Your Privacy is our Priority

This Privacy Code outlines our commitment to you and is designed to comply with applicable Privacy legislation in Canada, which incorporates the following ten (10) principles:

1. Accountability

Each and every one of our employees is responsible for maintaining and protecting the personal information to which they have access. We have strict policies and procedures for protecting personal information and designated individuals within BMO Financial Group who are responsible for monitoring our compliance.

BMO Financial Group has a Chief Privacy Officer who oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors and Executive Management on enterprise-wide privacy matters. See principle #10 for contact information.

2. Identifying Purpose

When you become a BMO Financial Group customer, or apply for additional products and services, we ask you for your personal information for the following purposes:

• to verify your identity and protect against fraud
• to understand your financial service requirements
• to determine suitability of products and services for you
• to determine your eligibility for certain products and services, or those of others, and offer them to you
• to set up and manage products and services you have requested, and
• to comply with legal or regulatory requirements

Your personal information may be verified with credit bureaus, credit insurers, registries, your employer, personal references and other lenders.

3. Obtain Consent

When you apply for a new product or service, we ask you for your consent to collect, use or disclose your personal information. You may, at any time, withdraw your consent as long as:

• you provide reasonable notice
• we are not legally required to collect, use or disclose your information
• withdrawing your consent does not impede our ability to fulfill your contract with us
• it does not relate to a credit product we have granted you where we are required to collect and exchange your personal information on an ongoing basis with credit bureaus, credit insurers and other lenders

4. Limit Collection

We only collect the information we need. We may ask you to provide the following personal information:

• Social Insurance Number (SIN) for tax reporting purposes as well as other government purposes, such as when opening an income generating account or a registered retirement investment. We do this in order to comply with the Canada Revenue Agency's income reporting requirements. We may also collect and use your SIN for administrative purposes, such as to ensure an accurate match between your personal information and your credit bureau information, or as an internal identification number to accurately identify customers having same or similar names.
• Financial Information to ensure that the advice we give is appropriate for you and/or the investments you purchase are suitable for your circumstances.
• Health Information is required for some of our insurance products to ensure that you are eligible for coverage.
• Contact Information such as your name, address, telephone number or email address.

You can choose not to provide us with certain information in some situations. However, if you make this choice, we may not be able to provide you with the product, service, or information you request. We may monitor or record our incoming or outgoing telephone calls with you for our mutual protection (e.g. to ensure that your instructions are carried out, to document that we have made required disclosures to you, and to ensure that customer service levels are maintained).

We will make certain that you are informed of the purposes listed above when you apply for any of our products or services. If a new purpose for using your personal information develops, we will ask you for your consent.

5. Limit Use, Disclosure and Retention

BMO Financial Group will only use or disclose your personal information for the reason(s) it was collected. Under no circumstances do we sell or give lists of our clients to other companies for their own use and, if we obtain client lists from other organizations, we require the organizations to confirm their compliance with all relevant privacy legislation.

Your personal information may be shared with other companies within BMO Financial Group for the purpose of marketing, including telemarketing, so that these companies can offer you a broader range of product and service solutions to meet your needs.

To ensure that you benefit from our full range of products and services, we will, with your consent, or as required by law or regulation, share your personal information (other than health information) amongst BMO Financial Group. Over time, we may buy new businesses or sell some of our businesses. Accordingly, personal information associated with any accounts, products or services of the business being purchased or sold will be transferred as a business asset to the new business owner.

We may use other companies to provide services on our behalf such as data processing, account administration and marketing. They will be given only the information needed to perform those services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed. In some cases, these other companies may be located outside of Canada and may be required to disclose information to government authorities, regulators or law enforcement under a lawful order made in that country.

Personal information may be released to legal or regulatory authorities in cases of suspected money laundering, insider trading, manipulative or deceptive trading, or other criminal activity, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations. Other reasons for the release of personal information include when we are legally required to do so (e.g. by court order) or to protect our assets (e.g. collection of overdue accounts). If we release personal information for any of these reasons, we keep a record of what, when, why and to whom such information was released.

BMO Financial Group has policies in place that govern the retention of your personal information so it will be kept only for as long as it fulfills its intended purpose or as legally required.

6. Be Accurate

We are committed to maintaining the accuracy of your personal information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our data, or your personal information changes, please notify the branch or office where you do business immediately, so that we can make the necessary changes. When required, we will make our best efforts to advise others of any important amendments to your personal information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision. Recourse is described in principle #10.

7. Use Appropriate Safeguards

Your personal information is secure within BMO Financial Group, regardless of the format in which it is held. We have comprehensive security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of your personal information.

We maintain physical, electronic and procedural safeguards to protect your personal information. Examples of safeguards include restricted access to our information processing and storage areas, limited access to relevant information by authorized employees only, use of passwords, PINs and pass keys, firewalls and encryption of electronically transmitted information, and the use of secure locks on filing cabinets and doors.

We have agreements and controls in place with credit bureaus, credit insurers, other lenders and third party service providers requiring that any information provided by us must be safeguarded and used only for the sole purpose of providing the service we have requested the company to perform.

Within BMO Financial Group web sites, cookies or other information-tracking technologies may be used to improve the functionality or security of web sites, or to provide you with a more customized online experience. Please note that cookies cannot capture files or data stored on your computer. Refer to BMO's Web Tools Statement for further details regarding information-tracking technologies.

8. Be Open

BMO Financial Group's Privacy Code is available in our branches and offices as a printed brochure. From time to time, we may make changes to this policy and will inform you of changes, as required by law. The most up-to-date Privacy Code, is always available at www.bmo.com and the privacy link located at the bottom of the page.

9. Give Individuals Access

If you want to review or verify your personal information, or find out to whom we have disclosed it, please request this by contacting the branch or office where you do business. We may need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. We may charge you a nominal fee depending on the nature of your request. However, we will advise you of the fee prior to proceeding with your request. There may be instances where we are unable to provide some of the personal information we hold about you and if we are unable, we will let you know the reason(s) why.

In most provinces you have the right to access and verify the personal information held about you by credit bureaus. We will provide you with the name and location of any credit bureau that has provided us with a report on you.

10. Provide Recourse

The branch or office where you do business is well equipped to handle any questions you may have about our Privacy Code. However, we want to hear from you if you have any further concerns. Please contact us at one of the following offices:

President and Chief Executive Officer
Personal and Commercial Banking Canada
BMO Financial Group
P.O. Box 1
1 First Canadian Place
Toronto, Ontario M5X 1A1
Call: 1 800 372-5111

President and Chief Executive Officer
Private Client Group
BMO Financial Group
P.O. Box 150
1 First Canadian Place
Toronto, Ontario M5X 1H3

Chief Privacy Officer
BMO Financial Group
P.O. Box 150
1 First Canadian Place
Toronto, Ontario M5X 1H3

Independent Oversight

Office of the Ombudsman
BMO Financial Group
55 Bloor Street West
Toronto, Ontario M4W 3N5
Call: 1 800 371-2541
Fax: 1 800 766-8029

Office of the Privacy Commissioner of Canada
Place de Ville, Tower B, 3rd Floor
112 Kent Street
Ottawa, Ontario K1A 1H3
Call: 1 800 282-1376
Fax: (613) 947-6850

Respecting Your Privacy Preferences

BMO Financial Group fully respects your privacy preferences. Simply contact the branch or office where you do business to discuss the following options that are available to you:

• Direct Marketing - If you do not want to receive direct marketing communications, please ask us to remove the personal information about you from our marketing lists.
• Sharing - If you do not want us to share personal information about you among BMO Financial Group members (see Scope for list of members), request to opt out of this type of sharing. Please note that you cannot opt out of sharing your personal information where you have requested a product or service that is jointly offered by more than one member of BMO Financial Group or when the sharing is required by law or regulation.
• Social Insurance Number (SIN) - If you do not want us to use your SIN for administrative purposes as described in principle #2, with the exception of income tax reporting or other legal or regulatory purposes, request to opt out.

Definitions

Direct Marketing

Direct Marketing is our communication with you by mail, telemarketing or email, using the contact information you have provided, to inform you about products and services that we think may be of interest and value to you. This does not include information on or enclosed with your written or electronic statements, posted at or on-screen at automated banking machines, posted online at www.bmo.com or electronic bulletin boards, or conveyed to you in person.

Encryption

Encryption disguises personal information that is electronically formatted. This process ensures that an unauthorized person will not have access to it.

Personal Information

Personal Information is information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources with your consent. It includes details such as your name and address, age and gender, personal financial records, identification numbers including your Social Insurance Number, personal references, and employment records.

PIN

PIN is the personal identification number that allows you to access your accounts. This number is known only to you. Our employees do not have access to your PIN and will not ask you to reveal it.

Scope

This Code applies to the operations of BMO Financial Group in Canada, regardless of how you choose to do business with us - in our branch or office, at an automated banking machine, online, or by telephone. Reference throughout this Code to "we" "our" and "us" means BMO Financial Group and its members which include: Bank of Montreal, Bank of Montreal Mortgage Corporation, BMO Investments Inc., BMO Trust Company, BMO Nesbitt Burns Inc., BMO Nesbitt Burns Ltée/Ltd., BMO InvestorLine Inc., BMO Harris Investment Management Inc., BMO Life Insurance Company, BMO Nesbitt Burns Financial Services Inc., BMO Asset Management Inc. and Guardian Group of Funds Ltd.

Our Commitment to You

BMO Financial Group appreciates the opportunity to help you meet your financial needs. From the day Bank of Montreal was founded in 1817, earning and keeping your trust has been at the very core of our business. We are committed to respecting and protecting the privacy and confidentiality of the personal information you have entrusted to us. It is important for you to understand what information we will collect, how we will use it, and who may see it.

To learn how to protect your accounts visit the security section at bmo.com

BMO Financial Group Web Tools Statement

The Use of Web Tools at BMO Financial Group Websites

Website Tools including Cookies and Web Beacons may be used within BMO Financial Group websites to enhance our online security provisions, evaluate the effectiveness and success of our websites and marketing campaigns, as well as provide our online users with a more customized online experience.

Cookies are a string of data sent between a server and a web browser to help facilitate the use of a website and to help understand how a website is being used. Cookies are not used to retrieve any data from your hard drive, nor can they run a program on your computer.

Web Beacons are small and transparent images embedded in web pages that, when combined with Cookies, help provide a website operator with information about the use and effectiveness of a website. Most of the Cookies we use are considered "session" Cookies, meaning they are not written to your hard drive and are only available for the duration of the session (i.e., log out or close your browser).

How BMO Financial Group Websites use Web Tools:

1. Security
BMO Financial Group websites that require authentication may use Cookies to help protect your accounts from unauthorized users. For example, our BMO Online Banking site uses Cookies. These Cookies help to maintain session integrity and enable enhanced security, ensuring that unauthorized attempts to access your account through BMO Online Banking are blocked.

2. Evaluate Web Sites and Marketing Campaigns
BMO Financial Group or its service providers may use Cookies and Web Beacons in order to evaluate the use and functionality of our websites. Web Beacons may be used on BMO Financial Group websites and in advertisements to better tailor our sites and provide an enhanced customer experience. BMO Financial Group will also use this information to compile data about website usage, and patterns. For example BMO Financial Group may track how many times a link or advertisement is clicked, or the success of an online application form.

The information collected using Cookies and Web Beacons on BMO Financial Group websites is used to evaluate the performance and functionality of the site. This information may include the pages visited, the type of web browser used, the level of encryption supported by your browser, your Internet Protocol (IP) address as well as the website that referred you to the BMO Financial Group website.

3. Customized Online Experience
BMO Financial Group websites may also use Cookies to collect information about online activities and preferences. Examples include web pages visited, length of visits, and successful downloads. This information may be used together with other information to:

1. Help us better understand your interests and needs
2. Provide you with a customized online experience
3. Present new tools and website functions

Accepting Cookies

Cookies are a commonly used technology and many web browsers default to automatically accept Cookies. You can set your Internet browser to notify you before a Cookie is set, providing you the opportunity to decide whether to accept it. If you decide that you do not wish to receive Cookies, refer to your browser's online help for further instruction and information on setting Cookie preferences. You can also set your browser to immediately reject Cookies. If you select this option, you may continue to browse BMO Financial Group websites; however, you should be aware that certain features of a website may not function properly without Cookies. You should note that if you would like to use a service such as BMO Online Banking, you will be required to accept the Cookies to maintain session integrity and enhanced security.