Code of Ethics

TCF is committed to leading with integrity. TCF is entrusted with customers’ money and confidential information because we demonstrate honesty, integrity and high ethical standards. TCF requires that all team members (including all employees, officers and directors) understand and uphold these ethical standards.

This Code of Ethics Policy outlines basic principles that TCF team members must follow. While this policy applies at all times, it does not address every situation you may face. Team members should be thoughtful and exercise good judgment in any situation that may present an ethical concern. If you believe that conduct could violate this policy or TCF’s expectations regarding ethical conduct, please tell us as soon as possible. This Code of Ethics Policy applies to TCF Financial Corporation, TCF National Bank and all affiliates and subsidiaries (collectively “TCF”).

EXPECTATIONS
  1. Follow the Law.
    It is TCF’s policy to always comply with the law. You are required to follow all laws, regulations and rules that apply to TCF and your performance of your job duties. These include, but are not limited to, laws that apply to banking products and services, consumer protection laws, anti-money laundering laws, privacy laws, antitrust laws, securities laws, campaign finance laws, non-discrimination laws, criminal laws and employment laws. In many circumstances, TCF implements policies and procedures to guide team members in compliance with the law. You are expected to know and follow all TCF policies and procedures that apply to you or your job duties. If you have questions about what the law requires, please contact TCF’s General Counsel or another member of the Legal Department. If you believe that a TCF team member has violated the law, or has asked you to do so, please tell us as soon as possible.

  2. Treat Customers and Others with Honesty and Integrity.
    TCF’s relationship with its customers is built on trust. Team members are expected to demonstrate honesty, integrity, responsibility and fairness when dealing with our customers, prospective customers, suppliers, business partners, other team members and competitors. Team members should not take unfair advantage of customers or others through manipulation, misrepresentation or other unfair practices. When offering products and services to customers, information should be shared in a fair and transparent manner that permits customers to make informed choices based on their individual needs. Team members must comply with TCF’s other policies about our treatment of customers, including the Fair Practices, UDAAP and Anti-Predatory Lending policies.

    TCF does not tolerate improper sales practices. Some examples of improper sales practices include: opening an account without the customer’s consent, opening an unwanted account, funding an account for a customer with your own money, or closing an account and then opening a new one without a valid business reason. Sales practices may be improper even if customers are not harmed. If you believe that a TCF team member is engaging in improper sales practices, or has asked you to do so, please tell us as soon as possible.

  3. Treat Team Members With Respect.
    TCF strives to foster an inclusive work environment. An inclusive culture appreciates the differences in our team members, leverages diversity of thought, fosters innovation and maximizes business results. Our team members expect to work in an environment where each individual feels welcomed, valued, respected and heard. Team members must be free to express their own views and opinions. You are required to be respectful towards other team members, even when you disagree. This includes following the Discrimination and Harassment policies and TCF’s other policies regarding workplace conduct.

  4. Do Not Take or Misuse Others’ Property.
    You may not take, either for your own use or anyone else’s, or misuse, the property or money of TCF or any of its customers or business partners. You should take care to protect TCF’s property and use it only as needed to perform your job. This applies to all types of property, including office equipment, office supplies, computers, software, access badges, confidential information, and intellectual property, including trade secrets.

  5. Protect TCF’s Confidential Information.
    As explained in the Confidentiality Policy, all team members are required to keep TCF information, including customer information, confidential. Team members may not share TCF confidential information outside TCF, and may share only with those within TCF who have a business need to know. Your obligation to protect confidential information applies at all times, including while you are at work, while you are at home, and after your employment with TCF ends. All team members must protect TCF information by following our Information Security Policies. You may not use or disclose TCF information in a manner that violates the Insider Trading Policy.

  6. Do Not Accept, or Offer, a Bribe.
    You may not solicit, accept or pay a bribe. Generally, you may not accept anything of value (other than wages or other normal compensation) from anyone for performing your job duties. As explained in the Bank Bribery Act policy, team members should not accept anything of value, such as gifts, trips, or tickets to events, except in accordance with that policy. You should exercise good judgment to determine what may constitute a bribe, and check with TCF’s General Counsel if you are unsure.

    If a customer or prospective customer gives you something of value to encourage you to extend him or her a loan or another service, that is a bribe. It is permissible for a customer to buy you lunch. But it is not permissible for a customer to give you a valuable gift, like a watch or smartphone. A loan made to a public official under normal terms and conditions with proper approvals is not a bribe. But a no-interest loan to a government official may be a bribe.

    Strict laws apply to gifts or favors given to public officials. If you are involved in any questionable circumstance involving a government official or government entity, you should consult with TCF’s General Counsel as soon as possible.

  7. Honor Your Duty of Loyalty to TCF.
    TCF team members have a duty of loyalty to TCF. When you are performing your job, you should act in TCF’s best interest. When TCF provides you with information, resources and opportunities, you are required to use them for TCF’s benefit. If TCF provides you with access to information or systems, or certain types of authority, you may use them only to perform your job duties, and not to improperly benefit yourself or someone else. For example, you may not reverse fees on your own account or the account of a family member or friend.

    While you are employed by TCF, you may not compete against TCF. For example, you may not solicit TCF customers for your own benefit or the benefit of another financial institution or company that offers similar products and services (a “competitor”). You may not divert business to a competitor, and you may not encourage TCF employees to leave TCF for a competitor. Your duty of loyalty also requires you to protect TCF’s confidential information and trade secrets after your employment ends.

  8. Prevent Conflicts of Interest.
    A conflict of interest is a circumstance in which your interests conflict with, or may conflict with, TCF’s interests. A conflict of interest may arise if you have an interest or engage in conduct that could make it difficult for you to perform your job objectively and effectively. Even the appearance of a conflict of interest is a problem, because others may perceive that TCF or its team members are acting inappropriately. For example, encouraging TCF to buy supplies from a company you or your family member owns, buying property from TCF at a discount, or borrowing money from a customer, are conflicts of interest.

    It is a conflict of interest for team members to receive improper personal benefits from TCF. You may not use your TCF position, TCF information or other TCF property for your own gain or the gain of someone else. For example, you may not take a business opportunity for yourself if you used TCF information to discover or develop the opportunity.

    A conflict of interest could arise if you perform other work, such as outside employment or consulting, or if you own your own business. A conflict could also arise if you hold a leadership or board member role for an outside organization. TCF encourages team members to volunteer and give back to the community, such as by serving on the board of a nonprofit or government entity. However, TCF’s General Counsel must approve any service on an outside board or with an outside organization or government entity.

    Restrictions apply if TCF enters into a transaction with a team member or a team member’s family member or close friend. TCF National Bank and its subsidiaries may make a loan to a team member only on normal (arm’s length negotiated) terms, and must be referred to others for approval. Generally, team members may not buy property from, or sell property to, TCF. Any such sale of property must be approved by TCF’s General Counsel. Specific laws apply if TCF extends a loan or lease to an Executive Officer. All such transactions must be approved by TCF’s General Counsel, in compliance with the Regulation O policy. TCF Financial Corporation may not extend loans or guarantees to team members.

    If a situation arises that could present or appear to present a conflict of interest, you should consult TCF’s General Counsel. TCF is required to report actual and potential conflicts of interest to its Board of Directors, and may also be required to report them to its regulators.

VIOLATIONS
Team members who violate this policy or otherwise engage in unethical or unlawful conduct will be subject to discipline, up to and including termination.

PLEASE TELL US
TCF takes allegations of unlawful or unethical conduct seriously. TCF encourages team members to tell TCF if they believe that this conduct has occurred. You may contact TCF in any manner that you feel most comfortable, including by phone, email, letter or in-person meeting.

You may contact TCF’s General Counsel, TCF’s Chief Audit Executive, TCF’s Corporate Internal Investigations Department or the HCM Solution Center using the contact information below.

You may also raise your concern anonymously by contacting TCF’s Ethics and Compliance Hotline. You may contact the hotline by phone or using an online form. The hotline is managed by an independent third party company and is available 24 hours per day.

General Counsel
TCF Financial Corporation
200 Lake Street East
Mail Code EX0-03-F
Wayzata, MN 55391
(952) 475-6498

TCF Corporate Internal Investigations
CII@tcfbank.com

Chief Audit Executive
Internal Audit Department
P.O. Box 776
Wayzata, MN 55391
(800) 620-8601

HCM Solution Center
HCMSC@tcfbank.com
833-426-8444

Ethics and Compliance Hotline
1-800-620-8601
www.tcfbank.ethicspoint.com

When you contact TCF about potential violations of this policy, you will be asked to provide information about the circumstances, including individuals involved, the date(s) of the incident(s), the conduct, what evidence may exist and the identity of any witnesses.

TCF will keep allegations of unlawful or unethical conduct as confidential as possible. Only those individuals who need to know will know. That said, it may not be possible to keep all allegations confidential as an investigation and action may be necessary.

RETALIATION IS PROHIBITED
TCF will not retaliate against any applicant or team member for reporting, objecting to, or assisting with an investigation related to this policy or a violation of law. Retaliation could take on many forms, including intimidation, threats, isolation, demotion or termination. If you believe retaliation is happening to you or any team member, please contact the HCM Solution Center at 833-426-8444.

CONCERNS
If you have a concern or question about this policy, please contact the HCM Solution Center at 833-426-8444.

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