Southwest Regional Credit Union: Market Conduct Code

Our Market Code Principles:

Credit unions are unique institutions. Operating in Canada for over 100 years, credit unions are financial cooperatives that are governed and financed differently than banks. At credit unions, members are shareholders. Being a member means sharing in Southwest Regional Credit Union’s success.

Our primary motivation is providing quality products and services to our members. We are committed to ensuring that our members are completely satisfied with the level of services they receive.

This is our Market Conduct Code.

The Code recognizes principles that we pledge to follow for soliciting, promoting, advertising, marketing, selling, or distributing our products and services. The Code demonstrates our commitment to the fair treatment of all those who use our services. We believe in fair sales practices, comprehensive access to banking services, transparency and openness, and a reasonable approach to settling complaints. Individuals are entitled to the best possible care of their financial interests.

We respect our provincial regulatory obligations, and continually practice excellence in consumer protection. Our code is comprised of the following five key principles:

• Business Practices: We are committed to providing customer service excellence to all our members and customers using our products and services. It is a core component of our governance and corporate culture.

• Fair Treatment and Fair Sales Practices: Treating members and customers fairly and demonstrating fair sales practices at all times are integral parts of our business practices.

• Access to Banking Services: We ensure that all credit union members and customers are granted access to fundamental financial services.

• Transparency and Disclosure: Southwest Regional Credit Union uses plain-language descriptions of products and services in its communications to ensure people make informed decisions.

• Complaint Handling: We examine complaints, work to settle them fairly, and track them to help ensure our practices continue to improve.

Business Practices:

We are committed to providing fair treatment to all our members and customers using our products and services. It is a core component of our governance and corporate culture.

1.1 Business Culture

Southwest Regional Credit Union will promote a “fair treatment” corporate culture by making strategic decisions, demonstrating in their daily conduct, and communicating with credit union employees, the expectation that fair treatment applies to all Members, Account Holders, and Consumers.

1.2 Governance and Accountability

Southwest Regional Credit Union’s Board of Directors (“Board”), as elected by Southwest Regional Credit Union membership, is responsible for ensuring the overall fair treatment of Members, Account Holders, and Consumers. Southwest Regional Credit Union has implemented a policy and/or procedure that sets out:

• Southwest Regional Credit Union’s requirement to promote a “fair treatment” corporate culture, as per section 1.1;

• Who, at the Board level is responsible for supervising adherence to the Code;

• That the Board will review the report set out in section 1.3 and take necessary action to remedy deficiencies noted in the report

• The regular monitoring and review of market conduct within business practices.

1.3 Reporting to the Board

At least annually, Senior Management will be responsible for reporting to the Board on Southwest Regional Credit Union’s adherence to the principles in this Code, including the results of Southwest Regional Credit Union’s annual self-assessment.

1.4 Protection of Personal Information

Southwest Regional Credit Union will safeguard, collect, use, and disclose Personal Information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

Southwest Regional Credit Union also commits to collaborating with partners, contractors and third-party providers for digital financial transactions which adhere to cyber security frameworks that are informed by international or national industry standards or guidelines which support the following principles in accordance with the G7 Fundamental Elements of Cybersecurity for The Financial Sector:

1. Cybersecurity Strategy and Framework: Establishes and maintains a cybersecurity strategy and framework.

2. Governance: Defines and facilitates performance of roles and responsibilities for personnel implementing, managing, and overseeing the effectiveness of the cybersecurity strategy and framework.

3. Risk and Control Assessment: Identifies functions, activities, products, and services—including interconnections, dependencies, and third parties—prioritizes their relative importance, and assess their respective cyber risks. Identifies and implements controls—including systems, policies, procedures, and training—to protect against and manage those risks within the tolerance set by the governing authority.

4. Monitoring. Establishes systematic monitoring processes to rapidly detect cyber incidents and periodically evaluate the effectiveness of identified controls.

5. Response: Conducts timely (a) assessments on the nature, scope, and impact of a cyber incident; (b) contain the incident and mitigate its impact; (c) notify internal and external stakeholders (such as law enforcement, regulators, and other public authorities, as well as members, third-party service providers, and customers as appropriate); and (d) coordinate joint response activities as needed.

6. Recovery: Resumes operations responsibly, while allowing for continued remediation, including by (a) eliminating harmful remnants of the incident; (b) restoring systems and data to normal and confirming normal state; (c) identifying and mitigating all vulnerabilities that were exploited; (d) remediating vulnerabilities to prevent similar incidents; and (e) communicating appropriately internally and externally

7. Information Sharing: Engages in the timely sharing of reliable, actionable cybersecurity information with internal and external stakeholders (including entities and public authorities within and outside the financial sector) on threats, vulnerabilities, incidents, and responses to enhance defenses, limit damage, increase situational awareness, and broaden learning.

8. Continuous Learning: Reviews the cybersecurity strategy and framework regularly and when events warrant.

1.5 Financial Well-being and Financial Literacy

Southwest Regional Credit Union values and supports the financial well-being and financial literacy of consumers in their communities. In this regard, Southwest Regional Credit Union makes strategic decisions that outlines initiatives. Initiatives that support these values may include offering awareness and/or education on improving credit bureau scores, safely using internet and mobile banking, and improving financial well-being through appropriate financial planning.

1.6 Whistleblowing

Southwest Regional Credit Union will provide a channel through which whistleblowers can report suspected unethical conduct in anonymity while respecting the rights of those about whom concerns are raised, to address, or answer, those concerns.

Southwest Regional Credit Union has a policy and/or procedure in place for employees to report incidents of actual or potentially improper or unethical conduct, without fear of reprisal or unwarranted negative consequences. Employees who report suspected unethical conduct (“whistleblowers”) will be protected, to the extent possible under the circumstances, as described in Southwest Regional Credit Union’s procedures.

Southwest Regional Credit Union’s board of directors is responsible for periodically reviewing, approving, and maintaining the Whistleblowing policy and/or procedure. Management of Southwest Regional Credit Union is responsible for managing, monitoring and controlling credit union operations, in accordance with the Whistleblowing policy and/or procedure. (See page 27)

1.7 Lobbying Activities

Southwest Regional Credit Union, like any other business, association, or individual, may occasionally interact with government and comment on policy, legislation, regulation, or other actions of government. This activity is both legitimate and in the best interests of Southwest Regional Credit Union and its Members and Account Holders.

In conducting these activities, Southwest Regional Credit Union may employ a lobbyist, either on staff or as a consultant, and when doing so will ensure that each lobbyist will:

• Identify that he or she is acting on behalf of Southwest Regional Credit Union;

• Disclose any conflicts of interest in accordance with subsection 2.1.3; and

• Act in accordance with any laws and regulations that apply to them, including be registered with the appropriate lobbyist registries.

Fair Treatment and Fair Sales Practices:

Treating members and customers fairly and demonstrating fair sales practices at all times are integral parts of our business practices.

1.4 Fair Treatment

Southwest Regional Credit Union treats Members, Account Holders, and Consumers fairly during their dealings. This section 2.1 (including subsections), sets out what fair treatment means and is meant as a minimum standard for fair treatment.

1.5 Fair Sales

Southwest Regional Credit Union provides accurate Product and Service information to assist Members, Account Holders, and Consumers in making appropriate Product and Service choices. This section 2.2 (including subsections) sets out what fair sales means and is meant as a minimum standard for fair sales.

Member Complaint Handling:

We examine complaints and work to settle them fairly, and we track complaints to help ensure our practices continue to improve.

1.6 Complaint Handling Procedures and Processes

A complaint is an expression of dissatisfaction about a Product, Service provided by Southwest Regional Credit Union.

Southwest Regional Credit Union has established a policy and/or procedure for fairly and transparently resolving complaints, internally, that are made by Members, Account Holders, and Consumers. Southwest Regional Credit Union has a designated compliance officer responsible for handling complaints.

Southwest Regional Credit Union has established a process for handling complaints that cannot be resolved satisfactorily internally. For example, an individual should have the option to escalate an unresolved complaint to a complaint handling system that is independent of Southwest Regional Credit Union.

Southwest Regional Credit Union has established a process for measuring the satisfaction of its members. This may be done by survey or another method appropriate to the size of Southwest Regional Credit Union.

1.7 Making Complaint Handling Information Available

Southwest Regional Credit Union has made available to Members, Account Holders, and Consumers, Southwest Regional Credit Union’s complaint handling policy and/or procedure and the contact information for accessing the service. This information is available on Southwest Regional Credit Union’s website (if applicable), in branch, and upon request.

1.8 Handling Complaints

Southwest Regional Credit Union handles complaints in a fair and transparent manner and responses will be timely.

1.9 Recording Keeping

Southwest Regional Credit Union maintains records of complaints received and the action taken to deal with them, for reporting purposes (in accordance with section 5.5), and if needed for future reference by Southwest Regional Credit Union or regulator (if applicable). The types of complaints that require record keeping will be set out in Southwest Regional Credit Union’s complaint handling policy and procedure.

1.10 Reporting Complaints

Southwest Regional Credit Union reports to the Board of Directors, at least annually, on the number of complaints received, the general nature of those complaints, how those complaints were dealt with and identified trends in complaints. The types of complaints that require reporting to the Board are set out in Southwest Regional Credit Union’s complaint handling policy and procedure.

Complaint Procedure

Southwest Regional Credit Union aims to provide an exemplary, fair and transparent service to all its members. However the credit union recognizes there will be occasions when some aspect of its service, procedures or processes will be perceived by the member to have failed to have come up to the credit union’s business standards and this may lead to a complaint by a member.

Rights of the Credit Union

Southwest Regional Credit Union Ltd asserts its right to make appropriate business decisions about any area of its operations; including admission of new members to membership and individual eligibility for credit as referenced in the membership and loan policies of the credit union.

Who can make a Member Complaint?

Complaints may only be made by eligible complainants. An eligible complainant is:

1. a credit union member or potential or former member.

2. a nominated beneficiary or personal representative of (1) above.

How do I make a Member Complaint?

A complaint may be made in writing or orally to an employee of the Credit Union by letter, by telephone, by email direct to info@southwestcu.com or via the Contact page on the credit union website https://www.southwestcu.com

Responding to a Member Complaint

The credit union aims to resolve the complaint to the complainant’s satisfaction as quickly as possible and within the following time frames:

Within one day – Member Services Representative Supervisor to Branch Manager

Where possible we will resolve your complaint to your satisfaction at the point that you make us aware of it, or at least by the close of business on the next business day after the day on which the complaint was received.

Within 3 days – Branch Manager to Director of Sales and Service

If the officer dealing with your complaint needs more time to collect information you will receive a letter (this may be by email) within 3 working days of the date of your complaint detailing the steps being taken and the expected date of completion. This letter will include the following information:

1. the name or job title of the person handling the complaint.

2. the credit union’s internal complaint handling procedure.

Investigating a Member Complaint – Director of Human Resources/Complaints Officer

Investigating a complaint is the responsibility of the Director of Human Resources.

Within 8 weeks (or Quarterly)

If still unresolved 8 weeks (or quarterly) after receiving a complaint, the Credit Union will send the complainant:

1. a final response, or

2. a response which explains the delay and advises the complainant when a final response can be expected. The complainant will be asked whether they are willing to extend the time for the investigation to be completed.

3. The complainant will be advised that if dissatisfied with the delay he can refer the complaint to the FSRA.

Final response

It is the Credit Union's intention to provide a complainant with a satisfactory final response within 8 weeks or quarterly of receipt of the complaint. The final response will include:

1. A summary of the complaint

2. A summary of the investigation into the complaint

3. Whether the credit union acknowledges it has been at fault in any way

4. Details of any redress or offer made to settle the complaint

5. The complainant’s right to refer the complaint to the FSRA (Financial Services Regulatory Authority of Ontario) if remaining unsatisfied with the final response from the Credit Union.

FSRA Complaint Form

https://www.fsrao.ca/media/4186/download

Instructions to file a complaint to FSRA

Complaints can be sent to the attention of the "Complaints and Risk Assessment Branch" by email to contactcentre@fsrao.ca, by fax to 416-590-8480, or by regular mail to: 25 Sheppard Avenue West, Suite 100, Toronto, ON, M2N 6S6.