Whistleblower Program
At Wealthsimple, we want to help our clients reach financial freedom no matter who they are or how much money they have. While pursuing our business goals is a vital part of what we do, integrity, ethics and responsibility shape our practices. We understand that our business decisions directly affect our clients, stakeholders and the community in which we operate and we are committed to doing things the right way.
To meet this commitment, we have put in place an anonymous and confidential reporting process through which any employee or individual acting in good faith can report a concern or complaint about our business activities or behaviours that may contradict any of our values or jeopardize our integrity and reputation.
How to Report
You can submit a report via our online portal, these reports are processed through an independent third-party, 24/7.
Reports can be submitted anonymously by anyone who chooses to do so. All steps will be taken by Wealthsimple to protect the identity of anyone who submits a report anonymously. We believe that it is important to create accessible, confidential, and reliable channels for reporting wrongdoing, and to protect whistleblowers acting in good faith from all forms of retaliation.
For more information, please read our Whistleblower Policy below.
Whistleblower Policy
Last updated: July 2024
1. Purpose and Scope
At Wealthsimple, we are committed to conducting business with honesty and integrity, and to upholding each of our core values, applicable laws, rules and regulations. This commitment applies equally to all employees, officers, and directors of the company.
Despite this commitment, intentional and unintentional violations may still occur. When these violations do occur, Wealthsimple has a responsibility to investigate and, where appropriate, to report these violations to regulatory and legal authorities. Therefore, speaking up is encouraged. No one should have any fears about raising concerns truthfully and in good faith based on their reasonable beliefs, even if they are later found to be mistaken.
This whistleblowing policy (the Policy) is designed to protect the integrity of Wealthsimple and to help ensure compliance with our legal and ethical requirements. We believe that it is important to create accessible, confidential, and reliable channels for reporting wrongdoing, and that protecting whistleblowers from all forms of retaliation helps protect Wealthsimple by providing a channel for identifying and addressing wrongdoing that may otherwise go undetected.
This Policy includes the process & procedures for:
reporting actual and suspected violations of laws, audit and accounting standards and practices and other matters (see: What is Reportable Conduct?)
receiving, retaining and responding to complaints received by Wealthsimple about accounting and/or audit matters.
the confidential, anonymous submission of concerns regarding questionable accounting or auditing matters established by the Audit and Risk Committee (the Audit Committee), which is a committee of the Board of Wealthsimple.
The Audit Committee oversees management’s monitoring of compliance with the Wealthsimple Code of Ethics and the administration of this Policy.
2. What is Reportable Conduct?
Individuals may make reports relating to any issue of concern, including but not limited to:
a. questionable accounting, internal accounting controls and auditing matters including
the circumvention or attempted circumvention of internal accounting controls or document retention policies
misinterpretation of applicable standards or guidelines
falsification of statements, records or other financial information
or any other behaviour that violates Wealthsimple’s accounting policies;
b. any matter that threatens the health or safety of other members of the Wealthsimple team and/or the general public;
c. any circumstance where a employee, director, or business partner believes that he or she is being asked to commit a wrongdoing; or
d. any other actual, potential or suspected violation of the law.
3. How do I Make a Report?
3.1 General
Any individual, acting truthfully and in good faith, may make a report to the Audit Committee, by going to the Confidential Designee or the Delegate. The “Confidential Designee” is a designated person that assists with responding to reports filed under the Whistleblowing Policy. The “Delegate” is a person authorized by the Confidential Designee to act on its behalf and perform all of its obligations as “Confidential Designee”. The Confidential Designee, and the Delegate, if applicable, will always be independent of Wealthsimple’s financial reporting function and, unless the Audit Committee designates another person, the Confidential Designee will also be Wealthsimple’s Chief Legal Officer.
Before making a report, the filer should consider discussing the matter with their direct supervisor or another person who may be able to help. In cases where this discussion cannot be had or does not resolve the matter, or where the issue is time sensitive, the report should be submitted directly to the Confidential Designee or the Delegate, if applicable. In addition, it must be emphasized that none of Wealthsimple’s agreements, policies, or procedures require employees to obtain consent or provide internal notification prior to reporting information to applicable regulatory authorities (e.g. the Ontario Securities Commission), a recognized self-regulatory organization or a law enforcement agency. Further, none of Wealthsimple’s employment and non-disclosure agreements prohibit employees from making a disclosure, assisting in an investigation or proceeding by the above-mentioned entities, or expressing an intention to do so. Disclosure to regulatory authorities, SROs or law enforcement is voluntary, and not limited to matters where disclosure is required by law.
Individuals at Wealthsimple who are part of a regulated profession (ie. accounting, law, and investments) may also seek guidance from their professional bodies, so long as they can maintain their obligations of confidentiality to Wealthsimple. The individual should consult with the Confidential Designee or Delegate, if applicable, in the event of a conflict between the guidance from their professional body and Wealthsimple policies and procedures.
3.2 Anonymous Reports
Reports can be submitted anonymously by anyone who chooses to do so. All steps will be taken by Wealthsimple to protect the identity of anyone who submits a report anonymously.
However, in some cases the source or nature of the report, or the steps required to investigate (see: 5. Treatment and Investigation of Reports – Investigating Reports) may make it difficult or impossible to maintain this anonymity.
3.3 Submitting a Report
The individual submitting the report should include as much detail as possible including dates, people or witnesses involved and any supporting material or evidence that may be relevant.
You can submit a report via our online portal, these reports are processed through an independent third-party, 24/7.
4. Receipt of Reports by Others
If you receive a report that has been made under the Policy in any form, it must be immediately forwarded to the Audit Committee by sending it to the Confidential Designee or Delegate, if applicable. This includes reports made by email and voicemail.
If a formal report is made to you orally, you are required to prepare a summary of the report and to forward that report to the Audit Committee by sending it to the Confidential Designee or Delegate, if applicable. Important: If the report has been made to you anonymously, you must state that in your summary.
The Confidential Designee or Delegate, if applicable, must review all reports promptly and will advise the Audit Committee (and, at their discretion, the CEO and/or CFO) immediately or at the next scheduled meeting of the Audit Committee.
5. Treatment and Investigation of Reports
5.1 Confidentiality
All Reports will be treated as confidential, whether or not made anonymously, and reports will only be accessible to people who need to know (as determined by the Confidential Designee or Delegate, if applicable). This may include individuals who need to investigate or to take remedial or disciplinary action on the basis of the information contained in the report.
Unless the report has been made anonymously, the Confidential Designee or Delegate, if applicable, will let the person who made the report know when it has been received and when the investigation (if any) has been completed.
The person who made the report will not be advised of the results of the investigation (if any) unless the Audit Committee determines otherwise.
5.2 Investigating Reports
The Confidential Designee or Delegate, if applicable, is responsible for assessing and evaluating reports and for conducting investigations, unless the Audit Committee determines otherwise. In determining whether a report should be investigated and what the extent of the investigation should be, the Confidential Designee or Delegate, if applicable, will consider the following factors (among others):
(a) Who is the alleged wrongdoer? If a member of management is alleged to have been involved, that factor alone may influence the decision in favour of conducting an investigation;
(b) What is the nature of the matter being reported? Depending on the nature of the allegation the core investigation team should include a management representative from People Operations, Finance and other departments, as necessary, depending on their area of oversight and expertise (for example, health and safety);
(c) How serious is the report? The more serious the allegation made in the report, the more appropriate it would be to investigate. For example, if the allegation would affect the integrity of the financial statements of Wealthsimple, that factor alone may influence the decision in favour of conducting the investigation; and
(d) How credible is the allegation? The more credible the allegation made in the report, the more appropriate it may be to undertake the investigation. In assessing credibility, all facts surrounding the allegation should be considered.
All employees, officers, directors and business partners have an obligation to cooperate with all investigations initiated by the Confidential Designee or Delegate, if applicable. At any time during the investigation of a report, the Confidential Designee or Delegate, if applicable, may notify the CEO, COO, CFO, or any other party it deems necessary (for example, Wealthsimple’s external auditors) about the submission of the report or about the progress of the investigation. However, in the course of providing this information to relevant parties, the Confidential Designee or Delegate, if applicable, will ensure that the the report is kept confidential and anonymous. The Audit Committee may engage independent advisors at the expense of Wealthsimple to assist the Confidential Designee or Delegate, if applicable, to undertake investigations and/or recommend appropriate action.
During the investigation of a report, the Audit Committee may determine that it’s in the best interest of the subject of an investigation, another involved person, or any other person at Wealthsimple (or any combination of the above) to be put on administrative or investigatory leave (or another similar arrangement). It’s important to note that a leave of this nature should not be interpreted as an accusation or a conclusion of guilt or innocence of any person, including the person on leave.
Individuals on leave will be informed of the completion of an investigation. Those who are investigated will be given an opportunity to be heard prior to any disciplinary action being taken against them. If a report indicates that illegal activity or a regulatory breach has occurred, the Confidential Designee or Delegate, if applicable (in consultation with and on behalf of the Audit Committee) may make a report to the police or other law enforcement or regulatory agency, as appropriate.
5.3 Remedial Action
If the Confidential Designee or Delegate, if applicable, determines that the report was made truthfully and in good faith and related to reportable conduct that happened or was going to happen, the Confidential Designee or Delegate, if applicable, will report to the Audit Committee immediately, if necessary, or otherwise at the next scheduled meeting of the Audit Committee as described under the heading “Records Relating to Reports”. Their report will include the remedial actions taken or proposed to be taken (if any).
The Audit Committee will report to the Board in respect of such matters. In the event that a report involves a complaint against the Audit Committee, the Board will retain independent advisors to solicit their view on the appropriate remedial action.
6. Protection of Whistleblowers
The Confidential Designee, or Delegate, if applicable, the Audit Committee and any persons involved in or retained to assist in an investigation of a report must take all reasonable steps to not reveal the identity of any person who files a report anonymously, unless required to do so by law.
Additionally, we will not permit any discharge, demotion, suspension, threats, harassment, intimidation, embarrassment or any other form of discrimination by any person or group, directly or indirectly, against any employee, officer, director, or business partner who, truthfully and in good faith:
(a) filed a report about a reportable conduct;
(b) lawfully provided information or assistance in an investigation regarding any conduct which the representative or business partner reasonably believes constitutes a violation of applicable laws;
(c) filed, caused to be filed, testified, participated in or otherwise assisted in a proceeding related to a violation of applicable laws;
(d) provided a regulator or law enforcement officer with truthful information regarding the commission or possible commission of an offence, unless the individual reporting is one of the violators; or
(e) provided assistance to the Confidential Designee or Delegate, if applicable, the Audit Committee, management or any other person or group in the investigation of a report.
Any retaliation against such a person who has taken an action outlined above, will be subject to disciplinary action, which may include dismissal.
However, it must also be emphasized that employees, officers, directors and business partners are protected from accusations that are frivolous or malicious, such as allegations made in bad faith or to pursue a personal grudge.
7. Records Relating to Reports
The Confidential Designee, or Delegate, if applicable, will maintain a log of all reports, tracking how and when each report was received, the nature and results of any investigation and the resolution of the matter. A quarterly summary of reports received, under investigation and resolved within the preceding quarter shall be reported to the Audit Committee by the Confidential Designee or Delegate, if applicable. The Audit Committee will report to the Board where it determines a report is necessary or appropriate following its receipt and consideration of such summary of Reports received, and the Audit Committee may report at such other times as it may determine.
Records pertaining to a report are the property of Wealthsimple and will be retained in accordance with Wealthsimple’s record retention policies.
8. Questions
Any questions concerning the Whistleblowing Policy should be directed to the Chief Legal Officer or to the Chair of the Audit Committee.