Seniors Code of Conduct

We have provided our employees with policies and procedures that are comprehensive and relevant to the issues facing seniors today. Employees have access to these resources to help them:

• Offer additional assistance to seniors for their banking activities
• Identify and escalate incidents of suspected financial abuse or fraud against senior customers

These resources are consolidated in one location on our internal intranet to make them easily accessible to employees. These resources cover the following topics:

• Serving clients 60 and older
• Financial abuse
• Powers of Attorney and Joint Deposit Accounts
• Incapacity

Governance of the Code

We incorporate all seven principles of the Code in our Regulatory Compliance Management framework, which ensures regular review of these policies and procedures.

Haventree Bank believes that our senior customers should have equal access to important information about their finances and their relationship with us. To ensure our products and services are accessible by:

• Regularly reviewing our documents using clear, plain, and simple language
• Providing statements and correspondence in alternative formats for both English and French
• Making available staff trained to provide additional explanations about our products and services
• Making available staff that are fluent in other languages

We have a dedicated webpage for seniors, which consolidates valuable information, resources, and tools such as:

• Encouraging financial literacy
• Links to resources by the Canadian Bankers Association
• Haventree Bank's proud support of a national charity dedicated to the financially vulnerable
• Instructions for reporting fraud
• Information on understanding Powers of Attorney and Joint Deposit Accounts
• A link to the annual Seniors Code report

The seniors webpage is regularly reviewed and updated to ensure our senior customers have timely, relevant information available to them when they need it.

We designed a dedicated “Delivery of Banking Services to Seniors” training program that was launched to our frontline employees in October 2021, and completed by December 2021. This is a mandatory training program that must be completed within 30 days of a new hire's start date, with quarterly awareness campaigns, and an annual refresher.

This training program uses various media (e.g., online, text, and video) tailored to its learning goals. The employees must successfully complete a final quiz to prove that the following learning goals were achieved:

• Explaining the importance of a safe banking experience for senior clients
• Naming the Seniors' Champion at Haventree Bank
• Describing the process for escalating a suspected concern involving a senior client
• Identifying red flags in customer service and/or underwriting transactions when interacting with senior clients
• Listing remedies available to address red flags

The following two case studies were discussed during team meetings to bring real-world application to the products or services specific to those employees:

• Identifying red flags in mortgage applications to refinance an existing loan (e.g. potential for financial harm, regulatory issues, and legal implications)
• Identifying red flags when servicing senior clients (e.g., financial literacy and unauthorized third parties)

In 2022, case studies will be featured quarterly through the company newsletter until Q4, when we trigger our annual refresher online training module.

All client-facing employees and support staff are trained and knowledgeable in delivering banking services to seniors. These employees also have access to specialized support experts that can provide additional information on the following:

• Financial abuse and fraud
• Legal incapacity and Powers of Attorney

Haventree Bank's Seniors' Champion acts as an additional layer of support if additional information about senior related topics is needed, and to ensure that the spirit of the Code is being applied in our responses.

Haventree Bank has robust processes in place to mitigate the potential for financial harm for all customers. However, given the rise in scams targeting seniors, we have reviewed and updated our framework for financial abuse prevention and mitigation.

The key to our customer service success are our employees. It is essential they remain vigilant when communicating with our clients. If an employee suspects that a senior client is a victim of financial abuse or fraud, it is their responsibility to intervene to protect the client while respecting the client's privacy and autonomy. This is accomplished as follows:

• Robust 'Know Your Customer (KYC)' and customer due diligence processes
• Employee training focused on anti-money laundering (AML), senior vulnerability factors, signs of financial abuse, PoA abuse, and types of senior scams
• Ongoing market scans of potential financial threats and scams
• Red flag employee guide focused on suspected financial abuse of vulnerable customers, including senior specific red flags
• Requirement for employees to complete Unusual Transaction Reports (UTRs) to support further investigation of potential elder financial abuse or exploitation
• Review of UTR submissions to determine whether a Suspicious Transaction Report (STR) should be escalated to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
• Additional activities as required, such as transaction monitoring, red flag changes, frontline communications, and leadership escalation

Haventree Bank does not have branches, so this principle does not apply.

Haventree Bank is committed to using this report as a platform to provide high-level updates to the public. We are also committed to publishing this report annually on our website to show the steps we take to support each Code principle and to improve the delivery of banking services to seniors.