Our commitment to eliminating bribery, fraud and corruption

We place great importance on the values of honesty and integrity. Bribery, fraud and corruption are incompatible with ANZ's Values and Code of Conduct and Ethics and present significant risks to our business. Putting in place robust policies and procedures and creating the right organisational culture is essential in the proactive prevention of bribery, fraud and corruption.

Our policies

Our ANZ employees (temporary and permanent), contractors and consultants are required to comply with our Code of Conduct and Ethics and related policies which include our Global Anti-Bribery and Anti-Corruption Policy and Global Fraud Policy. All our employees must act honestly and with integrity, manage all conflicts of interest, and report any suspicious activity using ANZ's escalation process, published on our intranet.

Any acquisitions (including joint ventures) that we undertake are governed by our Global Anti-Bribery and Anti-Corruption Policy. This requires us to conduct thorough due diligence to provide reasonable assurance that any target business is not involved in any bribery or corruption. We encourage our partners (such as suppliers and service providers) to adopt and maintain similar conduct and ethics principles.

Our policies have been developed in line with international best practice and in consideration of all relevant fraud, bribery and corruption laws in each of our countries of jurisdiction.

Our Anti-Bribery policy prohibits employees, officers, agents and representatives of ANZ from offering, promising or providing bribes directly or indirectly through third parties, in any form.

Our Fraud and Corruption policy sets out the requirements for governing fraud and corruption risks, and provides specific guidance in relation to roles and responsibilities of all employees in the identification, prevention and escalation of fraud and corruption risks and events, without fear of reprisal.

Embedding our policies in everyday business

Our approach to eliminating bribery, fraud and corruption, complements our commitment to the UN Global Compact and our aspiration to embed responsible practices in everything that we do.

We establish clear procedures and provide our employees with clear guidance and support through ongoing training and education to detect, avoid and report fraudulent and corrupt activity.

  • We apply consistent and robust procedures to eliminate bribery and corruption, for example:
    • We embed compliance with our Code of Conduct and Ethics - and supporting policies such as the Global Anti-Bribery and Global Fraud and Corruption policy - in employment contracts, recruitment and performance management activities
    • We put in place clear guidelines and procedures that require all employees to obtain the appropriate approval for and record any donations, sponsorships, gifts and charitable contributions. Political donations require approval of the CEO and are publicly disclosed each year in our annual report.
  • We provide employees with education, training and information to help them to understand and eliminate the risk of bribery, fraud and corruption. Regular employee training ensures adequate awareness of the risks policies and key controls to effectively embed risk management in our culture. For example, each year our employees complete:
    • Mandatory online training under, "ANZ Essentials" (risk accreditation framework) on fraud, corruption and bribery, in addition to topics such as anti-money laundering, security awareness, equal opportunity and health and safety; and
    • For employees at management level and above, declare they have read and understood 'The Blue Book' – ANZ's guide to Code of Conduct and Ethics, standards and behaviours, and important policies and procedures.

Additionally, every three years, employees are required to complete 'Preventing Fraud and Corruption' training.

Failure to complete required compliance training can be a factor in an employee's entitlement to performance-based remuneration and could lead to termination of employment in serious cases.

All employees can access comprehensive, confidential information to support our Code of Conduct and Ethics and supporting policies, via their local internal HR support team (which includes a dedicated phone helpdesk). Any employee, contractor or consultant can confidentially report concerns about conduct, practices or issues under our Whistleblower Protection Policy Summary.

Monitoring compliance

Our employees are required to comply with the Code of Conduct and Ethics and related policies, and report conduct that may be in breach of the law, code or policy. All breaches are monitored through a central database through to closure. Regular updates on our performance are reported quarterly to our Management Board and form part of regular risk reporting to the Operational Risk Executive Committee. Each year, we publicly report our breaches through our annual report, and online.

Annual testing of the controls that support the Code of Conduct and Ethics policy framework are undertaken as part of our financial reporting governance program, and the results are made available to ANZ's independent external auditor, as part of their audit of the Group's consolidated financial statements.

Our commitment to eliminating bribery, fraud and corruption aligns with our support of the UN Global Compact.

For further details about the policies that support our Code of Conduct and Ethics, please visit the ANZ Shareholder Centre.

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