Ethical Business Conduct

We want our associates to understand what our policies prohibit and to feel comfortable reporting violations. Our policies provide multiple examples of what is prohibited at Regions and give associates different avenues to make a report. Associates are annually assigned “Respect in the Workplace” training as a supplement to our annual “Business Conduct and Ethics” training to ensure associates understand our policies and guidelines, as well as the conduct that is expected of them.

Anti-Bribery and Corruption

Our Code of Conduct prohibits associates from engaging in bribery or corruption of any type. The Code of Conduct expressly prohibits associates from giving gifts to or accepting gifts from government officials. Associates who are offered a gift or other item of value that would result in a violation of Regions’ policies are required to immediately report the incident to the Ethics Program Manager.

Regions also has an Anti-Bribery and Anti-Corruption Officer, who reports through Financial Crimes Risk Management. We instituted an Anti-Bribery and Anti-Corruption Policy, which requires associates to comply fully with all applicable anti-bribery laws, including the Bank Bribery Act and the Foreign Corrupt Practices Act. This Policy, which incorporates the guidance contained in our Code of Conduct, establishes Regions’ requirements to conduct business activity in an honest and ethical manner, with a zero-tolerance approach to bribery and corruption.

Human Rights Statement

Honoring and affirming protections for human rights is embodied in our values and mission. Regions’ support of fundamental rights is also reflected in our policies and in our everyday interactions with associates, vendors, customers and the communities where we do business.

PRINCIPLES GUIDING REGIONS’ ETHICAL USE OF ARTIFICIAL INTELLIGENCE

Regions believes that there are certain aspects of banking that should never change: Trust. Security. Service. Value. Convenience. At the same time, however, banking should constantly evolve in ways that better meet—and even anticipate—people’s needs. One of the ways that Regions is tackling this dual challenge is through investing in, building and using Artificial Intelligence (AI) tools to help ensure a more consistent, efficient and secure banking experience for our customers. We utilize AI solutions to help us perform multiple important functions, like protecting our customers from fraud, connecting customers with the products and services that will best suit their needs and developing an “AI-ready” workforce.

The importance of these resources only underscores the need to use them ethically. Regions makes it a priority to use AI in a manner that is consistent with our values as an organization, and, as a result, the ethical use of AI receives significant attention at Regions. We are committed to strong AI ethics and AI governance; to demonstrate these commitments, we have developed and adhere to core principles that drive our ethical use of AI:

• Values. At Regions, we have a set of core values that drive everything we do: put people first, do what is right, focus on your customer, reach higher and enjoy life. We apply these same values to the building and use of AI at Regions by adopting a people-first, technology-second approach. We view AI as one important tool among many options designed to meet customer needs, and we carefully consider the impact on customers before building or using any AI.
• Governance. The development and use of AI tools at Regions is well governed. At the starting point, one of our business units identifies a customer need. Then, an analytical team architects a solution, considering AI as one of many potential components thereof. At that point, risk management evaluates any resulting AI tools for privacy, bias, potential risk, mathematical soundness and other considerations. Throughout the process, our builders and users of AI follow clear guidelines on the ethical creation and use of algorithms. A management-level committee provides oversight of the entire AI lifecycle, from development/acquisition to implementation and monitoring. Together, these strong preventative and detective controls help us keep our focus on the customer while improving services.
• Rigorous Testing. Regions is committed to rigorous testing of AI tools, whether developed internally or sourced externally. As an initial standard, Regions will abstain from using any AI unless our risk management function can perform rigorous testing and detect transparency in the AI’s decisioning. We take advantage of advancements in the fields of data science and model risk management, leveraging performance and explainability tools and algorithms to provide insight into how the AI makes decisions. Regions tests model design, data, ongoing monitoring, re-tuning and re-training, hyperparameters, edge-cases and limitations, model stability, implementation and multiple other aspects of all AI tools.
• Diverse and Inclusive Teams. It is crucial that AI be built in a thoughtful, fair and reliable manner and evolve to be non-discriminatory. Part of how Regions seeks to achieve these aims is by developing diverse and inclusive analytical teams, reflecting the diversity of the communities we serve. These teams provide clear insights into using AI in a manner that offers consistent benefit throughout our customer base. The teams’ work is supplemented by enhanced training, thorough consideration of customer impact, preventative and detective controls and the ability to address potential issues rapidly.
• Continuous Learning. Continuous learning is a cornerstone of Regions’ analytical capabilities. Ongoing training opportunities, which are arranged and offered internally by numerous analytical teams, include Data Science Days, Knowledge Cafes, Analytics Advantage Newsletters, Quant Summits and dozens more. One such training, our Regions Analytics Institute, is a 12-week training program that further enhances our associates’ skills at building algorithms with high levels of transparency, explainability and replicability, as well as how to test algorithms and data for bias. More than 50 data scientists at Regions have been trained on building ethical AI algorithms through the Institute. These ongoing learning events track the evolution of technology, complementing Regions’ overall culture of continuous improvement.

AI can be used to uncover insights from data that can greatly benefit our customers. All consumers should expect that this AI is being implemented in a responsible manner. At Regions, we are committed to meeting this expectation and doing what is right for our customers. In that same vein, Regions envisions the evolution of these principles as time and experience prompt the evolution of AI, both at Regions and in the surrounding environment.

Compliance Training

Regions strives to remain a leader in the banking industry, and for us, leadership and learning go hand-in-hand. Continuing education is a critical component of our culture, and we help associates reach higher by providing them with opportunities to learn more about the business of banking; staying aware of the risks Regions faces; and better understanding our responsibilities to protect our customers and comply with laws and regulations.

In addition to job-specific training, we require that associates complete six Mandatory Annual Compliance (MAC) training courses. Additional MAC courses are required for many associates based on their business units, roles and functions. All of Regions’ MAC online courses are revised in response to regulatory changes, industry events, and evolving risks. Completion of MAC training is a condition of continued employment at Regions; new hires must complete this training within 30 calendar days of their start date, and then again annually. In 2019, Regions associates completed 238,337 total hours of MAC training.

The following course descriptions provide the major topics contained within the six MAC courses required of every Regions associate.

Business Conduct and Ethics emphasizes every associate’s responsibility and accountability in the areas of conflicts of interest, insider trading/insider information, incentive program ethics, fair and consistent treatment and discrimination and harassment prevention. Associates are also required to certify that they have read and understand the Regions Code of Conduct and the General Policy on Insider Trading.

Fair and Responsible Banking explains the importance of providing Regions’ customers with a fair and responsible banking experience, including, among other things, fair billing. Associates are provided with the tools to identify and apply key aspects of fair and responsible banking regulations and policies and to understand their effects on Regions and our customers. The course also provides guidelines for avoiding discrimination and unfair, deceptive or abusive acts or practices and for properly reporting customer complaints through the Centralized Customer Complaint Database.

Fundamentals of Risk Management reminds associates how sound risk management affects our ability to serve our customers and protect Regions. The course explains the three lines of defense concept, the importance of a strong risk culture and how shared value helps build that culture.