CODE OF CONDUCT FOR CONTINGENT WORKERS 2018 - DTCC.com
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CODE
OF CONDUCT
2018
FOR CONTINGENT WORKERS
DTCC Controlled Non-Confidential [Green]
TABLE OF CONTENTS
A Message From CEO Michael Bodson ............................................................ 3
Introduction.................................................................................................. 4
Comply with the Law...................................................................................... 5
Ethical Business Practices.............................................................................. 6
Reimbursable Travel Expenses........................................................................ 7
Conflicts of Interest....................................................................................... 7
Anti-Money Laundering.................................................................................. 7
Sanctions..................................................................................................... 7
UK Modern Anti-Slavery Act........................................................................... 7
Communication with Our Global Regulators...................................................... 7
Protect Confidential Information...................................................................... 8
Client Confidential Information....................................................................... 9
Personally Identifiable Information.................................................................. 9
Protect and Appropriate Use of DTCC’s Assets................................................ 10
Information Systems and Communications Facilities....................................... 11
Electronic Communications.......................................................................... 11
Intellectual Property.................................................................................... 11
Social Media Policy..................................................................................... 12
Maintain Accurate Books and Records........................................................... 12
Protection and Fair Treatment of Contingent Workers and Our Communities...... 13
Personal Integrity........................................................................................ 14
Discrimination and Anti-Harassment.............................................................. 14
Diversity and Inclusion................................................................................. 14
Solicitation................................................................................................. 15
Social Responsibility.................................................................................... 15
Personal Relationships................................................................................. 15
Workplace Safety......................................................................................... 15
Who to Contact for Help............................................................................... 16
Key Policies and Procedures ........................................................................ 17
DTCC Global Ethics Hotline.......................................................................... 18
| 2 DTCC CODE OF CONDUCT
OUR CODE OF CONDUCT EXPRESSES AND
REINFORCES OUR FOUNDATIONAL VALUES AND
DEMONSTRATES THE COMMITMENT OF ALL WHO
WORK AT DTCC TO CONDUCT OURSELVES WITH
THE HIGHEST INTEGRITY.
A MESSAGE FROM CEO MICHAEL BODSON
As a trusted leader in protecting the security and integrity of the global financial system, DTCC and
our employees have a responsibility to act with the highest ethical standards in everything we do. We
support this by fostering a culture of respect, honesty, and diversity and inclusion – all characteristics
that sit at the heart of our values and which have served as the guiding principles of our business for
more than 40 years.
As we assume a broader mandate to help the industry during this period of market transformation,
we must always conduct ourselves with the highest integrity and “do the right thing” whenever, and
wherever, we act on behalf of the firm. This is critical to building and maintaining trust with our
stakeholders and creating a workplace where all employees feel comfortable speaking up.
It is an exciting time to work at DTCC, and as we establish a more commercially-minded and
entrepreneurial environment in order to expand our reach across the industry, we must remain true to
our core values and follow them in all of our actions.
The 2018 DTCC Code of Conduct is required reading for all employees so please make this a priority.
As always, thank you for your continued dedication to DTCC and the role you play in supporting our
integrity, values and ethics.
Sincerely,
Michael C. Bodson
President and Chief Executive Officer
DTCC CODE OF CONDUCT | 3
INTRODUCTION
As a global financial services leader, our Code of Conduct
represents our commitment to integrity and high ethical
standards. Adhering to the letter and the spirit of this Code YOUR CODE OF CONDUCT OBLIGATIONS
and applying sound judgment is integral to the success of
Failure to comply with any requirements of the Code,
our company.
including mandatory Compliance training, will result in
The Code should guide our actions and decisions at work, escalation to Human Resources. It is the responsibility
providing an ethical standard for us to follow when dealing of each manager to oversee their staff’s completion of
with clients, regulators, employees, and the community. all Compliance training. If you do not understand your
You are required to read and understand each section of obligations, it is your responsibility to seek clarity from
the Code, as well as to participate in supplemental Code of your manager, Compliance, Human Resources, or Legal.
Conduct training. Using our Code, and the underlying poli-
cies and procedures it represents, employees are encour-
aged to “speak up” if they perceive a Code violation, for the
benefit of their fellow employees as well as the organization as a whole. This Code is applicable to the DTCC Clearing
Agencies’ businesses (the National Securities Clearing Corporation, the Fixed Income Clearing Corporation, and the
Depository Trust Corporation) and the Solutions businesses, as well as their support areas.
| 4 DTCC CODE OF CONDUCT
COMPLY
WITH THE LAW
DTCC CODE OF CONDUCT | 5IF YOU COME ACROSS UNUSUAL OR POTENTIAL SUSPICIOUS ACTIVITY THROUGH YOUR
ROLE AT DTCC, YOU MUST IMMEDIATELY REPORT IT TO COMPLIANCE. PLEASE SEE THE
CONTACTS LISTED AT THE END OF THE CODE OF CONDUCT.
ETHICAL BUSINESS PRACTICES
A BRIBE CAN BE ANY OF THE FOLLOWING:
FAIR COMPETITION
We compete fairly for business by providing excellent service at ■■ Anything of value intended to improperly persuade
fair prices. someone to give a business advantage
DTCC is prohibited from participating in price fixing ■■ Merchandise, gifts, cash, favors, loans,
arrangements with competitors or potential competitors, and entertainment, seminars, charitable donations
may not collude with anyone in dividing up markets or denying ■■ Political contributions
a party access to services. Furthermore, laws and regulations
IN JURISDICTIONS WHERE LEGAL, A FACILITATION PAYMENT
may prohibit conditioning the availibity or price of one product
REQUIRES PRE-APPROVAL FROM COMPLIANCE OR LEGAL.
on the pruchase of another. Any diviations from standard
THIS CAN INCLUDE THE FOLLOWING:
pricing strategies, including offfering special pricing for
bundled services, must be approved by the Legal Department. ■■ Payments to further routine government action
■■ Passports, visas, supplying utilities, registrations, or
FRAUD
building permits
DTCC does not tolerate fraud, which is a false representation,
including concealment, of fact by words, conduct, or in MANAGER OBLIGATIONS FOR GIFTS AND
business records. DTCC staff are expected to behave ethically ENTERTAINMENT DISCLOSURES:
and honestly when conducting business; submitting travel and
expense reports, disclosing gifts and entertainment, conflicts of Managers may be required to review gifts and
interest; disclosing background information, and during contract entertainment after validating compliance with the
negotiations. Failure to do so may result in disciplinary action DTCC Code of Conduct, other applicable policies and
up to and including termination. procedures and anti-bribery laws, and to consider if the
expenditure may create an appearance of impropriety.
If you witness, or suspect, fraudulent behavior at DTCC, you must
report it to your manager, Compliance, Legal, Human Resources, If you are unsure whether something rises to the level
or the Global Ethics Hotline. of being a bribe, or is considered a facilitation payment,
please contact the Compliance Department for guidance.
BRIBES AND FACILITATION PAYMENTS
You should avoid, directly or indirectly, bribing others or
accepting bribes in connection with any dealings in any GIFTS AND ENTERTAINMENT
country. It is imperative that you avoid any activities that Certain forms of gifts and entertainment may be construed as
may interfere with your ability to act in the best interests of bribery, thus creating an actual or apparent conflict of interest.
DTCC, its clients, and your colleagues. In certain instances, DTCC permits the giving or receiving of reasonable business-
facilitation payments may be warranted, but only upon prior related gifts and entertainment unless they are: contrary to law,
approval of Compliance or Legal. intended to obtain special favors, or could impair the recipient’s
impartiality. That includes gifts from vendors, clients, or co-
workers. Please refer to the DTCC Gifts, Entertainment, and
Conflicts of Interest Policy for more information.
| 6 DTCC CODE OF CONDUCTREIMBURSABLE TRAVEL EXPENSES SANCTIONS
DTCC may reimburse contingent workers for reasonable travel The United States Department of the Treasury’s Office of Foreign
expenses. You are responsible for seeking the most cost-effective Assets Control (“OFAC”) administers and enforces economic
rates and complying with DTCC’s Global Travel and Expense and trade sanctions designed to further U.S. foreign policy and
Reimbursement Policy. national security objectives. OFAC sanctions programs prohibit
U.S. persons from directly or indirectly engaging in activities or
All anticipated travel for each contingent worker must be agreed
transactions with targeted foreign countries and with persons and
upon and included in the Statement of Work. You should
entities named on OFAC sanctions lists.
substantively review the supporting documentation and verify the
expenses conform to the negotiated terms in the Statement of Work. You must follow DTCC’s Global Sanctions Policy in order
to comply with all applicable OFAC and Global Sanctions
Certain expenses, such as personal items, lost property,
obligations. Failure to comply with sanctions laws and
traveling products, personal insurance, child care, corporate
regulations can result in significant penalties against both
card fees, airline upgrades, hotel upgrades, and spousal
yourself and DTCC.
entertainment, are not reimbursable. Please refer to the Global
Travel and Expense Reimbursement Policy for a full list of items
that are non-reimbursable. UK MODERN ANTI-SLAVERY ACT
In 2015, the United Kingdom enacted the Modern Slavery Act in
CONFLICTS OF INTEREST an effort to expose and combat forced labor. Millions of people
As DTCC is a global financial services leader, contingent around the world are trapped in some form of forced labor, the
workers may support multiple entities and business areas, term used to describe all forms of modern slavery, including
which may include different responsibilities for compliance with trafficking, debt bondage and child labor.
regulations. As a result, contingent workers may experience
The Modern Slavery Act includes a provision on transparency in
potential or actual internal conflicts due to competing demands.
supply chains that requires certain businesses operating in the
If this occurs, and you are in doubt as to whether a potential
United Kingdom (and, based on certain criteria, their UK and US
or actual conflict exists on your competing deliverables, raise
affiliates or parent) to take steps to ensure there is no modern
the question with your management, Human Resources, the
slavery in their own business and their supply chains (e.g.,
Compliance Hotline or the anonymous Global Ethics Hotline. If
companies and vendors that provide it with goods or services).
a potential or actual conflict is determined to exist, you must
While DTCC does not consider that it currently operates in high-
promptly disclose it to Compliance, who will determine how to
risk sectors or locations for modern slavery, we should be aware
proceed.
of the dangers of modern slavery, in particular with regard to our
vendor engagements, and report any suspected noncompliance to
ANTI-MONEY LAUNDERING the DTCC Compliance Hotline.
We are committed to protecting DTCC from being used to
facilitate money laundering, terrorist financing, financial crimes, COMMUNICATION WITH OUR GLOBAL REGULATORS
and any other illegal operations. Compliance with DTCC’s Whether it be for AML or OFAC related requests or any other
Anti-Money Laundering (AML) and Global Sanctions programs request, all interactions with regulators should demonstrate
are essential to promoting the safety and soundness of DTCC’s respect for their office and role. Responses to requests for
operations. information from DTCC’s regulators must be timely, accurate, and
complete.
Each year, Compliance trains staff to identify unusual and
suspicious activity. DTCC has defined AML Red Flags which DTCC has established centralized points of contact to facilitate
identify activities that may indicate attempts by individuals or all requests, communications and contacts from regulators. If
entities to launder money through DTCC’s products or services. contacted directly by a regulator or other government official,
All staff is trained on general corporate red flags and some coordinate with Regulatory Relations, local Compliance officers or
departments are provided additional training on specialized red Government Relations.
flags, specific to their roles.
DTCC CODE OF CONDUCT | 7PROTECT
CONFIDENTIAL
INFORMATION
| 8 DTCC CODE OF CONDUCTCLIENT CONFIDENTIAL INFORMATION PERSONALLY IDENTIFIABLE INFORMATION
DTCC is entrusted with confidential, competitively valuable, In the course of providing services to clients, DTCC may also
restricted, and proprietary information about its clients (Client collect, store and process Personally Identifiable Information
Confidential Information), including business transactions, (“PII”). PII, as used within DTCC, refers to information that
trade data, or market positions of any person and trade secrets can be used on its own or combined with other information to
or names of clients. identify an individual.
Additionally, your role at DTCC may allow you to have access to You must take appropriate measures to use and safeguard
material, non-public information (MNPI) and may not trade on any such information in accordance with applicable laws,
the basis of this MNPI, or allow others to do so. rules and regulations. In addition, you must comply with
the DTCC Global Privacy Policy, designed to address the
You must follow the DTCC Employee Personal Investment
appropriate collection, use, distribution and storage of PII.
Policy, as you may be required to disclose personal investment
accounts, held solely or with another individual, as well as those You may only use or share PII for a legitimate business purpose and
that are held by members of your household. may not access, use or otherwise misappropriate PII for personal
benefit, or for the benefit of anyone else other than as part of DTCC
In addition, you must comply with the DTCC Technology
business operations. This includes the use of PII to solicit any of
Usage Policy, which governs the use of the Internet, email
DTCC’s former, current or prospective clients or employees or in any
and other electronic communications through DTCC’s Systems
other manner adverse to the interests of DTCC.
and Facilities.
REPORTING AND ESCALATION
Report all suspected or confirmed breaches or
inadvertent access of Client Confidential Information
or PII immediately to the Technology Risk Management
mailbox at TVA@dtcc.com or by calling (212) 855-1810.
Incidents involving PII will be escalated to the Privacy
Office. The Privacy Office will be responsible for
assessing all reported matters in accordance with
applicable jurisdictional requirements to determine if
client and/or regulatory notifications are required.
DTCC CODE OF CONDUCT | 9PROTECT AND
APPROPRIATE
USE OF DTCC’S
ASSETS
| 10 DTCC CODE OF CONDUCTINFORMATION SYSTEMS AND ELECTRONIC COMMUNICATIONS
COMMUNICATIONS FACILITIES Clients’ privacy must be secured by complying with all
information security policies and procedures, including the DTCC
Periodically, managers are required to recertify that their
Technology Usage Policy. You are prohibited from sending any
contingent workers’ systems permissions are only for access to
information from your DTCC account to any web mail address,
systems required to perform their functions.
instant messaging (IM), or other internet account that is not
Contingent workers must diligently protect DTCC’s information provided by DTCC. All DTCC business communications must
systems and communications facilities that they have be sent using DTCC-supplied devices or approved applications,
access to, to prevent data leakage, unauthorized access or and any Client Confidential Information that is sent to clients
systems infiltration. Contingent workers are also required to via email should be encrypted and double-checked for
familiarize themselves with, and adhere to, DTCC’s information appropriateness.
classification system, in accordance with the confidentiality of
the material, as per the DTCC Information Asset Security Policy DTCC’s systems and facilities, and all internal and external
and Standards. messages, information and content accessed, viewed, created,
sent, downloaded, uploaded, stored, forwarded, transmitted
Contingent workers must keep all passwords to DTCC systems or received on or through them, are considered the property of
confidential and in accordance with DTCC’s password management DTCC, and DTCC reserves the right to access, inspect, monitor,
policies with regards to length and composition. Contingent delete, disclose and record such information and materials at
workers must not disclose passwords to anyone, including other its discretion. This includes, for example, your personal use of
staff, a member of the Helpdesk or IT. Furthermore, computers the Internet and use of your personal password-protected email
should be locked with a password when employees are not at their account and other online accounts accessed using the systems
desk. and facilities.
DTCC monitors its systems and facilities to protect its legitimate
business purposes, to detect violations of company policy, and INTELLECTUAL PROPERTY
where required for legal and regulatory obligations. Contingent You may only use intellectual property made available by DTCC for
workers are prohibited from using DTCC’s systems and facilities approved purposes and in accordance with applicable licenses,
to download, save and/or install unauthorized materials, such as terms and conditions, and laws.
software, applications and movies from the Internet that have not
been approved or authorized by Technology Risk Management. Discoveries, developments, improvements, works of authorship,
designs, know-how, concepts, ideas, processes and data and
information, regardless of form, that you develop alone, or
with others, during the course of and in connection with your
PROTECT AGAINST CYBER-ATTACKS engagement with DTCC (collectively, “Inventions”) must be
promptly disclosed and will be owned exclusively by DTCC. In
You can protect DTCC against cyber attacks by being alert addition, any intellectual property created prior to or outside of
for suspicious messages- including email, instant message, your engagement with DTCC must be disclosed if such intellectual
text or voice- as well as suspicious attachments, links and property is incorporated into any Invention.
web pages that may contain malware or viruses. Contingent
workers have a responsibility to identify and report any As a condition of your employment with DTCC, you assign all
suspicious emails to Technology Risk Management. rights, title and interest in the Inventions exclusively to DTCC, and
will provide all assistance necessary to secure intellectual property
You should use the “Report Phishing PhishMe”
rights for any and all Inventions developed.
Outlook task bar icon, the TVA@dtcc.com mailbox
or call +1-212-855-1810 to TRM upon receipt of Inventions may not be used externally or described in any
any such message. publication without express written permission from the Legal
Department. Should your employment with DTCC terminate
for any reason, all rights in the Inventions remain the exclusive
property of DTCC.
DTCC CODE OF CONDUCT | 11SOCIAL MEDIA POLICY
Our public image is very important in maintaining industry SOCIAL MEDIA POLICY
confidence and protecting the health of our company, including
when representing or referring to DTCC on social media. As per the DTCC Social Media Policy, when using DTCC
Systems and Facilities, engaging in social media as an
MAINTAIN ACCURATE BOOKS AND RECORDS official representative of DTCC, identifying yourself as
being employed by DTCC, or using social media activities
Our books and records must accurately and fairly reflect and
that may reference DTCC, you must be mindful not to:
describe all transactions. You may not knowingly make or
facilitate any misleading entries in DTCC’s systems of record or ■■ Disseminate DTCC Restricted (Red) or DTCC
in any supporting documents. For example, if you are required Confidential (Yellow) information outside of DTCC
to track your time at DTCC, you must accurately report your
■■ Violate any privacy, copyright, trademark, or
activity.
confidentiality laws
So that DTCC is complying with international legal and ■■ Provide any references or recommendations
regulatory requirements while limiting its legal risk, all concerning current and former employees
employees must also retain, retrieve, and dispose of electronic
■■ Be disrespectful towards co-workers, clients, vendors,
and hard copy records in accordance with the DTCC Global
members of the public, and other DTCC associates
Records Management Policy.
■■ Post sexually explicit, abusive, racist, defamatory, or
threatening messages or materials
MEDIA REQUESTS
You may not accept speaking engagements on behalf
of DTCC without prior approvals from your manager.
Requests for information from the media should
be directed to Marketing & Communications at
MarketingCommunications@dtcc.com
| 12 DTCC CODE OF CONDUCTPROTECTION AND
FAIR TREATMENT
OF CONTINGENT
WORKERS AND
OUR COMMUNITIES
| 13 DTCC CODE OF CONDUCT DTCC CODE OF CONDUCT | 13WE HARNESS THE POWER OF INCLUSION AND EMBRACE THE SIMILARITIES AND
DIFFERENCES IN OUR GLOBAL WORKFORCE TO SHAPE OUR ABILITY TO INNOVATE,
CREATE AND CONTINUOUSLY EVOLVE.
PERSONAL INTEGRITY DISCRIMINATION AND ANTI-HARASSMENT
You are responsible for the accuracy of any personal information At DTCC, You have the right to work in a professional atmosphere
you provide DTCC, both during the hiring process and that promotes equal employment opportunities and prohibits
throughout the course of your employment with DTCC. This discriminatory practices. We treat individuals fairly with respect
includes: to hiring, terms and conditions of employment, promotions,
training, disciplinary and grievance procedures and termination of
■■ Representations about education history
employment without regard to any characteristics protected by any
■■ Work experience history applicable law.
■■ Criminal history
We require all relationships among persons in the workplace
■■ Benefit plans to be businesslike and free of bias, prejudice and harassment.
■■ Outside business interests Reference the DTCC Equal Employment Non- Discrimination and
Anti-Harassment Policy for more information.
■■ Personal and familial investment accounts
If you are either arrested or charged with a crime, the subject of DIVERSITY AND INCLUSION
any regulatory investigation or proceeding, receive a subpoena
DTCC is committed to employing a workforce that reflects the
or other governmental inquiry, or involved in civil litigation
diversity in our markets, and one that understands and appreciates
relating to your position with DTCC, you must give prompt
the global client base with which we do business. At DTCC we
written notice to the Legal Department.
harness the full array of talent, ideas and attributes offered by our
global workforce to discover increasingly better ways to deliver for
our clients. Our approach is to fully integrate D&I into all aspects
of the DTCC community by fostering an environment where
MANAGER OBLIGATIONS everyone is valued, respected, and feels that they can play an
active part in the company’s success.
Managers should cultivate a working environment that
supports openness, candor and trust. If a manager We recognize that diversity and inclusion is core to who we
receives any reports of a potential DTCC Code of Conduct are and key to our business success. We harness the power
violation, they should immediately escalate the issue of inclusion and embrace the similarities and differences in
to Legal, Compliance, Global Security Management or our global workforce to shape our ability to innovate, create
Human Resources for further investigation. and continuously evolve – all of which enable us to secure the
financial services industry for today and shape it for tomorrow.
| 14 DTCC CODE OF CONDUCTSOLICITATION PERSONAL RELATIONSHIPS
Any form of solicitation during working hours is prohibited Although consensual relationships are a matter of personal choice
except as referenced in the Collective Bargaining Agreement. and privacy between the individuals involved, DTCC will exercise
Includes: sound judgment as it relates to any actual or perceived conflicts
of interest. Consensual relationships between a manager and a
■■ Distributing literature for personal causes via email or in
subordinate are contrary to the best interests of DTCC and are
person, or on bulletin boards
strongly discouraged.
■■ Soliciting employees to participate in sports pools, games of
If a romantic relationship between a manager and subordinate
chance or other similar activities
develops, or where these is any actual or perceived conflict
■■ Soliciting funds or other items of value for charity or any
of interest, it is the responsibility of each person to promptly
other purpose, except for charities and charitable events
disclose the existence of the relationship to the department
approved by Corporate Social Responsibity (CSR)
Senior Management.
If an employee or contingent worker believes that he or she
SOCIAL RESPONSIBILITY
has been adversely affected by such a relationship, they are
CARE, CONNECT, CULTIVATE encouraged to consult with their Human Resources Business
At DTCC, we give back to the community to build a better Partner or Employee Relations.
society and help shape the future of communities where we
live and work. This is driven by our character as a company and
our commitment to do more. We work to expand our impact on
WORKPLACE SAFETY
improving the communities in which DTCC operates through You should report to Global Security Management any threats
funding, partnerships and employee-directed initiatives. or perceived threats that you have witnessed, received, or have
been told that another person has witnessed or received. You
To learn more about our CSR program, review the Global
should also report any behavior you have witnessed which you
Charitable Donations Policy or contact the CSR office
regard as intimidating, threatening, or violent or believe that
at csr@dtcc.com.
the behavior of concern might be, or could be, carried out on a
company-controlled site or is connected to company business.
Any person, who makes threats, exhibits threatening behavior,
or engages in intimidating, threatening, or violent acts on DTCC
OUR CORPORATE SOCIAL RESPONSIBILITY INITIATIVES ALIGN TO: property or at DTCC sponsored events will be removed from
the premises by DTCC Global Security Management or Law
■■ Education – Expand access to STEM training and
Enforcement as quickly as safety permits, and should remain off
education, to increase diverse pool of talent ready for
DTCC premises pending the outcome of an investigation.
a career in financial services
■■ Economic development – Improve the communities
where DTCC operates through partnerships and
engagement
■■ Environmental Sustainability – Ensure our internal
operations such as power usage, recycling, etc. are
set up in a sustainable manner, and ensure that our
vendors also follow these sustainability principles
DTCC CODE OF CONDUCT | 15WHO TO CONTACT FOR HELP
AS A CONTINGENT WORKER, YOUR COMMITMENT TO THIS CODE IS ESSENTIAL. DTCC’S COMPLIANCE WITH
LAWS, REGULATIONS AND ETHICAL STANDARDS IS A SHARED RESPONSIBILITY BY ALL EMPLOYEES AND
CONTINGENT WORKERS.
You may report any potential violation of this Code by calling the Ethics Hotline (anonymously), a member of Compliance, or
one of the following contacts and reporting methods as applicable. Additionally, any conduct concerns may be brought to the
attention of your Human Resources Business Partner for remediation.
FOR POTENTIAL CODE OF CONDUCT VIOLATIONS, FOR AML ISSUES
please contact the following, 24 hours a day, seven days a week: to report potentially suspicious activities, please contact:
+1-844-815-4396 DTCCcompliancehotline@dtcc.com
MyComplianceReport.com Or, report using the “Think It’s Suspicious? Report It!” link on
the DTCC Intranet.
Acess Code: DTCC
If you are located outside the United States, refer to DTCC FOR GLOBAL SECURITY MANAGEMENT
GLOBAL ETHICS HOTLINE section below for access codes in please contact the following, 24 hours a day, 7 days a week:
your country or territory.
77-7777 (ON-SITE)
FOR GENERAL COMPLIANCE QUESTIONS, +1-212-855-8200 (OFF-SITE)
please contact the following:
INFORMATION SECURITY - TECHNOLOGY RISK
+1-212-855-8030 MANAGEMENT:
DTCCcompliancehotline@dtcc.com
+1-212-855-1810
FOR GIFTS, ENTERTAINMENT, AND CONFLICTS OF INTEREST tva@dtcc.com
QUESTIONS OR REPORTING, please contact the following:
PRIVACY OFFICE: privacyoffice@dtcc.com
+1-212-855-8030
Gifts, Entertainment, and Conflicts System REGULATORY RELATIONS: regulatoryrelations@dtcc.com
FOR EMPLOYEE PERSONAL TRADING QUESTIONS OR
DISCLOSURES, please contact
+1-212-855-8030
MyComplianceOffice Portal
| 16 DTCC CODE OF CONDUCTKEY POLICIES AND PROCEDURES
Note: You can find all corporate Policies and Procedures on the Enterprise Policy Repository within the DTCC Intranet.
ANTI-MONEY LAUNDERING INFORMATION PROTECTION AND PRIVACY
DTCC AML Policy DTCC Global Privacy Policy
DTC AML Program DTCC Information Security Program
ANTI-BRIBERY AND CORRUPTION Information Asset Security Policy and Standards
DTCC Employee FAQs on the Prevention of Bribery
LOBBYING/POLITICAL CONTRIBUTIONS
DTCC Lobbying Policy and Procedures
EMPLOYEE ESCALATION
DTCC Employee Escalation and Internal Investigation
DTCC Political Action Committee Policy and Procedures
Procedures
MEDIA/COMMUNICATIONS
GIFTS, ENTERTAINMENT, AND CONFLICTS DTCC Social Media Policy
OF INTEREST
DTCC Global Travel and Expense Reimbursement Policy RECORDS MANAGEMENT
DTCC Global Records Management Policy
DTCC Gifts, Entertainment and Conflicts of Interest Policy
DDR Code of Conduct SANCTIONS
DTCC Global Sanctions Policy
DDRJ Code of Conduct
DTCC Global Sanctions Procedures for Business Units
DDR Conflict of Interest Resolution Policy
TECHNOLOGY USAGE
DDRJ Conflict of Interest Resolution Policy
DTCC Technology Usage Policy
DDRL Conflict of Interest Policy
DDRS Conflict of Interest Resolution Policy
HUMAN RESOURCES
DTCC Equal Employment Non-Discrimination and
Anti-Harassment Policy
Global Charitable Donations Policy
DTCC CODE OF CONDUCT | 17DTCC GLOBAL ETHICS HOTLINE
ALL DTCC STAFF MEMBERS MAY ALSO REPORT ANONYMOUSLY VIA COMPLIANCE LINE’S WEBSITE:
MYCOMPLIANCEREPORT.COM ACCESS CODE: DTCC
FOR USA
Please Dial (using mobile or land-line) 844-815-4396
Step 1 Dial 844-815-4396
Step 2 Automated voice will come on that the line is owned by
ComplianceLine, Inc.
FOR INTERNATIONAL NUMBERS
Step 1 Locate your country from the list below and dial the
appropriate number using mobile or land-line.
Step 2 Wait for second dial tone or Listen to the international
operator’s (when he/she comes in) instruction – “dial the
number you are calling”.
Step 3 Dial 844-815-4396
Step 4 Automated voice will come on that the line is owned by
ComplianceLine, Inc.
EUROPE
Czech Republic Please Dial 00-800-222-55288
France (Hotels 1), Please Dial 0-800-99-1011
(Hotels 2), Please Dial 0-800-99-1111
(Hotels 3), Please Dial 0-800-99-1211
(Hotels Paris Only), Please Dial 0-800-99-0111
Germany Please Dial 0-800-225-5288
Ireland Please Dial 1-800-550-000
For Ireland (UIFN), Please Dial 00-800-222-55288
Sweden Please Dial 020-799-111
United Kingdom (British Telecom), Please Dial 0-800-89-0011
(C&W), Please Dial 0-500-89-0011
| 18 DTCC CODE OF CONDUCTDTCC GLOBAL ETHICS/WORKPLACE SAFETY HOTLINE
ALL DTCC STAFF MEMBERS MAY ALSO REPORT ANONYMOUSLY VIA COMPLIANCE LINE’S WEBSITE:
MYCOMPLIANCEREPORT.COM ACCESS CODE: DTCC
APAC
Australia (Telstra), Please Dial 1-800-881-011
(Optus), Please Dial 1-800-551-155
China (South, Shanghai - CT), Please Dial 10-811
(North, Beijing CNCG), Please Dial 108-888
(China Telecom Mandarin speaking Intl Operator), Please Dial 108-10
(North, Beijing CNCG Mandarin speaking Intl Operator), Please Dial 108-710
Hong Kong (Hong Kong Telephone), Please Dial 800-96-1111
(New World Telephone), Please Dial 800-93-2266
India Please dial 000-117
Japan (KDDI), Please Dial 00-539-111
(Softbank Telecom), Please Dial 00-663-5111
(NTT), Please Dial 0034-811-001
Korea (Korea Telecom) Please Dial 00-729-11
(US M.B. Korea Telecom), Please Dial 550-HOME
(ONSE), Please Dial 00-369-11
(Dacom), Please Dial 00-309-11
(US M.B. Dacom), Please Dial 550-2USA
Philippines (PLDT), Please Dial 1010-5511-00
(PLDT Tagalog speaking Intl operator), Please Dial 1010-5511-00
(2nd Option), Please Dial 105-11
(Globe), Please Dial 105-11
(Globe Tagalog speaking Intl Operator), Please Dial 105-12
(Philcom), Please Dial 105-11
(Philcom Tagalog speaking Intl Operator), Please Dial 105-12
(Digitel), Please Dial 105-11
Singapore (SingTel), Please Dial 800-011-1111
(StarHub), Please Dial 800-001-0001
13797-TC012418
DTCC CODE OF CONDUCT | 19visit dtcc.com | 20 DTCC CODE OF CONDUCT
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