Our Commitment to the Delivery of Banking Services to Seniors Report 2025

Wealth One Bank of Canada (“WealthONE”) is committed to supporting the unique needs of our clients aged 60 and over. We recognize that our senior clients are a diverse group who have made significant contributions to the communities we serve, and we are privileged to support their financial security and well-being.

As a member of the Canadian Banker’s Association (CBA), WealthONE has adopted the Voluntary Code of Conduct for the Delivery of Banking Services to Seniors (the “Seniors Code”), recognizing that certain issues may particularly affect seniors than individuals in other age groups. The principles of the Seniors Code were established to help guide banks in their delivery of banking products and services to Seniors.

At WealthONE, serving seniors is not a simply a regulatory obligation – it is an expression of who we are as an institution. Our senior clients may be affected differently by life events, health, mobility, cognitive changes, or financial circumstances. We fully support the intent behind the Seniors Code. WealthOne has incorporated the principles outlined in the Seniors Code into its regulatory compliance management framework. We have further appointed a Seniors Champion to promote seniors’ interests and improve their banking experience with WealthONE. Our annual detailed reports on the steps we take to support the principles outlined in the Seniors Code improve the delivery of our banking products and services to Seniors is published on our WealthONE “Support for Seniors” page.

To ensure Seniors have a safe and comfortable banking experience, we are:

• Providing ongoing relevant training to our employees and representatives on issues that may Seniors
• Enhancing how we respond to circumstances where Seniors may need additional assistance with their banking activities
• Improving our ability to identify and escalate incidents of suspected financial abuse or fraud against Seniors

Providing quiet, accessible, and private spaces for confidential conversations in our office. We believe everyone, including our Senior clients, should have equal access to important information about their finances and their relationship with us.

We are pleased to provide multi-language client service in English, Mandarin or Cantonese to help explain our services and related materials.

Our “Support for Seniors” webpage is dedicated to Seniors and provides valuable information, resources, and tools such as:

• Programs and Services from the Government of Canada, including Fraud reporting and understanding Powers of Attorney and Joint Bank Accounts.
• Access and information on our online and mobile banking services, including confidentiality and online security.
• In-Office accessibility.

The Seniors Code further underlines the importance of the focus our employees and representatives already have when providing seniors with the financial advice and services they need to enjoy the lifestyle they have worked so hard to achieve. To further support the WealthONE staff, we have designed and implemented a dedicated Dealing with Seniors Training Program.

Key areas of our training program focus on:

• Detecting and escalating suspected instances of financial abuse of Seniors, including understanding the vulnerability factors and possible warning signs of abuse, fraud, scams, bad actors, and how to discuss such topics with Seniors
• Ways to mitigate potential financial harm to Seniors due to financial abuse
• Ensuring our employees and representatives are aware of the accessible formats and delivery channels that are available to seniors
• Effectively communicating with Seniors – providing all necessary banking information in an accessible, clear, and transparent format, including communication strategies and escalating concerns

WealthONE Seniors’ Champion

Consistent with Principle 1 of the Code, WealthONE has designated a member of the management to serve as Seniors Champion. The Champion leads the Bank’s implementation of all seven Code principles, promotes seniors’ interests across the organization and serves as the primary advocate for their banking needs of our senior clients. Our frontline employees have a specialized support team to assist with the delivery of bank products and services to our Senior clients. WealthONE’s Seniors Champion acts as an additional layer of support if additional information about Seniors’ related topics is needed. The Seniors Champion also acts as a subject matter expert for complaint escalations to ensure that the spirit of the Seniors Code is upheld in all our interactions with Seniors.

Prevention, Detection and Mitigation of Financial Harm

Given the rise in scams targeting Seniors, our procedures include:

• Robust ‘Know Your Client’ (KYC) and client due diligence processes
• Employee training focused on the recognition and assessment of vulnerability factors, signs of financial abuse, Power of Attorney (POA) abuse, anti-money laundering (AML) protocols, and ongoing market scans of potential financial threats, frauds, and scams
• Streamlined and centralized processes to act swiftly when a fraud or suspected fraud has occurred
• Ongoing monitoring of Senior clients’ activities, transactions, and reassessing transactional client risks

Principles:

1. Establish and implement appropriate policies, procedures, and processes to support the Code.

   We have developed and maintain the Seniors Code Guideline that contains the relevant policies and procedures to support the Seniors Code and its principles.

   WealthONE has incorporated the Delivery of Banking Services to Seniors requirements into its Regulatory Compliance Management framework.

2. Communicate effectively with seniors.

   We endeavour to make communicating with us as easy as possible. One of the ways we do this is by offering multi-language client service in English, Mandarin and Cantonese. Senior clients may request to be served in their preferred language at any point in their banking relationship.

   Our Senior customers may consider having the name of a Trusted Contact Person (TCP) on file with us with which, in limited circumstances, we may contact.

   What is a Trusted Contact Person (TCP)?

   A Trusted Contact Person is someone you authorize us to contact in limited circumstances. It allows us to know who you trust and who we have permission to contact when we are concerned about your wellbeing under specific situations, for example:

   • If we need to get in touch with you but can’t.
   • If we have a concern you may be vulnerable and/or being financially exploited.
   • If we need confirmation of your legal representative(s).

   What can my Trusted Contact Person do?

   A Trusted Contact Person can help safeguard your financial assets, but they:

   • cannot authorize transactions on your behalf.
   • cannot make decisions on your behalf.
   • will not be given access to your detailed account information.

   You appoint a TCP to act solely as an additional resource to help protect your account(s) at WealthONE. You can specifically outline when your TCP should be involved.

   Who should be a Trusted Contact Person?

   A Trusted Contact Person may be someone you trust and someone who is mature and can handle conversations about your personal situation. Consider choosing someone who:

   • will protect your interests
   • will be comfortable talking to us
   • knows you well enough to notice changes in your personal situation
   • is familiar with your support network
   • agrees to take on the role
   • is typically not involved in decisions about your finances, and preferably, is not your power of attorney

   How is TCP different from a Power of Attorney (PoA)?

   A TCP can’t make financial decisions on behalf of you, meaning they can’t initiate or authorize transactions on your behalf. They cannot make account changes in any form or be given access to your accounts and/or your account information.

   A PoA can do anything that a grantor (a person giving a PoA to someone) could do unless constrained in the power of attorney document and/or by provincial and territorial law. They may have the ability to authorize the purchase and sale of securities in an investment account. There are two types of PoA:

   • Personal care – this allows an attorney to make decisions on your behalf about your health care needs, housing, other aspects of your general life, such as meals and clothing.
   • Property – this allows an attorney for property can make decisions about your financial affairs, including paying your bills, collecting money owed to you, maintaining or selling your house, managing your investments.

   Each provincial jurisdiction in Canada has legislation governing the powers of attorney, and the rules vary by province. Overall, the PoA must act in accordance with a fiduciary standard. These duties include:

   • acting in the best interests of you
   • exercising reasonable care and skill in conducting your affairs
   • keeping records of all transactions and accounting for your affairs
   • ceasing to exercise their authority and duties if the power of attorney is revoked

   A PoA generally cannot do the following:

   • make a will on your behalf
   • change an existing will
   • change the designated beneficiaries of any registered accounts (RRSP, RRIF, TFSA) or life insurance policies
   • grant a new power of attorney to someone else
   • provide gifts, unless allowed per the document
   • co-mingle your assets with their own assets

3. Provide appropriate training to our employees and representatives who serve seniors.

   Regular and appropriate training focused on the delivery of banking services to seniors is provided to our staff and representatives. The training includes:

   • An overview of the 7 Principles of the Seniors Code
   • Mitigating Potential Financial Harm
   • CBA’s Commitment on POA and Joint Deposit Accounts
   • Complaint Handling
   • Protecting Seniors’ Privacy
   • Internal and External resources for employees to help Seniors.

4. Make appropriate resources available to our client-facing employees and representatives to help them understand matters relevant to seniors’ banking needs.

   Through training and direct communication, we have made our employees and representatives aware of the necessary internal and external resources to help them in delivering banking products and services to seniors. WealthONE Seniors Champion and designated members of our Compliance Team are readily available to assist.

5. Endeavor to mitigate potential financial harm to seniors.

   We continue to train and provide resources to our employees and representatives to be able to identify and mitigate possible financial harm to seniors due to financial abuse, fraud or scams. This training includes ways to respect clients’ privacy, and security and autonomy.

6. Take into account market demographics and the needs of seniors when proceeding with branch closures.

   • Though WealthONE does not have branches, we continue to take into account seniors’ needs when providing our services.

7. Publicly disclose the steps we have taken to support the principles set out in the Code.

   We have provided this report to the public on our “Support for Seniors” webpage.