Code of Conduct for National Australia Bank - MBA402 Assignment

This report presents a comprehensive Code of Conduct drafted for National Australia Bank (NAB), addressing key areas such as discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement. The code emphasizes ethical conduct, fairness, and integrity in all operations. It includes specific policies against discrimination based on gender, race, age, and nationality, as well as measures to prevent and punish exploitation in the workplace. The code outlines strategies to combat corruption, including prohibiting political endorsements, preventing money laundering, and ensuring merit-based employment. It also details measures to prevent and address dishonest and fraudulent banking practices, such as ATM fraud and identity theft. Furthermore, the report establishes whistleblower protections, ensuring anonymity and legal recourse for those reporting illegal activities. The enforcement section outlines procedures for implementing and monitoring the code, including employee training, ethical guidelines, and a Committee of Conduct. The document references academic journals and other sources to support its recommendations, aligning with the assignment requirements of MBA402 Governance, Ethics, and Sustainability.

Title Page

National Australia Bank
Code of Conduct
National Australia Bank has been present for more than 160 years to help the customers and
manage their finances. There are various operations spread in more than 900 locations in
Australia, New Zealand among other countries in the world with the main aim of satisfying our
customers (“About us – We’re NAB”, 2015). Our aim is to serve businesses (including small
scale, medium scale and large scale) by giving them a positive experience and serving them
thorough out their business lives. We do our part to ensure that we fulfill our responsibility
towards the society. The focus is to carry out all financial and non-financial dealings with
fairness and integrity; and to avoid all forms of discrimination in our bank premises.
The purpose of creating and adopting this code of conduct is to ensure that we focus on
developing principles which are accepted by the staff as well as by the customers and to
maintain a high standard of work practices (McKay, 2019). All the members of the Bank are
expected to follow this Code at all times. This code of conduct is applicable to all customers,
staff and banking partners of National Australia Bank.
Our Principles
We, at NAB, aim to carry out our operations ethically and for this we have agreed to follow the
below given principles and establish a moral code of conduct which is also legally valid
(Leonard, 2019). Our principles are given:
 To act with fairness, honesty and integrity at all times.
 To conduct ourselves in a manner that is professional and dignified.
 To carry out all legal, ethical and moral duties towards all our partners and stakeholders.
 To manage all forms of conflict.
 To admit to and resolve all mistakes made by us and our partners.
 To follow client regulations.

 To ensure confidentiality in our dealings and not to disclose private information at any
time.
 To create and adhere to anti – discrimination policies and have an attitude of zero
tolerance towards exploitation of any form.
 To not participate in unfair acts or indulge in corruption in any manner.
 To meet our Corporate Social Responsibility and become more than just financial
institutions (Scholtens, 2009).
 To ensure protection of our whistleblowers.
 To identify, report and punish any form of misbehavior or fraudulent practice in the
premises.
 To give ethical education and training to all our workers so that enforcing this code is
easy (Green and Weber, 2010).
Anti-Discrimination Policy
Discrimination is the practice of unjust behavior towards certain categories of people and on the
basis of sex, race, religion and color. This discrimination causes low morale and a feeling of
dissatisfaction (Mayhew,2010.). At National Australia Bank, we aim to follow an anti-
discriminatory policy and promise to:
 Discourage and protect against all forms of gender bias. All men and women will be
treated equally and no unfair treatment of women on grounds of gender will be tolerated.
 Keep a firm check on discrimination on the basis of race or color of a person (Doyle,
2018). Any members who are found to discriminate on the basis of racial differences will
be terminated.
 Ensure that no age discrimination is practiced in the Bank. All staff members and
customers will be treated with respect and dignity.
 Ensure that all members and workers coming from different countries will be treated at
par and no discrimination on the basis pf nationality will be tolerated.
 Accept no discrimination on the basis of the profession of any party (Chau and Evlin,
2018). It does not seem fit that the Bank decides which professions are moral or immoral.
All work is equal for us.

 Follow no discrimination while selecting candidates for the job. If any employment
discrimination is reported, it will treated with in a just and fair manner.
Exploitation
Exploitation is the practice of treating someone unfairly in order to take advantage of them. It is
our aim to prevent and punish any and all forms of exploitation in the Bank. We at National
Australia Bank, aim to:
 Prevent and punish any form of criminal exploitation in the work place.
 Not tolerate any exploitation of minorities. Any offense of this nature, if found or
reported, will be dealt with seriously.
 Ensure that all workers are paid just wages and salaries for their services to the Bank
(Gausi, 2018). National Australia Bank aims to abolish any such practices which
contribute to ‘slavery’ where workers are not paid or grossly underpaid in comparison to
the work they performed.
 Ensure that no form of religious exploitation is a part of our work premises. No worker
will be discriminated against on the grounds of the religion that he/she practices. No
religious holidays will be denied to the workers. Any such practices if found will be dealt
with an utmost urgency.
 Deal with any incidents of sexual exploitation. Sexual exploitation of females has been
considered as the biggest setback to their careers (Shullman, et al. 2010).We at National
Australia Bank promise to play our part in putting a stop to this practice. All defaulters
will be dealt with seriously and legal action will be taken.
 Ensure that no exploitation of the workers’ commitment towards the organization will be
done. No worker will asked to work overtime with just rewards for it.
 Not accept any form of mental exploitation of the workers as well as the clients of the
Bank.
Corruption

Corruption is the practice of following unethical and dishonest ways in the organization in order
to get an advantage over the situation and reap personal benefit. It is mostly followed by the top
and middle level of the management (Kiplagat, 2014). The reason for this corruption at work
places is the intense amount of pressure of the job on the workers to give a better result than the
other (Boyd, 2010). We at National Australia Bank aim to stop and punish any form of
corruption in our premises and to direct all our efforts in the following areas:
 The Bank will not show support to any political parties or any religious associations and
will not give funding or patronage to any of these associations for any form of benefit
received.
 No bank accounts or safety lockers will be permitted in the Bank without completion of
all due formalities. No money laundering will be tolerated in the Bank.
 No members of the Bank will resort to frauds. All workers will carry out their jobs with
utmost dedication and any form of illegal activities practiced in the name of work will be
punishable.
 Taking bribes from businesses that aim to enter into financial relationships with the Bank
will not be tolerated on any account. Any person caught accepting or giving bribes will
be facing immediate suspension and even termination.
 All workers working in the Bank and all its branches will be employed on the basis of
skill and merit and not on the basis of ‘family connections’ to senior executives of the
Bank. The Bank has zero tolerance towards nepotism in any manner.
Dishonest and Fraudulent Behavior
We, at National Australia Bank, aim to remove any form of dishonest and fraudulent practices in
the Bank and its functioning areas. We provide the customers with knowledge about fraud
prevention measures so as to ensure their safety and improve our relationships with them (
Hoffmann and Birnbrich, 2012). All fraudulent and dishonest banking practices will be dealt
with seriously and strict action will be taken against the offenders. Our code of conduct applies
to the following types of banking frauds:
 ATM frauds.

 Fraudulent applications to avail loans generally for illegal businesses or without proving
their credit worthiness to pay the loan amount back.
 Identity thefts or impersonating other for the purpose of committing illegal activities and
frauds.
 Forged documents and fraudulent signatures on the documents.
 Bill Discounting frauds. In this the customer presents himself as the genuine customer of
the Bank and gains its trust. The customer then uses the bill discounting facility of the
Bank regularly. He then refuses to pay the amount to the Bank and settle his accounts.
 Accounting fraud whereby accountants of businesses indulge in dishonest book keeping
to either inflate or deflate the company profits and subsequently, its net worth.
 Fraud cheques issued in the name of the Bank.
 False applications to avail loans generally entering inflated amounts or for the purpose of
illegal businesses.
 Demand Draft fraud where the employees indulge in dishonest creation and payment of
demand drafts.
Whistleblower Protection
Whistle blowing is the practice of reporting any illegal activities or wrongdoings in the premises
of any organization. This section has been included in our Code of Conduct to ensure that harm
comes to those who report any such practices in the organization. In our Code, we aim at the
following:
 To allow for anonymous disclosure of illegal and fraudulent activities being carried out in
the Bank.
 To protect the privacy of the whistleblowers and ensure that their information with the
Bank remains confidential.
 To implement the adoption of the Treasury Laws Amendment (Enhancing Whistleblower
Protections) Bill 2017. This Bill’s purpose is to enhance the jurisdictions and the legal
actions available for the whistleblower protection in Australian organizations (Stappers,
2019).
 Identify and hire more persons who are capable of whistle blowing activities in the Bank.

 Allow past employees as well as parties outside to the Bank the permission to be
appointed as whistleblowers. No discrimination to be made in the privileges available to
insider and outside whistleblowers.
 Strict action to be taken against those who in any way hamper the freedom given to the
whistleblowers.
 Give proper access to compensations and rewards for whistle blowing. Compensation to
be adequate in all aspects.
Enforcement of the Code of Conduct
For the enforcement of the Code of Conduct, proper measures need to be taken in the
organization. The Bank has the authority to take action against those who violate the Code. The
enforcement of the code involves taking the following steps:
 Creation of and following all organizational policies to ensure that the principles which
have been defined above are followed.
 Understanding the dilemmas which the employees face when implementing this Code
and taking relevant measures to overcome any shortcomings.
 Defining and explaining the roles and responsibilities of the workers of the Bank with
regard to the Code. It involves clearly stating the practices that need to be followed so as
to ensure that the integrity of the Code is withheld.
 Presenting this Code in annual meetings and clearly explaining the subject matter of all
sections and sub-sections that make up the Code.
 Putting up the copy of the Code of Conduct on the notice boards or any common places
in the Bank to ensure continuous reminder to the workers.
 Explaining the fines, fees and the penalties which will be imposed on those who do not
adhere to the Code. All types of actions which can be taken against the workers should be
explained including monetary fines, legal actions, suspensions and terminations.
 Formation of a Committee of Conduct to ensure that the updates made in the Code of
Conduct are thoroughly reviewed. This committee is held responsible for editing, printing
and informing to the workers any and all changes made to the Code(sage,2015).

 Setting up of guidelines to measure the behavior of employees and the standards against
which this behavior will be measures.
 After measuring the performance against the standards, an ethics committee to be set up
to determine the magnitude of action to be taken against the defaulters.
 Explaining the reporting procedures to all employees.
 A copy of this Code to be made available on the website of the Bank.
 A copy of this Code to be attached to employment/job offer letter.
References
Boyd, A. (1997). Employee traps - corruption in the workplace. Management Review, [Online]
Volume 86 (8), p. 9. Available athttps://www.questia.com/magazine/1G1-20076969/employee-
traps-corruption-in-the-workplace. [Accessed 19 April 2019].

Chau, D. and Evlin, l. (2018). Sex industry faces 'financial discrimination' from banks,
ombudsman says. [Online] ABC News. Available at
https://www.abc.net.au/news/2018-01-04/sex-industry-businesses-face-financial-
discrimination/9303376. [Accessed 19 April 2019].
Doyle, A. (2018). Types of Workplace Discrimination. [Online] The Balance Careers. Available
athttps://www.thebalancecareers.com/types-of-employment-discrimination-with-examples-206
0914. [Accessed 19 April 2019].
Ethics Sage, (2015). Is Whistle-blowing an Ethical Act Practice? [Online] Available at
https://www.ethicssage.com/2015/03/is-whistle-blowing-an-ethical-act-practice.html. [Accessed
19 April 2019].
Gausi, T. (2018). The many faces of labour exploitation. [Online] Equal Times. Available at
https://www.equaltimes.org/the-many-faces-of-labour?lang=en#.XK4ns5gzbIV. [Accessed 19
April 2019].
Green, S. and Weber, J. (1997). Influencing Ethical Development: Exposing Students to the
AICPA Code of Conduct. Journal of Business Ethics. [Online] Volume 16 (8), p. 777. Available
at https://link.springer.com/article/10.1023/A:1017987609769. [Accessed 19 April 2019].
Hoffmann, A. and Birnbrich, C. (2012). The impact of fraud prevention on bank‐customer
relationships: An empirical investigation in retail banking. International Journal of Bank
Marketing. [Online] Volume 30 (5) p 390. Available at https://www.e
meraldinsight.com/doi/abs/10.1108/02652321211247435. [Accessed 19 April 2019].
Kiplagat, D. (2014). Corruption in the workplace. [Online] Career Addict. Available at
https://www.careeraddict.com/corruption-in-the-workplace. [Accessed 19 April 2019].
Leonard, K. (2019). What Are the Key Components of a Code of Ethics in Business? [Online]
Chron. Available at https://smallbusiness.chron.com/key-components-code-ethics-business-
244.html. [Accessed 19 April 2019].
Mayhew, R. (n.d.). Discrimination Policy in the Workplace. [Online] Chron. Available at
https://smallbusiness.chron.com/discrimination-policy-workplace-61273.html. [Accessed 19
April 2019].

McKay, M. (2019). Employee Code of Conduct. [Online] Available at
https://smallbusiness.chron.com/employee-code-conduct-2731.html. [Accessed 19 April 2019].
National Australia Bank Limited, (2015). About us – We’re NAB. [Online] Available at
https://www.nab.com.au/about-us. [Accessed 19 April 2019].
Scholtens, B. (2009). Corporate Social Responsibility in the International Banking Industry.
Journal of Business Ethics, [Online] Volume 86 (2), p. 159. Available at
https://link.springer.com/article/10.1007/s10551-008-9841-x. [Accessed 19 April 2019].
Stappers, J. (2019). Australia takes a big step forward in whistleblower protection. [Online]
WhistleB. Available at https://whistleb.com/blog-news/australia-takes-a-big-step-forward-in-
whistleblower-protection/. [Accessed 19 April 2019].