MBA402: Governance, Ethics and Sustainability - ANZ Bank Code

This report presents a detailed Code of Conduct for ANZ Bank, addressing critical aspects of ethical business practices. It begins with an overview of the code's purpose, emphasizing its alignment with corporate governance and ethical standards. The report meticulously covers key areas such as discrimination, defining unlawful practices and promoting workplace diversity, and exploitation, highlighting the bank's commitment to employee well-being and fair treatment. It further examines corruption, outlining prohibited activities and the bank's anti-corruption policy. Dishonest and fraudulent behavior is addressed, with specific examples of unacceptable conduct and the implementation of audits to ensure compliance. The report also details whistleblower protection mechanisms, ensuring confidentiality and offering multiple reporting channels. Finally, the report outlines enforcement measures, including penalties for breaches, and provides contact information for the ethics committee and senior management. The report is based on research of news articles and other information about ANZ Bank and includes references to academic journals and textbooks.

Code of Conduct
Australia and New Zealand Banking Group
Student Name
12/28/2019

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Contents
Overview....................................................................................................................................2
Discrimination............................................................................................................................2
Exploitation................................................................................................................................3
Corruption..................................................................................................................................4
Dishonest and Fraudulent behavior............................................................................................5
Whistleblower protection...........................................................................................................6
Confidentiality and record-keeping............................................................................................7
Enforcement...............................................................................................................................7
References..................................................................................................................................9

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Overview
This code of conduct is a reflection of the practice adopted by ANZ bank (hereinafter
mentioned as ANZ or the bank) to its stakeholders. The code has been designed considering
aspects of ethics and corporate governance and should be read along with the separate policy
documents of the company, which address some particular issues in detail. The code has
addressed many issues such as discrimination, exploitation, Whistleblower protection, and
others to develop a healthy and ethical organizational culture. By looking after this code, a
person may get an idea of vision, mission and goal statement of the bank. The code is
detailed as below:-
Discrimination
Discrimination is a situation, which seems to exist when different employer deals with
different workers/employee differently. Mainly two types of discrimination are there such as
lawful and unlawful discrimination (fairwork.gov.au, 2019). ANZ prohibits all forms of
unlawful discrimination that includes discrimination based on age, gender, ethnic or social
origin, marital status or any other basis that may have a purpose to treat people unfairly or
unjustly (Schermerhorn et. al, 2019). ANZ staff members are required to respect diversity in
the workplace and all the practices of favoritism shall be prevented. No manager or employee
or any other staff member may not favor particular groups over others, especially during
following conducts:-
Recruitment
Promotions
Appreciation

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Transfer
ANZ has a clear policy that prevents the appointment of family members by mangers and
officials of the company. The company wants to inform the stakeholders that we do not only
oppose a direct form of discrimination but also the indirect one. It is the liability of ANZ
personnel to be fair in their dealings and to treat every subordinate in an equal manner unless
there is a fairground to treat them differently exists there. We are allowed to treat two
employees differently if the matter is related to risk or quality of work. We trust being an
ethical employer and therefore comply with the provisions of the Equal Opportunity Act
2010 in all of our dealings. We understand the adverse consequences of unfair discrimination
and therefore do not tolerate any practices that support such actions.
Exploitation
For ANZ, human resources are a valuable asset and we provide a healthy environment of
working. Exploitation exists when one person takes advantage of others to gain personal
profit (Dalla and Sabella, 2019). We demotivate the practice of exploitation of our employees
and treat them similar to a family. Financial targets are an important aspect but ANZ does
equally consider the efforts and time of employees. Not only the employees but the interest of
other stakeholders are equally considerable and therefore ANZ fairly treats them. We cannot
see our long-term progress without the happiness and satisfaction of employees. To ensure
that no employee or other stakeholders are being exploited, the company prohibits the
following practices:-
Forcing employees or other staff members to do work even on holidays
Forcing employees or any other stakeholders for participating in sexual activities
Not paying salaries on time

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Not paying remuneration for overtime
Providing task to employees that do not correspond with them
Assigning Job for which an employee is not qualified
To reduce the exploitation at the workplace, the company provides holidays to its employees
as per the applicable laws. Further ANZ complies with national employment standards
whereby the same ensure providing minimum rights to every of ANZ staff personnel. We
provide fair remuneration to all employees according to their qualifications. Further, the bank
also ensures no employee is mentally harassed to achieve given targets and required support
is always available to them. The company has developed a structure whereby employees can
make a complaint against any of the incidents of sexual or another kind of exploitation to its
ethics and governance compliance.
Corruption
Corruption is nothing but misusing one's position in the organization to gain personal benefits
(Goldsmith, Halsey and Groves, 2016). The term corruption seems to be associated with
higher management but the same is not correct as corruption can exist at any level of
management or organizational hierarchy. In general, a confirmed number of activities are not
there which can be treated as corruption. However, ANZ identified some of the acts that shall
be considered as corruption. These activities mainly include taking bribe in monetary form or
otherwise. Every ANZ personnel have the responsibility of not taking or offering such bribe
during the performance of their duties. This code of conduct has been developed to ensure
ethical practices and in this manner, any activity that may lead to corruption in the bank shall
be treated as a breach of this code. The bank pays remuneration according to the applicable
standards and therefore personnel is required to perform their duties for the same. Any

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additional direct payments received from our client or any other benefit received from
stakeholders without information of the Bank shall be treated as corrupted conduct of the
employee.
ANZ also has developed additional documents to reduce and remove corruption from the
workplace in the form of an anti-corruption policy. If any of the staff members are offered
bribe then they are required to not to accept it unless immediate safety of them is in jeopardy.
To maintain the best practices in the best place, the audit and executive council shall review
the content of the anti-corruption policy every 3 years.
Dishonest and Fraudulent behavior
Corruption is a narrow term and to cover all the aspects of ethics, ANZ has also made
provisions regarding the prevention of other types of dishonest behavior. Moral character is
the foremost necessary element for our organization and unethical behavior of anyone shall
not be tolerated. ANZ expects that every staff member shall be honest in his/her performance
considering the best interest of the bank. To provide clarification about our expectations from
staff personnel, the bank has identified activities as dishonest and fraudulent behavior. In
general, followings are considered as fraud and dishonest behavior
Contracting in personal name
Use of bank's confidential information for self-benefit
Taking credit of other's works
Theft of money
Falsification in accounts (Padgett, 2014)
Claiming excess money in against of office expenditure
Taking unrecorded vacations and leaves

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Assets misappropriation
Other payroll and accounting fraud (Lomer, 2017)
These activities are only a few out of money and other actions of staff personnel can also be
treated as fraudulent and dishonesty if the ethics committee of the company decides so. To
develop ethical work culture, ANZ made it compulsory for every department head to conduct
timely audits of activities of team members. No one is allowed to make any secret profits at
organizational cost and if any person would be found doing this, then the same shall be
answerable to immediate senior as well as ethics committee of the company. Further penalties
shall be imposed on such a person considering the seriousness of the behavior. Employees, as
well as every other stakeholder, should feel free to report dishonest behavior of any ANZ
personnel.
Whistleblower protection
An activity whereby one person reports the issue of unethical to the authority or brings the
same into the knowledge of others is known as whistleblowing. The person who did this
activity is known as a whistleblower. In general, a whistleblower is likely to encounter many
types of risks such as a threat to life, dismissal from a job, workplace harassment and others
(Sweeney, 2019). To avoid such situations and to provide better protection to whistleblowers,
ANZ has covered this area as well in its code of conduct. The bank believes that it is one of
its responsibility to ensure that no whistleblower come across to any of the said issues. The
bank offers two easy processes through which whistleblowing can be done. First is reporting
to the immediate senior and another one is reporting to the ethics committee of the company.
For employees, it is advisable to report the issue to immediate senior as it is a close, fast and
confidential mode. Being an Australian company registered with the Australian Securities
and Investments Commission, we need to comply with the provisions of the Corporations Act

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2001 (Cth). The act also provides provisions related to whistleblower protection and hence
company needs to protect its whistleblowers against criminal prosecution, civil litigations and
administrative actions to submission of whistleblower disclosures (asic.gov.au, 2019)
The company also protects its stakeholders from detriments. It means you should be feel
protected if you did not make any whistleblower disclosure but someone detriments to you
due to the reason of suspect. The bank ensures to keep the whole process confidential and one
needs not to care for disclosure of identity or matter. A panel of ethics committee ensures that
any reporting is shared with only those who are relevant to the case. Any person found to
causing loss or threat to a whistleblower can liable for dismissal.
Confidentiality and record-keeping
During the work, an employee comes across confidential information of the company as well
as of its customers hence we expect that all the staff members shall use such information only
to do their jobs for ANZ. Further staff members also need to know that they are not allowed
to share such information even with their colleagues except the cases of "need to know". The
bank complies with the provisions of the Privacy Act 1988 (Cth) and therefore is liable to act
accordingly. These are the employee of the company who deals with such information in
their routines hence they are liable to behave ethically and professionally keeping the
information confidential. The company also arranges data handing training for its employees
on a timely basis. Personnel also have a liability to maintain record related to business
operations and to keep them secured.
Enforcement
The above-mentioned provisions are strictly applicable to all of its stakeholders. The code
applies whenever a person is identified as a representative of ANZ bank, that includes outside

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working hours or workplace. Any breach with this code attracts a minimum monetary penalty
worth up to $500. This penalty may go high considering the consequence of the breach.
Every ANZ shareholder is protected under this code and in case of any breach, reporting can
be made to the ethics committee using contact number or e-mail id of the same which is
mentioned at the bottom of this code. As an alternative option, stakeholders may directly
approach senior management of the bank by writing a letter to the corporate office of ANZ,
the address of which is also mentioned at the end of the code.
Contact details of the ethics committee
Contact number [phone]
Email:;- [e-mail]
Contact details of senior officers
331-339 Bourke St, Melbourne VIC 3000, Australia

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References
Asic.gov.au. (2019) Whistleblower rights and protections. [online] Available from:
https://asic.gov.au/about-asic/asic-investigations-and-enforcement/whistleblowing/
whistleblower-rights-and-protections/#protection-info [Accessed on 28/12/2019]
Corporations Act 2001 (Cth)
Dalla, R., L. and Sabella, D. (2019) Routledge International Handbook of Human
Trafficking: A Multi-Disciplinary and Applied Approach. Oxon: Routledge.
Equal Opportunity Act 2010
fairwork.gov.au. (2019) Workplace discrimination. https://www.fairwork.gov.au/how-we-
will-help/templates-and-guides/fact-sheets/rights-and-obligations/workplace-discrimination
Goldsmith, A., Halsey, M., and Groves, A. (2016) Tackling Correctional Corruptions.
Australia: Springer.
Lomer, D. (2017) 41 Types of Fraud and How to Detect and Prevent Them. [online]
Available from: https://i-sight.com/resources/41-types-of-fraud-and-how-to-detect-and-
prevent-them/ [Accessed on 28/12/2019]
Padgett, S. (2014) Profiling The Fraudster: Removing the Mask to Prevent and Detect Fraud.
Canada: John Wiley & Sons.
Privacy Act 1988
Schermerhorn, J., R., Davidson, J., P., r Woods, P., Factor, A., Junaid, F., McBarron, E.
(2019) Management. Australia: John Wiley & Sons.
Sweeney, H., M. (2019) The Professional Paranoid. Lulu.com.