At the senior executive level, support for ethical behavior and the compliance program is overseen by Gateway's Ethics Council, which consists of senior vice presidents and above from various functional areas.
Senior executives and department leaders are personally responsible for implementing and maintaining the program within their teams to ensure compliance with all laws and regulations and the provisions of the code by everyone in their organizations.
Managers and leaders of smaller teams share this same responsibility to act as role models, to show, through their words and actions, that they are personally committed to the highest standards of integrity.
Leaders at all levels fulfill this responsibility by:
• Providing an atmosphere of open communication in which the provisions of this Code are shared, discussed and even debated.
• Ensuring, through frequent communication and discussion, that employees understand Gateway's values and the requirements of this Code.
• Taking reasonable steps to ensure that unethical, improper or questionable conduct within their areas of responsibility is detected and addressed.
• Assessing whether an individual understands and practices Gateway's values before placing that person in a position of responsibility.
Accountability for ethical behavior, and sustaining the special work culture that has contributed so much to our success, demands personal leadership at all levels by all employees.
This means a commitment to not only complying with the letter and the spirit of all applicable laws and regulations, with the Code of Ethics and with Gateway's compliance program, but exhibiting the long-standing Gateway principles of caring, fairness and respect to all other employees.
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