Ethical Issues and Codes of Conduct: Case Studies in Australian Banks

This report provides an in-depth analysis of ethical issues and codes of conduct within the Australian banking sector. It examines two key case studies: the Commonwealth Bank's involvement in money laundering and terrorism financing allegations, and the National Australia Bank's bribery scandal. The report begins with an overview of the importance of ethical practices and codes of conduct in the banking industry. It then delves into the specifics of each case, outlining the violations and their implications. The cases are evaluated in terms of industry regulations and ethical guidelines. Furthermore, the report proposes strategies to mitigate these issues, including enhanced compliance measures, employee training, and improved risk management. The objective is to understand the nature of ethical violations, suggest positive outcomes, and provide a guideline for the banking industry to prevent future ethical breaches, ultimately safeguarding customer trust and financial integrity. The report compares the two cases to identify common themes and propose comprehensive solutions.

Running head: ETHICAL ISSUES AND CODES OF CONDUCT
Ethical Issues and Codes of Conduct
Name of the university
Name of the student
Author note

1ETHICAL ISSUES AND CODES OF CONDUCT
Executive summery
This reports aims to talk about violation of ethical conducts in Australian banking
sector by evaluating two case studies, allegation of terrorism financing against
Commonwealth Bank and bribery practices of National Australia Bank’s employees
respectively. Analysis and comparison of two case studies will help to understand the nature
of violation and assist to suggest future strategies. At first, this report has discussed the
relevance of code of conduct and ethical practices within a business scenario concentrating
on banking industry of Australia. After that from a brief descriptions of both the case studies
have assisted to understand varied nature of ethical violation within banking sector. The
trend of moral crime has been elaborated in this course. Following with the evaluation of
case studies in terms of banking sector, strategies for each issues have been suggested to
combat such major morality issues. Therefore, the purpose of this report is to analyse the
available information about these cases, suggest positive outcomes and strategies to
mitigate the issues. Comparing these two cases with the ethical guidelines of relevant
sector, the areas of violation will be understood. This report will work as a guideline to the
banking industry for applying safety measures in advance against the potential loss of
business ethics.

2ETHICAL ISSUES AND CODES OF CONDUCT
Table of Contents
Introduction................................................................................................................. 3
Importance of code of conduct and sustainable business...........................................3
The case of Commonwealth Bank: money laundering breaches and terrorism
financing................................................................................................................................. 4
The case of National Australia Bank: Bribery issue....................................................5
Evaluation of case studies in terms of industry regulation...........................................5
Strategies to mitigate terrorism financing....................................................................8
Strategies to mitigate bribery issues...........................................................................9
Conclusion................................................................................................................ 11
References............................................................................................................... 12

3ETHICAL ISSUES AND CODES OF CONDUCT
Introduction
This report intends to analyse one case study related to violation of ethical guidelines
of Australian banking sector. In addition to that, another case study will be presented as
compared to the former one in order to analyse and find positive outcome from the ongoing
crisis. Whatever the judgment will be, it must be integrated with the ethical guidelines of
relevant industry sector. Analysis and comparison of two case studies will help to understand
the nature of violation and assist to suggest future strategies. The chosen cases are bribery
scandal of National Australia Bank staff and allegation against Commonwealth bank of
encouraging money laundering breaches and financing terrorism activities. At first, this
report will talk over the relevance of code of conduct and ethical practices within a business
scenario. After that from a brief description of both the case studies will help to understand
varied nature of ethical violation within banking industry. The trend of moral crime will be
elaborated in this course. Following with the evaluation of case studies in terms of banking
sector, strategies for each issues have been suggested to deal with such major morality
issues. Therefore, the purpose of this report is to analyse the available information about
these cases, suggest positive outcome and strategies to mitigate the issues and comparing
these two with the ethical guidelines of relevant sector, the areas of violation will be
explored. This report will work as a guideline to the banking industry for taking safety
measures in advance against the potential loss of business ethics for accomplishing
organisational goals (Michaelson et al. 2014).
Importance of code of conduct and sustainable business
According to Chun et al. (2015), the corporate culture of business industry does not
entertain unethical practices to ensure company goodwill and a sustainable position in the
market. Yet, acknowledging the profit centred business industry it can be easily assumed
that organisations seek opportunities to satisfy customers with the intention of making more
profit and competitive advantage. They work for environmental and social sustainability to
attain organizational goals. That is why, while dealing with corporate governance and code
of conduct; higher authority finds numerous cases of both minor and major violation of
regulations (Lock and Seele 2015).
Ethics can be associated with behavioural aspects of a certain organisation or
individual. People can make themselves way behind from adopting such practices if they
consider one of the ethical guidelines into mind, whether it is personal or related to
organisation (Nicolăescu 2013). As instance, the cases of Australian banking scandals can
be mentioned. These two examples from banking industry are evidence of degradation from

4ETHICAL ISSUES AND CODES OF CONDUCT
an established business to an accused one. As a result, the relationship between customers
and the banking industry starts to degrade too. Whereas, described in Pérez and Rodríguez
del Bosque (2014), customer satisfaction is regarded as the highest priority of every
corporate scenario, by playing unethical cards how NAB and Commonwealth bank have
dishonoured the culture of the banking industry that has been described below.
The case of Commonwealth Bank: money laundering breaches and
terrorism financing
Australia’s financial intelligence agency has sued the bank for several breaches of
laws as the bank fails to present the report of almost $77m suspicious transactions from
ATMs of different locations (Bush 2016). The bank authority could not act in an expected
way against the allegation that associations of drug dealer was exploiting their deposit
machines to launder huge amount of money (Beekarry 2013). Estimation is in millions of
dollars. The bank was accused after the investigation conducted by The Australian
Transaction Reports and Analysis Centre (Austrac), which has been referred as financial
intelligence agency publicized the decision of suing Commonwealth bank’s inability to take
any concrete measures for almost 54,000 breaches of financial laundering.
It was claimed in the report of Knaus (2018), that their self-proclaimed “intelligent”
money deposit machines, which can be used to deposit money anonymously, even at
unusual hours of the day when banks are closed too. Discrepancy was spotted when the
bank employees failed to report properly and mitigate the crisis. As per Madary and
Metzinger 2016), online fraud cases in banking sector has become common these days. It
has been observed in Commonwealth bank those suspicious transactions were conducted
by money laundering associations among which three groups deal with drug importation
from foreign lands and distribute it via several channels. Consistently before the revelation of
such illegal activities, the deposit machine consistently helping to relocate and deposit cash
frequently (Liss and Sharman 2015).
In spite of receiving a warning from Australian Police, the organisation remains
neutral about the matter and did not show any act of responsibility towards their treasuries
security. Although, the issue was brought to notice in the year of 2014, still it takes more
than one year to stop such activities on behalf of banks until the culprits were arrested for
doing so. Hereby, the bank has been accused with failure of observing the origin of
transactions on almost 800,000 bank accounts over more than three years of time. The
Commonwealth Bank has stated to eliminate such allegations of terrorism financing and
announced that huge amount of money is going to be invested on compliance policy of anti-
money laundering. In order to ensure ultimate security the Bank decided to train their

5ETHICAL ISSUES AND CODES OF CONDUCT
employees to act against such cases of breaching. Such instances of negligence have a
great impact on customers who trust the organisation with their money and valuable
belongings. As argued by Tang and Ai (2013), Occurrence of such issues creates unstable
relationship with customers, which leads to reduced customer loyalty.
The case of National Australia Bank: Bribery issue
The case of National Australia Bank has been reported to banking royal commission
as an extraordinary evidence of ethical violation of both the company and business norms
(Hutchens 2018). The incidents of dishonest practices are numerous in various fields of
banking and surprisingly allegations are against the employees mostly. A bribery ring has
been found covering various branches of NAB, among which cases of fake documents,
payslips and Med claim records have been brought into notice. Employees are accused for
considering bribes from customers for loan sanction and staffs have been found to be
engaged in validation of new customers with fake documents to ensure their monthly
incentives.
It has been observed, as described in Choo (2014), that non-financial professionals
are being paid for referring unknown people and ask for requirement of loans. The pressure
of meeting the targets was so intense from the higher authority; employees had adopted
several unethical policies in order to be regarded as performing employee of the
organisation. However, the company policy cannot be questioned as far as violating ethical
policy is concerned (Fungáčová, Kochanova and Weill 2015). In this case, both the company
and individual ethical boundaries have been dishonoured. After the revelation of the actual
scenario, the organisation has complied with several compensation programme yet issue of
sustainability continues to be a part of NAB.
Evaluation of case studies in terms of industry regulation
In general, it is the Board members’ duty to monitor occurrence of ethical issues
within organisation whereas, an officer gathers data by following up employee performance
and informs the cases of incompliance. As per the study of Fritz et al. (2013), senior
management team has the responsibility to identify and mitigate ethical issues in order to
promote ethical behaviour. According to the ethical framework of banking industry, they have
to consider several moral boundaries before exploring profitable opportunities. Technical
interventions are encouraging the chances of both the internal and external ethical conflicts.
Bankers’ responsibility is to maintain the relationship of trust. They are trusted for taking care
for personal belongings, the result of utmost hard work. However, according to Martins,
Oliveira and Popovič (2014), under such pressure of performing risky activities, bankers’
must comply with several security issues for the welfare of society. Therefore, it is proven

6ETHICAL ISSUES AND CODES OF CONDUCT
fact that this industry is highly depending on their policies of maintaining ethical standard. As
per the study of Pérez, Martínez and Del Bosque (2013), industry responsibility is huge as
industry serves purposes of government, shareholders, customers and different communities
beyond boundaries. Bank’s responsibilities have been explained briefly as follows and
further according to that ideal guideline the cases of bribery and terrorism financing will be
evaluated that where those bank’s policy went wrong as far as ethics is concerned.
Banking industry is one of the risk-oriented sectors as it involves the responsibility of
handling money. Ethical execution of banking operations is important as organisations
depend on public trust entirely. Compared to any other industry, the responsibility is higher
as banks have to ensure safety, return appropriate amount to the depositors and investors is
taken as highest priority. The case of Commonwealth bank is related to the violation of
security regulation. The bank took the situation casually for the first place and waited until
police arrested some of the culprits. The authority was obliged to take security measures yet
it was indifferent act of management of Commonwealth Bank for not taking up action against
such threat of terrorism. As far as the second case of internal ethical violation is concerned
that is carrying more trust issues as employees themselves were involved into discrepancy.
Therefore, principal of building mutual trust is the basic criteria of banking industry to ensure
long-term relationship of serving shared interest.
The responsibilities of senior managers has been revised to enhance the security
system of banking industry so that cases like Commonwealth bank where the organisation
was accused for being indifferent even after several warnings. An active team of managers
and risk mitigation executive will serve the purpose of taking timely action (Anderson et al.
2013). Introduction of anti-bribery practice must be there within the banking regulation
according to availability of resources. In addition to that, monitoring each transactions and
keep a record of that falls under basic responsibility of employees. In the case of National
Australia Bank, faking documents, paying non-financial professionals for collecting new
contacts and considering bribery as an organisational practice for every loan sanction is
highly dishonest in terms of being the epitome of trust (Cohn, Fehr and Maréchal 2014).
Moreover, all these activities falls under criminal offences too as happened in the case of
National Australia Bank.
According to the trend of ethical violation, terrorism or anti-social activities are
performed under the name of terrorist financing. The market is highly aware of the concept
yet majority of people do not know how such allegation can be raised against banking
industry, which has been made for supporting societal needs. The procedure is actually
smuggling of cash to the terrorist syndicates unlawfully. The banks are being accused for
financial crime, whereas it has been observed that the authority is clueless about the
process. moreover, huge imbalance can be observed in balance sheet. This is a case of

7ETHICAL ISSUES AND CODES OF CONDUCT
violating regulation basic objective, which is providing security to the customers’ interest.
The banks are failed to understand the discrepancy on time, as financers do not transfer
huge amount of money at a time. Transactions are made with small amounts to dodge the
attention of governments. This ethical loss has been observed not only among terrorist
organisations but also among business persons who have to make or receive payments
from overseas. As described in SM Irwin et al. (2014), considering the banks’ inability to
track down every virtual transactions, money-laundering patterns can be noticed in a
suspicious way across complicated networks of those syndicates. In this due course, public
of the state are engaging themselves into thinking of their money’s future. With this concern,
the banking industry is losing its relevance within contemporary society. People are not
feeling safe anymore.
In these cases, company must take initiative right after discovering the discrepancy
yet Commonwealth violated that matter of both the treasury and customers’ security act.
Various laws have been created regarding this terrorist financing activities, which are known
as ‘counter terrorist financing policy’. As per the guideline of policy makers bankers must
maintain strict regulation regarding supervising and observing customers’ behaviour
regarding transaction. It is employee’s responsibility to keep the data in record.
Commonwealth bank failed to present the report of real scenarios regarding suspicious
transaction for which unpleasant consequences came up certainly. Besides, to reduce such
cases banks can introduce the policy for screening the customers before dealing with them.
Terrorist financing can be considered as external terror of banking industry, where
according to ethics bankers must monitor the system to remove threat of breaches for
securing customers’ concern. On the contrary, in the case of National Australia Bank,
employees are involved into unethical practices of making fake documents, Med claim cards
for meeting the monthly requirements of the company. Employees not only securing
incentive by doing this but also receiving bribery for sanctioning variety of loans. First, using
forged documents is not supported where government and public concerns are involved.
Banking industry portrays itself as epitome of trust. In this case, authority’s pressure has
been presented as one of the major reasons for adopting unethicality. However, the question
arises against the existence of individual sense of morality. Additionally, being an employee
complying with industry norms is mandatory for every job profile. After conducting extensive
research, as argued by Asongu, (2014), it has been observed that bribery is a global and
even complicated phenomenon existing within the system of every industry more or less.
Increasing demand of human lifestyle leads them to earn more money and if it is not
possible in a proper way people violate norms, ethical boundaries wishfully to earn some
extra amounts.

8ETHICAL ISSUES AND CODES OF CONDUCT
According to Abbink and Wu (2017), in order to mitigate this kind of organisational
practice improvement of lifestyle is required in the first place. Banking industry, more
specifically needs to adopt ethical framework strictly to avoid corruption within system. The
organisation must be well established and supported by both the monetary and human
resources (Levi, Halliday and Reuter 2014). A strong, well-built business model has the
capability to control external threats of reduced customer loyalty.
Strategies to mitigate terrorism financing
It has been perceived that among four suspicious channels of transactions
Commonwealth Bank has identified three of them to be part of drug dealing syndicates.
Whatever the identity of fourth breaches be, the fact has been made clear by the federal
police, that Commonwealth bank contributed in terrorism financing indirectly by ignoring the
issue and being indifferent in the matter of taking action. Anti-social activists requires huge
amount of money for conducting unlawful activities, which are against ethical behaviour.
Buying weapons, manufacturing explosives and using money from travelling are some
necessities of these type of organisations (Freeman and Ruehsen 2013). They are exploiting
city banks, violating ethics and circulating the money within society to create an atmosphere
of threat. Circulating drugs are responsible for degradation of society specially the young
generation.
Key strategies for combating terrorism financing and exploitation of banks FATF
stands provides a set of guideline to maintain for addressing and mitigating such practices
(Usman Kemal 2014).
 Financial sectors especially banks, insurance companies who deal with public
investments, need to improve the understanding about this concept. In order to
ensure extensive perception, management can arrange training on terrorist
financing risks.
 Effective tools must be identified to monitor the situation. The era of digitalization
has made it possible to execute several tasks, which were difficult before.
Installation of intelligent deposit machine is a good idea which can be used for
monitoring customers’ details too while the deposit session is going on.
Commonwealth’s machine did not have ability to record depositors’ data. That was a
major drawback though.
 Government must take initiative to supervise this industry minutely as several issues
have been generated regarding application of these tools among banking
organisations.
 Countries must come forward for strengthening their guidelines to save financial
organisations from accusation of participating in terrorism financing activities.

9ETHICAL ISSUES AND CODES OF CONDUCT
 Organisational structure must be strong enough for dealing against such allegations.
Honest and skilled human resource is necessary to understand, identify and
mitigate unethicality.
 Financial sectors like banks and their customers have various things to do to
prevent money laundering through the financial system of an entire country.
therefore, scanning customer details before dealing with them is as important as
serving facilities to run a sustainable business. Extreme cooperation is needed from
both the end to make the initiative successful (Quarshie, Salmi and Leuschner
2016).
 Customers must be faithful too towards every financial sector in terms of providing
original documents. Otherwise, it works as a loophole for terrorists or anti-social
groups to enter into the central financial system in disguise. It is citizens’ duty to
maintain the strict regulations of banks in order to help them to provide security.
Hence, it can be stated, private sectors, like banks have a crucial role to play in
putting restriction to terrorist financing. Terrorist exploits such organisations where public
invest in order to access the wide-reaching financial system. As suggested by Petrou and
Thanos (2014), unlike Commonwealth bank, national banking sector must be aware both
collectively and individually by gathering knowledge about the concept. It will enable them to
take necessary as well as timely action to make others alert. Certain policies must be
introduced to every banks in order to make them aware how they can identify cases of virtual
breaches (Wei et al. 2013).
However, in this due course Commonwealth suffered on a large scale for being
indifferent to both the government instructions and public security. Ethical guideline of a
banking organisation has been violated extremely in this case. Moreover, consequently
organisation settled to compensate by providing the biggest fine. Historically, it was the
highest amount ever paid by any organisation against multiple allegation regarding violated
ethical code of conduct. In order to rectify the mistake of reporting the amount of breaches,
banks are instructed from AUSTRAC to communicate within 10 to 12 business days about
transaction of large amounts. Although, an efficient supervision is necessary as anti-social
syndicates prefers to transfer money in small sum yet frequently. Banks are required to be
careful too in this matter.
Strategies to mitigate bribery issues
Moral sense of individual leads them to comply with organizational regulations and
help them to attain an ethical behaviour. However, in spite of being employed in highly
paying and respectable job, employees tend to feel of adopting unlawful practices influenced
by either organizational culture or urge of earning more money. The case of National

10ETHICAL ISSUES AND CODES OF CONDUCT
Australia Bank suggests revising company policy, as employees tend to create false
accounts and submitting fake documents to meet the target of enrolling new customers.
People are so money oriented these days that they do not even realise by doing these things
they are making the entire financial system fragile as well as creating a place for breaches to
enter easily. There is no alternative of a strong, strict financial system. Employees are
violating ethical standard both in terms of organisational and perspective of the country itself.
Financial sectors exist within society based on mutual trust. Customers need to be honest
too and think twice before offering bribe to any officials. Few strategies can be suggested in
order to resolve internal issues of banking sector. As per Akhlaq and Ahmed (2013), online
banking has become popular across both the developed and developing countries. The
industry cannot blame external breaches and the wide acceptation of online banking for
future threat. The bank itself must be ethically right in order to mitigate further issues.
 It has been noticed that civil servants are underpaying in most of the cases. They feel
too pressured to income a considerable amount, which leads them towards
supplementary ways. There are certain employees too, who have chosen to be
ethically correct considering both the individual and collective interest in mind (Zheng
et al. 2013). However, to change this mind set, employee policy needs to be revised
by banks. Additionally, reasons must be identified first, for which employees are
losing their ethical standard.
 Business standard must be structured as a part of national policy where ethical
behaviour and principles have to be base of any foundation.
 Adopting code of business ethics not only makes a business sustainable and earns
goodwill but also it is a strategy itself for securing the organisation from the risk of
external threats. As described in Carminati et al. (2015), people are trusting on
online banking, as banking sector has become more global than ever. Like the case
of NAB, if employees make the system weaker from its base then it will be difficult to
provide security for public financial system.
 Rather looking for supplementary ways of income, employees must concentrate not
to violate norms as well as to maintain a healthy financial structure. Strong financial
sectors like banks are one of the major institutions, which reflect a strong economic
condition of country.
 Training sessions can be arranged by Australian governments to make them
understand the global policies of ethical codes in business and how it will be
beneficial for the country.
 The entire banking industry must be monitored periodically to ensure strategies are
being followed properly.

11ETHICAL ISSUES AND CODES OF CONDUCT
 Dealing with huge amount of money is a matter of responsibility too. As suggested by
Barnes and Kilding (2015), appropriate anti-corruption culture must be inevitable to
follow not only for a sustainable business but also to sustain Australia’s economy as
public trust these organisations with their earnings (Hussain Chandio et al. 2013).
Conclusion
After evaluating Australia’s banking industry, its culture and two cases of violated
ethical standards it has been understood that ethical boundaries are easily violated as
people consider individual’s interest first before than collective interest. In this due course,
they forget that if they serve global purpose, individual one will be served eventually. On the
contrary, officials of banking sectors are well aware of the potential threats, which can occur
if the system is not strong enough. Therefore, National Australia’s case is surprising as their
employees are found to be participants of a bribery ring across the branches. It is a slam on
public trust, after realising the filthy reality of banking sector. On the contrary, even the
organisational structure and culture were fine enough to combat issues of external threats
like terrorism financing, being ignorant of the concept partly and remaining indifferent to the
issues even after realising the cases suspicious transactions cannot be accepted as they
carry huge responsibility of providing security to Australian’s money. It is a case of high
negligence and cannot be spared without accusing them for encouraging drug dealing
syndicates.
In order to ensure a bright future for Australian economy, it is responsibility of every
Australian citizen, especially who are within the financial system, to feel the soreness of
morally cheated by own fellow citizens. It is highly sensitive matter and important too.
Citizen’s trust must be renowned if both the business and financial system of the country
have to survive in the long run.


12ETHICAL ISSUES AND CODES OF CONDUCT
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