MBA402: Code of Conduct for National Australia Bank - Report

This report provides an overview of the Code of Conduct adopted by the National Australia Bank (NAB), focusing on promoting ethical practices and responsible conduct within the company. The assignment addresses key areas such as discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement mechanisms. The report outlines the goals and commitments of the code, its scope, and regulatory provisions, including compliance with Australian government legislation and collaboration with regulatory bodies like the ASX and ASIC. The core of the report delves into specific guidelines addressing anti-discrimination, prevention of exploitation, measures against corruption, policies against dishonest and fraudulent behavior, and protections for whistleblowers. The report emphasizes the importance of these guidelines in ensuring ethical governance and compliance to sustain the growth of the company. The report also highlights the role of the ethics committee and enforcement policies in maintaining the code's effectiveness, ensuring fair investigations, and promoting a positive work environment.

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Governance, Ethics and Sustainability

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Code of Conduct of National Australia Bank
Overview
The Code of Conduct adopted by the National Australia Bank (NAB) is focused on
promoting responsibility and obligation on the members of the company to make
sure that they engage in ethical practices. The goal of this Code is to make sure that
the company is able to address key challenges which it faces while managing its
operations in Australia and other countries (NAB, 2019a). The guidelines given
under this code ensure that members of NAB such as employees, business partners,
managers and the board of directors are focused on prioritising the interest of
customers while discharging their obligations in an ethical manner.
Goals and Commitment
 Increase the positive impact of NAB on society
 Uplifting the social status and wellbeing of our customers
 Fulfilling mandatory obligations imposed by government authorities
 Maintaining the confidentiality and privacy of customers
 Avoiding conflict of interest
 Maintaining honesty, integrity and fairness while doing business (NAB, 2019b)
Scope
This Code of Conduct applies on NAB along with its employees which are situated in
Australia. The branches of NAB that are situated outside Australia along with
members that manage those branches are also bound by the guidelines given under
this code.
Regulatory Provisions
This code complies with the guidelines given under the legislative regulatory
framework adopted by the Australian Government to guide the actions of companies.
Thus, the policies given under the Corporations Act 2001 (Cth) and other relevant
legislations that apply to the company are followed by NAB. NAB works closely with

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major authorities in Australia such as the Australian Services Exchange (ASX) and
the Australian Securities and Investments Commission (ASIC) (ASX, 2019). Other
legal guidelines issued by the government that applies to the operations of NAB are
also followed by the company.
Following guidelines are implemented by NAB in order to tackle major issues in the
organisation to achieve the goals of effective governance and compliance with
ethical principles to sustain the growth of the company.
A: Discrimination
NAB has implemented anti-discrimination guidelines in the company that discourage
discrimination and promotes diversity in the workplace. Discrimination means
treating a person or a group of individuals differently or unfairly based on their
personal characteristics such as race, caste, religion, gender, sexual preference,
disability, colour and age (Cheng, 2015). This code focuses on eliminating activities
that in any shape or form supports or tolerate discrimination. Following are some
guidelines which are mandatory to be followed in NAB to avoid discrimination.
1. New employee selection process is managed by more than one individual
who evaluates the applicants based on their ability to person the job and
qualifications rather than individual differences.
2. While promoting employees in the workplace, their performance and abilities
are analysed rather than their individual characteristics.
3. Diversity and Inclusion Policy is adopted by NAB to make sure that the
company focuses on building a diverse workforce which includes women,
disability and indigenous people by creating a positive working environment
for them (NAB, 2019c).
4. The jobs and roles of employees are decided in the company in non-
discrimination manner
5. Various other actions are also taken by the management to reinforce and
foster diversity in the organisation
The Australian Government has also issued a number of legislative guidelines for
companies in Australia to make sure that they did not engage in discriminatory
practices. NAB make sure that it also complies with these policies which include the

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Disability Discrimination Act 1992 (Cth), the Racial Discrimination Act 1975 (Cth), the
Age Discrimination Act 2004 (Cth) and the Sex Discrimination Act 1984 (Cth)
(Applied, 2019). NAB employees that face discrimination or witness others being the
victim of discrimination are encouraged to report these issues to make sure that they
did not face challenges. They can report these issues to the anti-discrimination
committee which conducts an independent investigation to make sure that the details
of employees remain private and the issue of discrimination can be resolved.
B: Exploitation
Exploitation means unfair treatment of an employee by senior managers to gain
benefit from their detriment or for the advantage of third parties (Harrison et al.,
2015). NAB has implemented policies in its code in order to prohibit exploitation of
employees in the workplace. The company recognises that the employees are a key
member of the company and it focuses on prioritising their interest by taking steps
for their promotions. Following are a number of activities which are implemented by
the company in order to eliminate exploitation from the workplace.
1. The manager or other officers cannot hold the salary of employees in order to
punish them.
2. Sexual harassment is strictly prohibited in NAB and employees have the
rights to report these incidents in private.
3. Working hours are fixed for employees, and they cannot be enforced to work
on public holidays.
4. Employees’ rights cannot be avoided by the managers in order to achieve
their goals (Shamsuddin and Xiang, 2012).
Along with these policies, the company has taken various steps that further make it
difficult for managers and senior managerial personnel to exploit the rights of
employees. Employees can report these issues to the ethics committee or other top-
level management who are enforced to take actions against these issues to make
sure that they eliminate this issue form the workplace.
C: Corruption
Corruption means misuse of the position of power by an individual by taking actions
for personal benefits or interest of third parties by taking actions that are against the

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interest of the company or its stakeholders (Osuagwu, 2012). Since NAB operates in
the banking sector, corruption is a major issue which is faced by the company which
affects its profitability. The company has to make sure that its employees or
managers did not take bribe from third parties to discharge their obligations. In order
to tackle this issue, the company strictly follow a strategy under which it has
prohibited its employees from receiving gifts from customers. The company has
adopted various other policies as well that are focused towards eliminating
corruption in the workplaces such as Anti-Fraud policy, Economic and Trade
Sanction Policy, Anti-Money Laundering and Counter-Terrorist Financing Policy and
Anti-Bribery and Corruption Policy (NAB, 2018). The target of these policies is to
reduce illegal or unethical practices in the company that leads to corruption to make
sure that they did not harm the interest of the customers or their relationship with
NAB. The management also encourages employees to make sure that they report
any incidents if they receive bribery or they see someone else receiving bribery in
the organisation.
D: Dishonest and Fraudulent Behaviour
The actions of the managerial officers engage in dishonest activities for receiving
personal benefits or for the benefit of third parties are considered as dishonest and
fraudulent behaviour (Dabbagoglu, 2012). NAB has implemented policies under this
code that are focused on prohibiting dishonest and fraudulent behaviour by its
employees and managers. Engage in dishonest or fraudulent conduct while dealing
with customers is strictly prohibited in the workplace and individuals that engage in
these practices could face civil as well as criminal penalties. Various activities are
specifically prohibited by NAB through this code such as falsification of books of
accounts, violation of customer interest, misuse of the private data of customers, a
false claim for remuneration by employees and others. Through these policies, the
company wanted to make sure that its employees did not discharge their duties in an
unfair manner which could lead to negative circumstances (Moosa and Silvapulle,
2012).
In order to eliminate fraudulent practices, the company has implemented policies
under which the operations of employees are checked by their senior managers.
Due to this monitoring process, it becomes difficult for the employees to hide any

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fraudulent activities in which they engage while discharging their duties (Wong,
2017). While at the same time, the actions of the managers and other supervisors
are audited as well in order to make sure that they also did not engage in dishonest
and fraudulent behaviour. Employees or managers can also report similar activities
to the ethics committee or other senior managers.
E: Whistle blower protections
A whistle blower is a person who exposes confidential and sensitive data regarding a
company or its members that engage in illegal or immoral practices (Overhuls,
2012). The whistle blower did not keep this information to himself; instead, such
information is shared with external authorities or the top level management to make
sure that they can take steps to prohibit these activities in the workplace. The whistle
blowers face risks in the workplace since they reveal confidential data; therefore, the
importance of effective whistle blower protection policies increases (Pacella, 2013).
Following policies are adopted by NAB to make sure that it protects the security of
whistle blowers in the company.
1. NAB has adopted an infrastructure under which it becomes easier for whistle
blowers to report illegal or unethical practices of the company or its officers.
2. NAB conducts an investigation after the reveal of information by the whistle
blower which is based on the principles of fairness and natural justice.
3. The company promotes its employees to reveal similar practices in order to
make sure that they disclose similar practices in a timely manner.
4. The rights of whistle blowers are protected by the company by making sure
that they are not discriminated in the organisation.
NAB has also implemented policies that promote liberty of employees to make sure
that they have different options available when it comes to reporting of illegal and
unethical practices. Whistle blowers can reveal the information to the ethics
committee of the company, or they can directly approach external authorities such as
ASIC to reveal details regarding the actions of the company (Pacella, 2013). All
these guidelines enable the corporation to make sure that a positive environment is
created in the workplace that supports the interest of stakeholders of the company.

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F: Enforcement
Enforcement is defined as the act of compelling the compliance of rules, obligations
or laws on parties to make sure that they did not violate these provisions. NAB has
adopted enforcement policies in this code without which the effectiveness of this
code cannot be achieved. As per these guidelines, the provisions given under this
act applies to all the members of NAB on an equal basis (NAB, 2019a). The
guidelines given under this act apply on the top as well as low level of employees
and managers and they cannot avoid the enforcement of these provisions. Everyone
in the company is equal before this code due to which they are bound to comply with
its directors. This act protects the rights of members of the company to make sure
that they did not face discrimination, exploitation or other hostile working
environment issues (NAB, 2019c). The provisions of this code require a fair
investigation in which the principles of fairness and natural justice are followed by the
company to make sure that innocent people did not face punishments.
Ethics Committee
This code is prepared by the ethics committee of NAB which is also responsible for
its enforcement. The right to make amendment in this code is also available for the
ethics committee which can introduce new policies in this code to make sure that it is
relevant as per changing market conditions. These guidelines assist NAB in ensuring
that its code remains up-to-date with the legislative guidelines which are
implemented by the government under the various acts that applies to the operations
of NAB. As per these guidelines, members that have any issues with this code and
who wanted to give certain suggestions have the option to directly reach the audit
committee regarding making changes in this code.

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