MBA402: Analysis of ANZ Bank Corporate Governance and Code of Conduct

This report delves into the corporate governance landscape of ANZ Bank, examining recent news articles and information to identify key issues. The analysis focuses on the bank's governance structure, ethical practices, and sustainability initiatives. A significant portion of the report is dedicated to drafting a comprehensive code of conduct for ANZ Bank, addressing critical areas such as discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement mechanisms. The code incorporates principles of ethical conduct and compliance with relevant laws and regulations. The report also provides a background of the company and discusses corporate governance issues. The assignment is based on recent news articles describing corporate governance issues and provides a detailed analysis of the issues and a proposed code of conduct.

Running Head: GOVERNANCE ETHICS AND SUSTAINABILITY
GOVERNANCE ETHICS AND SUSTAINABILITY
Name of the Student
Name of the University
Author Note

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Table of Contents
Introduction................................................................................................................................2
Background of Company.......................................................................................................2
Discussion..................................................................................................................................2
Corporate Governance...........................................................................................................2
Corporate Governance Issues at ANZ Bank..........................................................................3
Code of Conduct....................................................................................................................4
Draft of Code of Conduct at ANZ..........................................................................................5
Conclusion..................................................................................................................................7
Reference....................................................................................................................................9

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Introduction
Corporate governance is structure of the practices, rules and processes that are used
for managing and directing the company. This term encompasses external and internal
factors, which affects interest of the firm’s stakeholders, including customers, shareholders,
suppliers, management and government regulators. The sustainability practices focuses to
meet needs of the present without compromising future generations’ ability for meeting their
needs. Further, the term sustainability is comprised of three major pillars, which consists of
social, environmental and economic that is also informally known to be people, planet and
profit (Tricker and Tricker 2015). Hence, this report aims to discuss corporate governance
issues at ANZ Bank. Further, code of conduct will be drafted for ANZ Bank.
Background of Company
The Australia and New Zealand Banking Group Limited is also termed as ANZ. It is
the financial services and the banking firm that is headquartered in Melbourne. ANZ is third
largest bank in the market capitalization terms of the Australia and it is second largest bank in
assets terms. It offers ranges of the business financial solutions and personal solutions. The
services of bank includes internet banking, personal banking, foreign exchanges, personal
accounts, insurance, loans and credit cards (Anz.com. 2020).
Discussion
Corporate Governance
Corporate governance is defined as the set of principles, systems as well as processes,
with the help of which firm is governed. It provides the guidelines regarding the way firm can
be controlled or directed, which ultimately helps in fulfilling objectives and goals in manner
that it adds value of company. It is also beneficial for all the stakeholders in longer-run. The
firm’s management plays the role of trustee for others (Hermalin 2014). The principles on

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which corporate governance is based includes conducting business with fairness and
integrity, making all the necessary decisions and the disclosures, being transparent in relation
to all transactions, responsibility and accountability towards stakeholders and the
commitment towards conducting the business in the ethical manner as well as compliance
with all laws of land. It ensures the transparency that helps in maintaining balanced and
strong economic development. There is broader scope of corporate governance. This is
consists of both institutional and social aspects. It encourages morality, trustworthy and
ethical environment (Yermack 2017).
Corporate Governance Issues at ANZ Bank
The investigation was conducted by ASIC into rate-rigging in the Australia and there
was closely looking at the global markets team of ANZ, which was led by Steve Bellotti. It
was with joining of Steve Bellotti in 2010, he had earned colorful status as successful banker
of investment all across world. He was quite successful. He started loving money and was
good to make it. He rented Caribbean island of Richard Branson at cost of $40,000 for the
day of his wedding (Anz.com. 2020). The 40th birthday of Mr. Bellotti have lasted for three
weeks. He was hired for leading global markets team of ANZ. According to one of the
employee, “The Boardroom” become club because one can get their one-to-one time with
their boss there rather than in the office. Moreover, he instituted strategy, which was known
as “three in three”. In this particular strategy he aimed for lifting revenue to $3 billion.
During 2011, there was hiring of new trader, whose name was Etienne Alexiou. Moreover, he
took the senior role of trading in company. Almost immediately, he got the feeling that there
was something quite different at ANZ. The very first thing that has caught his attention was
talk regarding the trading-floor regarding “slaughtering the rate” (ABC News. 2019).
The 180-page court document filed by ASIC contained extracts of the emails and the
other evidences. This also included allegations by the ASIC that thirty eight employees of

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ANZ had involvement in and knowledge of the alleged manipulations of rate. This has
ranged relatively from the junior traders up to senior executives of bank, which includes Mr
Bellotti as well as Shayne Elliott. In addition, most of the employees, who has been named in
the court document as accused of involvement in or having the knowledge of alleged rate
manipulations were employed in global market divisions (Leipziger 2017).
The result of this was suspension of Mr. Alexiou at bank. Eventually, he got fired.
However, his termination was nothing to do with scandal of BBSW. Instead, Alexiou was
dismissed for the reason of making the lascivious remarks on internal system of messaging of
the bank. The learning of background briefing of those transcript were redacted and the full
versions has never became public. Further, releasing of snippets out of the context has given
conversations very diverse set of meanings (Samra 2016). He said that he was depicted as
person of lower moral character, homophobe, misogynist and racist. Further, Mr. O’Connor
was also asked to come in meeting and got terminated after accusations of misusing the credit
card. The bank confronted him with the receipts that showed that he has sold for $18,000 that
was worth of the rare coins. In addition, Mr. Bellotti resigned within the year of the BBSW
scandal of ANZ becoming public (Jizi et al. 2014).
ANZ gives the statement in the interview that when evidence is being provided
regarding breaching of the code of conduct, the company takes necessary disciplinary actions.
It is consists of dismissal, formal warnings and for the more senior staff, the bonuses are
scraped back. Just a year after allegations surfaced, the boss of Mr. Bellotti became chief
executive (Anz.com. 2020).
Code of Conduct
Code of conduct is the document that is voluntarily written up by firm, in which set of
principles are set out, which company commit itself for follow or it requires their employees

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to file. In some of the cases, codes of conduct reaches subcontractors, suppliers and third
parties. It helps in enumerating those values and standards, which makes the firm remarkable
and enable it for standing out from the similar firm. Code of ethics and the professional
conduct helps in outlining ethical principles, which governs behavior and decisions at
organization. The code of conduct of company sets forth its shared responsibilities, global
commitments, core values and the promises. The heart as well as soul of firm is defined by its
value (Chan, Watson and Woodliff 2014).
Draft of Code of Conduct at ANZ
 Discrimination: Discrimination is defined as treating less favorably someone because
of the protected attributes. The examples to treat someone in the less favorably way
includes limiting the access towards training or other kind of benefits, ending the
employment of someone and not prompting some one. Further, examples of the
protected attributes that is not the reason to treat someone less favorably is consists of
age, disability, religion, nationality, sexual orientation, gender, relationship status and
others. The employees should understand that any kind of discrimination is not
allowed. ANZ should always be open towards different and open approaches and
doing the businesses in number of countries with the different cultures (Leipziger
2017). The bank should be committed towards equal and fair treatment of all the
people and employees, who seeks employment at ANZ, including equal opportunities
for the advancement and development. The bank should not tolerate any kind of the
harassment or discrimination in workplace. The policy of ANZ should be to ensure
that employees’ behavior does not discriminate against the grounds of gender,
ethnicity, religion, national origin or any other relevant characteristic that is being
protected under applicable law (Liu et al. 2015).

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 Exploitation: The employees should not be exploited for their personal gain. It
involves opportunities, which are discovered through uses of corporate information,
property or position. The executives of the company should not be make uses of
firm’s information, properties or positions and should not be exploited, until and
unless there is fully disclosure of opportunity to board of directors and board of
company accord its approval for pursuing such type of opportunity (Van Amstel and
Rodenhäuser 2016).
 Corruption: The corruption inevitably leads towards diminished climate of business
when trust of people is being put at risk. It is dishonest behavior those individuals,
who are in the position of power. ANZ should not support or tolerate any kind of
corrupt or fraudulent activity. It damages the reputation, undermines social and
political stability, human rights and security of company. This policy has the purpose
for setting out the approach of ANZ towards corruption and fraud and relevant
employee obligations and guidance (Buzatu 2015).
 Dishonest and Fraudulent Behavior: Fraudulent is the dishonest activity that causes
potential or actual financial losses to entity or person including theft. This includes
concealment, destruction and falsification of the documents and improper use of the
position or information for the personal financial gain. ANZ should not entertain any
kind of fraudulent activities in the organization. The employees of ANZ should be
alert towards the behavior that indicate any kind of fraudulent activities. They should
be strongly encouraged for reporting any kind of dishonest and fraudulent behavior
going around them (Mamic 2017).
 Whistleblower Protections: The program of Whistleblower protection helps in
investigating claims of retaliation against the employees for the engagement in
different types of the protected activities. ANZ should be committed towards

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committing business ethically, integrity and with the consideration of expectations of
the stakeholders. The bank should highly encourage all the former and current
stakeholders and employees for raising any kind of concerns over any kind of alleged
conduct or state of affairs they use to encounter. The main purpose of whistleblower
protection policy is for raising concerns about the unacceptable behavior, by
clarifying with the person to whom there is disclosure of content and the way they ate
being made. The bank will also offers protection from disciplinary proceedings or
harassment and victimization (Salin and Ismail 2015).
 Enforcement: The ethical responsibility of all board of directors is helping to enforce
code. They are required to be alert to possible violations and management should be
reported about this. The threat, reprisal, retaliation or retribution against any person
who is in good faith has reported violation or suspended law violation, this policies of
other company or code against the person, who is assisting in any process or
investigation with the respect to such type of violation is being prohibited (Khuong
and Hoang 2015). Further, the part of employees’ job and their ethical responsibility
is helping to enforce business ethics and code of conduct. Further, the employees are
required to be alert regarding possible violations and possible violations should be
reported. Moreover, the employees should also cooperate in any kind of external and
internal investigations of the possible violations (Capua 2016).
Conclusion
Therefore, this report concludes that mechanism of good corporate governance helps
in ensuring the growth of economy and success of corporate. In addition, it helps to maintain
confidence of investor, as result of which firm can raise the capital effectively as well as
efficiently. It has been analyzed that good level of corporate governance minimizes
mismanagement, risks, corruption and wastages. It ensures that firm is managed in the

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manner that fits best interest of all. Further, this report has found corporate governance issues
of ANZ. It has been found that senior executives were involves in the alleged manipulations.
Almost thirty eight employees of ANZ were involved in alleged manipulation of rate. In this
regard, ANZ is in the view that whenever the evidence is being provided that code of conduct
of the company is breached then in that particular case, appropriate disciplinary action would
be taken. This may include formal dismissal, warnings and for the more senior staff, the
bonuses being scraped back. In addition, this report has analyzed has drafted code of conduct
for ANZ, which includes addressing principles for discrimination, exploitation, corruption,
dishonesty and fraudulent behavior, whistleblower protections and enforcement.

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Reference
ABC News. 2019. The 'Slaughter' House: ANZ's plans to thwart one of Australia's biggest-
ever financial investigations. Retrieved 6 January 2020, from
https://www.abc.net.au/news/2019-05-24/the-slaughter-house-anz-banks-plans-to-thwart-
investigation/9516708
Anz.com. 2020. Retrieved 6 January 2020, from
https://www.anz.com/documents/au/aboutanz/Code_of_Conduct_Non-Exec.pdf
Buzatu, A.M., 2015. Towards an international code of conduct for private security providers:
a view from inside a multistakeholder process (p. 61). Ubiquity Press.
Capua, I., 2016. Data sharing: a code of conduct for data on epidemics. Nature, 534(7607),
p.326.
Chan, M.C., Watson, J. and Woodliff, D., 2014. Corporate governance quality and CSR
disclosures. Journal of Business Ethics, 125(1), pp.59-73.
Hermalin, B.E., 2014. Transparency and corporate governance. In Enterprise Law. Edward
Elgar Publishing.
Jizi, M.I., Salama, A., Dixon, R. and Stratling, R., 2014. Corporate governance and corporate
social responsibility disclosure: Evidence from the US banking sector. Journal of business
ethics, 125(4), pp.601-615.
Khuong, M.N. and Hoang, D.T., 2015. The effects of leadership styles on employee
motivation in auditing companies in Ho Chi Minh City, Vietnam. International Journal of
Trade, Economics and Finance, 6(4), p.210.
Leipziger, D., 2017. The corporate responsibility code book. Routledge.

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Liu, C.C., Yu, Y.H., Wernick, I. and Chang, C.Y., 2015. Using the electronic industry code
of conduct to evaluate green supply chain management: An empirical study of Taiwan’s
computer industry. Sustainability, 7(3), pp.2787-2803.
Mamic, I., 2017. Implementing codes of conduct: How businesses manage social
performance in global supply chains. Routledge.
Salin, A.S.A.P. and Ismail, Z., 2015, August. Ethics practices of Malaysian public listed
companies-Empirical evidence. In 10th Annual London Business Research Conference (pp.
10-11).
Samra, E., 2016. Corporate governance in Islamic financial institutions.
Tricker, R.B. and Tricker, R.I., 2015. Corporate governance: Principles, policies, and
practices. Oxford University Press, USA.
Van Amstel, N. and Rodenhäuser, T., 2016. The Montreux Documents and the International
Code of Conduct: Understanding the Relationship between International Initiatives to
Regulate the Global Private Security Industry. Available at SSRN 2763932.
Yermack, D., 2017. Corporate governance and blockchains. Review of Finance, 21(1), pp.7-
31.