National Australia Bank Code of Conduct: MBA402 Assessment Report

This report presents a comprehensive Code of Conduct for the National Australia Bank (NAB), addressing key areas crucial for ethical business practices and governance. The code explicitly outlines NAB's commitment to ethical conduct, covering principles related to honesty, integrity, and respect. The report delves into specific expectations and policies regarding discrimination, exploitation, corruption, and fraudulent behavior, emphasizing NAB's zero-tolerance stance on these issues. It details the bank's approach to anti-discrimination laws, ensuring equal opportunities, and providing avenues for stakeholders to report concerns. The code also clarifies NAB's stance on exploitation, prohibiting unfair treatment of employees and stakeholders. Furthermore, it addresses corruption, emphasizing anti-bribery and anti-fraud measures, and the protection of whistleblowers. The report also highlights NAB's commitment to compliance with relevant laws and regulations, including the Corporations Act 2001 and Australian Stock Exchange listing rules. It concludes by outlining the enforcement mechanisms and contact information for the Ethics Management Committee, reinforcing the code's enforceability and the bank's commitment to ethical business conduct.

Running Head: BUSINESS AND CORPORATION LAW 0
Code Of conduct
National Australian
Bank

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Our code of conduct is our identity and it is a public statement that the national Australian Bank
is committed to ding correct things. This code lays down expectations and obligations that are
necessary to follow the objectives and principles set out under this code. As this code of conduct
cannot include everything, hence we expect you to use your best possible judgment and to raise
your concern when you have any concerns or doubt about it
This code of conduct is applicable to all the directors, members of senior manager, employees
and all the staff members of the National Australian Bank (NAB). Directors and senior managers
of the bank shall confirm compliance with this code of conduct at the end of each financial year.
The code outline the manner in which we behave with
 Our employees
 Our financial Stakeholders
 The community in which we operate
 Creating an environment that is full of dignity and respect.
Introduction
Applicabilty
Our Responsibility
Scope

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 Taking care of the interest of all the stakeholders
 Encouraging the positive and moral behavior in employees and staff members
The code outlines many principles related to different aspects and lets the management and
employees of the organization know what we actually expect from them. NAB has a general
principle regarding behavior that includes honesty and integrity; nevertheless, some areas have
been covered by this code, where the organization has certain specific expectations and have
zero tolerance policy on. These areas are mentioned below:-
Discrimination at the workplace is a circumstance where the employer treats employees of the
organization in an unequal manner (Dictionary.cambridge.org, 2019). Discrimination can be at
any stage of the employment from the selection of candidates to promotion of employees.
Discrimination can be direct as well as indirect (Vera and Feagin, 2017). Being a responsible
organization NAB does not support either form of discrimination. We provide equal
opportunities to all the eligible candidates and employees in our organization. Australian Anti-
discrimination law prevents discrimination among employees based on race, gender identity, sex,
age, sexual orientation, disability, and intersex status (Ag.gov.au, 2019). We adhere to follow all
the anti-discrimination laws that are applicable to us. These laws include the Age Discrimination
Act 2004, the Racial Discrimination Act 1975, the Disability Discrimination Act 1992, and the
Sex Discrimination Act 1984. While recruiting and selecting candidates and employees, we
require our senior staff to take the decision solely based on their skills, performance,
competence, merit, and potential. We ensure that no employee, as well as other stakeholder,
Our Core Principles
Discrimination

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faces unlawful discrimination while dealing with NAB. While dealing with employees, the
managers will ensure that:-
 Every employee get an equal opportunity to show his/her skills and talents
 Because of the above-mentioned attributes, employees are not getting different treatment
 During the appraisals and promotions, the performance of the employee in the past is the
whole sole criteria of decision.
We would like to highlight that whenever an employee or other stakeholder face any
discrimination from the side of NAB or its any director/manager/staff then the same can raise the
issues and can address the same to our ethics management committee.
Exploitation is an act where an employer treats employees in an unfair manner for his/her
personal benefits (Komlos, 2018). We as an organization understand the expectations of our
employees as well as outsider stakeholders and therefore prohibit all those practices that can lead
to the issue of exploitation. The organizational structures, role and responsibilities and working
hours of every NAB personnel are defined. In addition to these rules and provisions related to
holidays are also explained. We comply with the defined standards in our practices and ensure
that in the performance of their roles and responsibility no manager or employee exploits others,
especially to their juniors. We strictly prohibit the following activities
 Irregular working hours of employees against their consent
 Asking for the overtime without additional pay
Exploitation

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 Asking to join office even on public holidays
 Taking advantage of financially week candidate and giving them a job on very less
remuneration
 Late payments of wages/salary
 Giving the tasks to employees that do not correspond to their portfolio
Above mentioned points are not all inclusive but they are just a few identified examples. In a
general sense, neither any senior management nor the junior staffs of NAB are allowed to do any
kind of exploitation. We believe that the satisfaction and happiness of our employees is the
primary thing that we want. In order to earn more financial benefits, the company shall not
exploit its employees or any other stakeholder.
Corruption can be understood as a fraudulent activities by the people who are in position, mainly
involves bribery, which they pursued for personal gain (U4.no, 2019). Accepting gifts, money or
any advancement in an unfair manner comes under the category of bribery (Lexisnexis.com,
2019). Our employees as well as all those representing us, including intermediaries and agents,
shall not offer or get any improper or illegal payments and benefits in a direct or indirect manner
that is intendant to obtain undue favors. Company demotivates all the activities that are related to
bribing and corruption. All the NAB personnel has their responsibilities and they are getting
remuneration for the same. If any employee receives any gift or money for the performance of
the designated duties then it is considered as bribe and corruption.
Corruption

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We would like to state that the only receipt of bribe is not prohibited but payment of the same is
too prohibited. Company has separate anti-bribery and corruption policy that set out
organizations' approach and responsibilities of the employee for complying applicable regulatory
and legal requirements regarding bribery and corruption. We shall comply with all the related
and applicable anti-fraud, anti-money laundering and anti-corruption laws and we shall establish
a proper process to check and prevent such breaches. We have a zero tolerance policy with
respect to bribery and corruption. We understand that such activities defeat the value and
goodwill of the organization. We deal with every instance of suspected corruption and bribery
seriously. If an employee detects to be involved in a corrupted practice then the burden of proof
will be on such an employee.
Ethics is the primary concern for NAB. Not only the senior management but every other staff
member of the organization is liable to follow the ethics and moral in his/her practices. This code
of conduct outlines the wanted behavior of employees. Fraud and dishonesty are wider terms and
includes bribery and corruption in itself as well. All the NAB personnel are required to decide
what is ethical and what is not while acting on behalf of NAB. Honestly is the core of business
ethics (Robinson and Dowson, 2012). There is no particular definition of fraudulent and
dishonest behavior but it includes all those activities where people give priority to their personal
interest over and above of organizational goals (Oxfordre.com, 2019). Following activities shall
be considered as the fraudulent and dishonest one
 Theft of money
Fraudulent and dishonest behavior

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 Act of bribery
 Falsification of accounts
 Use or organizational resources for personal benefits
 Falsification in salary claims
 Insider trading (Atlassociety.org, 2011)
 Sharing of business information with outsiders
It is the responsibility of every employee to keep their hands safe and not to be involved in any
fraudulent activities; nevertheless, managers have some more liability in this direction. NAB
gives responsibility to all the senior managers of the department to review the activities of their
subordinates. Goodwill of the organization is a precious intangible asset (Patchett, 2016).
Protection of goodwill of NAB is moral liability of all the personnel. Ethics management
committee is there to entertain all the complainants and issues related to fraudulent activities. We
give enough freedom and liberty to all of our stakeholders to report any dishonest behavior of
our personnel as ethics comes first and the fraudulent behavior of any employee or manager will
not be tolerable.
The section is focused on whistle-blower protection. Whistleblowing can be understood as
reporting of any unethical issues to the authority. On the different side, a whistle-blower is a
person who performs whistleblowing activity. This is one of the important parts of this code and
every stakeholder should have a deep look into it. In the rest of the parts, we gave our
stakeholders freedom to report any issues related to discrimination, fraud, corruption exploitation
Whistle Blower Protection

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and fraudulent behaviour and breach of other provisions of this code. Now, we want to let our
stakeholders inform that while doing so they will get the security from our side. A person should
not be afraid of reporting any such issues as being we ensure that we will keep the identity of
whistle-blower secure. We understand that reporting fraud can lead some danger to you and
hence we have required measures to carry this activity in a secret manner. Following are some
authorities to whom a fraudulent activity can be reported:-
 Ethics management committee
 Chief Human Resources Officer
 Any director of the company
 Any senior management of the company
 Immediate senior
 Complaint box
Company will investigate all the reported matters. The whistle-blower will get protection from
detrimental treatment such as demotion, dismissal, disciplinary action, harassment or any other
kind of unfavorable treatment. On the receipt of any report, NAB will only share your personal
identity if
 You consent
 the concern is reported to the Australian Federal Police, Australian Securities, and
Investments Commission or the Australian Prudential Regulation Authority
Further, the company will secure all the documents are reports related to the investigation of an
issue. We ensure that any release of information related to a whistle-blower in breach of this

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code will be treated a serious matter and company will deal with the same under NAB’s
disciplinary procedures.
The organization is registered as a company with ASIC and therefore is required to comply with
all the provisions of Corporations Act 2001 (Cth). Further Listing rules prescribed by the
Australian Stock Exchange is another requirement that NAB is required to follow. We ensure
compliance with all the applicable laws, rules, and regulations. Governance is another area of
law that NAB strictly follow. Every employee of the corporation shall follow the applicable laws
and shall ensure a good level of compliance.
The code is strictly enforceable on all the NAB personnel. Compliance of the same is mandatory
and not voluntary. Directors of the company have all the rights to impose penalties and fines on
those who breach with the provisions of this code. Manager of each department will be liable to
check the enforcement of this code of conduct.
Ethics Management Committee is the committee responsible for the check of all provisions with
this code of conduct and played an important role in the development of this code. Any person
who has confusion regarding this code or has any doubt then the same can contact to this
committee. A further breach of any provision of this code can also be reported to this committee.
Enforcement
Enforcement
Law and Regulations
Enforcement
Ethics Managment Committee
Contact

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One may contact the ethics and management committee of the organization using the following
details:-
Telephone [phone]

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References
Ag.gov.au. (2019) Australia’s anti-discrimination law. [online] Available from:
https://www.ag.gov.au/RightsAndProtections/HumanRights/Pages/Australias-Anti-
Discrimination-Law.aspx [Accessed on 27/04/2019].
Atlassociety.org. (2011) The Morality of Insider Trading. [online] Available from:
https://atlassociety.org/commentary/commentary-blog/4883-the-morality-of-insider-trading-
[Accessed on 27/04/2019].
Corporations Act 2001 (Cth)
Dictionary.cambridge.org. (2019) Discrimination. [online] Available from:
https://dictionary.cambridge.org/dictionary/english/discrimination [Accessed on 27/04/2019].
Disability Discrimination Act 1992
Discrimination Act 2004
Komlos, J. (2018) Foundations of Real World Economics: What Every Economics Student Needs
to Know. Oxon: Routledge.
Lexisnexis.com. (2019) Anti-bribery and corruption—gifts and hospitality—overview. [online]
Available from: https://www.lexisnexis.com/uk/lexispsl/practicecompliance/document/
393850/5KVJ-S0D1-F18F-Y0C5-00000-00/
Anti_bribery_and_corruption_gifts_and_hospitality_overview#[Accessed on 27/04/2019].

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Oxfordre.com. (2019) Business and Management. [online] Available from:
http://oxfordre.com/business/view/10.1093/acrefore/9780190224851.001.0001/acrefore-
9780190224851-e-122 [Accessed on 27/04/2019].
Patchett, K. (2016) Financial Consulting Brief: How Important is Goodwill to Investors. [online]
Available from: https://8020consulting.com/how-important-is-goodwill-to-investors/ [Accessed
on 27/04/2019].
Racial Discrimination Act 1975
Robinson, S. and Dowson, P. (2012) Business Ethics in Practice. London: Kogan Page
Publishers.
Sex Discrimination Act 1984
U4.no. (2019) What is corruption? [online] Available from: https://www.u4.no/topics/anti-
corruption-basics/basics [Accessed on 27/04/2019].
Vera, H. and Feagin, J., R. (2017) Handbook of the Sociology of Racial and Ethnic Relations.
Springer Science & Business Media.