet and smartphone) from loss and theft, anytime and anywhere (e.g. leave equipment unattended in plain sight) 
  
• Share passwords or user IDs or not protect them adequately 
  
• Publish confidential or strategic information on social networks 
  
• Do not adequately protect any document or electronic file containing confidential information (e.g. forward confidential customer information to their personal email address) 
  
• A merchant grants a consumer loan to customers to finance a good other than the one defined 
  
• Voluntarily failing to document a customer complaint according to our procedures 
  

Q: If I make a report, will my supervisor be informed of my identity? 

A: No, your identity is confidential.  

Q: Will I receive a call following my report? 

A: Yes, if you decide to do so confidentially but not anonymously, you will be contacted by the Reporting Office's team so that they can fully understand the situation. 

Q: If I witness wrongdoing in another institution, can I report it to National Bank? 

A: Every institution must have this policy. We invite you to inquire with them or on their website. 

Q: How do I report wrongdoing anonymously over the phone? 

A: All you have to do is leave a detailed message of the act, the name of the person concerned and the location on the voicemail without identifying yourself. Be fearless, we have no way to trace the call. 

Q: How do I report wrongdoing anonymously by form? 

A: It is not necessary to fill in all the fields of the form. Simply enter the details of the report in the text box without filling in the fields that identify you. Be fearless, we have no way to trace the provenance, nor the person who filled out the form.