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Driving our Ethical Culture Reinforcing our Foundation

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 Culture Reinforcing our Foundation

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  1. Driving our Ethical CultureReinforcing our Foundation Learnings from 2012 & Actions for 2013 Ethics and Business Conduct Office

  2. 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

  3. Slight increase in total reported cases with a 16% drop in total substantiated cases over 2011 12 11 12 11 12 11 11 12 11 12 Compliance Cases by Disposition 2012 vs. 2011

  4. Higher total per capital volume due to distributed work force/accessibility issues Attorney Client Privileged Per Capita by Business 2012 vs. 2011

  5. 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

  6. Redesigned Code of Ethical Business Conduct • 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”

  7. Questions • 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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