Corporate Governance Report: IOOF Holdings Code of Conduct - CGRM4000

This report presents a comprehensive Code of Conduct for IOOF Holdings, addressing critical aspects of corporate governance, sustainability, and ethics. The report meticulously examines key areas including discrimination, exploitation, corruption, fraudulent and dishonest behavior, whistleblower protection, and enforcement mechanisms. It outlines the company's commitment to providing an equal opportunity environment, preventing unfair treatment based on personal characteristics, and ensuring compliance with relevant legislation like the Fair Work Act. The code also establishes policies against exploitation, emphasizing fair treatment of employees, customers, and stakeholders, with clear guidelines on ethical practices and penalties for violations. Furthermore, the report details the company's stance on corruption, prohibiting bribery and promoting responsible conduct, alongside a separate anti-corruption policy. It also addresses fraudulent and dishonest behavior, defining prohibited activities and emphasizing the importance of honesty and reputation. The code also emphasizes the protection of whistleblowers, ensuring their safety and confidentiality while reporting misconduct. Finally, the report outlines the enforcement procedures, including reporting channels and potential penalties for breaches of the code, with a focus on promoting ethical conduct across all levels of the organization. This report is a detailed analysis of the Code of Conduct for IOOF Holdings, which is contributed by a student on Desklib.

Running Head: BUSINESS AND CORPORATION LAW 0
Code of Conduct
Student Name
Student Number
Subject Name: Corporate Governance, Sustainability, and Ethics
Subject Code: CGRM4000
IOOF Holdings

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Contents
Introduction......................................................................................................................................2
Discrimination.................................................................................................................................2
Exploitation......................................................................................................................................3
Corruption........................................................................................................................................4
Fraudulent and dishonest behavior..................................................................................................5
Whistleblowers Protection...............................................................................................................6
Enforcement.....................................................................................................................................6
Conclusion.......................................................................................................................................7
References........................................................................................................................................8

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Introduction
This code of conduct has been prepared to present our thinking towards our stakeholders and
manner of working that we pursue in practice. The lead objective of this code of conduct is to
brief our values and to let our stakeholders know about the responsibility of management. The
scope of the code is extended up to every stakeholder and personnel of IOOF holdings. Further,
the compliance of the code is mandatory and expected to be followed in stick manner by all to
whomever it applies.
Discrimination
Being an equal opportunity employer, the lead aim of the company is to provide the employee
with an environment free from all forms of unlawful discrimination. Discrimination is proposing
to treat or treating a person differently in comparison to other people. Discrimination is not an
issue for unlawful discrimination is. Unlawful Discrimination in the workplace refers to a
situation where an employer treats one employee in a less or more favorable manner due to
his/her personal characteristics such as age, gender, race, and others. Such unlawful
discrimination may be direct or indirect (Townsend and Luck, 2012). Fair Work Act 2009 (Cth)
address different type of discrimination and states that an employer must not discriminate his/her
employees based on race, age, color, marital status, sex, family or carer’s obligations, Sexual
orientation, pregnancy, National extraction, religion, political opinion, or social origin (CCH
Australia Limited, 2010). Company has a strict view with respect to the prevention of unfair
discrimination. We believe in ethical practices and understand the consequences that may arise
out of unfair discrimination hence we ensure to comply with following legislations:-
Sex Discrimination Act 1984 (Cth)

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Age Discrimination Act 2004 (Cth)
Disability Discrimination Act 1992 (Cth)
Racial Discrimination Act 1975 (Cth)
The above-mentioned legislation prevents unfair discrimination and company ensure that every
of its personnel act according to the provisions of these acts. Not only the top managers, but
department heads and team leaders are also required to report on matters of unfair discrimination
report during the quarter of the year. The company does not promote any activity that directly or
indirectly leads to unlawful discrimination with employees or any other stakeholder and
therefore the management of the company must
1. Make job vacancies considering the only qualification as a factor and must not use age,
gender or any personal characteristic as the basis of criteria.
2. Conduct interviews in an ethical way giving by giving equal opportunities to every
employee.
3. Select employees based on their qualification and experience
4. Pay the same wages to employees where they have the same skills and doing the same
work
5. Treat every employee in an equal manner irrespective of any other aspect and must
discriminate only based on his or her qualification or work experience or any other
academic skills.
Here this is to make clear that the prevention of discrimination guidelines mentioned above do
not apply to senior employees and top managers but junior employees are also bound with the
same. Any person, which would be found in breach of this section of code shall be obliged to pay

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a fine not less than $250 and shall be further subject to sanctions as may be decided by the ethics
committee of the company.
Exploitation
Exploitation refers to an act where a person takes unfair advantage of others for own benefits
(Scott, 2017). Exploitation at the workplace means using employees, customers or another
workgroup in an unfair or/and unethical manner with the purpose of gaining an advantage. Such
exploitation has a wider scope and it includes forcing labor to work against their will, forcing
them to work in dangerous situations, paying them less than minimum wages (Aph.gov.au,
2019). These are some of the areas where exploitation is most likely to happen. Being an
employer believing in ethical practices, company demotivates every practice that leads to
exploitation. For the prevention of exploitation, IOOF holdings have developed an anti-
exploitation policy. This policy lists all the activities that will be considered as exploitation by
the company and can be reported. We consider employees as one of the most significant parts of
the business and cannot think ourselves growing without them. Company is employing nearly
2000 employees and considers them as one of the most valuable assets of the company
(Ioof.com.au, 2019). Management, as well as other senior managers, are required to consider
provisions of labor code while dealing with the employees. The company wants to make it clear
that under the anti-exploitation policy of the company, customers and other stakeholders are also
covered and the subjective policy should not be considered as applicable to workers only.
Company has identified some activities that are necessary to be considered by every staff
personnel of IOOF holdings. These practices demand that every manager shall:-

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 Set practical targets for the juniors and shall not harass them mentally to achieve the
same. Targets are important but satisfaction and happiness of employee are way ahead.
 Ensure timely payment of wages and shall resolve every issue related to wage payment
within 7 days of reporting.
 Not force employee to work overtime or on holidays without offering additional
payments.
 Ensure providing a safe and healthy work environment.
 Give employees facility of flexible working hours as per the terms of their employment
contracts.
If any IOOF holdings personnel would find liable for any kind of exploitation then the board of
directors shall have the power to remove the same from their position. Further, they may also
held liable for a monetary penalty not less than $200 considering the seriousness of the issue.
Corruption
Corruption refers to a situation where people who are employed at some position misuse the
same for personal benefits (U4.no, 2019). No inclusive list is there that defines corrupted
activities but it mainly involves accepting money, gifts, or any advantages for the performance of
their duty or for conducting some unlawful activities (Kiplagat, 2014). No IOOF holdings
personnel or anyone other who represent the company is allowed to offer or accept any kind of
bribe directly or indirectly in any form such as gifts, money, or so on. With the support of this
code of conduct, the company clarifies that the same neither supports nor motivates any conduct
that falls in the category of corruption. For the functions assigned to every employee, the

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company pays remuneration and expects that such people shall perform their duties responsibly
and fairly.
This is to clarify that only acceptance of bribe is not prohibited but granting of the same is also.
We expect that none of our staff members shall present bribe in any form to others. For
compliance with anti-bribery law and regulation, the company has separately developed its anti-
corruption policy that provides provisions related to incidents of bribery in detail. Company has
developed a proper system of check and balance to identify suspected activities and therefore
every staff member is advised to not to engage in any corrupted activities as the company has
strict penalty provisions to address such issues.
Anyone who find liable engaged in practices of corruption shall be dismissed unless the board of
directors considers the action allowable considering the circumstance of individual cases. In
conjunction with this, the person shall be liable to return all the advances gained by him/her to
the company out of the conduct of corruption.
Fraudulent and dishonest behavior
Moral characteristics are necessary for the behavior of employees and other IOOF holdings
personnel. Ethics are not only demanded from top management but also any other staff member.
In the list of business ethics principles, honesty comes at first place (Robinson and Dowson,
2012). We expect that each of our personnel shall be honest in his/her dealings. The term
Fraudulent and dishonesty are the wider one. We have identified some of the activities that shall
be considered as fraudulent and dishonest behavior, as below:-
 Use of the company's information to earn personal benefit
 Use of their position in order to attain a personal advantage

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 Competition with the company's business
 Theft of money
 Theft of information
 Misappropriation of assets (Turner & Weickgenannt, 2008)
 Theft of goods
 Theft of time i.e. coming later or leaving early, taking unnecessary leaves (Landy and
Conte, 2010)
 Bribery and corruption
The above-mentioned list is not inclusive of all activities and ethics committee of the company
shall decide whether an act should be considered fraudulent or not and shall resent proper
reasoning for the same. Every staff member in addition to managers of business shall keep
themselves away from fraudulent or dishonest practices. Goodwill and reputation are valuable
assets of every organization. Therefore, IOOF holdings also not allow any person to defeat the
goodwill or reduce the market reputation of the same. The company considers dishonest behavior
as a serious matter hence strict provisions are in place that addresses this issue.
As per this code of conduct, if any person would seem to be involved in dishonest or fraudulent
practices then the company reserves right of dismissal and penalties that shall not be less than
$200 in any case.
Whistleblowers Protection
A person that report any misconduct or any type of wrongdoings happening in the organization is
called whistleblower and the act of reporting such conduct is known as whistleblowing. Different
activities come under the purview of whistleblowing. Some of the examples of whistleblowing

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that can be there in the company reporting regarding corruption, sexual harassment, racial
discrimination, fraud and so on (Olsenlawapc.com, 2019). A whistleblower is a very significant
person, there is always a chance that the same can access some difficult situation like threats and
so on. The company ensures protecting the whistleblower. Corporations Act 2001 (Cth) protects
whistleblowers and we believe to comply with the same. The subjective act ensures the
following protection to whistleblowers:-
 Protection against legal actions
 Protection of information submitted by whistleblowers
 Protection from detriment (Asic.gov.au, 2019)
This is important to inform that any type of harassment with whistleblower shall be considered
as a breach of this code of conduct. The company ensures that the identity of the whistleblower
shall not be revealed by any of its personnel. People, who wish to pursue whistleblowing, can
address the same to their immediate seniors or to the ethics committee of the company. We
provide proper space to our employees and welcome them to report any unethics identified
happening in the organization. The contact details of the ethics committee are mentioned at the
end of this code.
Enforcement
The code applies to all the stakeholders and managerial personnel of the company. Any breach of
this code can be reported in various manners. However, as a standard process, we expect the first
reporting to immediate seniors. Any employee or other staff members can simply write a formal
letter to their immediate seniors containing key points of the breach. If no actions find to be
taken by such senior, then the person has the option to approach to ethical committee developed

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in the company. The lead motive of this committee is to promote ethics in the organizational
culture and contact details of the same is given at the end of this code. Thereafter as a last resort,
compliant can be made to the board of directors of the company. Such complaints are expected
to be made through official e-mail id of the employee or staff personnel.
In case of breach of any of the requirements mentioned under this code shall attract a minimum
penalty of $200 and can reach up to $1000 subject to the discretion of the board.
Conclusion
Every IOOF holdings personnel shall be honest in their dealings and shall not be a part of
dishonest behavior. Discrimination is another important matter that must not be promoted in any
matter. Company does not support any activity that leads to exploitation of workers and demands
healthy practices from every senior as well as a junior manager. The further company ensures to
provide every possible protection to whistleblowers and hence they are free to approach our
ethics committee using the following contact details:-
Telephone [phone]

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References
Age Discrimination Act 2004 (Cth)
Aph.gov.au. (2019) 9. Labour exploitation and Australia's visa framework. [online] Available
from:
https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Foreign_Affairs_Defence_an
d_Trade/ModernSlavery/Final_report/section?id=committees%2Freportjnt
%2F024102%2F25425 [Accessed on 26/08/2019].
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 26/08/2019].
CCH Australia Limited. (2010) Australian Fair Work Act 2009: With Regulations and Rules.
Australia: CCH Australia Limited.
Corporations Act 2001 (Cth)
Disability Discrimination Act 1992 (Cth)
Fair Work Act 2009 (Cth)
Ioof.com.au. (2019) About IOOF. [online] Available from:
https://www.ioof.com.au/about-us/about-ioof [Accessed on 26/08/2019].
Kiplagat, D. (2014) Corruption in the workplace. [online] Available from:
https://www.careeraddict.com/corruption-in-the-workpslace [Accessed on 26/08/2019].

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Landy, F., J. and Conte, J., M. (2010) Work in the 21st Century: An Introduction to Industrial
and Organizational Psychology. USA: John Wiley & Sons.
Olsenlawapc.com. (2019) Whistleblower Examples Include Employees Who Report Corruption,
Discrimination, Harassment, and Fraud. [online] Available from:
http://www.olsenlawapc.com/employment-law/whistleblower-retaliation/examples [Accessed on
26/08/2019].
Racial Discrimination Act 1975 (Cth)
Scott, S. (2017) Labour Exploitation and Work-based Harm. UK: Policy Press.
Sex Discrimination Act 1984 (Cth)
Turner, L. & Weickgenannt, A., B. (2008). Accounting Information Systems: Controls and
Processes. USA: John Wiley & Sons.
U4.no. (2019) What is corruption? [online] Available from: https://www.u4.no/topics/anti-
corruption-basics/basics [Accessed on 26/08/2019].