National Australia Bank's Code of Conduct: A Comprehensive Analysis

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Code of Conduct
National Australia Bank
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Table of Contents
Introduction..........................................................................................................................................3
Code of Conduct.................................................................................................................................4
Discrimination..................................................................................................................................4
Exploitation......................................................................................................................................5
Corruption........................................................................................................................................7
Dishonest and Fraudulent Behaviour...........................................................................................8
Whistleblower Protections...........................................................................................................10
Enforcement..................................................................................................................................12
Conclusion.........................................................................................................................................13
References........................................................................................................................................14
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Introduction
National Australia Bank works with the commitment of conducting professionalism
and acting with integrity, fairness, and honesty towards the society, employees,
community, government, customers, and other stakeholders. The code of conduct of
NAB provides a set of guidelines to the company and its personnel for acting
ethically and, and the NAB Board is responsible for monitoring the application of the
code of conduct. The NAB personnel act professionally to foster confidence,
goodwill, and trust in suppliers, customers, community, and colleagues. The code of
conduct of NAB outlines the guidelines concerning corruption, exploration,
whistleblower protections, discrimination, enforcement, and dishonest and fraudulent
behaviour.
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Code of Conduct
Discrimination
Discrimination refers to the treatment given to someone with having the less
desirable attribute. NAB possesses an anti-discrimination policy which involves the
prevention of harassment and discrimination. Main reasons for the discrimination
and harassment at the workplace happen on specific protected attributes such as
race, gender, sexual orientation, age, disability, and colour and so on. Under this
policy, all the employees associated with the organisation NAB require participation
in the training and education program weekly regarding the prevention of
harassment and discrimination at the workplace (Nab.com.au, 2019). All the
employees of NAB require completion of the course of Equal Employment
Opportunity. Prevention of discrimination considers while recruitment, promotion,
and training and other events. This policy outlines the penalties, job termination, and
other significant aspects of the organisation on found guilty of such allegations. An
investigation conducts for resolving the case by the Board of NAB. Incident of any
discrimination considers unlawful and prevention of such incidents is of utmost
importance for the Board. A case determines the breach of discrimination when
discrimination takes place:
 Within the organisation premises
 By the employee of the organisation within or outside the organisation
 Outside the organisation at the meeting, function, or another event for the
organisational purpose (Knoppers et al., 2014)
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Exploitation
Exploitation refers to the act of mistreating specific employee or labour for getting
benefits from his works. The code of conduct of NAB concerns mainly for the sexual
exploitation and outlines provisions for protecting the staff on duty as well as off-duty
from any act of sexual exploitation. Sexual exploitation implies taking the benefit of
one's sexuality for personal profit. The NAB Board directs the staff members for
achieving the following standards and behaviour for the stakeholder protection
(Bounds, Julion, and Delaney, 2015). Sexual exploitation considers serious
misconducts when undertakes with a child or another person. The term ‘child’
defines in this context as the individual below the age of 18 years.
An act considers sexual exploitation when
 Unwanted touching
 Recording of sexual acts as video or photo
 Forceful engagement for sex or prostitution
 Demand for sex to gain favourable profits
What should not do?
 No staff person should engage in sexual abuse or exploitation directly or
indirectly.
 No establishment of sexual relationship with the person affected from crisis
considering their vulnerability (Hardy, Compton, and McPhatter, 2013.).
 No staff person should engage in the purchasing, consumption, development,
or selling of pornography.
 No engagement in sexual harassment or exploitation activity with a child or
children irrespective of the age. Majority age or local consent age would not
consider for defence.
 Any staff person should not ask for sexual favours or other humiliation forms
using money exchange or exchange of any product or service. One should
not engage in the behaviour reflecting the exploitation or degradation of
another person.
 No exploitation of target group given their vulnerability in terms of
humanitarian, advocacy work or development.
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What should we do?
 Any staff facing sexual exploitation must report directly to the top
management or NAB Board (Rafferty,2013).
 Any staff must report to the NAB Board when knowing about the incident of
sexual exploitation.
 The staff person must take necessary actions for the prevention of sexual
harassment and exploitation.
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Corruption
Corruption and bribery in an organisation lead to the erosion of legal business
activities, exposure of NAB personnel to the vital risks, and deformation of
competition within the organisation. The Anti-corruption policy of NAB involves the
zero-tolerance towards corruption and bribery activities. This policy outlines the
mandate requirement of the compliance of anti-corruption laws and regulations of the
countries where NAB operates. The code of conduct of NAB guides the employees
and other organisational personnel for ensuring whether to accept the gifts or other
contributions. The organisation engages actively in the initiatives in association with
other organisations (governmental or non-governmental) for fighting against
corruption and bribery. Global partnerships for anti-corruption focus much under this
anti-corruption program of NAB (Joseph et al., 2016). This program developed in
consultation with the employees considering different factors such as potential risks,
size, operational locations, and business sector. The compliance program of Anti-
corruption laws and regulations of NAB encompasses the following requirements:
 Effective communication internally and externally
 Transparent and accurate development of financial reporting mechanisms
 Prohibition of bribery within all the business relationships and transactions
 Human resources activities such as promotion, recruitment, recognition, and
performance evaluation require conducting without corruption
 Demonstration of ownership as well as commitment towards the program
along with effective leadership
 Monitoring and Review of the program by top management
 Training to the employees of NAB
Scope of the Corruption and Bribery
 Prohibition of gifts, expenses or hospitality when it violates the domestic law
 Prohibition of contributions to party officials, political parties or political
individuals (Lament, 2015)
 Non-acceptance of charitable donations as bribery and the acceptance should
be transparent
 Prohibition of facilitation payments
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Dishonest and Fraudulent Behaviour
Fraudulent behaviour implies the act of dishonesty leading to the financial loss to an
organisation or an individual. The scope of the application of NAB anti-fraudulent
policy refers to the organisation NAB and its entire employment-population whether
executive or non-executives. The primary purpose of NAB for integrating or
implementing this Anti-fraudulent policy states as the undertaking of business
ethically and responsibly. An employee can report the line management or the Board
of NAB regarding the knowledge of dishonest or fraudulent activity within the
organisation (Lee, and Fargher, 2013). As per the code of conduct, it is the
responsibility of the employees as well as the NAB Board for preventing or taking
steps for the prevention of any dishonest or fraudulent activity within the
organisation. An act considers corrupt or fraudulent when:
 Thefts of organisational assets such as supplies or cash
 Unauthorised use of organisational assets
 Reporting of falsified, dishonest or misleading financial performance
Prevention of false and fraudulent acts within NAB is the responsibility of the
employees and the Board itself. It considers the most crucial way for prevention of
such activities by fostering and integrating the influential ethical culture within the
organisation. Following are the preventive ways developed in the code of conduct
against these activities:
 An Ethical Behaviour Policy with the inclusion of conduct and behaviour
standards (Hess, and Cottrell Jr, 2016)
 Employee screening before initiating the employment
 Development of a Whistleblower process for encouraging the organisational
personnel reporting any fraudulent incidents to the top management or line
manager
 Policies of expenses and accounting for the governance of costs claimed,
discouragement to money laundering activities, and accounting treatments
 Employees are equally responsible for the prevention of all such dishonest
and fraudulent activities. The employees can detect and reduce the likelihood
of dishonest and fraudulent activities within NAB. Following are the employee
responsibilities towards this program:
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 Provide cooperation with the management of fraudulent incidents
 Gaining an understanding of fraud and dishonest through this policy and
training (Bromley, and Orchard, 2016)
 Avoid receiving or requesting any bribe
 Reflects transparency in their attitude against the incidents of fraudulent and
dishonesty
 Adhere to the appropriate job procedures and aware of their responsibilities
and duties
 Always report the fraud vulnerabilities and suspicious behaviour to the line
management or the NAB Board
 Avoid the position abusing for personal profit and act in the best interests of
NAB and its stakeholders
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Whistleblower Protections
Whistleblower protections refer to provide protections to the employees who
responsibly report against any misconduct or suspicious behaviour. The
Whistleblower program provides protection and support to such employees and
stakeholders from harassment, disciplinary proceedings, or victimisation. The scope
of this program entails the organisation NAB, its employees (casual, directors, fixed,
or permanent), and stakeholders as well (Wainberg, and Perreault, 2015). The
fundamental principles for the guidance of NAB approach towards the Whistleblower
Protections program are:
 Improper conduct by the stakeholder or an employee including unsafe
working, attempt to conceal, harassment, unethical practices, and bullying
 Raising the concern of improper conduct to the Whistleblower Protections
Officer of NAB, Line management or NAB Code of Conduct team
 Raising the concerns anonymously by contacting the Whistleblower
Protections Team of NAB through either external website or intranet of NAB
 Non-disclosure of information to anyone regarding the raising concerns by
maintaining confidentiality
 Protection to the interests of Whistleblowers as per the policy and other
applicable legislation (Near, and Miceli, 2016)
 Investigation of the raised concerns by integrating the values of objectivity and
fairness, and the involvement of external party when necessary
 In the case of no wrongdoing identified, no action against the whistleblower
for raising the concerns in good faith
 Policy review within the time of at least 12 months whenever appropriate and
applicable
 Protection to whistleblowers is significant to encourage the reporting against
unethical conduct or suspicious behaviour within NAB. Therefore, this policy
mainly emphasises the security to the interests of the employees or
stakeholders who report any suspicious activity and different ways of
providing them protection (Andon et al., 2018). Following ways adopt by NAB
for giving protection to the whistleblowers:
 Protection of identity and confidentiality
 Protection of related records, files and other information
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 Protection against inimical and undesirable behaviour
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Enforcement
NAB commits for integrating the values such as unbiased, integrity, and honest in
the behaviour within the organisation. Enforcement of Code of Conduct provides
significant support to NAB in fulfilling the commitment towards NAB’s Code.
Moreover, enforcement of the Code of Conduct involves the proper communication
of what Code signifies for the company and its employees. The Code of Conduct
enforces in NAB in different ways by the top management such as adopting Code of
Conduct as guiding force for the NAB employees as well as their commitment for the
enforcement (Locke, Rissing, and Pal, 2013).
NAB Code of Conduct involves the zero-tolerance approach to misconduct or
unethical activity. It includes the harsh penalties when the wrongdoing identified as
NAB believes that this would prevent unethical activities within the organisation and
promoting an ethical working environment.
Investigation process against improper misconduct in NAB undertakes in the prompt
and fair manner (Hill, and Rapp, 2014). The key focus areas of the NAB Code of
Conduct comprise discrimination, sexual exploitation, corruption and bribery,
whistleblower protections, and dishonest and fraudulent behaviour.
The employees and stakeholders of NAB receive appreciation and recognition for
reporting the happening of any unethical or illegal behaviour. Breaching of Code of
Conduct in NAB involves remedial and disciplinary actions such as counselling and
training to the organisational personnel proved right in the investigation for engaging
in the misconduct.
Moreover, the remedial actions also encompass the termination of employment,
formal warnings, or payment loss of variable reward (Lund-Thomsen, and Lindgreen,
2014). The communication of the NAB Code of Conduct undertakes to the
employees and stakeholders using annual general meetings, annual reports,
financial results, and corporate reporting.
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