Governance, Ethics, and Sustainability: NAB Code of Conduct Report

This report provides an in-depth analysis of the Code of Conduct at National Australia Bank (NAB). It begins with an introduction to the code, emphasizing NAB's commitment to ethical and sustainable practices. The report then examines various aspects of the code, including NAB's stance on discrimination, which covers different forms of unfair treatment and its commitment to a respectful workplace. It further discusses exploitation, outlining prohibited behaviors such as harassment and bullying. The report also addresses corruption, emphasizing NAB's zero-tolerance policy, and dishonest and fraudulent behavior, detailing conflicts of interest and unethical conduct. Additionally, the report covers whistleblower protections, outlining the procedures for reporting misconduct and the measures taken to protect whistleblowers. Finally, the report describes the enforcement of the Code of Conduct, including the consequences of non-compliance. The conclusion reiterates the importance of adherence to the code by all employees and stakeholders.

Running head: CODE OF CONDUCT 1
Governance, Ethics and Sustainability
Student details:
4/28/2019

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Code of Conduct
Contents

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Introduction......................................................................................................................................4
Overview of National Australia Bank.............................................................................................4
Discrimination.................................................................................................................................5
Exploitation......................................................................................................................................6
Corruption........................................................................................................................................7
Dishonest and Fraudulent Behavior.................................................................................................8
Whistle blower protections..............................................................................................................9
Enforcement.....................................................................................................................................9
Conclusion.....................................................................................................................................10
References......................................................................................................................................10

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Introduction
The code of conduct of company refers to the set of the procedures and regulations defining the
social norms, rule related to religious and responsibilities of, and or appropriate exercise for the
people. An organisation’s code of conduct, which is made for the employees of the organisation,
secures the business and provides the data to the workers in respect of the expectation of
employees of company. In the following parts, the code of conduct of National Australia Bank is
discussed and assessed. The National Australia Bank is committed for providing the social
contribution, financial assistance and conservational contribution to societies and relevant
policies related to the honour, dignity, fairness and justice (Jayanti, 2018). The board of
organisation had adopted code of conduct to give the set of directing the principles followed by
the employees of organisation. National Australia Bank is committed to getting sustainable
performances and rendering values to the shareholders and clients, without cooperating with
beliefs and authenticated image. It is also expected by the National Australia Bank to act always
with set of principles in the code of conduct. The code of conduct of National Australia Bank is
applicable to Board of Directors, employees and all the company’s members. This report states
the code of conduct of National Australia Bank by describing corruption, discrimination,
exploitation, enforcement and dishonest and fraudulent behaviour.
Overview of National Australia Bank
National Australia Bank Limited renders the various wide-ranging banking and financial services
such as wealth management all through Australia and New Zealand. The branches of National
Australia Bank Limited are located in United Kingdom, United States of America and Asia.
National Australia Bank Limited also accepts the transaction accounts, deposit accounts, savings

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accounts, term deposit, and specialized accounts, such as foreign currency, business’s interest,
communities free savers, farm management’s accounts and statutory beliefs. National Australia
Bank also provides the home loan, business and marketing loan agribusiness loans, personal
loan, and equipment and automobile loans.
Discrimination
The organisation is dedicated towards making the working condition, which is free from
separation, aggression and stands on the principles of the mutual respect to each other,
collaboration, discipline and self-respect. In this way, the organisation complies with numerous
state laws and central laws as well as central regulations such as Fair Work Act 2009 (Cth).
According to the meanings mentioned in the various acts, the discrimination means an action of
handling the people favourable or unfavourable on the basis of numerous physical, social, and
political characteristics. The attributes, which led to the commencement of the discriminatory
conduct and creates the services against the rules are the physical disabilities or psychological
disabilities, color, civilization, race, class, population, sexual status, marital status, foundation,
sexual category, femininity, gender identification, age and others. This is significant to note that
the discriminatory conduct may arise at the different stages of the service chain. For an example,
during the service, interviews, work’s allocation, commencement of the promotion or leadership
post, and other functions within the company. Additionally, the choice of people for objectives
of training depended on attributes as listed above also comes in the range of the discriminatory
conduct (Reamer, 2013).Thus, this is a duty of workers, management and all the members to not
get involvement in the conversation or act that create the working atmosphere unfriendly and
corrupt for other workers of company. The top level executives of organisation make sure that

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the different aspects of the employer-employee relations are free from individual biasness
depended the features stated above, and are depended on merits, personal abilities and
reasonability (Capua, 2016).
Exploitation
The code of conduct of National Australia Bank restricts the workers and officers to involve in
harassment, bullying and illegal actions. According to the section 789FD of the Fair Work
Amendment Act 2013 (Cth), bullying is an unreasonable conduct of group and people to the
employees (Fair Work Commission, 2018). It involves the conduct that develops the danger to
the protection and health. Bullying involves inclusive range of actions that are listed below. The
list is not comprehensive.
a. Use of wrong language or yell;
b. Actions leading to mental harassment;
c. Prohibition or separation of the workers
d. Conveying incredible job or pointless task unconnected to the jobs;
e. Criticizing the workers continually or overpowering the concepts, and many more these
kinds of actions (Kundu, Mazumdar and Ferket, 2017).
Further, the provisions of harassment are stated in various laws, certain are mentioned below-
The Sex Discrimination Act 1984 describes the meaning of sexual harassment in section 28A
that includes an unwanted sexual advances, unwanted behaviour that is sexually aggressive to
others, appeal for sexual favours, and more these actions. These actions lead to embarrassment or
bullying.

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Furthermore, as per section 25 of the Disability Discrimination Act 1992, the disabilities of
workers must be used as the grounds for nuisance. As per theAustralian Human Rights
Commission (AHRC), certain examples of harassment are sending sexually offensive mails or
texts, unwanted physical interaction, showing of illegal posters or ethnically violent contents,
addressing bad jokes in respect of sexual preferences or appearances of the people (Ashraf,
2018).
Corruption
The organisation works on a route of the Zero Tolerance Policy for the bribery and corruption.
The frauds and corrupt activities cover the determined falsification, stealing money, the property
or data of company, destruction or the destruction of the documents of information in the IT
system of company; and include the steps for bribery. Additionally, the bribe refers to the
activities of influencing the actions and decisions of people to attain and keep the business’s
advantages and is motivated by anything of values offered and rendered, devoted, established or
validated to accept either indirectly or indirectly, whether in economic term or not (Givati,
2016).
Furthermore, the manager and employee is not required to accept gifts, entertainment, the
incentives from current customers and future customers and suppliers if approval is not
contracted to them for this as per the guidelines of gift related to business. The managers and
workers of the organisation should be allowed to do same only with the approval of the top
management (Butler, Serra and Spagnolo, 2017). Additionally, it is regarded as the obligations of
executives and employees to report the leaders or the relevant authorities in respect of the
suspected fraud or the action related to corruption occurring in a company. This would be in an

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addition to the convincing conduct by the customers and staff quit from anti-corruption
approaches or the anti-bribery approaches of an organisation. The collapse to do this would itself
be regarded as fraud (Charania, et. al, 2017).
Dishonest and Fraudulent Behavior
The interest conflict and the resulting fraudulent conduct may take place at the different stages. It
may happen at the service level, management level and the complete group level due to the
placing of an individuals or personal interest ahead of that of clients, shareholders and the
company as the whole. Dishonest and fraudulent behaviour may occur in a form of dealing with
the vendor, customer, other corporations, connections and families. In this way, the managers
and workers should not participate in the various kinds of activities. The list mentioned as
follows, is not comprehensive.
a. Getting involvement in the professional engagement out of the company.
b. By means of the confidential data contained during a course of the service, for the
individual advantages
c. Making the business decisions in favour of himself or the family members and the
associates, which are harmful or unfavourable to the organisation’s interest
d. Using the facilities of the bank, employees or properties for the purpose of to be used in
the personal activities.
e. Taking gifts, favour, entertainments and advantages, in other than an ordinary course of
the businesses that can be in the positions of affecting businesses of the profitable
decision (Cubbage and Brooks, 2016).

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Whistle blower protections
National Australia Bank is committed to operating the business ethically and with dignity. It is
required by this organisation to meet the expectation of the stakeholders. National Australia
Bank encourages the employees and stakeholders of the organisation to raise the concerns
regarding the inadequate and wrong conduct or performance. The key target of whistle-blower
policy is to produce the ways and processes to raise the concerns regarding the unbearable
conduct in trust and faith, while also offering the protection from the sexual harassment and the
oppressions. The whistle blowing policy of the organisation is relevant to the National Australia
Bank Limited group, company and other branches, and the workers of organisation. It is required
by all to adopt whistle-blower policy forcibly.There are certain main Principles to direct this
Whistle-blower policy (Gao and Brink, 2017). The key principles to direct the approaches in
respect of the whistle-blowers are below-
1. Raise concerns- if the stakeholders and workers of organisation are careful for the wrong
conducts, then they should raise the concerns to the risks team of organisation by e-mail
and to WPO through e-mail (Heilman and Manzi, 2016).
2. Improper behaviour- according to the whistle-blower policy, an organisation would
consider following to be immoral conduct-
a. Unsafe work environment
b. Illegal conduct
c. Sexual harassment

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3. Raise concerns in secret manner- the stakeholders and workers of organisation who
would wish to raise the concerns regarding unproven immoral conduct can covertly
contact WPO of the National Australia Bank through the organisation’s intranet or the
organisation’s website.
4. Give protection to whistle-blowers- according to the whistle-blower policy of company,
WPOs will be liable to protect the whistle-blower’s interest. The organisation is
committed to make necessary steps and protects the whist blower’s interest (Garland-
McLellan, 2015).
5. Procedures related to investigation- WPOs are accountable to make sure that whistle-
blowers of the organisation are notified of how grievances are following and resulting.
The organisation is committed to make alterations in internal procedure and taking
actions in respect of the employees who have made inappropriate conduct.
6. Untrue claims- according to organisation’s code of conduct, the organisation may take
relevant steps for the misconduct and false claims and inappropriate conducts of the
employees and stakeholders.
7. Secrecy- the complaint of the immoral conduct raised and assessed according to the
whistle blower policy will be treated as secret (Grayson-Morison and Ramsay, 2014).
Enforcement
The Code of conduct of National Australia Bank is the relevant for the individuals who are hired
to do functions in the company’s Group. This Code of conduct is applicable to individuals while
that individual is identified as an agent of organisation. In certain situations, it will include time
when the employee is outside of organisation. The agent also anticipates it; contractor,

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consultant, and the expert to identify and review the principles stated in code (Smith and
Thompson, 2017).
The code of conduct of the company is applicable to an organisation, National Australia Bank
group, other branches and stakeholders. The stakeholders of company involve organisation’s
security holders, suppliers, customers and outside partner of business and the groups. These
related principles are also applicable to the stakeholders and employee of company who claim
wrongly. Furthermore, on the violation of Code of conduct, workers can handle corrective action
such as service’s closure.The company levies the fine to that stakeholders and workers, who
violate the law, regulations and principle. They are also required to report conducts where there
are no assurances whether the breach of the code of conduct has happened (Zgheib, 2014).
Conclusion
According to the above discussion, it can say that it is required by the top level management and
departmental heads that they should affirm the compliance with National Australia Bank’s code
of conduct. The affirmation will be provided in the set manner on the Company’s website.

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References
Ashraf, M.M. (2018) NAB in the line of fire. United States: Columbia University Press.
Butler, J.V., Serra, D. and Spagnolo, G. (2017) Motivating whistleblowers. New York:
Routledge
Capua, I. (2016) Data sharing: a code of conduct for data on epidemics. Nature, 534(7607),
p.326.
Charania, N.A.M.A., Ferguson, D.L., Bay, E., Freeland, B.S., Bradshaw, K. and Harden, K.,
(2017) A professionalism and safety code of conduct designed for undergraduate nursing
students. Journal of Professional Nursing, 33(6), pp.460-463.
Cubbage, C. J., and Brooks, D. J. (2016) Corporate Security in the Asia-Pacific Region: Crisis,
Crime, Fraud, and Misconduct. United States: CRC Press.
Gao, L. and Brink, A.G. (2017) Whistleblowing studies in accounting research: A review of
experimental studies on the determinants of whistleblowing. Journal of Accounting
Literature, 38, pp.1-13.

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Garland-McLellan, J. (2015) Ethical practices: Governing without boundaries. Company
Director, 31(9), p.60.
Givati, Y. (2016) A theory of whistleblower rewards. The Journal of Legal Studies, 45(1), pp.43-
72
Grayson-Morison, R., and Ramsay, I. (2014) Responsibilities of the Board of Directors.
Cambridge: Cambridge University Press
Heilman, M. and Manzi, F. (2016) Sex discrimination. The Wiley Blackwell Encyclopedia of
Gender and Sexuality Studies, pp.1-3.
Hymel, S. and Swearer, S.M. (2015) Four decades of research on school bullying: An
introduction. American Psychologist, 70(4), p.293.
Jayanti, R.K. (2018) SUSTAINABILITY BASED CORPORATE IDENTITY: A STUDY OF
CORPORATE WEBSITES. Academy of Marketing Studies Journal, 22(3), pp.1-16.
Kundu, S., Mazumdar, M. and Ferket, B. (2017) Impact of correlation of predictors on
discrimination of risk models in development and external populations. BMC medical research
methodology, 17(1), p.63.
Reamer, F. G. (2013) Social work values and ethics. United States: Columbia University Press.
Smith, P.K. and Thompson, D. (2017) Practical approaches to bullying. New York: Routledge.
Zgheib, P. W. ed., (2014) Business ethics and diversity in the modern workplace. United States:
IGI Global.

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