Chief Compliance Officer and Vice President

**Chief Compliance Officer/ Vice President, Compliance**

The Chief Compliance Officer (“CCO”) reports directly to the Governance and Review Conduct Committee (“GCRC”) and the Board of directors with an administrative reporting line to the CEO and coordinates all of the Bank’s compliance activities. The Chief Compliance Officer ensures that key day-to-day Regulatory Compliance Management (“RCM”) controls throughout the enterprise are sufficiently robust to achieve compliance with all the applicable regulatory requirements enterprise-wide and, where significant issues arise, escalates them to Senior Management and the Board as appropriate. The function should be independent of the activities it oversees and capable of providing Senior Management and the Board with information including objective opinions and advice they need to fulfill their oversight functions. The Chief Compliance Officer is also responsible for the AML/ATF Compliance Management and Privacy Compliance Management.

**Key Responsibilities & Accountabilities**
- Build a Compliance function and department that drives a compliance culture and

supports an enterprise wide risk mindset and audit ready environment
- Build and effectively execute a comprehensive RCM framework that includes policies,

procedures, roles, responsibilities, ensuring an enterprise wide implementation of

program and practices
- Ensure adequacy of policies and practices and ensure that the organization is

operating in accordance with applicable laws and regulations
- Develop and implement procedures where issues are identified, risk assessed and

tracked to remediation with detailed action plans, and timelines for successful

resolution
- Stay abreast of new and changing legislation and to document new or amended

compliance policies and communicate them across the institution on a timely basis
- Assign responsibility for each compliance element to designated officers within the

relevant areas of the Bank and oversee;
- Make sure adequacy of the function’s resources and appropriateness of its collective

qualifications and competencies for executing its mandate
- Identify and assess inherent compliance risks associated with the Bank’s business

activities including in support of the development of new products and business

practices or proposed establishment of new businesses
- Responsible for the enterprise-wide implementation and oversight of the Bank’s anti
- money laundering and anti-terrorist financing program compliance with the PCMLTFA

and the associated regulations
- Oversight of AML/ATF control activity in all relevant business areas for the purpose of

establishing a reasonable threshold level of control consistency throughout the Bank
- Keep the AML program current relative to the Bank’s identified inherent risks

(customers and business relationships, products and delivery channels, geographic

locations of activity and any other relevant factors); overseeing the development,

implementation, and documentation
- Ensure an inherent risk analysis of any new products/services, and identifying

appropriate measures to mitigate associated risks
- Monitor business activities, including outsourced activities, to confirm compliance

with anti-money laundering and anti-terrorist financing requirements
- Communicate with stakeholders to ensure that appropriate action is taken as required,

such as ensuring that internal audit is aware of the requirement in the PCMLTFR for

effectiveness testing of the AML program every two years
- Performing oversight on the adherence of the control standards and requirements

under the Privacy Policy and procedure for both internal and external stakeholders

potential privacy risks
- Ensure that all regulatory requirements have been met and have been delivered to the

appropriate regulatory body in a timely manner
- Report quarterly to the Board of Directors and GCRC Committee on the status of the

Bank’s compliance with its governing statute, regulations and OSFI guidelines;
detection of a privacy breach incident to provide an objective view on privacy risk

management and risk taking activities
- Report to Senior Management and the Board on the AML program adequacy and

effectiveness along with any other related issues driving a compliance culture
- Provide leadership to a best-in-class team (hiring, developing, retaining), ensuring that

the team members have the requisite skills, knowledge and performance to deliver an

effective compliance function
- Ensure continuing professional development programs in place to enhance senior

management, employees and other persons authorized to act on the Bank’s behalf
- Liaise with relevant external regulatory bodies, auditors, and other government

agencies

expertise, accountability and collaboration that drive a positive workplace culture
- Comply with or operate in accordance with applicable laws, regulations, and

prescribed practices relating to its bankin