Code of Conduct of NAB

This document is the Code of Conduct of National Australia Bank (NAB), which outlines the bank's policies and practices related to discrimination, exploitation, corruption, dishonesty, and fraud. It also discusses whistleblower protections and the enforcement of these policies. NAB is a major business bank in Australia with a strong ethical culture and a commitment to diversity and inclusion.

Running Head: Code of Conduct of NAB
National Australia Bank
Code of Conduct
System04104
4/24/2019

Code of Conduct of NAB
Table of Contents
CODE OF CONDUCT OF NATIONAL AUSTRALIA BANK............................................................................2
1. Discrimination............................................................................................................................2
Our Approach to Diversity and Inclusion.......................................................................................2
Preventing Discrimination and Harassment...................................................................................3
Breaching:.....................................................................................................................................3
2. Exploitation................................................................................................................................3
Prevention of Exploitation:............................................................................................................3
Breaching:......................................................................................................................................3
3. Corruption.................................................................................................................................4
Prevention of Corruption...............................................................................................................4
Employees Responsibility..............................................................................................................4
Breaching.......................................................................................................................................4
4. Dishonest and Fraudulent Behaviour........................................................................................5
Prevention of Fraud:......................................................................................................................5
Employees Responsibility:.............................................................................................................5
Detection and Reporting of Fraud or Corruption:..........................................................................5
Breaching:......................................................................................................................................6
5. Whistle-blower Protections.......................................................................................................6
Reportable matter for Whistle-blower:.........................................................................................6
Role of Whistle-blowers................................................................................................................6
Whistle-blower Officer Vs. Investigating Team..............................................................................7
6. Enforcement..............................................................................................................................8
References.............................................................................................................................................9

Code of Conduct of NAB
CODE OF CONDUCT OF NATIONAL AUSTRALIA BANK
National Australia Bank (NAB) is a major business bank of Australia, which serves more
than 9,000,000 customers all around the world. NAB operate its business with 30,000
organisational people in 900 locations in Australia, New Zealand and all around the world
from last 160 years (NAB, 2019). NAB is the largest financial organisation in Australia, and
it gives financial assistance to small, medium, and large business organisation (Dengate,
2018). The bank supports in every phase of business lifecycle of these small and large
organisations. National Australian Bank is known for its best human resource policies and
practices. NAB is known for its best organisational culture and strong ethical practices. That
is why, it is known for best organisation to work in Australia. This code of conduct shows
how NAB implement various rules and regulation in the organisation related to
Discrimination, Exploitation, Corruption, Dishonest and Fraudulent Behaviour, whistle-
blower protections, and Enforcement.
1. Discrimination
The focus of NAB is to support employee’s wellbeing and cultural diversity. Any
discrimination based on gender, race, nationality, or colour will not be accepted in the
organisation.
Our Approach to Diversity and Inclusion
The NAB also care the interest of LGBT community and provide a safe and inclusive
workplace for LGBT community people as well. The NAB is not discriminating between
men and women during their promotion, appraisal, or evaluation of performance. NAB
provide equitable attraction, retention, and remuneration for both men and women (Behal,
2018). Apart from this, NAB cares for several other things that are as follow:
1. Recruitment and Selection of Employees based on their eligibility criteria, talent,
and skills. NAB is always preventing discrimination during selection and hiring of
employees.
2. Involvement of Different genders in various internal committees and working
groups that helps to work on key business initiatives and decision-makings.
3. No discrimination between the remuneration of male and female candidates on
same designation.

Code of Conduct of NAB
4. Performance and Rewards: The performance evaluation has been conducted in the
organisation without any bias or gender discrimination. Every people have equal
opportunities to work in NAB and they have equal career advancement opportunities.
Preventing Discrimination and Harassment
NAB is committed to prevent discrimination and harassment at the workplace. NAB provides
equal employment opportunities for every people and every employee required to complete
an online course upon this. NAB provides a refresher module course after every 2-3 year.
This online course educates and aware the organisational people about any sexual or physical
harassment and gender discrimination. Managers of different branches participate in the
workshop to increase the awareness of people about any bias, discrimination and stereotype
beliefs (Stockland, 2018).
Breaching:
If any gender or race based discrimination or harassment of workers found in the organisation
then the accused will be punished with substantial penalties and even he/she may put in
prison according to Australian laws related to gender discrimination or law related to physical
harassment.
2. Exploitation
NAB is very strict about the sexual exploitation or abuse in the workplace. Exploitation is an
action or fact of treating someone unfairly in order to benefit from their work. It has been
seen that people use other people for their own benefit. Sexual exploitation is common in
organisations and it is a serious offence on NAB (Ransom and Oaxaca, 2010). Exploitation in
NAB includes various offence such as Actual or attempted abuse, sexual harassment or
purposes, using power for exploiting others, sexual abuse, threatening or profiting monetarily
to other, physical intrusion etc. The exploitation of workers is termed as serious offense and
any unwelcome comments, unfair behaviour, or taking advantage of other employees will not
be accepted in any case in any branches of NAB (National Australia Bank, 2019).
Prevention of Exploitation:
The respective bodies and branch managers of NAB are responsible to ensure that there will
be no case found related to misconduct or any type of work or sexual exploitation in the
organisation. It is the responsibility of every branch manager and the whistle blower to
prevent any type of exploitation in the organisation.

Code of Conduct of NAB
Breaching:
Any unwanted behaviour of a person that includes this offence is termed as a serious offence
in the organisation, and the person will be terminated or suspended from the organisation, if
he/she found guilty. This code of conduct also involves requesting or sending, or showing
sexual or offensive messages (including phone or social media) to co-workers.
3. Corruption
Corruption shows the dishonest behaviour of a person or entity which intentionally involves
in taking bribes or give bribe for mutual benefits. National Australia Bank is responsible for
prevention of corruption in the organisation. The corrupt behaviour of involves dishonest
actions, or dishonestly failing to act that cause actual or potential financial loss for
organisation (Citron and Pasquale, 2014). Corruption involves following activities:
1. Theft of money, secret files, data, property, or physical resources.
2. Destroying documents, or concealing of documents, or deliberately falsifying.
3. Involvement in bribery case (Taking or giving bribe for personal/mutual benefits).
Prevention of Corruption
NAB takes strong actions against corrupt people. Although, NAB does not provide any
product or services to the suspected person who involved in any corruption or fraudulent
behaviour. The NAB focuses on strong ethical culture within the organisation that encourages
people to do not involve in any unethical behaviour or act. If they found to involve in any
corruption, then they will be terminated or suspended from their post. NAB have zero
tolerance policy against fraudulent behaviour and for all forms of bribery. NAB is very
sensitive to this aspect while dealing with any clients or entities regarding any business
(Amarasinghe, et.al. 2013).
Employees Responsibility
Employees of NAB should avoid any type unethical way to making money. The employees
or external stakeholders of NAB should care about that no one will involve in any unethical
behaviour in ant type of work. It is also the responsibility of employees to honestly
participate in their work and keep a dedicated approach towards the organisational success
without any cheating or fraud. The employee should aware about their responsibilities and
should be transparent towards the organisation. The employee should never offer or receive
bribe to or from any person (Preuss, 2010).

Code of Conduct of NAB
Breaching
If NAB found that any person or entity is trying to influence other party by promising or
giving anything excess of a certain value, either directly or indirectly, then bank will take
strong action against these type of people or entity. Failure of compliance of the above
corruption code of conduct policy may result in heavy penalty or even termination of
employees from the organisation. The person can also serve six months to 10 years of prison
for his corruptly behaviour or unethical act related to corruption.
4. Dishonest and Fraudulent Behaviour
Fraud is related with any dishonesty of people, or their cheating behaviour with any other
person or entity that causes financial loss for the organisation. Fraud includes destruction,
concealment, and falsification of documents or information. People usually can do fraud with
accessing secret information and use it against the bank or any entity.
Prevention of Fraud:
The best way to prevent the fraud in NAB is to foster and encourage the employees and
associate people for strong ethical and responsible culture. Apart from this, code of conduct
related to ethical behaviour policy determines the behaviour of people in the NAB. The NAB
should screening the employees behaviour and their conducts before hiring them or
commencement of employment. NAB can also take prevention activities against those who
are suspected to leak the secret information of the Bank with the help of IT policy and
surveillance system (Fetiniuc and Luchian, 2014).
Employees Responsibility:
Employees can play a key role in preventing fraud and dishonesty in the organisation. To stop
and prevent the fraud and dishonesty employees should understand the Bank policy related
and should follow the ethical behaviour. The employee should aware about their
responsibilities and should be transparent towards the organisation. The employees should
ensure themselves that they will not engage in any misconduct. The employee should never
offer or receive bribe to or from any person. (Woolworth, 2019)
Detection and Reporting of Fraud or Corruption:
If any employee or person found anything that is unethical, fraud, or dishonesty of person,
then he/she should inform the superior in the bank such as manager, or should inform their

Code of Conduct of NAB
respective branch head about the dishonesty or bribery. One thing should be remembered that
hiding one’s fraud is also belongs to fraudulent behaviour of person (National Australia
Bank, 2019).
Breaching:
Breaching of policy or failure to comply the fraudulent policy may result in substantial fine
and penalties on the fraud person. The major damage of financial resources or any damage to
company may result in direct termination of employees and even prison according to
Australian Penal Court.
5. Whistle-blower Protections
Whistle blower practice in NAB is implemented that helps employees to raise any issue or
concerns against any malpractice such as immoral, unethical practices, sexual harassment,
exploitation of employees, discrimination, fraud, corruption, breaches of copyright or paten
etc. (Wesfarmers, 2018). The Whistle blower policy protect the personal interest of
organisational people in NAB as well. It outlines the reporting procedures and investigation
mechanism to be follows in case of any misconduct behaviour of misleading activity in NAB.
Whistle blower provide security to both employees and employers as it provides them
protection in two areas- confidentiality and against retaliation. Whistle-blower ensures that
every employee of the NAB can raise the concern freely and without fear of retaliation. The
employees can raise the concern to whistle-blower in good faith (Carr and Lewis, 2010).
Reportable matter for Whistle-blower:
1. Abuse of Authority
2. Manipulation or theft of company data/records
3. Deliberate violation of NAB law or rules and regulations
4. Breaching of company law or failure to comply NAB policy regarding employment or
anything.
5. Breaches of copyright, patent or IPR.
6. Any illegal act whether criminal/civil
7. Probable violations of the code of conduct.
Role of Whistle-blowers
The whistle blower in company is responsible for following actions and responsibilities:

Code of Conduct of NAB
1. Bring too early attention of company about any unethical or improper practice they
became aware of.
2. Whistle-blower follow the policy and code of conducts of NAB and ensure that no
one violates it.
3. Avoid any inconspicuousness when raising a concern.
4. Whistle blower is responsible for marinating full confidentiality and cooperate with
investigating authorities.
5. Whistle-blower has right to protection from retaliation, but it does not mean they will
not support in any matter of investigation.
6. The whistle-blower officer provide protection to employees from any malicious
allegations.
7. If the whistle blower is not agreed with the investigation result upon any case, he/she
can raise the issue in front of the chairman of the NAB.
Whistle-blower Officer Vs. Investigating Team
Whistle-blower officer Investigating Team
1. Safeguarding and arranging
documents related to any
investigation or complaints etc.
2. Maintain confidentiality
3. Maintain register of issues
4. Act as a secretary of ombudsperson
5. Protect the employees from any
malfunction or discrimination and
listen their problem with
maintaining the secrecy.
1. Responsible for conducting
enquiries on the issues in fair and
unbiased manner.
2. Responsible for complete fact
findings
3. Responsible for Maintaining harsh
confidentiality
4. Find out whether the unethical
activity is committed or not, and if
yes then by whom?
5. Recommend the company about
taking appropriate actions
(suggested disciplinary actions such
as suspension, penalties,
termination, etc) (Meng & Fook,
2011).
6. Provide relevant information and
documents to whistle officer related
to inquiry.

Code of Conduct of NAB
6. Enforcement
The code of conduct of NAB is a cultural foundation of the company and it is essential for
everyone to follow this code of conducts and organisational policies. NAB promoted the
Code of conduct and its various policies and urge people for adherence to it. The authorities
and activities are also determined by the code of conduct that how one should behave and act
in the organisation. Enforcement of the company ensures that people follow the code of
conduct and act ethically in the organisation. Enforcement of the code of conduct
communicates the importance of code of conducts to the NAB employees and ensures that
people will follow the ethical way in the organisation. For example, the various branch
manager of NAB can use the code as a guiding force for employees and ensure their
commitment for the enforcement (Williams and Adams, 2013).
Enforcement officer ensures a legal behaviour of employees in the company by a clear threat
for violating the code of conducts. Although NAB provides training programs for its
employees to follow the company’s code of conducts that helps to set a basic cultural norm
for everyone in the organisation.

Code of Conduct of NAB
References
Amarasinghe, M., Tan, H., Larkin, S., Ruggeri, B., Lobo, S., Brittain, P., Broadbent, M.,
Baggaley, M. and Schumann, G. (2013) Banking the brain: Addressing the ethical challenges
of a mental‐health biobank. EMBO reports, 14(5), pp.400-404.
Behal, R.P. (2018) Discrimination of Women in Labour Force. Summerhill, 5(2), pp.19-20.
Carr, I. and Lewis, D. (2010) Combating corruption through employment law and
whistleblower protection. Industrial Law Journal, 39(1), pp.52-81.
Citron, D.K. and Pasquale, F. (2014) The scored society: Due process for automated
predictions. Wash. L. Rev., 89, p.1.
Dengate, C. (2018) LinkedIn Top Companies 2018: Where Australia wants to work now
[online]. Available from: https://www.linkedin.com/pulse/linkedin-top-companies-2018-
where-australia-wants-work-cayla-dengate [Accessed: 24/04/2019]
Fetiniuc, V. and Luchian, I., (2014) Banking ethics: main conceptions and problems. Annals
of the University of Petroşani. Economics , 14, pp.91-102.
Meng, T. P., & Fook, O. S. (2011). Comparative analysis of whistleblower protection
legislations in England, USA and Malaysia. African Journal of Business Management, 5(27),
11246-11255.
National Australia Bank (2019) About us: Our Business at a glance [online]. Available from:
https://www.nab.com.au/about-us/our-business-at-a-glance [Accessed: 24/04/2019].
National Australia Bank (2019) Code of Conducts [online]. Available from:
https://www.nab.com.au/content/dam/nabrwd/documents/policy/corporate/code-of-
conduct.pdf [Accessed: 24/04/2019].
Preuss, L., (2010) Codes of conduct in organisational context: From cascade to lattice-work
of codes. Journal of Business Ethics, 94(4), pp.471-487.
Ransom, M.R. and Oaxaca, R.L. (2010) New market power models and sex differences in
pay. Journal of Labor Economics, 28(2), pp.267-289.

Code of Conduct of NAB
Stockland (2018) Corporate Governance [online]. Available from:
https://www.stockland.com.au/about-stockland/corporate-governance [Accessed:
24/04/2019].
Wesfarmers (2018) Code of conducts [online]. Available from:
https://www.wesfarmers.com.au/docs/default-source/corporate-governance/code-of-
conduct---may-2015.pdf?sfvrsn=8 [Accessed: 24/04/2019].
Williams, S.J. and Adams, C.A. (2013) Moral accounting? Employee disclosures from a
stakeholder accountability perspective. Accounting, Auditing & Accountability
Journal, 26(3), pp.449-495.
Woolworth (2019) Our Code of Conduct: Creating better experience together [online].
Available from:
https://www.woolworthsgroup.com.au/icms_docs/183764_Code_of_Conduct.pdf [Accessed:
24/04/2019].