- Ethics, Conduct and Policies
Research shows that as a symbol of Canadian corporate excellence, BCE is held to a high standard of behaviour by the many people who take an interest in our affairs. As Canada's leading telecommunications company, we believe it is our responsibility to live up to and even exceed this standard. We do this through an environment that fosters ethical conduct and is intolerant of any breaches.
Governing Business Conduct
The conduct of directors, officers and employees of BCE companies is governed by an over-arching Code of Business Conduct* (the "Code") which sets out our principles, rules and guidelines for ethical behaviour. It includes topics such as conflicts of interest, use and protection of company assets, confidentiality, dealing with business partners and competitors, diversity in the workplace, protecting the environment and others. The Code is written in reader-friendly language and includes hypothetical case studies to help readers understand and appreciate its contents. It was significantly updated in December 2005, and is updated annually.
All Bell Canada employees must review and sign the Code within a few weeks of being hired and thereafter on an annual basis. They are also required to take an on-line training course to ensure understanding of this policy. The compliance training program was audited and highly-rated by the Competition Bureau of Canada.
BCE and Bell Canada require all directors, officers and vice-presidents to certify that they comply with the Code and support the standards that discourage wrongdoing and promote ethical conduct. This includes honesty; full, fair and accurate disclosure in the company's public communications including reports and documents that we file or submit to securities regulators; and compliance with laws, rules and regulations.
*The Bell Canada Enterprise's Code of Business Conduct applies to all employees, officers and directors, where applicable, of BCE Inc., its subsidiaries (including Bell Canada), controlled entities and joint ventures. These companies are also encouraged to adapt the BCE code to meet their specific business needs, provided the principles of conduct laid out in the BCE Code of Business Conduct are preserved. Publicly-traded BCE companies have their own code which respects the spirit of the BCE document.
Managing Ethics and Policies
In mid-2005, as part of a corporate-wide initiative to strengthen our governance, and in response to requirements of the Sarbanes-Oxley Act, we established a new Ethics and Policy Management Group (EPMG) which reports to our Corporate Secretary and in turn to the Corporate Governance and Audit Committees of the Board of Directors.
The EPMG's responsibilities include:
- Oversight of the company's ethics program (including the Bell Canada Enterprises Code of Business Conduct)
- Ethics training
- Management of various communication and feedback tools that give employees access to information on business conduct and facilitate reporting of issues under the Code or questionable accounting and auditing practices (See "Communication and Feedback" below.)
- Implementation and oversight of a new corporate policy management framework designed to ensure that employees have improved access to and increased awareness of key corporate policies and business unit-specific processes, procedures and systems.
Policies and Rules of Conduct
BCE and Bell Canada have a wide range of policies. Some of the key policies are managed centrally by the EPMG and applied by individual business or functional units. Other policies are managed directly by business or functional units. In all cases, policy breaches may result in disciplinary action, up to and including dismissal. In certain instances, they may also result in civil or criminal prosecution.
BCE's codes, policies and rules address a range of issues including:
- Anti-competitive Behaviour
- Accounting and Audit Complaints
- Auditor Independence
- Code of Business Conduct
- Community Investment
- Consumer Protection
- Corporate Security and Emergency Management
- Disclosure
- Environment
- Health, Safety and Wellness
- Human Resources
- Political Contributions
- Privacy
- Procurement
Communication and Feedback
Enhanced Employee Help Line
We believe that employees should have the best possible tools to ask questions or raise issues concerning ethical dilemmas. As part of our ethics compliance initiative, we have made important improvements to our long-standing Employee Help Line. Employees and other parties can anonymously and confidentially access our new support system by telephone or on-line, 24/7. They can ask questions, report concerns, and track the progress of their enquiries. Users may raise concerns relating to issues under the Code of Business Conduct, suspected accounting or auditing irregularities, or any matters relating to compliance with laws, regulations or company policies and procedures. Administered by an independent outside firm that specializes in the field, this new system also provides the company with an auditable record of issues raised.
Complaint Procedures for Accounting and Auditing Matters
In early 2004, the Audit Committee of the Board of Directors established procedures for the receipt, retention and treatment of accounting and auditing concerns and complaints directed to BCE or any of its subsidiaries. Specifically, the procedures address issues raised by employees or other persons, on a confidential and anonymous basis, regarding accounting, internal accounting controls, auditing matters or corporate fraud. We developed an innovative, on-line web tool that allows users to report questionable accounting and auditing practices in complete confidence. This is in addition to the other means of communications available to our employees, such as the Employee Help Line discussed above.
Contacting the EPMG
Bell employees who have questions regarding general business conduct or who wish to report questionable practices can send an e-mail to ethics@bell.ca. In addition, employees located in Ontario and Québec can call the support line, 310-6600.
