Code of conduct and compliance

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Our approach

We use globally recognised frameworks such as the OECD Guidelines for Multinational Enterprises and the UN Global Compact along with our our values, Corporate Responsibility framework and human right standards to guide our approach to responsible business, including employee conduct. They also help employees to successfully navigate ethical challenges in their everyday work.

Code of Conduct and Ethics

Our employee Code of Conduct and Ethics (PDF 368kB) applies to everyone who works at ANZ, including employees (both permanent and temporary), contractors and consultants. The Code is supported by a number of more detailed policies that form part of the Conduct and Ethics Policy Framework. These cover issues such as anti-bribery, fraud and corruption, equal opportunity, bullying and harassment, conflicts of interest and work expenses. A Non-Executive Directors' Code of Conduct (PDF 446kB) guides ANZ non-executive directors in pursuing the highest ethical standards in the interests of shareholders, employees, customers and the communities in which we operate.

We encourage our banking partners (such as suppliers, related bodies corporate, joint venture partners or companies in which ANZ is a strategic investor) to adopt and maintain similar conduct and ethics principles to those outlined in our Code of Conduct and Ethics.

Monitoring compliance

Compliance with our Code of Conduct and Ethics is embedded in ANZ employment contracts, recruitment and performance management activities. We have set explicit targets for compliance, commencing at executive management level. All employees are required to comply with our Code of Conduct and Ethics and report conduct that may be in breach of the law, the Code or ANZ policy. Advice on ANZ policies, practices and management systems is available via our staff hotline, ‘ANZ People Assist’ or local Human Resources specialists in some countries of operation. Any employee, contractor or consultant can confidentially report concerns about conduct, practices or issues under our Global Whistleblower Protection Policy (PDF 30kB).

To help our employees in applying the principles of our Code of Conduct and Ethics and the Conduct and Ethics Policy Framework, we have developed a training course, called ‘Living the Code’ which forms part of our ‘ANZ Essentials’ risk accreditation framework – available to staff in English, Traditional Chinese and Bahasa. Case studies are provided to assist staff in translating the Code and related policies into real-life situations. All employees are required to complete this training course each year. Declarations within the course require each employee to confirm whether they understand the Code's principles, have complied with them over the previous 12 months and agree to comply with them in the future. Compliance is a Key Result Area examined as part of our Performance Management Process and failure to complete required compliance training can be a factor in determining the employee’s entitlement to performance-based remuneration and could lead to termination of employment in serious cases.

Additionally, employees are required to undertake issue-specific training for topics such as money laundering, counter terrorist activity, fraud, corruption and privacy.

Our ‘Blue Book’ sets out the ‘ground rules’ for all employees working at ANZ. It covers our Code of Conduct and Ethics, standards and behaviours, and important policies and procedures such as our Anti-Bribery Policy and Fraud and Corruption Policy. All Managers must complete an annual attestation that they have read and understood these ground rules and failure to complete this may result in a ‘flag’ being raised in an individual’s performance review.

Reporting compliance

We have reported breaches of our Code of Conduct and Ethics framework since 2005. Breaches of operational, regulatory and compliance requirements are tracked using an online reporting system and case management, with corrective action closely monitored until ‘closed’. All breaches of the Code are reported annually to our Governance Committee and form part of regular risk reporting to the Operational Risk Executive Committee.

Our Community Expenditure Tool ensures that our Code is applied in respect to charitable contributions and community investment.  The tool requires a high level of disclosure for all forms of community expenditure and reports are provided bi-monthly to the Corporate Responsibility Committee.

Compliance with our Code of Conduct and Ethics is monitored by Internal Audit, who ensure processes are in place to appropriately investigate alleged breaches of the Code.  We also conduct annual testing of the controls that support our Code of Conduct and Ethics, which forms part of our financial reporting governance program and the results are made available to KPMG in connection with their external audit of the Group's consolidated financial statements.

2011 results

In 2011, 55,288 employees (over 96% of our staff) completed our ‘Living the Code’ training program.

There were 1,297 alleged breaches of our Code of Conduct and Ethics investigated across the Group. This compares favourably with 2010 given there were increases in headcount over the 12-month period.

The majority of breaches of our Code relate to ‘Compliance with the Code, law and ANZ procedures’ and more specifically the inappropriate use of our email and intranet systems. Outcomes arising from breaches of the Code included 209 dismissals, 75 resignations, 149 staff being counselled and a number of reprimands. We continue to improve our reporting systems and increase awareness of the ethical standards expected of all our employees.

* Mainly related to inappropriate use of email and systems

Bribery/ corruption incidents

In 2011, we investigated six cases of alleged bribery, corruption or improper payments.  Five employees were exonerated following investigation, and one employee was reprimanded for a matter that was unrelated to bribery, corruption or improper payments.

Discrimination incidents

There were 36 discrimination incidents in 2011; 25 involving ANZ employees and 11 involving customers.

2010 results

In 2010, 50,393 employees (98% of our staff) completed our Living the Code training program. In addition, more than 46,000 of our employees completed either our ‘Leading Risk in Our World’ or ‘Understanding Risk in Our World’ training sessions.

There were 1,294 serious breaches to our Code of Conduct and Ethics across the Group. This has slightly increased from 2009 due to the increase of headcount over the 12-month period.

The majority of breaches of our Code relate to ‘Compliance with the Code, law and ANZ procedures’ and more specifically the inappropriate use of our email and intranet systems. Outcomes arising from breaches of the Code included 195 dismissals, 69 resignations, 174 staff being counselled and a number of reprimands. We continue to improve our reporting systems and increase awareness of the ethical standards expected of all our employees.

* Mainly related to inappropriate use of email and systems

2009 results

We recorded 42,396 completions of the Code of Conduct and Ethics Declaration training course for this year, which represents around 99% of ANZ staff.

100% of ANZ's top 200 Executives have completed an ethics training workshop which is now being rolled out to employees, commencing with participants in ANZ's Leadership Talent Radar.

In 2009 there were 1093 serious breaches of the ANZ Code of Conduct across the Group. Our analysis is that the increased number is mainly the result of improved reporting mechanisms and higher awareness across the organisation of the requirements of the Code and the importance of reporting breaches (which is in itself a requirement of the Code). Seventy-five per cent of breaches related to infringements of the requirement to abide by the law, the Code and ANZ policies and procedures. These breaches largely related to the inappropriate use of email and internet contrary to ANZ policy.

The outcomes of Code breaches in 2009 were:

• 173 exonerated/no action
• 120 counselled
• 524 reprimands
• 57 resignations
• 199 dismissals
• 11 suspended
• 0 mutual separation
• 6 performance improvement
• 1 agreement to improve
• 2 training.

2008 results

Training for ANZ's new Employee Code of Conduct and Ethics will be conducted with all employees rolled out during 2008-2009.

In 2008 there were 525 serious breaches of the ANZ Code of Conduct across the Group. These mainly related to breaches of 'Abiding by the law and this code' and more specifically for breaching the ANZ Email and Internet Policy. The outcomes of these breaches were:

• 97 exonerated/no action
• 65 counselled
• 167 reprimands
• 38 resignations
• 147 dismissals
• 2 suspended
• 2 mutual separation
• 5 performance improvement
• 1 agreement to improve
• 1 training.