CGRM4000 Corporate Governance: Code of Conduct for IOOF Holdings

This report presents a comprehensive analysis of the Code of Conduct for IOOF Holdings, a financial services company. It addresses key issues such as discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement. The report examines the recent scandals within IOOF Holdings and the need for a revised Code of Conduct to prevent misconduct. It explores the importance of valuing diversity, preventing exploitation through transparent practices, and maintaining ethical standards to avoid corruption and fraudulent activities. The report emphasizes the protection of whistleblowers and the enforcement of laws to ensure the company adheres to ethical guidelines and regulatory requirements. The analysis draws on various news articles, academic journals, and company examples to provide a well-rounded understanding of corporate governance and ethical practices within the financial services sector.

Running head: CODE OF CONDUCT FOR IOOF HOLDINGS
Code of Conduct for IOOF Holdings
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1CODE OF CONDUCT FOR IOOF HOLDINGS
Table of Contents
Introduction................................................................................................................................2
Body...........................................................................................................................................2
Conclusion..................................................................................................................................7
Reference List............................................................................................................................9

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Introduction
IOOF Holdings is a company that is mainly associated with various financial services in
terms of financial advisories, management of investment, superannuation as well as other
trusted services. There had been recent scandals in IOOF Holdings who want to compensate
as a result of faults of two most important officials of the Company with that of financial
investor as well as regulator. When IOOF Holdings appeared before Royal Commission
Banking, Australian organization who holds Authority over Prudential Regulation sought
orders from Court of Federal Laws in order to prevent those alleged officials of the Company,
senior executive Chris Kelaher, and George Venardos who is the Chairman of the
organization as well three other officials from appearing to super fund board because they
failed to act as per interest concerns of various fund members. Since there have been such
problems in the organization therefore the previous Code of Conduct did not work properly
therefore a new code of conduct requires to be framed. This report presents a Code of
Conduct that is being framed in order to prevent such misconduct from side of employees or
other senior executives for the organization. It is basically a set of rules that includes various
social norms, religious beliefs as well as rules and responsibilities of an individual required to
shoulder themselves (Steen, McGrath and Wong, 2016). Code of Conduct designed for a
Company is applicable to all employees in the organization that provides protection to
business laws and reminds the employees about its goals and objectives.
Body
A. Discrimination Grounds
It is important on part of IOOF Holdings to support as well as value diversity of culture in
workplace and create an environment that would be absolutely free on grounds of
discrimination (Taylor et al. 1924). This is because people face lack of positive

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motivation from the board of authority members as they are frequently subjected to
discrimination on the basis of skin-colour. White-skinned people enjoy many advantages
as well as benefits provided by the Company in terms of payment as well as appraisals
while people with black skinare looked down up on and they are not treated respectfully
with dignity in the organization. This kind of ill-treatment towards employees due to
differences in race and culture or sexual orientation is required to be prevented and care
must be taken so that they do not become subject to victim of bullying or feel isolated
(Kerr, 2014). Code of Conduct is being prepared so that the Company shows an ethical
attitude while behaving with other members in organization, prevent those kind of
behavioural attitude that might make other employees feel discriminated and harassed on
the basis of social origin as well as political opinion (Coetzee, 2006).
B. Exploitation Grounds
When parties are ready to sign agreements of confidentiality as a result of relationship
between employer and employee going bitter, the problem starts arising in IOOF
Holdings. These contractual agreements prevent various parties from discussing about
situations that revolve round an acrimonious departure and force untrustworthy as well as
incompetent employees to shift to other companies without letting the employers know
regarding their resignation. In addition, some well competent employees are forced to
move aside instead of allowing them to take an active part in decision making process and
these agreements debar them to learn about the problem, therefore these employees feel
exploited and feel like scapegoats inside the organization (Mees, 2017). There must be a
code of conduct to protect the rights of these employees that would prevent them from
getting exploited and feel demotivated. The Company is required to maintain transparent
attitude regarding every procedures, investments as well as agreements so that the
employees do not have a feel of being thrown-out or disappointed regarding any action or

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plan undertaken by IOOF Holdings (Australia, Stock and Green, 2012). The women
working in the organization are required to be treated with respect and proper recognition
and care must be taken so that they do not receive any misbehaviour from other
employees and also they should not be treated like they possess lesser quantitative ability
than their male counterparts.
C. Corruption or Unethical Practices
There had been a recent scandal that took place in IOOF Holdings and the company
received allegations due to insider trading, “misrepresentation” as a result of rising issues
with respect to culture as well as insidiousness as a result of vertical integration. A
financial article submitted by Australian Regulation organizations states that the company
has committed errors while unit pricing of cash management and clients have been
complaining that they received large amount of money in their accounts associated with
cash management in a financial year 2009 and after that they were receiving lower
amount of money (Gilligan, 2018). In order to avoid these inconvenience and in order to
prevent chaos and confusion prevailing among the clients, the Company must maintain
good quality communication with financial planners and report the clients as well as
investment partners about the latest dealings as well as procedures. There were large
amount of breaches that have been discovered that are associated with cash management
trusts of IOOF Holdings and two important officials were part of these unethical
activities. An example is there have been a rising issue associated with an error in pricing
of Platinum unit in financial year 2012 and an issue associated with management of
Quester in the year 2013. In order to manage these problems, a Code of Conduct should
be framed to invest towards new technologies in order to develop various products,
services as well as delivery channels (McInnes, 2018). The company is also required to
develop a responsive attitude to these changes and deal with data integrity issues. They

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must try to understand demand of customers as well as clients and be at par with the
prevailing competition in the market so that people mainly the investors do not feel
exploited.
D. Dishonest as well as Fraudulent Behaviour on part of members of organization
Certain fraudulent activities usually prevail in organizations on account of inappropriate
deduction of money from accounts of members of IOOF Holdings and also the authorities
of this organization usually getting involved and experiencing failures in managing
financial records as well as investments, they usually getting involved in retaining or
holding of public money instead of distributing them. They have been deliberately
involving in various offences and undergo contravention of laws as laid by Royal
Commission. The Company has failed to according to the interests associated with Fund
Members as a result of which Australian Prudential Regulation Authority (APRA) has to
impose 12 various conditions of licenses. Although investors have to push the value of
shares up to 17% in $6.18 however it is undergoing a loss in value as the current rate is
$10.95 in the month of March. A Code of Conduct is required to be framed in order to
stop these dishonest activities associated with financial services in the matter of
jurisdiction. Certain difficulties are faced by trustees while dealing with various conflicts
associated with duty as well as interest. The Code of Conduct would include the fact that
trustees are required to act according to interests of various members in the organization
and the person should not breach his own duties that would make the retail business
suffer to a greater extent. In cases of disputes, the trustee is required to discharge the
duties that are concerned with MySuper team members where people must abide by rules
and regulations of MySuper Production units (Steen, McGrath and Wong, 2016). The
Company is required to develop Democratic leadership style that would make all the
members in an organization involve while taking an initiative along with the leader when

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the Company undergoes through financial crisis. Several capital investment and taking
proper care of the proceedings in the organization and clear vigilance over law and order
would help to minimize rate of fraudulent behaviour. Statutory Regulatory bodies would
help to keep a control over financial activities and these code of conduct would help to
run the organization in a smooth manner.
E. Protection of Whistle-blowers
A Whistle-blower is a person who would make an organization for example IOOF
Holdings aware against all possible improper activities that are undergoing inside the
organization. According to the Act of Corporations in the financial year 2001 an officer
of directorate laws or an employee of the organization should not receive any humiliation
if he or she raises voice against certain activities on misconduct in the organization
(McInnes, 2018). IOOF Holdings is required to maintain confidentiality act and ensure
that all those protestors are treated with respect in the organization. A moral Code of
Conduct is drafted ensuring that whistle-blower can speak with management units of
business association and also so that they can approach to Group Managers, Secretary of
the Company who looks after the cultural aspects in an organization in an easier process.
In certain cases that aroused in the Company associated with cash flow management
activities, organization may adopt unfair means and various fraud activities that might
cause suffering to various members in the organization. The protestors are require to
inform about these to senior members through emailing or post a warning message in the
website of the Company. People who are getting involved in unfair activities shall be
properly investigated by Group Member Council and report these proceedings to the
Board associated with acts against Financial Crime. It is required to take care of security
and appropriate measures so that whistle-blowers are not subjected to threat from
members committing crime within the organization (Jones et al. 2008). Certain examples

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like cashing out benefits of consumers on superannuation business in which clients have
to face creation of schemes on investment without applying for any verification process
or sometimes the Company gets involved in vandalism, cheating as well as disregarding
legislation laws and activities in those situations whistle-blowers would appear to APRA
and inform their members and they are ought to listen them in compliance to preserving
rights of employees working under any organization like IOOF Holdings.
F. Enforcing of laws
The Board of Directors in the Company may try to develop a process of comprise with
respect to shares and determine validity of issues and adopt cases of surrender that would
involve various powers of Company in terms of liability towards payment or sharing of
interests. A mode of conduct should be active that would abide by laws on shareholders
and claim various interests of people. The Board of members must hold the authority to
issue certificate for holding shares so that they have the evidence against any information
if it is lost (Watt, 2003). The Code of Conduct must ensure the fact that the Company
abides by all the orders and laws and the Company is liable to pay a sum of compensation
if it is found to commit any wrong doing. It is required on part of Board or Constitution if
the Company undertakes forfeiture or if it wants to re-issue shares. This Code of Conduct
must be framed such that proper enforcement of laws take place that would protect basic
fundamental rights of employees, clients and other partner companies (Pash et al. 2019).
Conclusion
Therefore from the above discussion it can be concluded that if IOOF Holdings follows
through the Code of Conduct then there would not be irregular activities and employees as
well as higher authorities would not be able to breach any laws. This would enable all
proceedings go in a simple manner and it would lead to a sequential flow of process under the

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organization. The Company that is mainly involved in taking responsibility of accounts of
cash of large number of customers all over Australia as well as abroad would be able to
acquire satisfaction of customers. If the officials of the organization are involved in taking
democratic decisions through involvement of most of the people who work under the
organization then it would be easy to find a solution to a particular aspect or issue. It is
required on part of IOOF Alliances to provide support services in order to make the
organization so that it can run differently from other organizations. Members are required to
utilize the benefit of network communication as well as practice of management activities so
that it encourages innovation as well as various ideas that would be beneficial for
improvement of business processes. This discussion has been made keeping in mind to
preserve rights and interests of community as well as surroundings.

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Reference List
Steen, A., McGrath, D. and Wong, A., 2016. Market failure, regulation and education of
financial advisors. Australasian Accounting, Business and Finance Journal, 10(1),
pp.3-17.
McInnes, A., 2018. Legitimacy of the current Australian Financial Services Licensee-
authorised representative licensing model: Theory and Australian empirical evidence.
City, W.A.D.V.L. and Blythe Bay, D., Harrison, Amanda Len Mackintosh: Brief of
Appelant.
Gilligan, G., 2018. The Hayne royal commission and trust issues in the regulation of the
Australian financial sector. Law and Financial Markets Review, 12(4), pp.175-185.
Mees, B., 2017. Financialization and the Stewardship of Workers’ Capital in Australia. The
Contradictions of Pension Fund Capitalism, p.79.
Kerr, N.P., 2014. " To bear all that comes upon us": Resurrecting the Aurora Colony
narrative through mortuary analysis (Doctoral dissertation, University of Oregon).

10CODE OF CONDUCT FOR IOOF HOLDINGS
Law, U., Buckskin Properties, Inc. v. Valley County Clerk's Record v. 4 Dckt. 38830.
Jones, S., Van der Laan, S., Frost, G. and Loftus, J., 2008. The investment performance of
socially responsible investment funds in Australia. Journal of Business Ethics, 80(2),
pp.181-203.
Watt, K., 2003. Proxy Voting Trends: Funds Managers in the United States of America and
Australia. Bond L. Rev., 15, p.i.
Steen, A., McGrath, D. and Wong, A., 2016. Market failure, regulation and education of
financial advisors. Australasian Accounting, Business and Finance Journal, 10(1),
pp.3-17.
Australia, W., Stock, A. and Green, K., 2012. Our vision.
McInnes, A., 2018. Legitimacy of the current Australian Financial Services Licensee-
authorised representative licensing model: Theory and Australian empirical evidence.
Coetzee, J.J.L., 2006. Wellness: a phenomenological perspective on organizational and
individual efficacy (Doctoral dissertation, University of the Free State).
Taylor, P.R., OBI, K.A., Cusack, B.L., Mclellan, D.I.I. and OBE, M.M., 1924. THE
COMPANY. Washoe County Nevada.” Official map approved by Board of County
Commissioners, May l9.
Pash, C., Niesche, C., Gergis, C. and Linwood, S., 2019. Governance: The new
realities. Company Director, 35(2), p.24.