Safe Disclosure and Transparency Corporate Policy

Summary of the Safe Disclosure and Transparency Corporate Policy
(formerly the Whistleblower Policy)

Overview

Coast Capital Savings requires that its employees, officers and directors observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. They are obligated to fulfill their responsibilities honestly and with integrity and must comply with all applicable laws and regulations.

Policy Description

The Safe Disclosure and Transparency Corporate Policy (formerly the Whistleblower Policy) is intended to encourage and enable employees, officers and directors to raise serious concerns within Coast Capital Savings rather than merely overlooking a possible problem.

Individuals within an organization are often the first to realize that there may be something seriously wrong within an organization. However, they may decide not to express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organization. They may also fear recrimination, harassment or victimization. In these circumstances, they may feel it would be easier to ignore the concern rather than report what may just be a suspicion of wrong doing.

The purpose of this policy is to make it clear that all Coast Capital Savings' employees, officers and directors can report wrong doings or suspected wrong doings without fear of reprisal or retaliation.

Coast Capital Savings recognizes that, under some circumstances, employees may be reluctant to make a report for fear of retaliation. The Safe Disclosure and Transparency Corporate Policy protects employees who make a good faith report from retaliation.

Any form of retaliation, blatant or subtle, against any individual who makes a good faith report under this Policy is unacceptable and will not be tolerated.

How to report under this Policy:

Individuals should share their questions, concerns, suggestions or complaints with someone who can address them properly. For employees, an employee's supervisor is in the best position to address an area of concern. However, if they are not comfortable speaking with their supervisor or are not satisfied with their supervisor's response, they can also speak to anyone in management whom they are comfortable approaching. Individuals can also report suspected wrong doing to the Chief Risk Officer, who is responsible for ensuring that all such reports are thoroughly investigated and appropriate action is taken.

Reports may be made to the Chief Risk Officer in the following manner:

Telephone:  604.517.7404
Email: CorporateComplianceOfficer@coastcapitalsavings.com

Confidential Mailbox:
Coast Capital Savings
Attention: Chief Risk Officer
PO Box 55510
Surrey, BC V3R 9Z9

Confidentiality

Investigational reports made under this policy are handled promptly, professionally and with the highest degree of confidentiality that is permitted by law. The Chief Risk Officer will acknowledge receipt of each report within five business days. The Chief Risk Officer will ensure that all reports made under this Policy are confidentially documented and investigated. The Chief Risk Officer will advise the Board Chair, Risk Review Committee Chair and/or the Chief Executive Officer as appropriate. The Chief Risk Officer provides the Risk Review Committee with quarterly updates on any incidents and reports made under the Policy. Internal Audit will conduct periodic reviews relating to the application of this Policy and will report the findings to the Risk Review Committee as appropriate.

Acting in Good Faith

Coast Capital Savings is proud of its reputation and uses substantial resources to investigate any report of wrong doing or suspected wrong doing. However, anyone filing such a report must be acting in good faith, have an honest belief that the complaint is well founded and have reasonable grounds for believing that the information disclosed indicates wrong doing. This Policy does not protect employees who make a bad faith report. Employees who deliberately make false or malicious allegations may be subject to disciplinary action including termination of employment for just cause without notice or pay in lieu of such notice.

For information on changes to deposit insurance and the transition period if we become a federal credit union, see the notice pursuant to the Disclosure on Continuance Regulations (Federal Credit Unions).