An In-depth Analysis of National Australia Bank's Code of Conduct

This report provides a comprehensive analysis of the National Australia Bank's (NAB) Code of Conduct, highlighting its commitment to governance, ethics, and sustainability. The report delves into the core values and principles that guide NAB's operations, emphasizing its dedication to customers, employees, and stakeholders. It examines key areas within the code, including anti-discrimination policies, the prevention of exploitation and corruption, and the protection of whistleblowers. The report also explores the consequences of violating the code, emphasizing the importance of ethical conduct and compliance with laws and regulations. It references the NAB's commitment to fostering a diverse and inclusive workplace, while also addressing the bank's responsibilities in combating financial crimes. The analysis underscores NAB's efforts to maintain a strong reputation and uphold the trust of its customers and the financial system. This report serves as a valuable resource for understanding the ethical framework that governs NAB's business practices and its commitment to responsible corporate citizenship.

Running head: GOVERNANCE ETHICS AND SUSTAINABILITY
GOVERNANCE ETHICS AND SUSTAINABILITY
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National Australia Bank Code of Conduct
Recognized as one of the most leading business banks in Australia, we work with small,
medium as well as large businesses. The National Australia Bank has been consistently operating
its business from the start of these businesses in order to support them through every vital stage
of the business lifecycle
Natioanal Australia Bank
Source: (Nab.com.au 2019)
NA
About Code of Conduct
At National Australia Bank, we uphold certain universal values and standards along with
a common way of working together. This code of conduct covers a wide range of business
practices and procedures. it establishes fundamental principles for National Bank of Australia its
subsidiaries and the Board Of Directors to follow representing power core principles and values
in our business dealings. The code of conduct implies to all employees whether full time, part

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time, contractual or temporary in addition to the board members. All individuals covered by our
code must conduct themselves accordingly and seeks to mitigate even the appearance of
immodesty or a conflict of interest ((Nab.com.au 2019). Those who are the standards and
principles in this code will be subject to disciplinary action and even termination of employment.
The National Australia Bank is committed to demand its workforce and investors adhere
to the same high standards of ethical and disciplinary conduct in the performance of the bank’s
business.
Our Values
NAB is highly committed to achieve sustainable performance and further delivering
considerable value to all our customers, employees as well as stakeholders, without
compromising our values and trusted reputation ((Nab.com.au 2019).
Our core values lie on protecting individuals who have been making authentic rules,
guidelines, and disclosures and seriously condemn any acts of victimization or unfavourable
consequences such as demotion, inequality, dismissal or any other difficult treatment in reprisal
for those authentic disclosures.
Our business dealings
At NAB, we recognize that a bank must uphold special roles and responsibilities. The
fundamental business of NAB is established on a commitment to successfully create more of
what mainly matters for people, communities and the financial system. Through our business we
aim to establish a conviction which will increase the motivation of our people to engage into the

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right thing, show enthusiasm for clients, win collectively and further show high dynamism and
respect and deference for people ((Nab.com.au 2019).
Our customers and communities
At the National Australia Bank, we believe we have both the prospect and the
accountability to create the perfect balance of economic, social as well as environmental
conditions for our customers, clients, stakeholders, investors and communities at present and in
the future ((Nab.com.au 2019).
Compliance with laws, rules and regulations
Adherence to the law both in letter and in spirit is is the core foundation on which
National Australia Bank's ethical standards are established. All employees must respect and obey
the laws written in the code of conduct. All employees as well as directors of the bank are
accountable for comprehending the laws and regulations which associate with their respective
responsibilities ((Nab.com.au 2019). However the Bank does not expect any individuals to know
the details of every law regulation but expects employees to know when to seek suggestions
from supervisors, leaders, managers when an issue of law arises which can impact the decision
making for business of the organisation.
We, the National Australian Bank will focus on the following areas in our code of conduct.
A) Discrimination
The National Australian Bank is highly committed in providing a work environment that
sincerely disregards and condemns all forms of harassment, marginalisation or discrimination
acts as per the following legislations:

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 Age Discrimination Act 2004
 Disability Discrimination Act 1992
 Racial Discrimination Act 1975
 Sex Discrimination Act 1984.
These areas will primarily include acts of discrimination of promoting prejudices on the
basis of culture, ethnicity, nationality, race, gender, colour, religion, age, disability, sexual
orientation in addition to any genetic information and status protected by law (Ag.gov.au 2019).
The bank further provides Equal Employment Opportunity (EEO) in accordance to the Equal
Opportunity Act 2010 and proficiently seeks to guarantee that each and every employee as well
as job candidates are treated with utmost dignity, equality and fairness during recruitment and
employment time.
The code of conduct clearly states that any employee may not retaliate against any
employee for reporting any case which is concerned with a potential violation of the policy,
regulation, law or legislation. We value differences and are highly committed in attaining a truly
diverse workforce which exhibit high intrusiveness and dignity of each other's differences. Some
extreme examples of few banks indulging in discriminatory acts reveal that many Indigenous
clients are often turned down by for loans due to their socio-economic status. NAB strongly
criticizes such acts (Austrade.gov.au 2019). All the employees in our organisation are expected
to consider all individuals we deal with as equals and through our business operations at NAB
with utmost fairness, dignity and respect with our stakeholders, customers, colleagues, suppliers
or other third party agents. We critically disregard any form of illegal discrimination harassment
bullying bigotry comments or any other unacceptable for offensive behaviour.

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B) Exploitation
We believe that all our business dealings should align with relevant legislation in force
from time to time and all regulations enacted under such legislation. Moreover, as one of the
leading banks in Australia we sincerely illustrate our business operations with utmost priority of
the proposed dealings without any form of exaggeration and do not include any unauthentic or
misleading data and duly overemphasize to secrete our services with an attempt to exploit the
public's unawareness on misapprehensions (Ag.gov.au 2019). Our code of conduct clearly states
that we try to position ourselves within the resilience of just competition and must pay utmost
regard to our customers trust as well as to the Banking systems of good reputation and guarantee
that it does not instigate the concern of customers regarding any credit institution. In addition to
this, we sincerely refrain from making any form of defamatory remarks or exploit the services of
our competitors in the sector.
C) Corruption
Our organisation advocates the development of of established regulations along with
internal procedures in order to combat financial crime which includes tax evasion or any kind of
money laundering. All our employees are expected to other to these requirements which have
been aimed to prevent our bank from engaging into intentionally or unintentionally any kind of
corruption or criminal offences. For example, terrorism financing recently has been identified as
the providing distributing collecting or depositing of funds through any forms or being aware
that they are to be comprehensively or partially used for or indulging into any form of anti-social
activities. As a result, in order to combat any form of money laundering and terrorism financing
NAB has efficiently developed a range of policies outlining its anticorruption standards, values

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and principles (Ag.gov.au 2019). Employees are required to adhere to these values in order to
protect the organisation and its reputation from being exploited for money laundering or
corruption cases or any other illegal purposes.
D) Dishonest or fraudulent behaviour
In this area of our code of conduct we expect our employees to seek advice from
organizational managers of supervisors, if they have any knowledge of any fraudulent activity
happening within the organisation which has a reason to be suspected. Such a responsibility is
expected from all the employees of our organisation which is identified as an escalation process
for the offender defined in our anti fraud policy. As per our Code Of Conduct every employee,
stakeholder, manager are accountable for ensuring that they have no involvement or contribution
to the dishonest behaviour. NAB efficiently provides a range of internal and external reporting
options. It is important to note that have the authority to notify our senior management team,
stakeholders and managers or other key contacts regarding any fraudulent activity or violation of
the codes which can put the organisation at risk of loss or exploitation.
All reports of fraudulent activities will be critically investigated and NAB keeps the
Identity of the offenders in order to investigate as well as address the act of dishonesty legally if
essential. Few examples of fraudulent activities involve improper use of company’s or clients
assets or systems as well as exploiting sales reporting. Furthermore, there are other examples of
dishonest behavioural pattern which will include inappropriate client referral or disclosure of
client information or violating the laws set by the organisation.
E) Whistle blowing protection

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This code of conduct is an internal policy on disclosure by the company's directors or
employees, stakeholders regarding any unethical or inappropriate practices and access to the
audit committee if the whistleblower is a director and to the head of department if it involves
senior management personal access to the managing director.
This Code of Conduct supporting the Public Interest Disclosure Act 2013 (PID Act)
prevents our organisation to engage into any unfavourable workforce action against its
employees for revealing in good faith any kind of inappropriate or illegal practices to the head of
department of the managing director or to the audit committee. However we will annually
confirm that the code of conduct does not contradict any personal admission to the audit
committee and it has provided substantial protection to whistleblower from adverse personnel
action. It is important to note that affirmation shall form part of corporate governance report as
attached to the annual report of the Bank.
F) Enforcement
The Human Resource Officer of NAB is mainly responsible for administering the Code
of Ethics and enforcing the Code for employees as well as officers. The Audit Committee will
further be accountable for enforcing the Code of Ethics for Executive Officers as well as
directors. NAB clearly states that the Human Resource Officer is responsible for the conduct of
all Code-related training, preservation of all Code-related accounts and reports and investigating
as well as resolving all Code-related matters. Furthermore, NAB mentions in the Code of
Conduct that unlawful or criminal conduct will be directly reported to our chief regulators and
any law enforcement agencies with authority consistent with privacy and the safeguard of
applicable privacy privileges.

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Moreover, we will provide full cooperation with such authorities in order to bring parties
liable for impermissible, prohibited or illegal conduct to justice. For example, if any employee
requests another to share customer data from former employer with a claim of obtaining greater
number of new clients for present company, it should be enforced immediately by NAB. The
reason behind such enforcement is because the employee has no right to reveal any data or
information of former employers and employee has a legal obligation to protect information even
after leaving the organization.
Consequences of Violating the Code of Conduct
A strong reliability is expected from all employees and stakeholders. If any case of
violation of code of conduct is observed stringent action will be taken against the offender.
Remedial actions will range from knowledge development sessions, coaching, counselling,
formal warnings or even termination of employment for severe breach.

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