Corporate Governance Report: IOOF Holdings Code of Conduct (CGRM4000)

This report presents a detailed Code of Conduct designed for IOOF Holdings, a major financial services company. It addresses critical areas such as discrimination, ensuring a fair and inclusive workplace by outlining policies against various forms of bias. The code also tackles exploitation, em...Read More

CODE OF CONDUCT

Table of Contents
Introduction................................................................................................................................3
Code of conduct.........................................................................................................................3
A. Discrimination...................................................................................................................3
B. Exploitation........................................................................................................................4
C. Corruption..........................................................................................................................5
D. Dishonest and Fraudulent Behaviour.................................................................................6
E. Whistleblower Protections.................................................................................................7
F. Enforcement.......................................................................................................................7
Conclusion..................................................................................................................................8
Reference list..............................................................................................................................9
2

Introduction
IOOF is helping Australians for securing their financial independence for the past 170 years.
This company has expanded and grown to become a leader in providing quality financial
advice and other services to the clients. IOOF Holdings has about 500000 customers and
2000 employees manage these customers properly (Ioof.com.au, 2019). IOOF Holdings is
included in ASX top 200 companies and offices are located in Sydney, Brisbane, Melbourne,
and other cities. Therefore to manage the large workforce and providing uninterrupted and
transparent service to the customers a proper code of conduct is necessary.
IOOF has been hit by scandals that have impacted on trust of customers and other
stakeholders of the company. Senior executives of this company have failed to act in the
interest of fund members that has created legal issues (Smh.com.au, 2019). This code of
conduct can guide IOOF’s directors, management and employees to maintain high ethical
standards of conduct. Thus, scandals can be avoided and trust will be gained from customers.
This new code of conduct can help employees and directors of this company to act honestly
and maintain fairness. The old code of conduct has failed to engage stakeholders like
employees, directors in business relationships professionally and honestly. According to
APRA, the directors and their teams have misunderstood their key responsibilities (Afr.com,
2018). Hence, it is essential to improve the ethical standards of this company. An effective
code of conduct can be written by discussing company values and reviewing previous code of
conduct that can help to find gaps.
Code of conduct
IOOF is committed to gaining the trust and loyalty of customers and shareholders with
principles of integrity, fairness, and honesty. The management of IOOF will provide this set
of guidelines, which must be followed by employees and other personnel. All personnel of
this firm is expected to act consistently with the principles and codes.
A. Discrimination
Treating a person less favorably due to a protected characteristic refers to discrimination.
Different kinds of workplace discriminations include racial discrimination, gender
discrimination and age discrimination (Humanrights.gov.au, 2019). For example, if and
employee gets promoted as he is young and energetic, it will be a clear case of age
3

discrimination with other aged workers. On the other hand, if work is distributed based on
gender, it will be a clear case of gender discrimination (Peters and Maniam 2016). Similarly,
customers and employees can be treated based on their religious beliefs or race. It is
important to ensure a discrimination-free workplace for ensuring good performance. On the
other hand, a discrimination-free business is more efficient in satisfying the needs of
customers and shareholders.
IOOF personnel will follow the given codes:
● This company will not treat a person on the basis of marital status, gender, pregnancy,
family responsibility. Training program will be arranged to train all the internal
stakeholders of this business regarding this code. These facts will not be considered
by any of our employees while treating consumers and shareholders.
● This company will request employees to avoid judging people based on their sexual
preference, gender expression, and gender identity. These facts are entirely personal
and these aspects cannot be the center point of treating people in business. We respect
all genders and the basic right of individuals to have different sexual-orientation. Our
managers and leaders are instructed to take initiation in eradicating gender
discrimination within our business.
● This company will not treat any person less favorably due to race, nationality,
ethnicity, and religion. People from any cultural background will get equal treatment
from the management team of this company.
● We will not underestimate any person based on their age and disability. All of the
stakeholders will get equal opportunity and respect from this company.
B. Exploitation
Exploitation can be described as an act of treating people in an improper manner for
achieving benefit from their labor. For example, employee exploitation occurs if an employer
violates the legal protection of workers for gaining additional benefits. Australian Council of
Human Rights Authorities has framed adult safeguarding models that help in eliminating
exploitation of adults (Eoc.wa.gov.au, 2019). Exploitation can happen if any directors of this
company force any employee to work under the threat of punishment. Under any
circumstances, these activities of exploitation will be held punishable offense.
IOOF personnel will follow the given codes:
● This firm strongly supports the rights of employees and suppliers and focuses on
creating a safe work environment that eliminates any sort of exploitation. The
4

directors, managers, and leaders must ensure that they operate and manage the
workforce in an ethical way.
● The employees must be paid the wage assigned by the company and directors or
managers will not have any power to make a deduction in employee's pay. In
addition, minimum working hours in a week for each employee is 38 hours
(Fairwork.gov.au, 2019). Any additional work allocation and overtime must be
informed to the board of management.
● Employees should limit the disclosure of personal information. Different personal
information must be kept safely without other access (Fairwork.gov.au, 2019). This
can help them to prevent exploitation and also help them to keep information safe and
secured.
● Directors and managers must not misrepresent IOOF in any way regarding employee
management and need to avoid any action that can create legal issues under the Fair
work act, 2009.
C. Corruption
Corruption is any type of dishonest activities, which a person conducts that is contrary to the
interest of entity. Conducting dishonest activities causes abuse of own position and trust of
higher management (Kleynjans and Hudon, 2016). Corruption is done for personal gain of a
person but it impacts on image and reputation of a company. Bribery is an example of
corruption that occurs in many forms like accepting cash, political donations and making
improper tenders and false invoices. Accepting bribery and other forms of corruption
hampers company’s interest and it can be categorized as a punishable offense (Stohl et al.
2017). All employees, managers, and directors are included in this code of conduct and they
must follow the guidelines while performing different activities.
Code of conduct regarding corruption:
● Employees should understand the corruption policy and it is compulsory for them to
related training that will be offered by IOOF Holdings. All the transactions and
management of documents should be done under the monitoring of supervisors.
Employees must inform their respective supervisors regarding any transactions that
were made without a supervisor's notice.
● All employees should not accept any kinds of bribes, offers or request from any kind
of internal or external personnel. In addition, they must avoid themselves in
encouraging, helping others in accepting bribes or any other additional facilities.
5

● All employees should maintain transparency while management of company internal
documents. Different documents like internal administration documents, financial and
debt documents must be reviewed regularly to eliminate corruption (Asic.gov.au,
2019).
● Employees can report any instance of corruption to the management. The
management will assess the case of corruption and final decision will be taken by
them.
● It is compulsory for all employees to maintain anti-corruption policies and cooperate
during any assessment of corruption incidents. Moreover, employees should act in the
best interests of IOOF, which can help them to avoid abuse of their own position and
reputation of the company.
D. Dishonest and Fraudulent Behaviour
Knowledge of people to understand dishonest and fraudulent behavior occurring within the
workplace is required to maintain a safe workplace. Several behavioral changes and changes
in lifestyle of a person indicates about that person’s dishonesty and fraud activities
(Business.gov.au, 2019). For example, unlawful behavior of an employee must be recognized
and investigation is required to verify whether the concerned employee is getting any
financial benefit or not (Cappelli and Tavis, 2016).
Code of conduct regarding dishonest and fraudulent behavior:
● This company will give responsibility to all leaders and managers to monitor the
activities of each of the stakeholders. Leaders and managers of this company will
monitor behavioral changes and reasons behind changes.
● Employees of this company will be encouraged to lodge a complaint if they found
something unlawful within the workplace. Managers will take actions after getting the
complaints.
● After getting the complaints regarding dishonest and fraudulent behavior, a proper
investigation will be done to disclose reasons behind this kind of activities.
● If proven, the concerned person will get fired by this company on immediate ground.
This approach will help us to maintain a good workplace environment and we will be
able to serve better to our clients.
6

E. Whistleblower Protections
Whistleblowers in a firm play an essential role in identifying and reporting any sort of
misconduct, which harms consumers. Whistleblowers need to be motivated and encouraged
to come forward and it is the duty of IOOF to protect them under corporations act 2001. For
example, tax whistleblowers, who disclose information to the company regarding any tax
avoidance behavior and issues (Ato.gov.au, 2019). A whistleblower can be a current or
former employee of this company who discloses any fraudulent behavior about this firm. Any
other associate, suppliers, contractors can be categorized as whistleblower who discloses
information that is related to IOOF Holdings. Subject of disclosure regarding whistleblowing
can be related to any misconduct in the company like exploitation, breaching of corporations
act or any improper state of circumstances (Garegnani et al. 2015).
Protection of whistleblowers includes:
● Whistleblowers will be given easier access to various compensation and support if
they suffer any damage while reporting. This includes costs unless the investigating
board finds the claim vague or if whistleblower acted improperly.
● Whistleblowers can only be provided with support and compensation if they maintain
confidentiality and security of information related to this firm.
● It is a criminal offense if any personnel-related with IOOF causes any damage to the
whistleblower or even threatens the person. In addition, whistleblower's
confidentiality must be protected by the concerned persons and they will be held
liable in case of any breach of information regarding whistleblower.
● Company will give value to whistleblowers because they are helping in enforcing the
laws properly and acting in favor of saving company reputation.
F. Enforcement
Enforcement refers to complying with law or codes for avoiding legal issues. For example,
this code of conduct is being developed to improve business operations and organizational
culture. All of the stakeholders are responsible to maintain these codes to avoid legal issues.
In case of failure in maintaining this code of conduct, one may face disciplinary action. In
case of foreign deal, it is important for employees of a company to enforce the cd of conduct
for maintaining all legal guidance (Dfat.gov.au, 2019). Breach of conduct by stakeholders
7

may lead to a breach of foreign trade rules by the company. In that case, shareholders may
face financial distress.
Codes for enforcement:
● This code of conduct is being supported by the leaders and board of this company. We
are expecting to have cooperation from all levels of our business regarding this
matter. Compliance with this code is being taken on topmost priority by the
management team of this company.
● Every internal stakeholder of this company is liable to maintain this code of conduct.
If they fail to do so, they can face disciplinary actions. We can terminate your
employment at any time if you fail to comply with this code of conduct.
● On behalf of this company, the HR manager of this company is liable to monitor
compliance if employees with this code.
● On breaching of this code, we may refer this case to the appropriate authority of law
enforcement. the n the concerned person may face legal issues. Due to this reason, it
is recommended for all stakeholders to comply with this code of conduct.
Conclusion
The codes mentioned above are applicable to all personnel who are currently employed in
IOOF. The code applies to a person who is identified as a representative of this firm. All
representatives of IOOF Holdings needs to remember and maintain the guidelines during the
working hours. Any violence of these guidelines can result in enforcement of actions by the
management. Proper evaluation and maintenance of these codes can help personnel of IOOF
Holdings to maintain harmony and integrity among them.
8

Reference list
Afr.com (2018), APRA says IOOF rots from the head, [Online], Available at:
https://www.afr.com/companies/financial-services/apra-says-ioof-rots-from-the-head-
20181207-h18v8x [Accessed on 3rd September 2019]
Asic.gov.au (2019), Whistleblower protection, [Online], Available at: https://asic.gov.au/for-
business/small-business/protecting-your-small-business/ [Accessed on: 3rd September 2019]
Ato.gov.au (2019), Whistleblower protection, [Online], Available at:
https://www.ato.gov.au/general/gen/whistleblowers/ [Accessed on: 3rd September 2019]
Business.gov.au (2019), Fraudulent behavior, [Online], Available at:
https://www.business.gov.au/People/Managing-and-developing-staff/Complaints-and-
dispute-resolution [Accessed on: 3rd September 2019]
Cappelli, P. and Tavis, A., 2016. The performance management revolution. Harvard Business
Review, 94(10), pp.58-67.
Dfat.gov.au (2019), Enforcement, [Online], Available
at:https://dfat.gov.au/about-australia/australia-world/Pages/business.aspx [Accessed on 3rd
September 2019]
Eoc.wa.gov.au (2019), Exploitation, [Online], Available at:
http://www.eoc.wa.gov.au/mediacentre/news-detail/2019/04/29/australian-council-of-human-
rights-authorities-statement---april-2019 [Accessed on: 3rd September 2019]
Fairwork.gov.au (2019), Exploitation, [Online], Available at:
https://www.fairwork.gov.au/how-we-will-help/templates-and-guides/best-practice-guides/
workplace-privacy [Accessed on: 3rd September 2019]
Garegnani, G.M., Merlotti, E.P. and Russo, A., 2015. Scoring firms’ codes of ethics: An
explorative study of quality drivers. Journal of Business Ethics, 126(4), pp.541-557.
Humanrights.gov.au (2019), Discrimination, [Online], Retrieved on 3rd September 2019 from:
https://www.humanrights.gov.au
9

Ioof.com.au (2019), About us, Available at: https://www.ioof.com.au/about-us/about-ioof
[Accessed on 3rd September 2019]
Kleynjans, L. and Hudon, M., 2016. A study of codes of ethics for Mexican microfinance
institutions. Journal of business ethics, 134(3), pp.397-412.
Peters, S. and Maniam, B., 2016. Corporate fraud and employee theft: Impacts and costs on
business. Journal of Business and Behavioral Sciences, 28(2), p.104.
Smh.com.au (2019), Scandal-hit IOOF takes action after horror year, [Online], Available at:
https://www.smh.com.au/business/banking-and-finance/investors-heartened-as-ioof-takes-
action-on-regulator-conditions-20190219-p50ytg.html [Accessed on 3rd September 2019]
Stohl, C., Etter, M., Banghart, S. and Woo, D., 2017. Social media policies: Implications for
contemporary notions of corporate social responsibility. Journal of Business Ethics, 142(3),
pp.413-436.
10