National Australia Bank (NAB) Code of Conduct Report, MBA402

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This report presents a comprehensive analysis of the Code of Conduct for the National Australia Bank (NAB), addressing critical elements essential for maintaining ethical standards and ensuring responsible business practices. The report meticulously examines various facets, including the bank's stance on discrimination, ensuring fair treatment of all employees and customers, and its commitment to diversity management. It delves into the measures implemented to prevent exploitation, such as misconduct and fraudulent information sharing, emphasizing the protection of customer data and the promotion of a supportive work environment. Furthermore, the report scrutinizes NAB's approach to combating corruption, highlighting its zero-tolerance policy and the mechanisms in place to prevent bribery and unethical practices. It also explores the bank's efforts to address dishonest and fraudulent behaviors, outlining the measures taken to safeguard financial transactions and maintain customer trust. The report also discusses whistleblower protections, the enforcement of the code, and the importance of adherence to regulations. This analysis provides valuable insights into NAB's commitment to ethical conduct, corporate governance, and sustainable business operations.
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21 Apr 2019
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Introduction
National Australian Bank (NAB) is a leading bank of Australia which is strongly committed to
providing exceptional services to its customers. The code of conduct of NAB outlines
responsibilities and ethical content that are expected among the engaged employees. At NAB it
is strongly believed that customers and employees must be treated with dignity and respect,
which is in accordance with their code and cultivate adequate organizational behavior (Code of
Conduct – NAB 2019). For this, completion of annual training, for all the engaged employees of
NAB is mandatory. In the present report, we will outline the important conduct with which NAB
aims to maintain the standards of service and prevent possible breaches that can bring
undesirable business outcomes.
NAB Principles
NAB is primarily oriented to deliver industry-leading services, achieve sustainable outcomes,
and strongly integrate with its stakeholders as well as a broader community. It is strongly
believed that all employees will behave responsibly and ethically to their customers (Royal
Commission Conduct Report 2018). However, the employees or customers are also encouraged
to speak and report about any suspect for breach of the code. Notably, NAB is committed to
protect the genuine disclose and hence will not tolerate consequence of discrimination, dismissal,
and demotion (Code of Conduct – NAB 2019). As a matter of fact, this financial institution is
highly appreciated in the market, following its strong commitment and ethical business practices.
Discrimination
At NAB all the employees were treated fairly, and more appropriately without any
discrimination. The staff, managers, agents, vendor, and supply chain network have adequate
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knowledge of diversity management. Here, more than 10% of employees are expatriate, which
gives a clear sense of effective cultural diversity management. NAB also endeavors to recruit,
promote, and include employees in the decision-making process; based of their skills, expertise,
and track record. Importantly, the discrimination based on culture, ethnicity, gender, and sexual
orientation is highly discouraged at the workplace (Guo and Liang 2016, pp. 24). Likewise, equal
opportunity, in all the ways considered, irrespective of gender, personal philosophy, and
disability (Clancy 2018). Among the employees, NAB's code ensures that a supportive
relationship and mutual cooperation is always preserved which satisfies the organizational
objectives. For example, the relationship between employee and supervisor, as well as between
employees and colleagues must ensure this framework (Fraser 2015). There exist clear policies
that can implement these considerations into the strategic framework.
Importantly, all the employees at NAB were also motivated to treat the customers without any
discriminatory perspective. All the customers were irrespective of their culture, religion,
background, and nationality. With this, the bank encourages a pleasant environment, the attitude
of respect, and aims to develop a trustworthy relationship with customers (Bartlett III 2015, pp.
201). This is of high relevance to NAB because maintaining a long-term relationship with
employees enables the company to retain a competitive advantage in the market (Royal
Commission Conduct Report 2018). Furthermore, non-discriminatory actions not only keeps the
organization bound with loyal customers, but it also attracts new segment.
Exploitation
NAB code of conduct also ensures that the issues related to exploitation such as misconduct,
fraudulent information sharing, safeguard the customer information, and abused in any form
should not be reflected in the routine practices. In particular, the relationship among employees
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is always reviewed to be in positive and supportive form. At NAB, there exists a strong
regulatory framework and appropriate action in conjunction with sexual exploitation at the
workplace (including employees as well as customers) (Code of Conduct – NAB 2019).
Likewise, information sharing, exchange of data, and utilization of information must be handled
and accessible among authorized personnel. This means the exploitation of data in any form is
not tolerated at NAB.
The necessary action against the exploitation of data is also secured in conjunction with the
information management system. This is covered within the scope of the duty of confidentiality
(Salim, Arjomandi and Seufert 2016, pp. 121). The provision seeks necessary preventive action
against unauthorized disclosure, use of personal data, calibrate exploitation of Bank information,
and advertising based on such information (Edwards 2018).
At NAB, It is believed that protecting the information system and maintaining security for
confidential information means preserving the integrity and information of underlying processes.
These issues were mainly handled by IT system and security personnel (Salim, Arjomandi and
Seufert 2016, pp. 118). In particular, the information is stored in electronic format and within the
secure shell network system. All the internet related data were encrypted and the security of
information flow is ensured within the organization as well as with channel networks.
For any associated concern or queries related to the information security system, employees or
customers can contact information security officer. Additionally, the support system available
across 24x7, ensure that necessary concerns will be solved within the timely approximation.
Corruption
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It is believed that corruption is not only a question of ethics or morality, but it is with the legal
compliances, degradation of relationship in the market, and damage of reputation. As a matter of
fact, NAB offers two distinct part of the code of conduct, which deals with corruption or related
issues.
The first part is drafting and implementation of the code, while the second part is the
enforcement of the code (Howell 2015, pp. 544). All the information management system,
relationship among employees, sharing of information with stakeholders, community network,
and relationship with employees fall within the scope of these codes. In particular, it is also
ensured that the data system, information flow, and communication remains transparent and
documented (Royal Commission Conduct Report 2018).
Against the bribery issues, each employee is responsible to ensure that they will not be involved
in any form of corruption (Bartlett III 2015, pp. 201). This includes money, gift, favor, or any
related reliance which is not covered under work agreement (Evans and Niesche 2016).
Furthermore, there exists a whistleblower provision, under which employees, as well as
customers, can report for any breach of the code, which signifies or denotes bribery and a related
act. Additionally, the code is also applicable to associated agents, supplier, and third parties.
NAB strongly believe that corruption affects not only the moral values within the organization,
but it has a strong opportunity to degrade the market image of the organization (Koh, McConnell
2018). The regulatory framework in conjunction with the anti-bribery code is strict and aligns
with national legislative codes.
All the employees are entitled to not receive any things of value, advantage, in the form of fees,
commission, acknowledgement, service, favor, and gift (Salim, Arjomandi and Seufert 2016, pp.
120). Likewise, the political campaign contribution, as well as a risk associated with social
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power, is also reviewed to be not influencing any act that can signify (or depict) corruption-
related actions.
Dishonest and Fraudulent Behavior
NAB behave in accordance with the ethical code of conduct, for the public which is served. The
strength of this business and its success in the market is primarily based on credibility,
reputation, and confidence that is acquired over from the customers, stakeholders, and
community network.
NAB define dishonest and fraudulent behavior as follows (McCulloch 2018; Moradi Motlagh
and Babacan 2015, pp. 400):
By indirectly or directly offering promises which can be of value to a political candidate,
small medium or large sized enterprises, public or private sector and members thereof, to
achieve any competitive advantage.
Employees were engaged in the exchange of information that can affect, attain, ascertain,
or hold promises for financial support.
Performance at the workplace in conjunction with inappropriate or illegal documentation,
market positioning, or marketing benefits.
The financial transaction of NAB involving falsified information, the false claim by
customers, and non-alignment of financial statement with respect to the national and
international accounting standards (Bartlett III 2015, pp. 201).
Giving or receiving valuables by employees, representatives, or thirty party member, in
conjunction with the sharing of information, customer data, or decision-making issues,
with the person outside of the organization.
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Using financial support, information, or organizational property for personal use, without
the consent from an appropriate authority.
Processing banking activities or engaging with the customer, without proper
documentation procedure.
Additionally, NAB also provides an important support system that can help employees as well as
customers to remain protected against any fraudulent or dishonest behavior. These provisions
mainly include (Koh, McConnell 2018; Royal Commission Conduct Report 2018):
Customers or employees can contact their nearest branch manager, is it an appropriate
appointment.
The support system available 24x7 can be used for resolving queries, obtaining
appropriate information, and sharing relevant information of organizational importance.
E-mail services and messaging provisions are available, to ensure that customers are
informed about financial activities and related events.
Overall, it is believed that sharing an appropriate and adequate piece of information among
employees as well as with customers, can help in retaining a strong brand image. However, the
provisions of conduct are also subjected to revision on periodic basis. As a result of which, the
organization can remain successful in the long run as well as it can retain the competitive
advantage in the market (Adams, Potter, Singh and York 2016, pp. 286).
Whistleblower Protections
The provision of the whistleblower is to prevent any breach in the code of conduct, which in turn
can help the organization to maintain ethical standards and appropriate practices. At NAB, it
recognizes any individual, employee, or customer as a whistleblower, if they can report or
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inform about activities which do not fall within the scope of appropriate functioning. The
provisions offered in support of whistleblower includes (Evans and Niesche 2016, pp. 22; Royal
Commission Conduct Report 2018):
Customer support, where the report of the breach to the code of conduct can be
addressed.
E-mail or personal communication with the manager.
Approaching to any employee of NAB and addressing the concerned issue.
Importantly, NAB also pays attention to protect the whistleblower, in conjunction to their
reporting or information shared that can help the organization to maintain its integrity. NAB has
a special team that protects the whistleblower, who report appropriate information in conjunction
with fraudulent activities against the law, inappropriate use of the fund, or abuse of authority
(Koh, McConnell 2017; Bartlett III 2015, pp. 203). This team protects the whistleblowers by the
following measures:
By educating and providing adequate information in conjunction with rights and
remedies, review of a retaliation claim, potential relief, and prohibition against any case.
It promotes protected disclosure and reprisal complaint, true and appropriate reviewing
system, and in a timely manner.
Coordinate with counsellors, legal personal associated with the court, and consult on
regulatory measures, for whistleblower related issues.
Enforcement
At NAB, all the employees and the associated third party members are obligated to follow the
regulations implemented by the local state, national, and international bodies (Adams, Potter,
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Singh and York 2016, pp. 285). Bank have designed specific policy measures in conjunction
with routine standards of practice as well as ethical provision. These were included in the
agreements between NAB and its employees; constituting the Code of Conduct. Timely and
periodic amendment in these agreement are made effect, however with consent, agreement, and
acknowledgement to all the associated members (Guo and Liang 2016, pp. 24). Further, these
codes are in compliance with the legislative and public policies and are enforced consistently.
The code of conduct at NAB, shall actualize in conjunction with the workplace environment as
well as with the associated community channel, in following regards (Corporate governance
framework 2019):
The professionalism and integrity within the organization is enforced.
Employees and associated members are encouraged to avoid conflict of interest.
The relationship at workplace must be supporting, should maintain self-reliance, and
should address positivity and cohesion.
All the documentation and procedural activates are required to be transparent and in
accordance to the legislative framework.
Maintaining the norms of duties, code of conduct, ethics, and socio-economic
consideration of the society is thoroughly mandate.
Overall, there exists strong provision against breach of conduct, which ensures that NAB
maintain the ethical standard and optimal practice in accordance to the requisite and expected
framework.
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References:
Adams, C.A., Potter, B., Singh, P.J. and York, J., 2016. Exploring the implications of integrated
reporting for social investment (disclosures). The British Accounting Review, 48(3), pp.283-296.
viewed 21 Apr 2016 < https://www.sciencedirect.com/science/article/pii/S0890838916300154 >
Bartlett III, R.P., 2015. Do Institutional Investors Value the Rule 10b-5 Private Right of Action?
Evidence from Investors’ Trading Behavior following Morrison v. National Australia Bank
Ltd. The Journal of Legal Studies, 44(1), pp.183-227.
Clancy, Y 2018. 'Raising the bar': Banks vow to be more ethical under new code. The Sydney
Morning Herald, viewed 21 Apr 2016 < https://www.smh.com.au/business/banking-and-
finance/banks-vow-to-lift-ethical-standards-under-new-code-20180731-p4zuqa.html >
Code of Conduct – NAB 2019. National Australia Bank Ltd, viewed 21 Apr 2016 <
https://www.nab.com.au/content/dam/nabrwd/documents/policy/corporate/code-of-conduct.pdf >
Corporate governance framework 2019. National Australia Bank Ltd, viewed 21 Apr 2016 <
https://www.nab.com.au/about-us/corporate-governance >
Edwards, C 2018. NAB reveals mass code breaches. AB + F, viewed 21 Apr 2016 <
https://www.rfigroup.com/australian-banking-and-finance/news/nab-reveals-mass-code-breaches
>
Evans, N.W. and Niesche, C., 2016. Time for change. Company Director, 32(6), p.22.
Fraser, D. 2015 National Australia Bank reveals Clydesdale demerger plan. BBC News, viewed
21 Apr 2016 < https://www.bbc.com/news/business-32618769 >
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Guo, Y. and Liang, C., 2016. Blockchain application and outlook in the banking
industry. Financial Innovation, 2(1), p.24. viewed 21 Apr 2016 <
https://www.biomedcentral.com/openurl?doi=10.1186/s40854-016-0034-9 >
Howell, N.J., 2015. Revisiting the Australian code of banking practice: is self-regulation still
relevant for improving consumer protection standards. UNSWLJ, 38, p.544.
Koh, B, McConnell, P 2017. Bank codes of conduct: add bars to the window dressing and make
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Salim, R., Arjomandi, A. and Seufert, J.H., 2016. Does corporate governance affect Australian
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