Conduct & Ethics
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- Conduct & Ethics
- Performance
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At TD, our Code of Conduct and Ethics provides a framework for how to deal with each other, our shareholders, customers, communities, suppliers and competitors.
The Code addresses issues such as how to handle potential conflicts of interest and ensure confidentiality of information. Employees understand clearly that any irregular business conduct, including bribery, corruption or insider trading, will not be tolerated. Any breach is considered a serious offence, and employees must report any possible violations they witness.
Internal Control Framework Policy
Extensive security systems are maintained to detect financial crime, particularly fraud. Each of our businesses is subject to periodic reviews by our internal audit teams, who independently assess the level of risk and the effectiveness of internal controls.
Whistleblower Program
TD has a confidential whistleblower hotline for employees and other stakeholders to report any accounting concerns. In addition, employees may use this process to report any suspected breach of our Code of Conduct and Ethics should they not be comfortable using other established reporting methods. TD employees are encouraged to bring forward their concerns through the employee complaint resolution process, and they also have access to an ombudsman office to report workplace issues on a confidential basis.
Compliance Incidents
We respect and strive to comply at all times with all laws and regulations in jurisdictions where we operate. With more than 19 million customers worldwide and hundreds of thousands of transactions completed daily, there are times when we do fall short and make mistakes, and our response is to act quickly and address the issue.
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Compliance Incident Reporting 2010 2009 2008 Total number of legal actions for anti-competitive behaviour, anti-trust and monopoly practices. 0 0 0 Monetary value of significant fines1 and total number of non-monetary sanctions for noncompliance with laws and regulations (in millions). $11.22 $1.03 $2.94 Monetary value of significant fines1 and total number of non-monetary sanctions for noncompliance with environmental laws and regulations. 0 0 0
1 We determine a significant fine to be incidents that are of a regulatory nature and involve a fine of $1 million and above. Penalties of an administrative nature are not considered material.
2 On December 17, 2009, the Financial Services Authority UK fined Toronto Dominion Bank (London Branch) £7,000,000 (CDN$11,236,000) for repeat systems and controls failings around the pricing of sophisticated financial products.
3 Refer to our 2009 Corporate Responsibility Report for an explanation of fine.
4 Refer to our 2008 Corporate Responsibility Report for an explanation of fine.
