MBA402: Analysis and Development of ANZ Bank's Code of Conduct Report

This report provides a comprehensive analysis of the Code of Conduct that ANZ Bank should adopt to prevent scandals. The report, prepared for MBA402, examines key areas including discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement. It outlines specific measures ANZ Bank can implement to foster an ethical workplace, such as promoting respect, preventing harassment, and ensuring transparent practices. The report emphasizes the importance of establishing clear guidelines and protocols to address issues like corruption and fraudulent activities, including the implementation of whistleblower protection mechanisms and enforcement strategies. The analysis draws on academic research to support the development of a robust and effective Code of Conduct for the bank.

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Mba402
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Executive Summary:
The report tries to comprehend the Code of Conduct that ANZ Bank should adopt in order to
prevent from becoming a slaughter house of scandals. Established in the year 1951, ANZ Bank
also known as Australia and New Zealand Banking Group Limited has its headquarters in
Melbourne. In Australia, it is considered second largest bank in terms of the assets and the third
largest in terms of the market capitalization. The banks operations in Australia is considered to
be one of the largest with retail and commercial banking being the dominating service. It is also
one of the largest bank of New Zealand. ANZ along with subsidiaries had a total workforce of
about 51,000 employees and served close to six million customers across its 570 branches.
Recently, the bank has been engrossed in various scandals hence calls for the need of Code of
Conduct. The report thus puts forward code of ethics which the bank can adopt to avoid such
scandals in future. This conduct aids in outlining the white and the black thereby enabling
employees in realizing things that are meant for constituting ethical as well as unethical
behavior.

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Table of Contents
Code of Conduct:.............................................................................................................................2
A. Discrimination:...........................................................................................................................2
B. Exploitation:................................................................................................................................3
C. Corruption:..................................................................................................................................4
D. Dishonest and Fraudulent Behavior:...........................................................................................5
E. Whistleblower Protections..........................................................................................................7
F. Enforcement................................................................................................................................7
References:......................................................................................................................................9

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The code of conduct represents collection of norm, rules, proper practices and
responsibilities guiding individuals within workplace. A properly written code of conduct helps
in clarifying the mission, values and the principles of an organization thereby linking it to the
standards of the professional conduct. It also acts as valuable reference thereby helping the
employees in locating the relevant documents, resources and services related to ethics of the
organization. This code of conduct also instructs employees in portraying appropriate behavior
within workplace. The report portrays the code of conduct that ANZ Bank might undertake to
prevent it from becoming a slaughter house for scandals.
Code of Conduct:
A. Discrimination:
Discrimination refers to prejudiced consideration or treatment or the practice of making
distinction based on class, category or group to which they belong. They mostly include caste,
age, disability, gender identity, family status, criminal record, generation, gender expression,
marital status, genetic characteristics, color, race, nationality, religion, sex, ethnicity, social class,
species and sexual orientation. In other words, discrimination refers to the treatment of the group
or the individual based on perceived or the actual member in a particular social group or category
(Vickers 2014). However, within workplace, some of the prominent examples of discrimination
includes limiting promotion of individuals, ending one’s employment and ensuring limited
access towards training and the other benefits (Okechukwu et al. 2014). Discrimination might be
direct or indirect. Direct discrimination refers to ensuring different treatment to employees with a
particular attribute in comparison to an individual without the attribute. For instance, not
recruiting an individual as they belong to a particular religion. Indirect discrimination refers to

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imposing a particular requirement that the individual having specific attributes is not able to
comply with. For instance, asking a worker with the family responsibilities to work over
weekends.
Discrimination in workplace can be prevented by undertaking various measures. Thus,
with the accurate protocol and system in place it is not only possible to prevent discrimination
but also the undesirable behavior and thereby ensure the cultivation of a stronger organizational
environment that would help the bottom line.
To prevent discrimination, a workplace must have its foundation on mutual respect that will
help in the development of trust within working partnership. To eliminate discrimination a
workplace should not tolerate harassment, threatening, hostility or abusive behavior. An
organization should encourage employees from varying diversity that not only enriches the work
life but also the communities. Further, to prevent discriminations, an organization should also
take care in resolving complaints confidentially and respectfully. Thus, some of the steps that an
organization needs to undertake as a code of conduct for resolving discrimination would include
(Buckner et al. 2014):
 Ensuring cooperation amongst one another in spirit of respect, trust and the partnership
 Prevention of harassment and any kind of retaliation against colleagues
 Ensure the formation of diverse team.
 Treatment of employees with respect
 Ensure appreciating diverse points of view and undertake decisions depending on merit
and integrity.

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 Striving for the local practice and customs which will possess the power to influence
decisions into proper perspective.
B. Exploitation:
Exploitation at a workplace can be defined as an act where some of the workers are
treated unfairly for someone else’ benefit. It basically refers to the social relationship depending
on asymmetry of the relationship of authority between the employers and the workers (Wall,
Tran and Soejatminah 2017). In other words, exploitation can also be referred as taking unfair
advantage of a person due to their position while giving power to the exploiter. Exploitation can
be either be termed legal or illegal. Illegal exploitation of an employee takes place when he
oversteps legal protections of the workers against own benefit. On the other hand, legal
exploitation occurs primarily when an employee is asked for performing task that are considered
to be self-damaging. However, in both the scenarios higher awareness regarding the needs, rights
and contribution can help in protecting their career and income. Exploitation can be in the form
of overworking, employee segregation based on appearance, sexual harassment, leave
repercussions and denial of adequate compensation.
ANZ Bank can however adopt a code of conduct devoid of exploitation by maintaining a
safe and healthy work ambience and encouraging the implementation of culture that puts across
equal opportunities for all. This helps in ensure better employee commitment and empowerment
of employees (McDonald, Charlesworth and Graham 2015). The code of conduct to be adopted
by the bank should not encourage any kind of unprofessional behavior thereby contributing
towards valuing physical integrity of colleagues. The bank should not only encourage employees
to raise a voice but also indulge in open, honest and constructive communication. The bank

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should also encourage transparency in all its work that will act as encouragement for the
employees.
C. Corruption:
Corruption refers to the dishonest and illegal means through which people in the
positions of authority and power engages in illegal and unethical activities for generating
personal gain. This allowed them in taking unnecessary advantage of the others and in
possessing the abilities of causing harm or influencing those who does not adhere to the request
made. Bribery is considered to be the most common ways of corruption that includes giving or
receiving gifts in return of the personal favors made across boundaries and the limits of job role.
Corruption is however a rampant phenomenon across all the sectors that leads to major injustice,
disturbance and harm to the employees and citizens across various sectors. Within workplace,
corruption is believed to be a hindrance to the efficiency and quality of service delivered by
organizations. In other words, corruption is portrayed as the negative impact on the employee
performance and ultimately to the organizational profit. However, corruption at senior
management level has direct impact on the organizational progress which results in huge losses
(Larmour and Wolanin 2013)
As far as corruption is concerned, ANZ Bank should adopt a code of conduct that must
comply with corruption regulations and laws. In doing so, the bank should not only maintain
integrity and transparency in all its dealings but at the same time foster an open communication.
There should be certain protocols that employees must follow to identify and suspect corruption.
The code of conduct to be adopted by the bank should adopt face to face interaction with the
subordinates. The conduct code should also allow the bank to overview and spot any kind of

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inconsistencies related to accounts or payroll or billing. There should be a system where a person
would write checks while another person would sign it (Purnamasari and Amaliah 2015). To
avoid corruption action should be taken on an immediate basis along with proper investigations.
If a person is found guilty then proper protocol needed to be followed for punishing the person
(Hauser and Hogenacker 2014).
D. Dishonest and Fraudulent Behavior
Dishonest behavior within a workplace refers to the unethical conduct that employees
portrays as a rest of lower morale. This might range from employee theft, submission of
improper time sheets, telling lies to co-workers and managers and unethical conduct (Leavitt and
Sluss 2015). Dishonest behavior in a workplace might leads to loss in revenue and drop in the
productivity.
In order to dissuade the workplace dishonesty an organization should have extensive
policies outlining the implication of dishonesty and consequences for the employees in violating
the policies. The company ownership and management should remain vigilant towards enforcing
policies that would help in creating a culture that would totally shun dishonesty. ANZ Bank can
however reduce dishonest behavior amongst employees by adopting a code of conduct that
addresses the following (Moore and Gino 2015):
 Creating proper systems for maintaining accounting entry and inventory
 Ensure addressing moral issues or concerns related to workplace dissatisfaction
 Ensure proper checking of employee background through strictly scrutinizing the resume
 Keeping an eye on interactions of existing employees with the supervisors, customers and
the other employees.

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Fraudulent behavior within a workplace refers to the criminal activity that might lead to the
significant consequences like imprisonment. This kind of behavior might range from market
abuse to insider trading.
In order to prevent such behavior, ANZ Bank must adopt a code of conduct that focuses on
the anti-fraud measures by addressing the following (Gill, Prowse and Vlassopoulos 2013):
 Enhancing perception of detection: Through this step employees can be made aware of
the fact that the dishonest acts would be punished.
 Segregation of the Duties: This involves implementing independent checks for serving
as fraud deterrent.
 Setting the Tone at Top: This implies towards having ethics policy. Written ethics
policy serves as an excellent means through which management is able to communicate
its philosophy toward the fraud.
 Reducing Risk of Being Fraud: This involves including surprise audits as a proactive
step towards preventing fraud behavior. This would prevent the fraudsters in destroying,
altering or misplacing the evidence of the wrong doing.
E. Whistleblower Protection
Whistleblowing is the procedure through which the employee is able to report abuse of
the authority, mismanagement or other unethical or illegal activities to executive branch that had
far reaching capabilities. In Australia, Whistleblower protection is put across for particular
disclosures under patchwork of the laws both at the federal and the state level. The eligibility for
the protection is based on requirements of valid law and subject matter for disclosures. All

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disclosures are however not protected by law. At federal level, Whistleblowers faces potential
imprisonment for disclosures related to immigration and national security (Brown 2013).
In the workplace, Whistleblowing protection encourages an employees in raising concern
and speaking up against any kind of wrongdoing or conduct or situations that raises the ethical,
legal and regulatory concern.
In case of ANZ Bank, authorities might undertake prompt action to escalate against any
breach of conduct as a means of Whistleblowing protection. The code of conduct should also
focus on the whistleblower hotline which is a 24 hours service for the employees to report
against anything confidential. The hotline also help in reporting any concern anonymously.
F. Enforcement
Enforcement refers to the official discovery of a problem by a federal agency along with
submission of the official report for conducting a study. In other words, this indicates a means of
ensuring compliance with rules, laws, regulations, standards and social norms (Delis, Staikouras
and Tsoumas 2016). It has been found that the Office of Comptroller of Currency (OCC)
undertakes enforcement actions in case of violations of the rules, laws, final orders, conditions or
regulations and unsound or the unsafe practices. They are authorized in taking enforcement
actions for national banks, federal chartered associations and its subsidiaries, federal agencies
and branches of the foreign bank and the institution-affiliated parties comprising of the
directors, officers, agents, controlling stockholders and the employees. Enforcement and the
Compliance Division (E&C) however serves as the counsel for the OCC for ensuring the formal
investigations and the enforcement actions.

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Certain enforcement action that ANZ Bank could undertake as part of their code of
conduct include (Wu and Salomon 2017):
 An organization should take actions or follow necessary prohibitions when subjected to
terminate order.
 A banking organization must pay fine when subjected to orders related to civil penalty
 Banking organization remaining subjected to formal agreements must agree to follow
action or prohibition according to written document.
 A banking organization that faces the filing of a notice can litigate matters to
administrative judge.
 Banking organization that has been subjected to directives of quicker and corrective
action must undertake essential action.
 A banking organization that remains subjected to soundness and safety order must take
necessary actions or trail the imposed prohibitions.
 A banking firm involved in securities activities involving government or the municipal
securities is usually subjected to restitution and suspension based on the law.
Thus, ANZ Bank needs to adopt a code of conduct that put forward measures against
discrimination, exploitation and corruption, dishonest and fraudulent behavior, provided
whistleblower protections and ensured enforcement actions. This will not only prevent the
organization from any major scandal but at the same time will empower the employees in
undertaking necessary actions based on the code of conduct.

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References:
Brown, A.J., 2013. Towards ‘ideal’whistleblowing legislation? Some lessons from recent
Australian experience. E-Journal of International and Comparative Labour Studies.
Buckner, G.E., Hindman, H.D., Huelsman, T.J. and Bergman, J.Z., 2014. Managing workplace
sexual harassment: The role of manager training. Employee Responsibilities and Rights
Journal, 26(4), pp.257-278.
Delis, M.D., Staikouras, P.K. and Tsoumas, C., 2016. Formal enforcement actions and bank
behavior. Management Science, 63(4), pp.959-987.
Gill, D., Prowse, V. and Vlassopoulos, M., 2013. Cheating in the workplace: An experimental
study of the impact of bonuses and productivity. Journal of Economic Behavior &
Organization, 96, pp.120-134.
Hauser, C. and Hogenacker, J., 2014. Do firms proactively take measures to prevent corruption
in their international operations?. European Management Review, 11(3-4), pp.223-237.
Larmour, P. and Wolanin, N. eds., 2013. Corruption and anti-corruption. ANU E Press.
Leavitt, K. and Sluss, D.M., 2015. Lying for who we are: An identity-based model of workplace
dishonesty. Academy of Management Review, 40(4), pp.587-610.
McDonald, P., Charlesworth, S. and Graham, T., 2015. Developing a framework of effective
prevention and response strategies in workplace sexual harassment. Asia Pacific Journal of
Human Resources, 53(1), pp.41-58.

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Moore, C. and Gino, F., 2015. Approach, ability, aftermath: A psychological process framework
of unethical behavior at work. The Academy of Management Annals, 9(1), pp.235-289.
Okechukwu, C.A., Souza, K., Davis, K.D. and de Castro, A.B., 2014. Discrimination,
harassment, abuse, and bullying in the workplace: contribution of workplace injustice to
occupational health disparities. American journal of industrial medicine, 57(5), pp.573-586.
Purnamasari, P. and Amaliah, I., 2015. Fraud prevention: Relevance to religiosity and spirituality
in the workplace. Procedia-Social and Behavioral Sciences, 211, pp.827-835.
Vickers, M.H., 2014. Towards reducing the harm: Workplace bullying as workplace corruption
—A critical review. Employee Responsibilities and Rights Journal, 26(2), pp.95-113.
Wall, T., Tran, L.T. and Soejatminah, S., 2017. Inequalities and agencies in workplace learning
experiences: international student perspectives. Vocations and Learning, 10(2), pp.141-156.
Wu, Z. and Salomon, R., 2017. Deconstructing the liability of foreignness: Regulatory
enforcement actions against foreign banks. Journal of International Business Studies, 48(7),
pp.837-861.