National Australia Bank Code of Conduct

This document provides an overview of the code of conduct adopted by National Australia Bank (NAB) to ensure ethical and responsible operations. It covers the scope of the code, management rights, NAB's commitment, principles, regulatory compliance, discrimination, exploitation, corruption, dishonesty, whistleblower protections, enforcement, and the ethics committee.

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Governance, Ethics and Sustainability

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National Australia Bank
Code of Conduct
Overview of the Code
Following is the code of conduct adopted by National Australia Bank (NAB) in order to make
sure the company makes a commitment towards conducting its operations in an ethical and
responsible manner. Under this code, the company recognises its responsibilities towards
different stakeholders and set priorities for people who represented NAB such as the board
members, employees, contractors, or leaders to make sure that they act honestly with
integrity and in a professional manner (NAB, 2019a). This code contains different factors
that highlight the practices and ideology of the company.
Scope
The scope of this code is wide which apply to the stakeholders of the company. All the
board members/officers, employees, and other members of the company are obligated to
comply with the guidelines of this code.
Right of Management
The management of the company has all the rights reserved regarding taking actions against
parties that engage in any practices which violate the provisions of this code. The right to
take actions against these parties is also limited to the management despite that fact
whether they have breached these terms in a director or indirect manner (NAB, 2019b).
Our Commitment
 NAB comply with provisions relating to the privacy and confidentiality of its
customers
 NAC fulfil mandatory commitments, internal standards and other statutory
obligations
 NAB focuses on eliminating conflict of interest
 NAB focuses on conducting activities in a professional manner

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 NAB focuses on maintaining integrity, fairness and honesty in its operations (NAB,
2019c)
Our Principles
The management of NAB has implemented various principles regarding different aspects
which are necessary to its followed by all organisational personnel to maintain honesty,
integrity and professionalism in their work.
Regulatory Compliance
While managing its operations in Australia, NAB is subject to different regulations and
legislation which it has to comply with. The company has to register itself with the
Australian Securities and Investments Commission (ASIC) and also comply with the
guidelines issued by the Australian Stock Exchange (ASX) to make sure that it made
necessary disclosures (Salim, Arjomandi and Seufert, 2016). The corporation prioritises
compliance with these laws, and it understands the importance of government authorities
as a key stakeholder of the company; therefore, the company maintains a high level of
responsibility and accountability in its operations by submitting necessary documents and
maintain transparency in the operations.
Discrimination
Discrimination is defined as treating people in a different manner due to individual
differences such as religion, gender, sexual preference, race, ethnic origin, pregnancy,
disability, family responsibilities, age or other attributes that are given under the anti-
discrimination legislation (Volpone and Avery, 2013). NAB did not support any form of
unlawful discrimination in the workplace, and it did not allow its managers or employees to
discriminate with employees based on their individual differences. These guidelines also
apply to the employees while they deal with customers. In order to discharge its obligations,
the company complies with various regulatory guidelines imposed by the government in
different acts such as:
 Disability Discrimination Act 1992 (Cth)
 Racial Discrimination Act 1975 (Cth)
 Age Discrimination Act 2004 (Cth)

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 Sex Discrimination Act 1984 (Cth)
As per the guidelines given in these regulations, NAB ensures that its workplace remains fair
and discrimination-free which is crucial for conduct its operations in an ethical manner.
Therefore, the following practices are followed by the company to make sure that it did not
promote discrimination:
 Promotion of employees based on their performance
 Deciding the role of employees in non-discrimination manner
 Selecting employees based on their qualifications and experience rather than
personal characteristics
 Other actions to promote and support diversity in the workplace
Along with these legislative practices, the company has also implemented a separate anti-
discrimination policy that focuses on recognising human rights and these provisions also
apply throughout the company (Case, 2014). As per this policy, employees or outside parties
can raise an issue against the company if they face discrimination at any level of the
company. Employees are also encouraged to report discrimination if they face
discrimination from seniors and they can directly reach the anti-discrimination committee if
they wanted to keep their information private.
Exploitation
Exploitation is referred to the act of unfair treatment of a worker or an employee by a
manager or another person in authority in order to get benefit from their efforts (Hahn, Lee
and Lee, 2015). NAB focuses on implementing policies to make sure that its employees did
not face any challenges due to exploitation by the top level management. The success of the
company depends upon the performance of employees, and they are a key stakeholder of
the organisation due to which it has to make sure that it did not take unfair advantage of
them. There are various activities which are prohibited by the company in the workplace,
for example, they cannot:
 Force employees to work on public holidays
 Focus on the interest of stakeholders rather than profit maximisation
 Force employees to work for additional working hours specified in legislation

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 Hold their salary for an unfair reason
 Force them to promote sexual harassment or sexual activities
Although all practices involving exploitation cannot be included in the code; however, there
are various other practices which are also prohibited in the workplace. Appropriate training
is given to senior managerial personnel to make sure that they under how to discharge their
duties without engaging in exploitation. Moreover, the company also continuously engage
in practices that are focused on satisfying the demand of customers and maintaining the
interest of employees (Pearce, 2018).
Corruption
Corruption is defined as misused of position or authority by an employee or manager that
take actions against the interest of the company while focusing on their personal benefits or
benefit of third parties (Vickers, 2014). Since NAB engages in banking practices, the
company ensures that it is not exposed to bribery practices or other fraudulent activities.
The company has prohibited its employees and management from taking gifts from third
parties to engage in unfair or unethical conduct. The company has implemented different
policies to eliminate corruption such as:
 Economic and Trade Sanction Policy
 Anti-Bribery and Corruption Policy
 Anti-Fraud Policy
 Anti-Money Laundering and Counter-Terrorist Financing Policy
All these policies are targeted towards reducing and preventing corrupted activities in the
workplace by informing employees regarding these practices. The company has prohibited
its employees from engaging in illegal or criminal activities, and they focus on identifying
fraudulent practices to eliminate them (Iyer and Samociuk, 2016). The company also did not
take fund from political parties or give them fund to avoid political corruption. Furthermore,
the company encourages its employees to report any corrupt practices of their colleagues or
managers in the organisation. They have the option to report these practices in an
anonymous manner if they did not want to reveal their identity in the workplace.

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Dishonest and Fraudulent Behaviour
Fraudulent behaviour is referred to dishonest act that is taken by the management in order
to gain an unfair advantage by taking actions for self-benefit or third parties (Cohn, Fehr and
Marechal, 2014). The company expects its employees to engage in ethical and fair dealings
and they are expected to be honest while dealing with customers. Since the company
operates in the banking sector, it has to make sure that its employees did not engage in
dishonest practices during loan sanction or other practices. Dishonesty and fraudulent
behaviour resulted in adversely affecting the reputation of the company that affects the
interest of stakeholders. The practices that come within the scope of fraudulent activities
include misuse of confidential information, falsification of accounts, false claim for
remuneration and others (Bonny, Goode and Lacey, 2015).
In these practices, the employees put their personal, selfish interest above the interest of
the company and its stakeholders. Thus, every activity head in NAB focuses on checking the
work of their junior to make sure that they did not engage in dishonest practices. Ethical
principles are a key part of the organisations and managers are expected to form policies
while considering these principles to make sure that they did not engage in fraudulent
practices. Strict legal actions are taken against people who are found guilty of engaging in
fraudulent practices to set an example for others (Bonny, Goode and Lacey, 2015).
Furthermore, the managers encourage employees to report any fraudulent practices which
they face in the workplace to make sure that the interest of stakeholders is not violated. The
identity of the employees who report these incidents remain confidential in order to
encourage them to report these actions to the top level management.
Whistle-blower Protections
A whistle-blower is referred to a person who exposes particular information or practices
that are considered as unethical, wrongdoing or illegal in the organisation. Rather than
tolerating the illegal or unethical practices, the whistle-blower reports them to higher
authorities in order to make sure that they take corrective actions to eliminate these
practices from the workplace (Pacella, 2013). Since whistle-blowers reveal information
regarding top as well as low-level management, they are at risk of danger. Thus, it is the
responsibility of the company to make sure that they take corrective measures to protect

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the interest of whistle-blowers to encourage them to raise their voice against unjust, illegal
or unethical practices. NAB has implemented policies that are focused on ensuring that the
identity of whistle-blowers is protected and they did not face danger from the management.
The whistle-blower policy of the company includes the following policies:
 Appropriate infrastructure is arranged in order to make sure that employees can
safely report an issue
 The company ensures that employees that reveal unethical or illegal conduct are not
disadvantaged in the workplace
 NAB reviews the adverse consequences in a timely manner to make sure that
whistle-blowers are encouraged to reveal information regarding illegal or unethical
practices
 NAB follows the principle of fairness and natural justice during the investigations
 The company ensures that outcomes of the major reveal by whistle-blowers are
positive and used to eliminate illegal practices from the workplace (NAB, 2019d)
Furthermore, the company has ensured that adequate policies are implemented to maintain
the liberty of the employees to make sure that they have different options through which
they can report an issue and take immediate action with the help of human resource
manager or other senior managers in the company.
Enforcement of the Code
The code applies to all operations of NAB, and it is mandatory to be followed by everyone.
The management and employees of NAB have to work according to this code, and any
breach or violation of this code could lead to negative consequences that are handled by the
ethics committee of the company. NAB has set policies under which a person can violate this
code two times; however, such violation must be minor in nature rather than severe. The
power to determine the seriousness of an activity or action is given to the board, and it is up
to their discretion to determine whether the person should be given another chance or not
(Mamic, 2017). After two times, a person is not forgiven for a minor violation of the code
and action is taken by the board to make sure that such a person is punished for his/her
action. The policies of this code apply to employees as well as the management, and

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everyone is treated equally before this code, and they are punished despite their position in
the company.
Ethics Committee
This code is developed by the ethics committee, and they also have the power to entertain
matters relating to a violation of the provisions of this act. Anyone can directly approach the
ethics committee to report a particular issue. People can mail the issue regarding further
information about this code, or they can also report an issue by mailing the ethics
committee on its official ID.
Telephone Number: [phone]

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References
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.
Case, M.A. (2014) Legal Protections for the Personal Best of Each Employee: Title VII's
Prohibition on Sex Discrimination, the Legacy of Price Waterhouse v. Hopkins, and the
Prospect of ENDA. Stan. L. Rev., 66, p.1333.
Cohn, A., Fehr, E. and Marechal, M.A. (2014) Business culture and dishonesty in the banking
industry. Nature, 516(7529), p.86.
Hahn, M.H., Lee, K.C. and Lee, D.S. (2015) Network structure, organizational learning
culture, and employee creativity in system integration companies: The mediating effects of
exploitation and exploration. Computers in Human Behavior, 42, pp.167-175.
Iyer, N. and Samociuk, M. (2016) Fraud and corruption: Prevention and detection. Abingdon:
Routledge.
Mamic, I. (2017) Implementing codes of conduct: How businesses manage social
performance in global supply chains. Abingdon: Routledge.
NAB. (2019a)
Code of Conduct. [PDF] Available at:
https://www.nab.com.au/content/dam/nabrwd/documents/policy/corporate/code-of-
conduct.pdf [Accessed 25/04/2019].
NAB. (2019b)
Our People. [Online] Available at:
https://www.nab.com.au/about-us/corporate-responsibility/our-people [Accessed
25/04/2019].
NAB. (2019c)
Corporation Responsibility. [Online] Available at:
https://www.nab.com.au/about-us/corporate-responsibility [Accessed 25/04/2019].
NAB. (2019d)
National Australia Bank Ltd Code Of Conduct. [Online] Available at:
https://www.nab.com.au/about-us/corporate-governance/national-australia-bank-limited-
code-of-conduct [Accessed 25/04/2019].

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Pacella, J.M. (2013) Inside or Out? The Dodd-Frank Whistleblower Program's Antiretaliation
Protections for Internal Reporting. Temp. L. Rev., 86, p.721.
Pearce, R. (2018)
NAB to offer cloud training to 2000 employees. [Online] Available at:
https://www.computerworld.com.au/article/635990/nab-offer-cloud-training-2000-
employees/ [Accessed 25/04/2019].
Salim, R., Arjomandi, A. and Seufert, J.H. (2016) Does corporate governance affect Australian
banks' performance?. Journal of International Financial Markets, Institutions and Money, 43,
pp.113-125.
Vickers, M.H. (2014) Towards reducing the harm: Workplace bullying as workplace
corruption—A critical review. Employee Responsibilities and Rights Journal, 26(2), pp.95-
113.
Volpone, S.D. and Avery, D.R. (2013) It’s self defense: How perceived discrimination
promotes employee withdrawal. Journal of Occupational Health Psychology, 18(4), p.430.