Governance

Sound governance helps us protect the integrity of our data, manage risk with clarity and maintain the trust that our customers and stakeholders depend on.

Data Governance
In 2025, we continued to mature our data governance operating model. Our Data Governance Council—a cross-functional body of business leaders—convenes bi-weekly to review and approve strategic changes to our data ecosystem, with authority and scope defined in a formal charter. Subcommittee work advanced with continued focus on business glossary definitions, data ownership and identifying critical data elements—steps that reduce ambiguity and increase confidence in reporting outputs.

Privacy Enhancements
We continued to embed privacy into day-to-day business practices through expanded training, tighter contracting, and a privacy-by-design approach across our technology roadmap. In 2025, we delivered tailored privacy trainings to California-based employees, published monthly knowledge articles firm-wide, insourced corporate contracting to bring privacy compliance fully in-house, and began comprehensive product counseling for technology initiatives.

Enterprise Risk Management
We strengthened enterprise risk management governance by formalizing our framework and expanding the network of risk liaisons across the organization.

A key area of focus was deepening oversight of top enterprise risks: We conducted structured workups that clarified specific root causes, assessed business impacts and documented mitigation strategies, then enhanced controls where risk reduction was needed. We also deployed a custom-built AI capability to support consistent evaluation of technology initiatives against our top enterprise risks, and improved executive visibility through regular reporting on core risk programs including issues management and emerging risks.

As part of our commitment to integrity and accountability, we take steps to ensure that every employee understands and abides by ethical, lawful and proper workplace conduct.

Setting Standards for Workplace Integrity
Our Code of Conduct and Employee Handbook establish clear expectations for how every team member engages with colleagues, customers, business partners and the communities where we operate, covering inclusion, workplace safety, anti-harassment policies and regulatory compliance.

Ethics and Compliance Reporting
Employees are encouraged to raise concerns or report suspected violations through multiple channels: our 24-hour anonymous hotline; our Legal, Risk & Compliance or People & Culture departments; or directly to a manager. All reports are reviewed thoroughly, and our non-retaliation policy is strictly enforced.

Expectations for Vendors
Our Vendor Code of Conduct defines what we expect from suppliers on ethical business practices, labor rights, anti-corruption and environmental compliance.

Progress in 2025
In 2025, we strengthened our Corporate Compliance & Ethics Program by onboarding a dedicated Compliance team member, conducting a compliance and ethics gap assessment, updating compliance processes and launching self-help and training resources for employees.