Code of Conduct: NAB

This article provides an overview of the Code of Conduct of National Australia Bank (NAB) and its commitment towards responsibility, ethics, and stakeholder interests. It discusses key principles related to discrimination, exploitation, corruption, dishonest and fraudulent behavior, and whistle blower protections. The article also highlights the enforcement of the Code of Conduct and the role of the ethics committee.

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Governance, Ethics and Sustainability

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Overview of the Code of Conduct
The Code of Conduct of National Australia Bank (NAB) shows the company’s commitment
towards responsibility and ethics. As per this code, the company focuses on ensuring that
people who represented NAB – whether they include employees, manager, contractors or
board of directors – embrace the spirit of this code while maintaining integrity, honesty and
professionalism (NAB, 2019). Through this code, the company focuses on giving priority to
the interest of its customers and also taking decisions while putting their interest above
anything else.
Following are the key principles of this code which defines how NAB conducts itself, and it
also shows the commitment of the company towards its stakeholders.
A: Discrimination
In human social behaviour, discrimination is defined as the treatment of a person based on
the category, group or class to which the person belongs. It means unfair treatment of a
person or a group of people based on the difference of their age, caste, race, colour,
religion, ethnic origin, sexual preference, gender, disability or others (Volpone and Avery,
2013). There are strict measures taken by NAB in order to prohibit discrimination from the
organisation. The code focuses on guiding the actions of managers and employees to make
sure that they did not discriminate others inside or outside the workplace. Same principles
apply when they deal with customers to make sure that they did not give unfair advantage
or detriment to a customer based on their characteristics. Along with the provisions given
under this code, the company also focuses on complying with a range of legislative
provisions which are implemented by the Australian government. These provisions include
the Age Discrimination Act 2004 (Cth), Sex Discrimination Act 1984 (Cth), Racial
Discrimination Act 1975 (Cth) and Disability Discrimination Act 1992 (Cth) (Powell and Sang,
2013).
The provisions of these acts are incorporated with the Code of Conduct of the company to
eliminate any conflict in order to promote fairness and equality in the workplace. In order to
achieve the goal of promotion of diversity in the workplace and the elimination of
discrimination, various practices are implemented by NAB.

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1. The human resource department cannot design job structure based on specific
characteristics of people
2. Employees are promoted to higher positions based on their performance
3. During the employee selection process, a fair criterion has applied that focus on the
qualifications and capabilities of candidates rather than their personal characteristics
4. Implementation of diversity and inclusion policy in the workplace to create a positive
working environment for everyone (NAB, 2018)
Furthermore, the company has also taken steps towards implementation of anti-
discrimination policy in the workplace. This policy focuses on recognising human rights and
ensuring that people have a platform where they can report any incidents in case their basic
rights are breached (NAB, 2018). In case employees face discrimination in the workplace,
they can report to higher authorities. In case they are discriminated by higher authorities,
then they can report to the ethics committee or external authorities to make sure that
appropriate actions are taken to eliminate similar practices in the future.
B: Exploitation
Exploitation is referred to the act of treating someone in an unfair manner in order to
benefit from their work. The exploitation of employees is defined as unfair treatment of
workers for their own benefit (Sok and O’Cass, 2015). This is a major issue, and NAB has
implemented policies in its Code of Conduct that is targeted towards the protection of
employees from exploitation. The low level employees are at the risk of exploitation from
the top level management since they can abuse their powers to unfair treat employees for
their personal benefit or benefit of third parties. Since employees are a key stakeholder of
NAB, the company has taken strict actions to prohibit exploitation in the workplace by
forming specific guidelines.
1. Employees cannot be formed by the top level managers to work on public holidays.
2. The human resource department or any other department cannot hold the salary of
employees for any reason
3. Sexual harassment is strictly prohibited in the workplace
4. The managers are expected to put the interest of employees above profit
maximisation (Boehm, 2012)

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5. Employees cannot be forced to work above the working hours fixed by the
legislation, and if they work additionally, then they are paid extra for their work
There are a number of other activities which are also prohibited in the company but cannot
be included in the Code of Conduct. However, the company not only focuses on punishing
people for these practices, but it also focuses on stopping these activities from happing in
the first place. This goal is achieved by effective training which is given to all level of
employees and managers. In this training, they learn about appropriate behaviour and
professional conduct and understand the importance of ethical practices (Gentilin, 2016).
Along with these practices, the employees are encouraged in the workplace to make sure
that they report any unfair or illegal treatment by top level management to address the
issue of exploitation.
C: Corruption
Corruption is referred to the abuse of a person’s power or position in order to gain personal
advantage or benefits for third parties. It involves dishonest or fraudulent behaviour
conduct by a person who is in the power which typically involves bribery (Vickers, 2014).
The threat of corruption is substantial in the case of NAB since the company operates in the
banking and financial services sector. Under the Code of Conduct, the company has taken
strict measures that are targeted towards prohibiting and exposing bribery or fraudulent
practices by employees or management of the company. The company make sure that its
employees are aware that they cannot take any form of gifts from their clients in order to
give their priority or engage in unethical practices. A wide range of policies is implemented
by the company that is targeted towards addressing the issue of corruption and prohibiting
employees from engaging in similar practices.
1. Anti-Money Laundering and Counter-Terrorist Financing Policy
2. Economic and Trade Sanction Policy
3. Anti-Fraud Policy
4. Anti-Bribery and Corruption Policy
All these policies are implemented to make sure that activities in the organisation are
closely monitored to expose any corrupt practices. Employees are also encouraged by the
management to make sure that they disclose any activities which they are suspicious of to

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make sure that they did not engage in corrupt activities (SBS, 2018). Employees who report
these practices are rewarded for their actions, and they are protected from unfair
treatment. The option of anonymous feedback is also available for employees as well.
D: Dishonest and Fraudulent Behaviour
Fraudulent behaviour is defined as the intentional deception that is designed by a person in
order to gain personal advantage or benefit third parties (Bonny, Goode and Lacey, 2015).
Engagement in dishonest and fraudulent behaviour is strictly prohibited in NAB, and it is a
criminal activity as well for which a person could face monetary penalty or imprisonment.
The Code of Conduct provides guidelines to make sure that employees did not intentionally
or unintentionally engage in any practices that constitute as dishonest or fraudulent. For
example, strict guidelines are issued for the loan sanctions department to make sure that
employees follow particular steps while providing a loan to customers to make sure that
they did not misuse their position to gain an unfair advantage or conduct fraud with them.
In case the employees of NAB engage in fraudulent or dishonest practices, then it resulted in
negatively affecting the public image of the company, and it also affects its market
reputation (Purnamasari and Amaliah, 2015). Thus, the company make sure that it takes
corrective measures to eliminate fraudulent practices such as a false claim for
remuneration, misuse of private data of customers, falsification of books of accounts and
others.
The operations of lower level employees are checked by the senior managers, and the
senior managers have to present a report to the top level management to make sure that
they did not misuse their powers. Along with these policies, the company also focus on
taking strict legal action against those employees who engage in fraudulent or dishonest
conduct (Moorthy et al., 2015). Employees are encouraged by the management to make
sure that they report these practices to the top level management or the ethics committee.
The company conducts investigations against people based on the principles of natural
justice to make sure that they are able to represent their side of the story before they are
found guilty. NAB has also given its employees the operation to stay anonymous while
reporting these incidents to make sure it increases the number of reporting of cases to
promote ethical principles in the workplace.

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E: Whistle Blower Protections
A whistle blower is referred to the person who gives information regarding a person or
organisation that engages in unlawful or immoral practices. This information is released to
the public or other higher authorities that have the power to take actions against the illegal
authority to stop the same and punish those people who engage in illegal or unethical
conduct (Delk, 2013). Whistle blowers play a major role in organisations since they ensure
that the company or its officials did not use their position to engage in illegal or unethical
conduct. Whistle blowers reveal information about major entities in the organisation due to
which they face risks in the workplace. Therefore, the objective of NAB’s whistle blower
policy is to protect whistle blowers and make sure that they did not face any risks after they
reveal details regarding illegal or unethical conduct. NAB has incorporated a range of
policies in the Code of Conduct to create a positive environment for whistle blower while
also promoting ethical reporting in the workplace (ACFE, 2018).
1. NAB encourages its employees to engage in whistle blowing in case they see any
unethical or illegal activities in the organisation.
2. Policies are implemented in the organisation to make sure that employees are able
to safely report practices that could be considered as fraudulent or illegal
3. Principle of fairness and natural justice are followed by the company during the
investigation which takes place after the reporting made by a whistle blower
4. Whistle blowers receive equal treatment in the workplace, and the company has
implemented policies to ensure that they are supported in the workplace
5. Appropriate measures are implemented to reveal to the public the outcomes of the
whistle blowing to make sure transparency is maintained in the organisation
Various other policies are also implemented in the organisation that is targeted towards
promoting ethical reporting in the workplace. Under these policies, employees have the
option to hide their identity and report any illegal practices without revealing their identity
(Pemberton et al., 2012). The company also reward those employees that expose illegal or
unethical conduct of top level management. Immediate actions are taken by the human
resource department and other top level management in case similar practices are
recognised to eliminate them as quickly as well.

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F: Enforcement of the Code of Conduct
The provisions of this code of conduct equally apply to all the members of NAB throughout
Australia and in other countries as well where the company manages its operations. Minor
violation of the code is acceptance twice after evaluation of the seriousness of the breach;
however, there is no such limit in the case of a serious breach of the code such as deliberate
engagement in illegal or unethical practices (NAB, 2019).
Ethics Committee of NAB
The ethics committee has prepared this Code of Conduct, and they are also responsible for
making necessary amendments in the code to keep it up-to-date. The ethics committee
further evaluates the performance of this code to identify any gaps which are necessary to
be fulfilled. Anyone who wanted to report an issue or learn more about this code can
directly contact the ethics committee.

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References
ACFE. (2018) NAB Whistleblower Says Australian Banking Industry Has “A Long Way to Go”
in Promoting Ethical Behavior. [Online] Available from: https://www.acfe.com/press-
release.aspx?id=4295003834 [Accessed on 27th April 2019].
Boehm, J.L. (2012) Private Securities Fraud Litigation after Morrison v. National Australia
Bank: Reconsidering a Reliance-Based Approach to Extraterritoriality. Harv. Int'l LJ, 53,
p.249.
Bonny, P., Goode, S. and Lacey, D. (2015) Revisiting employee fraud: gender, investigation
outcomes and offender motivation. Journal of Financial Crime, 22(4), pp.447-467.
Delk, K.L. (2013) Whistleblowing—Is it really worth the consequences?. Workplace health &
safety, 61(2), pp.61-64.
Gentilin, D. (2016) The Origins of Ethical Failures: Lessons for Leaders. Abingdon: Routledge.
Moorthy, M.K., Seetharaman, A., Jaffar, N. and Foong, Y.P. (2015) Employee perceptions of
workplace theft behavior: A study among supermarket retail employees in Malaysia. Ethics
& Behavior, 25(1), pp.61-85.
NAB. (2018) National Australia Bank Limited: Group Human Rights Policy. [Online] Available
from: https://www.nab.com.au/content/dam/nabrwd/documents/policy/corporate/
human-rights-policy.docx [Accessed on 27th April 2019].
NAB. (2019) National Australia Bank: Code of Conduct FY 2018. [PDF] Available from:
https://www.nab.com.au/content/dam/nabrwd/documents/policy/corporate/uk-code-of-
conduct.pdf [Accessed on 27th April 2019].
Pemberton, S., Tombs, S., Chan, M.M.J. and Seal, L. (2012) Whistleblowing, organisational
harm and the self-regulating organisation. Policy & Politics, 40(2), pp.263-279.
Powell, A. and Sang, K. (2013) Equality, diversity, inclusion and work–life balance in
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Purnamasari, P. and Amaliah, I. (2015) Fraud prevention: Relevance to religiosity and
spirituality in the workplace. Procedia-Social and Behavioral Sciences, 211, pp.827-835.
SBS. (2018) NAB target of alleged fraud by ex-employee. [Online] Available from:
https://www.sbs.com.au/news/nab-target-of-alleged-fraud-by-ex-employee [Accessed on
27th April 2019].
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