Comprehensive Code of Conduct Report: ANZ Bank's Ethical Guidelines

This report presents a detailed Code of Conduct for ANZ Bank, addressing crucial aspects of ethical business practices. It covers key areas such as discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protection, and enforcement. The document emphasizes the importance of ethical conduct for all stakeholders, including employees, managers, customers, and suppliers. The report outlines core principles like upholding ethical standards, respecting all stakeholders, and adhering to applicable laws. It details how the code's effectiveness is ensured through regular reviews and employee confirmations. Specific sections address using information technology responsibly, preventing discrimination, and prohibiting exploitation. The code strictly prohibits corruption, bribery, and dishonest behavior, including fraud and money laundering. It also provides robust whistleblower protection mechanisms. The report concludes with a clear enforcement section, outlining potential penalties for breaches of the code and providing contact information for reporting violations. This report aims to provide a comprehensive understanding of ANZ Bank's commitment to ethical conduct and corporate governance.

Running Head: ANZ Code of Conduct 0
Code of Conduct
ANZ
Student’s Name
12/30/2019

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Contents
About the code of conduct...............................................................................................................1
Using the code.................................................................................................................................2
Our core principles..........................................................................................................................2
How we ensure the effectiveness of the code..................................................................................2
Using information technology.........................................................................................................3
Discrimination.................................................................................................................................4
Exploitation......................................................................................................................................5
Corruption........................................................................................................................................6
Dishonest and Fraudulent behavior.................................................................................................7
Whistleblower protection.................................................................................................................8
Enforcement.....................................................................................................................................8
References......................................................................................................................................10

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About the code of conduct
Whether a person is an employee, manager, worker, customer, or a supplier of ANZ, this
document is significant as the same set out guiding principles for working with the ANZ bank
(ANZ or bank or company) to encourage an inclusive workplace. It is the responsibility of every
stakeholder of ANZ to comply with this code of conduct and motivate others to do so. The bank
made timely updation to this document as per the applicable law and changed the business
environment.
Using the code
Every section of this code stipulates the importance of the same to our company. It clearly
stipulates what is acceptable or not. We all are required to work with ethics and morality using
the principles of good judgment, integrity, and respect and considering applicable laws in
behavior. We expect our stakeholders to understand this code and to adopt the same in everyday
working. If there is anything unclear about this document, the reader should feel free to talk to
people advisory.
Our core principles
We believe to carry the business according to ethical and moral standards.
We do not negotiate with the safety of our employees and staff members to gain a
commercial advantage.

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We do not pursue any unfair trade practices.
We respect the dignity of all the stakeholders
We adhere to all the applicable laws, rules, and policies.
We expect our leaders to show their commitment to the code of conduct and to adopt the
practices accordingly.
We identify a conflict of interest and resolve the same
How we ensure the effectiveness of the code
The code is subject to under review and development on a timely basis. In the period of every 12
months, employees working with ANZ have to confirm that during the last 12 months they have
understood and complied with this code of conduct. Further, every breach of this code is required
to reported and recorded according to the procedures and policies. Trust and reputation are one
of the greatest assets we have. Stakeholders of the bank expect ANZ personnel to act in a
professional and ethical manner
Using information technology
Every team member has a responsibility to protect the information of the company as well as the
information of the customers. Privacy Act 1988 (Cth) is the legislation of the commonwealth that
outlines the standard manner to handle the private information of others by businesses (Allan,
2019). To protect information and technology within this company the following provisions have
been developed:-

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Employees are granted separate working accounts with unique passwords, which they are
not allowed to share with others.
System of any employee can be monitored
We advised employees that on receipt of any suspicious mail, they should not respond
over that and should inform the matter immediately to the in house information security
team of the bank
Employees should ensure to do the working and to use information security according to
information technology policy of the company
Discrimination
Discrimination is a situation where a person is treated less favorably than others due to one or
more protected attributes (Colella and King, 2018). These protect attributes includes age,
disability, sexual orientation, gender expression, relationship status parental status, pregnancy or
family responsibilities. Any discrimination done based on these attributes is considered unlawful
discrimination and the bank avoids the same. Australia has anti-discrimination laws such as Sex
Discrimination Act 1984, Racial Discrimination Act 1975, Age Discrimination Act 2004, and
Disability Discrimination Act 1992 (ag.gov.au, 2019). ANZ comply with all these laws in its
dealing. ANZ has clearly instructed every employee that they must not make an assumption
about any candidates based on family responsibilities. We provide equal opportunities for
employment to everyone in addition to the opportunities for further growth. Hiring and
promotion related decisions are required to be taken based on the merits of employees only. We
expect that every team leader and the senior manager would treat other employees with dignity
and respect without any discrimination. To ensure equality in employment, ANZ always

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Ensure that every employment decision such as selection, hiring, promotion, transfer are
based on merits only
Comply with all workplace-related laws and regulations to ensure this equality.
Provides facility to employees where they can speak up about the issues and experience
of the unlawful discrimination
We are committed to providing a safe and healthy workplace to our employees where they can
show their skills and therefore we do not support unlawful discrimination on any basis. Further,
this is also to inform that we identify direct as well as indirect discrimination. Indirect
discrimination at the workplace is the situation where one make unreasonable policy which is
equally applicable to all but make an unfair impact on some of the employees. We make policies
considering the interest of all the employees and while developing or implementing policies we
do not specifically focus on one or more employees.
Exploitation
Exploitation refers to a situation where one treat other unfairly to gain advantages (Sweeney and
Mitchell, 2019). Similar to discrimination, exploitation can also be lawful and unlawful. Illegal
employee exploitation is a situation where an employer denies the legal protection given to the
employer. Further legal exploitation is the one where an employer asks to do a task to
employees, which can adverse to their well-being or does not compensate them fairly but are not
explicitly illegal. We understand the value of our employees and do not exploit them.
Nevertheless, to protect employees and to make them aware, we have identified some activities,
which shall be considered as exploitation:-

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Overworking employees: - We do no ask employees for overworking unless it is a matter
of urgency. Further, we ensure to provide additional payment for such additional work.
Not allowing break: - We provide regular breaks to employees as per the employment
contract. If any manager denies giving such breaks, it shall be considered as exploitation.
Sexual exploitation: - Any sexual comment, showing pornography, or any other forms of
sexual harassment are prohibited considering them exploitation.
Deny adequate compensation: - ANZ identifies gender pay gap, unpaid internship,
refusing deserved pay rates shall be considered as exploitation.
We do not support any of these activities and to ensure no exploitation at the workplace, we
adhere to the provisions of all the applicable laws. Employees should feel free to report any
matter of exploitation to the legal department or ethics department to the company. Employees
should not feel afraid to negotiate and speak to your direct manager.
Corruption
We feel that anti-corruption law is necessary to protect the reputation of ANZ. Corruption
reinforces poverty and misallocates resources. Corruption is considered a criminal offense. To
comply with anti-corruption law, we prohibit giving or offering anything of value directly or
indirectly to any government officials. Further, we also ensure that any third party working on
our behalf is not engaged in any corrupted activities as it can lea the criminal offense
consequences to ANZ. Anti-corruption laws demand that all the transactions should record fairly
in the books of ANZ and facilitation payments should be prohibited. In addition to the
corruption, abuse of power is also restricted. No officer or employee is allowed to use the
position in the company to gain personal profits. Bribery is the lead form of corruption and no

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ANZ personnel are allowed to take any amount or gift going outside of the anti-bribery and anti-
corruption policy of the company. This policy applies to every director, employee, and contractor
of ANZ and its controlled entities. The main principles of this policy state that no person ANZ
will:-
Give, request or accept a bribe
Donate anything to drive personal benefit or benefit of ANZ out of the same
Give, or receive any gift or sponsored travel or entitlements that may lead unreasonably
to business transactions.
We understand that to perform the duties team members have to engage with an industry
association, NGO and government but they should not engage in any form of corruption or bribe.
We have identified and developed multiple channels that can be used to report any matters of
fraud, bribery, or corruption.
Dishonest and Fraudulent behavior
The company demotivates all the actions that lead to dishonesty in the behavior of our
employees. Fraud refers to an intentional act whereby one undertakes an activity for personal
gain or gains of the third party that results in loss to the organization (Hashim and Majeed,
2014). Corruption and bribery also come into the category of dishonest behavior. To prevent
dishonest and fraudulent behavior we ensure that every employee use assets for the intended
purpose. The company prevents no authorized personnel from accessing any information or asset
of the company. No ANZ personnel is allowed to enter into any illegal or fraudulent transactions
that involve assets of the company. Following activities are considered as dishonest and
fraudulent behavior:-

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Money laundering
Forgery
Misuse of customer and company information
Misappropriation or theft of cash, assets or company credit card
Irregular commission or payments
Falsification of accounting records (Schwartz, 2017)
While dealing with financial accounts or handling information or payment with respect to
record-keeping, all employees are required to deal with integrity. The above-mentioned activities
constitute fraud and liable employees may be dismissed as well as may be charged with criminal
activities. ANZ has a zero-tolerance policy with respect to such fraudulent activities and if there
are any related issues, strict actions can be taken by the company against the person who
committed default. No justification for misrepresentation or falsification of records is allowed
under the policies of the company and therefore the company shall not tolerate any creation of
misleading information.
Whistleblower protection
Whistleblowing is an activity where a person raises action against the unethical or dishonest
behavior of others. A person who pursues whistleblowing is termed as a whistleblower. ANZ
encourages accountability and integrity in the operations. A whistleblower my often face
warnings of exploitation due to raising a voice against wrong and therefore ANZ takes
responsibility to protect such people. We ensure to developing and providing a reporting
structure where our employees can freely raise a concern about any dishonest or unethical

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conduct without any fear. Further, we also expect that all the employees or contractor or any
other staff member who disclose whistleblowing shall do the same in good faith acting honestly
and ethically. The bank ensures that a whistleblower who reports a concern or any other person
who takes part in an investigation process is safe and not victimized as well as disadvantaged.
Australian Securities and Investments Commission outline some protection for whistleblowers in
referring to Corporations Act 2001 (Cth). ANZ also complies with these provisions and provides
a safeguard to whistleblowers against criminal or civil charges.
Enforcement
This code of conduct is enforced to all the ANZ personnel complying with all the applicable laws
and rules over the company. All the sections of this code apply to staff members in a mandatory
manner. Breach of any of the provisions of this code may attract monetary as well as other
penalties. Incidents of fraud and dishonest behavior are subject to dismissal of a liable person.
Further, we expect you to speak up if come across any breach of this code. Such a breach can be
reported to the following:-
Supervisor
Department head
Ethics committee
Compliance officer
Whistleblower protection officer
In case of any queries related to this code, you may approach to the compliance department of
ANZ who contributed to the making of this report.

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References
ag.gov.au. (2019) Australia’s anti-discrimination law. [online] Available from:
https://www.ag.gov.au/RightsAndProtections/HumanRights/Pages/Australias-Anti-
Discrimination-Law.aspx [Accessed on 31/12/2019]
Age Discrimination Act 2004
Allan, S., (2019) Law and Ethics for Health Practitioners – eBook. Australia: Elsevier Health
Sciences.
Colella, A., and King, E. (2018) The Oxford Handbook of Workplace Discrimination. USA:
Oxford University Press.
Corporations Act 2001 (Cth)
Disability Discrimination Act 1992.
Hashim, R., and Majeed, A., B., A. (2014) Proceedings of the Colloquium on Administrative
Science and Technology: CoAST 2013. Malaysia: Springer,.
Privacy Act 1988 (Cth)
Racial Discrimination Act 1975
Schwartz, M., S. (2017) Business Ethics: An Ethical Decision-Making Approach. John Wiley &
Sons.
Sex Discrimination Act 1984

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Sweeney, F. and Mitchell, R. (2019) Ecology, Environment and Pollution. UK: Scientific e-
Resources.