IOOF Holdings Code of Conduct Report: CGRM4000, Corporate Governance

This report presents a comprehensive Code of Conduct designed for IOOF Holdings, a financial services provider. It addresses critical areas such as discrimination, defining discriminatory practices and the company's commitment to zero tolerance, referencing relevant legislation like the Age Discrimination Act and the Sex Discrimination Act. The report then explores workplace exploitation, encompassing harassment and bullying, and clarifies prohibited behaviors, including offensive language and undermining work performance, while referencing the Fair Work Amendment Act. It also tackles corruption, defining corrupt acts like bribery and embezzlement and emphasizing the responsibility of employees to report such activities. Dishonest and fraudulent behavior is also examined, highlighting instances like prioritizing personal interests over organizational ones. Furthermore, the code emphasizes whistleblower protections, outlining reporting channels and the company's commitment to confidentiality and support for whistleblowers. Finally, the report details enforcement measures, including disciplinary actions for breaches of the code. The report includes references to academic journals and other sources to support its content.

CODE OF CONDUCT

Contents
Introduction and Scope of the Code...........................................................................................2
Contents of the Code..................................................................................................................2
Discrimination:.......................................................................................................................2
Exploitation:...........................................................................................................................3
Corruption:.............................................................................................................................4
Dishonest and Fraudulent Behaviour:....................................................................................5
Whistle-blower Protections:...................................................................................................6
Enforcement...............................................................................................................................6
References..................................................................................................................................8

Introduction and Scope of the Code
The company IOOF Holdings Limited is a leading provider of the financial services
including the advices in relation to the retirement planning, superannuation, estate and the
trustees; and the range of products. The company is based in Australia. The company is one
of the names among the ASX Top 200 with a history of business of 170 years in the financial
business, and a strong base of 500000 customers and 20000 employees (IOOF, 2019).
However, the company was in news during the Royal Commission enquiries, where
irregularities were found in the operation of superannuation fund, following which few
executives and directors were banned from the company (Frost, 2019).
The following code of conduct is a statement guiding the members of the organisation to
adhere to the integrity, moral values, and the professional standards. The code of conduct lays
down the standard of conduct that is expected out of the employees and other members while
discharging their duties and the responsibilities. The underlying principles that have guided
the designing of the code of conduct are the laws of the land and the industry, principles of
the ethical behaviour and the highest standards of the workplace practices.
The code applies to Senior Management, employees and other members of the organisation.
It is the duty of the employees to read the policies laid down in the code of conduct to remain
aware of their conduct in their conduct while at workplace.
Contents of the Code
Discrimination:
Discrimination in workplace is defined as the treating or the proposal to treat individuals
unfavourably on lines of a personal characteristic that is preserved by the law (Australian
Human Rights Commission, 2019). Eighteen personal characteristics have been prescribed by
the Equal Opportunity Act 2010 on lines of which the discrimination at workplace is
purported. Some of these characteristics are the age, disability, marital status, race, sex,
parental and carer status, physical features, political belief, religious belief, sexual orientation
and others (Okechukwu et. al, 2014). There have been prescribed a range of federal anti-
discrimination laws in Australia, such as the Age Discrimination Act 2004, Disability
Discrimination Act 1992, Racial Discrimination Act 1975 and the Sex Discrimination Act
1984.

The company is dedicated to the adherence of the legislations mentioned and follows a zero
tolerance towards the discriminatory practices at the workplace premises. The activities that
fall in the ambit of the discriminatory activities in the workplace are listed as follows.
 Refusing to employee an individual because of his or her age.
 Treating the subordinates or other individuals unfairly based on the gender, religious
beliefs, and other attributes.
 Application of the above unfair criteria in the hiring and firing practices.
 Denying disability leave, maternity leave, or retirement options.
 Favouritism when issuing promotions,
 Passing off colour comments,
 Termination without sound reasons and others (Boone et. al, 2013).
It is the duty of the senior managers of the entity, the departmental heads as well as the
employees of the organisation to support the creation of a healthy work culture comprised of
values, coordination, mutual respect and the professionalism. It must be ensured that the
workplace is free from the favouritism and similar unhealthy practices. Any employee or
member found to be breaching the above mentioned guidelines will face the disciplinary
action which can involve termination from the job as well as stated in the enforcement
section of the code.
Exploitation:
Workplace exploitation is comprised of mainly two elements namely harassment and
bullying behaviour. Workplace bullying or the Workplace harassment denotes the
unreasonable and repeated behaviour that results in a risk to health and safety and the
direction of which is not limited to an individual but can also involve a group (Safe Work
Australia, 2019). The section 789FD of the Fair Work Amendment Act 2013 (Cth), states that
the said behaviour can be in different forms such as the psychological and physical bullying
and can also include the deliberate exclusion. Some of the activities that fall in the above
category are the use of the offensive and abusive language, physically aggressive and
intimidating behaviour, passing humiliating comments, and indulging in unjustified criticism
or complaints (Hodgins, MacCurtain and Mannix-McNamara, 2014). These are in addition to
the giving employees’ impossible jobs, withholding information vital for effective work
which leads to the undermining of the work performance, overloading a person with work
and others (Bartlett and Bartlett, 2011). The provisions governing the discrimination and

harassment are further contained in the various sections of a range of legislations such as
section 28A of the Sex Discrimination Act 1984 in context of unwelcoming sexual advances
and section 18C of the Racial Discrimination Act 1975 in context of the offensive behaviour
on basis of racial hatred. Further, the section 25 of the Disability Discrimination Act 1992
regulates the harassment on basis of disability (Law Council of Australia, 2017). However,
the activities pertaining to taking of the disciplinary actions, directing or controlling the way
work is carried out and making decisions with respect to the poor performance would not be
constituted as bullying (Fair Work Ombudsman, 2019).
The said activities can result in depression, psychological distress and emotional exhaustion
for the employees and utmost care and consciousness is requisite to be exercised by the
employees and members at all times. Hence, it is the responsibility and duty of the employees
to not to engage in such unacceptable range of behaviours. The employees must be aware of
their language and overall conduct at all times while being associated with the entity IOOF.
For instance, the Former Managing Director of the organisation was accused of refusing
unilaterally to shift the staff super fund of Optus elsewhere without the support of proper
reasons (Frost, 2019b). The said accusation undermined the goodwill of the entity. The
company would not tolerate any acts of exploitation that hinders the mental and physical
space of any employees, and any sort of violation would result in the disciplinary action
depending upon the grievance of the issues involved.
Corruption:
 Acts of bribery and corruption undermine the integrity and the overall success and
functioning of an organisation. Corruption is referred to as a dishonest and illegal way
of people to gain undue advantage over the others by the misuse of the positions of
authority (Larmour and Wolanin, 2013). The acts are also inclusive of the giving or
accepting of bribes or inappropriate gifts. The said acts are purported directly or
indirectly to earn certain kind of advantage that is otherwise not available. Some of
the acts that constitute acts of corruption and bribery are mentioned as follows.
Stealing and selling business secrets
 Charging money or gifts from the customers or other associates of the business
 Embezzlement of money
 Falsification of the documents of the entity
 Modifying the information or data in the computers and information systems
 Stealing passwords and others (Carr and Lewis, 2010).

These are in addition to the stealing or misusing the organisation’s assets for the personal
purposes including the cash meant to be expended in a particular manner (Vickers, 2014).
Hence, any sort of activities that undermine the interests of the organisation or loss of the
property would fall in this category.
Each employee at IOOF has been extended a responsibility through this code of conduct to
ensure that the company will not get involved in corruption. The employees must report any
sort of the above activities in their knowledge and those members who have been held
responsible for the unlawful actions on the lines of corrupt behaviour will be exposed to
penalties and punishment including litigations depending on the range of violation, as
elaborated in the enforcement section of the code.
Dishonest and Fraudulent Behaviour:
Yet another serious internal concern in the workplace is in the form of dishonest and
fraudulent behaviour. The various hierarchal levels, are vulnerable to such issue and various
members from top to bottom can be involved in the chain (Corruption and Crime
Commission, 2018). The dishonest or the fraudulent behaviour denotes the process of
prioritizing personal interest over the organisational interests (Hollow, 2014). A few of the
instances that highlight dishonest and fraudulent behaviour are securing a business contract
or transaction that is detrimental to interest of the entity but beneficial for self, and securing a
contract in which the employee or his or family members are personally interested. These are
in addition to passing on the confidential information acquired during the professional
engagement with the enterprise to the competitors and others (Wells, 2017). It also includes
the setting up of a competing business or entering into simultaneous other professional
engagements outside the present job role at IOOF unless the company rules permit, and
acceptance of the gifts of the amount and nature that are prohibited by the law or the
enterprise rules.
It is one of the yet another prime duties of the employees and members to ensure the
maintenance of the highest standards of professionalism and integrity in their dealings and
overall conduct at the enterprise.

Whistle-blower Protections:
It is imperative to note that the above discussed issues on the lines of the inappropriate,
wrongful or unethical behaviour by any employee, supervisor, or the members of the
enterprise can lead to the serious harm to the reputation of the entity as well as the objectives
of the business. Hence, such issues must, be reported immediately. It is the responsibility of
the employees to report concerns or questions relating to apparent violations of law and
regulation, malpractices, unethical behaviour, or any other issues perceived at the workplace
(Pascoe and Welsh, 2011).
The entity IOOF recognises its responsibility towards the employees in terms of safety and
security of being the whistle-blowers and considers the protection of such whistle blowers as
one of the prime responsibilities. The reporting can be done by the employees to following
officials or entities, namely the-
 Immediate supervisor
 Unit Head or the Department Head
 Human Resources Manager
 Whistle-blower Committee
 Ethics Officer
The employees can also report the issue anonymously by writing the mail or calling on the
contact credentials mentioned at the end of the code of conduct.
On coming across of such a reporting, it is the duty of the managers or the whistle blower
committee to conduct the enquiry or conversations within or outside the entity and collect the
appropriate evidences. The same must be documented properly and the process must be
carried till the conclusion are reached in terms of support to the claims made or rebuttal of the
same to be baseless. The entity ensures to keeping the records of such whistleblowing
confidential including the personal details of such employees and ensures to provide support
in the form of legal assistance if needed.
Enforcement
The affirmation and adherence to the policies mentioned in the code of conduct is
compulsory. The same must be complied on a consistent basis and in the events of breach of
the guidelines the management of the entity IOOF is free to take any actions, depending upon

the severity of the issues. The following disciplinary actions may be taken by the
management of the organisation.
 Imposition of monetary penalties
 Issue of Warning
 Letter of reprimand
 Demotion from present job role
 Withholding of promotion
 Termination of the services
 Legal actions
 Possible criminal chargers or civil lawsuits in case of discrimination, exploitation, and
corruption acts.

References
Australian Human Rights Commission 2019, Discrimination - Workplace [online] Available
from: https://www.humanrightscommission.vic.gov.au/the-workplace/workplace-
discrimination [Accessed on: 28 August 2019].
Bartlett, J E, and Bartlett, M E (2011) Workplace bullying: An integrative literature review.
Advances in Developing Human Resources, 13(1), pp. 69-84, doi:
10.1177/1523422311410651
Boone James, J., McKechnie, S., Swanberg, J., and Besen, E. (2013) Exploring the workplace
impact of intentional/unintentional age discrimination. Journal of Managerial Psychology,
28(7/8), pp. 907-927.
Carr, I., and Lewis, D. (2010) Combating corruption through employment law and
whistleblower protection. Industrial Law Journal, 39(1), pp. 52-81.
Corruption and Crime Commission (2018) What is Corruption? [online] Available from:
https://www.ccc.wa.gov.au/what-is-corruption [Accessed on 28 August 2019].
Fair Work Ombudsman (2019) Bullying & harassment [online] Available from:
https://www.fairwork.gov.au/employee-entitlements/bullying-and-harassment [Accessed on:
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Frost, J. (2019a) IOOF unveils $235 million compensation bill [online] Available from:
https://www.afr.com/companies/financial-services/ioof-unveils-243-million-compensation-
bill-20190825-p52kl2 [Accessed on: 29 August 2019].
Frost, J. (2019b) IOOF skimmed super members: APRA [online] Available from:
https://www.afr.com/companies/financial-services/ioof-skimmed-super-members-apra-
20190430-p51imq [Accessed on: 29 August 2019].
Hodgins, M., MacCurtain, S., and Mannix-McNamara, P. (2014) Workplace bullying and
incivility: a systematic review of interventions. International Journal of Workplace Health
Management, 7(1), pp. 54-72.
Hollow, M. (2014) Money, morals and motives: An exploratory study into why bank
managers and employees commit fraud at work. Journal of Financial Crime, 21(2), pp. 174-
190.

IOOF Holdings Limited (2019) About Us [online] Available from:
https://www.ioof.com.au/about-us/about-ioof [Accessed on: 28 August 2019].
Larmour, P., and Wolanin, N. (Eds.). (2013) Corruption and anti-corruption. ANU E Press.
Law Council of Australia (2017) Bullying and harassment in the workplace [online]
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