PNC has long demonstrated a commitment to integrity and corporate responsibility, and its commitment has only deepened as it has grown into one of the leading financial services companies in the country. PNC’s Code of Business Conduct and Ethics and ethics-related policies provide important guidance for conducting daily business activities, including complying with laws, managing and reporting conflicts of interest, upholding fair dealing and protecting confidential information. The company does not tolerate unethical or inappropriate behavior and also includes a risk management goal in all employees’ performance reviews to ensure that all employees remain focused on and accountable for the ethical and risk implications of their work. Detailed information about PNC’s corporate governance policies and procedures and other documents, including the Code of Business Conduct and Ethics, can be found at pnc.com/corporategovernance.
We trust the capabilities, character and judgment of our colleagues, and treat each other with respect. That is the definition of our corporate value of Respect.
At PNC, we take respect very seriously – at every level of the organization. It is a key pillar of our culture, and every employee is responsible for embodying not only our respect value, but all of our values.
We strongly encourage our employees to raise any concerns about respect in the workplace and provide them with multiple avenues, including an anonymous hotline, to report complaints without fear of retaliation. And when issues arise, we address them quickly and effectively. We are committed to an environment in which employees who report issues are supported.
We also require our managers to regularly complete “Managing with Respect” training. This training provides PNC leaders with the concepts needed to create and maintain a values-based work environment that is free from harassment, discrimination and other inappropriate conduct.
PNC has a strict Anti-Corruption Policy that prohibits its employees from engaging in or tolerating bribery or any other form of corruption. PNC’s Anti-Corruption Policy states that all employees must comply with all applicable anti-bribery laws, including the Foreign Corrupt Practices Act, the Bank Bribery Act, the United Kingdom’s Bribery Act and Canada’s Corruption of Public Officials Act. It also states that violations of these laws can result in serious consequences, up to and including criminal and civil penalties, and specifically prohibits the following:
Employees are required to complete ethics training when their employment commences and annually thereafter.
Ethics training provides an overview of the Code and ethics policies, including PNC’s Anti-Corruption Policy. Training is updated regularly to reflect changes in PNC’s business and in laws and regulations. The Code and all ethics policies are available to employees through the company intranet. The Corporate Ethics Office serves as a valuable resource to employees, ensuring that the company’s ethics policies are enforced and providing further guidance on ethical matters. PNC has a defined set of procedures for employees to follow should they suspect that an employee or third party is violating these policies. The Business Conduct and Ethics Hotline, which employees may choose to use anonymously, is available 24/7 to report concerns. In addition, PNC’s Code of Business Conduct and Ethics expressly prohibits retaliation for good faith reporting.
PNC strictly complies with all applicable laws and regulations regarding sanctions, money laundering, terrorist financing and other financial crimes.
Further, PNC has a written BSA/AML and Sanctions Compliance Program approved by its Board of Directors. This program includes a system of internal controls for reporting BSA-related information and for preventing, detecting and reporting sanctions violations, money laundering, terrorist financing, and other financial crimes and suspicious activity in a timely manner.
The Risk Committee of the Board of Directors has appointed an enterprise-wide BSA/AML Compliance Officer who serves as PNC’s primary point of contact with PNC’s regulatory authorities on AML and sanctions matters and oversees PNC’s compliance with BSA/AML and sanctions requirements.
All PNC employees are required to complete annual AML, BSA and sanctions compliance training, which also includes details on identifying and escalating unusual or suspicious activity.
Finally, PNC’s Internal Audit Department coordinates and conducts an independent review and validation of the BSA/AML and Sanctions Compliance Program.
PNC’s culture and business philosophies are predicated on understanding the financial objectives and needs of our customers and then providing product and service options that fit those objectives and needs. While sales are important to PNC, as they are to any business, the overall customer experience and maintaining the trust of our customers, as well as all our stakeholders, are fundamental to our long-term success.
Our sales programs reflect our overarching commitment to our customers. At PNC, sales goals define what we believe is achievable – not what must be achieved regardless of customer desires or circumstances. These goals are developed in partnership across distribution, product management and marketing, and we strive to ensure that the goals set for a particular geographic market, region or branch take into consideration local opportunity, market competition and PNC’s staffing and market presence, among other factors.
Our sales programs reflect our overarching commitment to our customers. At PNC, sales goals define what we believe is achievable - not what must be achieved regardless of customer desires or circumstances.
Our values drive our behavior and reflect our priorities.
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