Market Code of Conduct 

L.I.U.N.A. Local 183 Credit Union (The Credit Union) aspires to make fair treatment a core principle of all our business practices. It is a hallmark of our corporate culture and demonstrated in the dedication of our leadership, governance, and employees.

Our culture is based on making strategic decisions in the best interests of our members. All our employees are expected to support this culture by treating everyone who comes into the credit union — and one another — fairly and with respect. Fairness is a fundamental right of every individual we serve.

Ensuring this culture is implemented and maintained is the responsibility of our Board of Directors, which is elected by our membership. The credit union sets fair treatment policies and procedures, and it is the responsibility of senior management to report to the Board on matters of adherence to the principles with the code.

Fair treatment also applies to how we manage personal information. Everyone has a right to expect their financial affairs will be handled with discretion. We collect, use, and disclose all personal information strictly in accordance with provincial and federal legislation. Our commitment to the fair treatment of all individuals is a key responsibility.

Governance and Accountability

• The Board of directors has implemented a Market Code of Conduct Policy which took effect in February 2023
• The appointment of the supervising Board member, who is responsible for the adherence to the code.
• The annual completion of the Market Code of Conduct attestation by the CEO and its submission to the audit committee

Reporting to the Board

Annually, the Market Code of Conduct supervising Board member will be responsible for reporting to the Board on the L.I.U.N.A. Local 183 Credit Union’s adherence to the principles in this code, including the results of L.I.U.N.A. Local 183 Credit Union’s annual self-assessment, and necessary action taken to remedy deficiencies noted in the report.

Protection of personal information

As set in our existing policies, Corporate Governance, Operational Risk Policy, Cyber Security IT Framework and Privacy Policy, we adhere by the importance of safeguarding, collecting, using and disclosing members personal information as set out in the PIPEDA Act.

The Credit Union collaborates with partners, contractors and third-party providers for digital financial transactions which adhere to the cyber security frameworks informed by the international or national industry standards or guidelines in accordance with the G-7 Fundamental Elements of Cyber Security for the Financial Sector. (“G7FE”)

Financial well-being and literacy

L.I.U.N.A. Local 183 Credit Union values and supports the financial well-being and financial literacy of all members of our community. Information and guidance on the topics for the following are available in branch and on our website.

• How to utilize mobile and online banking safely and securely.
• Fraud prevention
• What you need to know (AML)
• Member Awareness

Whistleblowing

As set out in the existing L.I.U.N.A. Local 183 Credit Union’s Market Code of Conduct policy definitive procedures are in place and provide a channel through which whistle blowers can report suspected unethical conduct in anonymity, and without the fear of reprisal or unwarranted negative consequences, while respecting the rights of those about whom concerns are raised. Employees will be protected, to the extent possible under the circumstances, as set out in L.I.U.N.A. Local 183 Credit Union’s procedures.

L.I.U.N.A. Local 183 Credit Union’s Board of Directors will be responsible for the annual review, approval, and maintenance of said Whistle Blowing Policies and Procedures and L.I.U.N.A. Local 183 Credit Union Management will be responsible for the management, monitoring, and control of operations.

Lobbying

Like any other business or association, we enjoy the freedom — and the responsibility — to interact with governments and comment on policy, legislation, or regulations. We do not employ lobbyists, instead we will support the lobbying efforts of the Canadian Credit Union Association.

Fair Treatment

The credit union treats all individuals who use our services fairly, and we demonstrate fair sales practices in all our business relationships. We will not discriminate against any of our members, or anyone considering using our services. We abide diligently by provincial human rights codes. We make exceptions only when justified by law, or if a special product or service is designed to serve a particular group.

We never take advantage of anyone by misrepresenting facts, concealing information, or engaging in manipulation, unfair dealings, or unethical activities. We do not take advantage of people, and we take extra care to be clear and comprehensive with those who are unable to protect their own interests or who are only just familiarizing themselves with how we operate.

Conflicts of Interest

Where conflicting interests compete with the L.I.U.N.A. Local 183 Credit Union’s duty of care owed to Members, risks may be created. The credit union takes all reasonable steps to identify, and avoid or manage, conflicts of interest.

As set out in L.I.U.N.A. Local 183 Credit Union’s Human Resources Policy, the credit union will ensure conflicts of interest are addressed and appropriately dealt with.

Debt Collection

L.I.U.N.A. Local 183 Credit Union does not use threatening, intimidating or abusive language, or apply excessive or unreasonable pressure to repay against any borrower of the credit union, including the use of any false statement, any unfair practice, or harassment.

The credit union will determine when a debt has been deemed uncollectable at the branch level, at which time the account may be referred to a third party for collection following board approval.

Fair Sales

Everyone who uses the credit union has access to accurate information to help them choose the most affordable and appropriate product or service. Our advertising, marketing materials, and communications are straightforward, accurate, and easy to understand. We provide information that helps ensure that individuals considering our products and services can make informed and suitable choices. We exercise reasonable and prudent judgment in all our business dealings.

The credit union is committed to the professional development of our employees, who are trained to provide financial information that individuals can trust. Their knowledge is gained, and improved upon, by appropriate training programs or work experience. Employees will keep abreast of changes in products and services, industry standards and regulations relevant to their role.

Appropriate Products and Services

L.I.U.N.A. Local 183 Credit Union ensures that members are given sufficient information on the products or services. Including lending activities and products it offers to enable that person to select the most suitable, affordable, and appropriate product or service for their needs.

Professional Standards

L.I.U.N.A. Local 183 Credit Union exercises reasonable and prudent judgement in the provision of products and services. We are committed to the professional development of our employees by communicating relevant product information and market conduct related topics such as ethics, and integrity, and ensures the proper training is provided through such resources as webinars and courses.

Knowledgeable employees are accessible in-person through the branch or branch telephone numbers for members to contact if they have questions about a product or service. This information is available on L.I.U.N.A. Local 183 Credit Union’s website.

Tied Selling and Undue Pressure

The credit union does not engage in undue pressure or coercion to convince people to select any particular product or service. We do not impose any form of pressure to induce someone to buy a particular product or service they do not want in order to obtain another desired product or service.

Negative-option billing and consent

The credit union does not practice negative-option billing, which means automatically billing people for a product or service they have not asked to purchase. We will always obtain member’s consent for new and optional products and services and will seek out their consent for changes made to agreements that affect their rights and obligations.

Preferential Pricing

Preferential pricing means offering a member a better price or rate on all or part of their business. In instances where L.I.U.N.A. Local 183 Credit Union may offer preferential pricing on a product or service to a member, we are transparent about such preferential price or rate with the member as well ensuring that it is fully documented and approved at the correct level.

Risk Management

L.I.U.N.A. Local 183 Credit Union may apply, to the extent necessary, reasonable requirements on members as a condition of acquiring a product or service in order to manage risk, costs, or to comply with any laws that apply to the credit union.

Obtaining Consent

L.I.U.N.A. Local 183 Credit Union obtains the member’s express consent for new and optional products or services (such as mortgage insurance), and for changes made to agreements (such as increases in credit limits), where the change is not contemplated in the agreement and will affect the individual’s rights and obligations.

Providing Products and Services Digitally

Where products and services are offered digitally, L.I.U.N.A. Local 183 Credit Union ensures the same level of fair treatment, transparency, and disclosure is applied as with traditional means, in a manner appropriate to the medium, including, where necessary, access to a knowledgeable credit union employee.

Sales Practices

L.I.U.N.A. Local 183 Credit Union refrains from implementing sales targets requiring financial or non-financial incentives, therefore no monitoring and tracking is required.

Deposit Account- Refusal

L.I.U.N.A. Local 183 Credit Union may refuse to open a deposit account if it has a sound of business reason to do so. A sound business reason can include the following:

• It is suspected or confirmed that the account will be used to break the law or commit fraud;
• The applicant intentionally provides false information during account opening;
• The opening of the account will expose the credit union, or employees to physical harm, harassment, or abuse;
• The applicant has a history or illegal or fraudulent activity with L.I.U.N.A. Local 183 Credit Union or any provider of financial services;
• The applicant cannot or will not provide acceptable identification, in accordance with the credit union deposit account opening process:
• The applicant will not allow the credit union to verify identification or information provided;
• L.I.U.N.A. Local 183 Credit Union has a sound business reason to place restrictions on the deposit account and the applicant will not accept the restrictions;
• The applicant represents an unacceptable risk to the credit union

When L.I.U.N.A. Local 183 Credit Union Refuses to Open a Deposit Account

When the credit union refuses to open a deposit account, it will inform the applicant. The credit union will document such refusal and the reason for refusal being noted and authorized by management.

When L.I.U.N.A. Local 183 Credit Union Cannot Refuse to Open a Deposit Account

The credit union will not refuse to open a deposit account, solely if:

• The refusal is based on a reason that is prohibited ground of discrimination as set out in the Ontario Human Rights Code: age, ancestry, colour, race, citizenship, ethnic origin, place of origin, creed, disability, family status, marital status, gender identity/expression, receipt of public assistance, record of offences (employment only), sexual orientation, accommodation, contracts, employment, membership in unions, trade or professional associations.
• The applicant does not have a job or has been bankrupt, unless the bankruptcy has resulted in write-offs or losses to L.I.U.N.A. Local 183 Credit Union

Where L.I.U.N.A. Local 183 Credit Union closes a deposit account, it will do so in accordance with the agreement that governs the relationship between the member and the Credit Union, as set out in the new member account application.

Restrictions on deposit accounts

The credit union may impose reasonable restrictions on certain deposit accounts. Restrictions include placing temporary holds on cheques to allow time for them to clear or limiting the amount of cash provided on a deposited cheque. If warranted, we may impose limits on overdraft restrictions, on debit card privileges, or on ATM and online access. We are transparent regarding any changes or restrictions imposed upon members’ accounts.

Low-fee and no-fee deposit accounts

The credit union believes low-fee and no-fee accounts should be available to ensure fundamental banking services are available to those who cannot otherwise afford to open and operate an account due to the cost.

Access to funds

At the credit union, account holders have immediate access to the first $100 deposited by cheque into a deposit account (or by the next business day). We may not grant the funds if the cheque is endorsed more than once or is in a foreign currency, if we believe it is tied to illegal activities, or if the account is less than 90 days old. L.I.U.N.A. Local 183 Credit Union may limit the amount of funds accessed or extend the hold period for cheques deposited using sound business reason. We will inform affected members or account holders of any reductions to funds access limit amounts or increases to cheque-hold periods.

Cashing Government Cheques

The Access to Basic Services Regulations for federally regulated financial institutions states that any branch that dispenses cash through a teller must cash a Government of Canada cheque if the cheque is for $1750 or less, at no cost to the individual, as long as the individual cashing the cheque shows acceptable identification. The federal government provides and indemnity of up to $1750, per occurrence, to all financial institutions that provide this service and are members of the Canadian Payments Association. While the Access to Basic Banking Service Regulations do not apply to provincially regulated credit unions, L.I.U.N.A. Local 183 Credit Union will follow the regulations for cashing Government of Canada cheques for members.

Refusal to Cash Government of Canada Cheques

L.I.U.N.A. Local 183 Credit Union may refuse to cash a Government of Canada cheque if one or more of the following apply:

• The cheque is for more then $1750;
• The individual requesting to cash the cheque cannot produce acceptable identification;
• The cheque has been endorsed or signed by a third-party;
• There is evidence that the cheque has been altered in any way or is counterfeit;
• L.I.U.N.A. Local 183 Credit Union has reasonable grounds to believe that there has been illegal or fraudulent activity in relation to the cheque; or
• L.I.U.N.A. Local 183 Credit Union cannot verify that the cheque is legitimate, after contacting the federal government’s Cheque Inquiry Unit found on Payments Canada

The credit union will provide suitable product and service information that is easy to understand, and considers the financial needs of the member or account holder. Up-to-date information is made available to individuals before and after a product or service is acquired. Our documents are clear and contain all the financial implications of a transaction.

When a member opens an account, we ensure they are making an informed decision by letting them know the key features of an account and any associated risks, exclusions, or limitations. We make sure they are aware of the financial implications of a transaction, that they understand all related costs, and that they know the terms and conditions and their rights and obligations. We draw special attention to the key areas of an agreement, including fees and charges, changes to the agreement, applicable restrictions, overdraft protection, deposit insurance coverage, and other relevant terms and conditions.

To ensure people are fully informed, when a member or account holder acquires a product or service, we provide them with the related documentation. Account holders have access to online statements at any time and are advised of any changes. Members and account holders may request to receive a paper statement. We may charge a reasonable fee to provide a paper or duplicate copy of a statement. The credit union gives advance notice of changes to agreements, service fees or account structures, and interest rates in accordance with applicable legislation. In cases where notice is not legally required, the credit union may provide notice on their website, in-branch, by mail or electronically.

Providing Mortgage Information

Upon request, L.I.U.N.A. Local 183 Credit Union will provide general mortgage information to members that have mortgages. The general information should include, the cost of borrowing, how the prepayment penalty is calculated, applicable prepayment privileges, and contact number the member can call to obtain specific information about his or her mortgage from the credit union. The credit union will abide by all provincial and national regulations governing disclosure of the cost of borrowing. The information provided to the member is easily understandable, and does not hide, diminish, or obscure important statements or warnings.

Branch and ATM closures

We understand the potential inconvenience that the closing of a branch or ATM may have on our members and account holders, and thus we make every effort to alert our members to the closing of a branch or ATM as soon as possible. The credit union will notify members and account holders of any closures – permanent or temporary – in accordance with applicable legislation. In cases where no legislation applies, notice may be communicated by the credit union on their website, in-branch, by mail or electronically.

Disclosure

When L.I.U.N.A. Local 183 Credit Union uses the word “bank”, and/or “banking”, and/or “banker” in advertisements or marketing materials and when onboarding, the credit union will disclose:

• That the account being opened is a credit union
• That L.I.U.N.A. Local 183 Credit Union is not a bank,
• The province L.I.U.N.A. Local 183 Credit Union is authorized to operate in,
• L.I.U.N.A. Local 183 Credit Union’s deposit insurance system.

Identifying Deposit Insurance System

When identifying our Deposit Insurance System, we follow the restrictions, guidance, requirements, display, and advertising rules established by the provincial regulator, the Financial Services Regulatory Authority of Ontario.

The credit union examines all complaints and settles them fairly using a process that is accessible to everyone. Every credit union has procedures for fairly handling dissatisfied members, account holders, or consumers. We recognize that many complaints can be effectively resolved at the point of contact.

For those complaints that cannot be resolved at that stage, the credit union has established a procedure for escalation and has designated a senior employee responsible for handling these matters.

L.I.U.N.A. Local 183 Credit Union’s designated complaints officer is the CEO.
The CEO’s contact information is available through the credit union’s website, and readily available in branch and over the phone if requested.The CEO must be engaged when a member’s complaint exposes L.I.U.N.A. Local 183 Credit Union to financial or reputational risk, or when a member has filed a formal complaint.

The credit union’s goal is to resolve the problem or manage the complaint quickly and in a manner that is appropriate for both the member and L.I.U.N.A. Local 183 Credit Union. It is understood that members may not always be satisfied with the credit union’s response. Members may appeal decisions regarding any product or service in accordance with L.I.U.N.A. Local 183 Credit Union’s processes, policies, and by-laws in writing.

The credit union has established a process for measuring the satisfaction of its members in order to identify trends and the types of complaints logged. The credit union will maintain records of complaints received and the action taken to address them to facilitate process improvements.