Our approach and performance
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 192kB) 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.
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 Whistleblower Protection Policy Summary.
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.
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.
Our expectation of all people working with us is that they comply with our Code of Conduct and Ethics, called ‘Living The Code’. This is one of a suite of courses within ‘ANZ Essentials training’, which specifies our expectations concerning:
All permanent and temporary employees, consultants and contractors are required to undertake ‘ANZ Essentials’ training, and to refresh their knowledge of specific courses within the suite, annually, or every two or three years, depending on the subject. Failure to do this can lead to disciplinary action and/or remuneration consequences; in serious cases it can lead to termination of employment.
Everyone is required to complete the ‘Living the Code’ training course, within ANZ Essentials, annually. The course aims to reinforce the importance of our values and ethics and seeks a declaration of compliance with our Code of Conduct and Ethics. In 2012, 58,104 people working with ANZ completed the ‘Living the Code’ training program.
As we grow our business and expand in new markets, it is essential that our people understand and act upon our Code of Conduct and Ethics.
Banking is built upon trust. We therefore set high standards and we continually improve our approaches to ensuring that our employees live our values. For example in 2012 we placed Whistleblower champions in all ANZ markets. These enhancements are leading to more suspected incidents being identified and reported.
In 2012, 1,828 alleged breaches of our Employee Code of Conduct and Ethics were reported and investigated across the Group, compared with 1,297 in 2011.
As was the case in 2011, the majority of alleged breaches in 2012 related to Principle Seven, "A failure to comply with the Code, the law or ANZ policies". This accounted for 1,246 cases or 68% of alleged breaches. A significant number related to misuse of ANZ systems, including inappropriate use of e-mail, intranet or the Internet. Others related to more serious actions such as failing to manage conflicts of interest or misuse of private or confidential information. A very limited number of breaches were in direct conflict with the law. Any such breach of the law is referred to relevant legal authorities.
We operate a central reporting and follow-up function to ensure we achieve the highest possible investigation completion rate each year. We will continue to maintain our high expectations and standards regarding the behaviour of all people working with ANZ.
Our Code of Conduct and Ethics (PDF 324kB) can be viewed here.
Issues that are covered under our discrimination policy include allegations of: bullying, harassment and discrimination on the grounds of age, gender, race, sex, and parent or carer responsibilities.
There were 53 alleged discrimination incidents in 2012; 45 involving ANZ employees and eight involving customers. 48 of these incidents were resolved and three are on-going. This is an increase on the 2011 figure of 36 reported incidents. We attribute this to a greater awareness amongst employees of their rights, entitlements and responsibilities. We have not seen a corresponding increase in substantiated claims.
We have a network of employee relations specialists across all ANZ locations who undertake an investigations into allegations and makes recommendations to an appropriate decision maker.
Bribery, corruption and improper payments
We continue to roll-out training across the ANZ network to ensure that it is clear to all employees that we have a set of standards that apply wherever we operate that are over and above local conditions.
ANZ Essentials course “preventing fraud, bribery and corruption” is mandatory for all new joiners and must be revisited by all employees, contractors and consultants every three years. In 2012, over 30,000 ANZ people completed the course.
In 2012 we investigated 18 cases of alleged bribery, corruption and improper payments. Four of these allegations were substantiated and were sufficiently serious that they resulted in dismissal. Nine cases resulted in written or verbal warnings; four people were exonerated and one resigned. If an employee resigns during an investigation, we complete the investigation, and determine the reason for their leaving based on the investigation outcome.
As in other related areas in this section, we attribute the increase in reported and alleged incidents to better training and more comprehensive reporting systems.
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.
There were 36 discrimination incidents in 2011; 25 involving ANZ employees and 11 involving customers.
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
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.
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:
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:
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