in tegrity - Canada - RBC

1 code of conduct ; hone sty. pri nciples t o e t h ical eren ce 1. adh integrity def. n. ( (. Doing What's Right * Do business openly and fairly. * Comply with the law in all our dealings. * Consider the impact of our decisions and actions on others. * Speak up when we believe something is wrong. * Seek diverse views and constructive challenge when we make decisions. A message from David McKay President and CEO. Building Trust RBC and You Why do banks matter? They facilitate personal and business financial transactions, match saving and borrowing needs, and help domestic and international markets function. They provide financial advice, help manage risks and are vital for economic growth.))

2 Banks hold this important position in our society because of the trust others place in them. It's crucial that clients, employees, investors, communities, and regulators have confidence that banks act fairly and ethically. At RBC, we hold ourselves to the highest standards of integrity to build trust with every interaction. By listening to clients and communities to understand their interests and needs, we reinforce the trust that is so important to our success and to our Vision To be among the world's most trusted and successful financial institutions. Our Values, especially our Value of Integrity, and code of conduct guide us and set expectations for ethical behaviour and decision-making.

3 They help us decide how we serve our clients and deal with each other with respect, transparency and fairness. Our code protects employees, clients and RBC by providing a common understanding of what's acceptable and what's not. It's a resource that helps us understand what's expected and why. We are all responsible for protecting and enhancing RBC's reputation by following our code of conduct . It's also important that we support one another in doing what's right, by speaking up candidly and challenging situations we believe are wrong. Please read the code carefully, discuss what it means with your manager and colleagues, and ask questions to ensure you understand it and what it requires of you.

4 You represent RBC both on and off the job. You keep RBC a leader in a changing world by living our enduring beliefs our Values of Client First, Collaboration, Accountability, Diversity and Inclusion, and Integrity, and you bring to life our purpose of helping clients thrive and communities prosper. Successful companies simply don't exist without the right people. It all starts with you. David McKay President and CEO. A message from David McKay, President and CEO i Our Vision and Values RBC's Values define what we stand for everywhere we do business. They are reflected in our behaviour and the way we build relationships and deliver value to all our stakeholders clients, employees, shareholders, communities and others we deal with.

5 Guided by our shared Values and united in a common purpose, we can achieve our strategic goals and accomplish great results. We demonstrate our Vision To be Among the World's Most Trusted and Successful Financial Institutions - by living our Values in the decisions and actions we take every day. These five Values set the tone for our culture and unify us across geographies and businesses: CLIENT FIRST. We will always earn the right to be our clients' first choice. Put client needs above our own whatever our role, to build lasting relationships Listen with empathy, understand client needs to offer the right advice and solutions Bring the best of RBC to deliver excellent value and differentiated client experiences COLLABORATION.

6 We win as One RBC. Believe in each other and trust in teamwork and colleagues' intentions Share knowledge, listen, and teach to learn and achieve more together Look beyond ourselves to see the bigger picture for opportunities and solutions ACCOUNTABILITY. We take ownership for personal and collective high performance. Be bolder, reach higher, act with courage to realize potential and make a difference Own it; seek out accountability and empowerment to grow and excel Be curious and learn continuously to build skills and careers DIVERSITY & INCLUSION. We embrace diversity for innovation and growth. Speak up for inclusion and empower people to grow and achieve more Seek out and respect different perspectives to challenge conventional approaches Identify and act on the opportunities and needs that client diversity brings INTEGRITY.

7 We hold ourselves to the highest standards to build trust. Be respectful, transparent and fair in all relationships Stand up for what we believe; speak with candour; constructively challenge Build trust of clients, colleagues and community partners by listening to and understanding their interests and needs At RBC we bring these Values to life every day continuing to earn the trust of RBC's clients and ensuring our strong reputation for doing what's right. Our Vision and Values ii Table of Contents OUR VISION AND VALUES ii 1. Our Culture of Integrity 1. Living Our Values and Acting with Integrity 1. Our Culture of Integrity Doing What's Right 1. Our Shared Commitment and Accountability 2.

8 2. Speaking Up, Raising Concerns and Reporting Misconduct 3. Speaking Up and Raising Concerns 3. Reporting Misconduct 3. Investigations, Inquiries and Reviews 3. RBC's Commitment to Non-Retaliation 3. What We Expect of Our People Managers 4. 3. Integrity in Dealing with RBC Clients, Communities and Others 5. Protecting RBC Client Information 5. Protecting RBC Business Information 5. Protecting RBC's Reputation in Our Communities 5. Responding to Government or Regulatory Inquiries 6. 4. Integrity in Working Together at RBC 7. Respectful Workplace 7. Equal Opportunity, Fair Workplace and Human Rights 7. Personal Information About Us 8. Workplace Health and Safety 8. 5. Integrity in How We Do Business 9.

9 Business Dealings 9. Avoiding and Managing Conflicts of Interest 9. Preventing Financial Crime 12. Securities Trading 12. Fair Competition 13. Global Economic Sanctions 13. 6. Integrity in Safeguarding Entrusted Assets 14. Protecting RBC Client Property 14. Protecting RBC Property 14. Keeping Accurate Books and Records 15. 7. Conclusion 16. Publication date: January 1, 2018. esty. es; hon principl ethical ( integrity(. to erence 1. adh def. n. 1. Our Culture of Integrity Doing What's Right Living Our Values and Acting with Integrity Throughout the code , RBC means RBC is a values-based organization. Respect for each other, RBC clients and our Royal Bank of Canada and all its commitments to all our stakeholders are rooted in our Values.))

10 RBC's code of subsidiaries and affiliates. conduct (the code ) incorporates RBC's Values, and in particular our Value of Integrity, to guide our day-to-day actions and decisions so we can always do the right thing. Our Culture of Integrity Doing What's Right Every day our actions demonstrate not only our Value of always earning the right to be our clients' first choice, but also our personal commitments. We each have a responsibility to be truthful, respect others, and comply with laws, regulations and RBC's policies. (In the code , the word policy includes policies, procedures, standards, standing orders and frameworks.) Over many years RBC has earned trust and a reputation for doing what's right through the actions of those who work here.