As our Corporate Code of Ethics states, "We recognize that our first duty to our customers, to our stockholders, and to the public in general, is to conduct all matters in a manner that merits public trust and confidence." Because that tenet is so important to us at Commerce, our Code of Ethics is accessible to Commerce employees on an ongoing basis.
- Each year, all Commerce employees take an on-line Code of Ethics class and quiz.
- Annually, all Commerce officers are expected to certify compliance with the Code.
- Additionally, we have an internal Ethics Committee comprised of five members of senior management. It is the responsibility of the Committee to consider ethical issues as they arise; interpret the Code of Ethics; and decide any conflict of interest or other policy issues that may be in conflict with the Code.
Through these efforts, Commerce employees understand that our Corporate Code of Ethics applies in their day-to-day activities.
In addition, we offer Commerce employees the ability to anonymously report any suspected violations of any financial, accounting, ethical or other policies of Commerce and any suspected violations of law or regulation. Commerce employees are provided a toll-free telephone number for Speak Up, a vendor that receives the reports and provides a summary to management while protecting the anonymity of the employee. The program also provides the employee feedback on the disposition of the complaint.