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Code of conduct and compliance - Corporate Responsibility

Code of conduct and compliance

Codes of Conduct

In October 2008, ANZ introduced a new employee Code of Conduct and Ethics (PDF 600kB). This Code applies to anyone who is employed by or 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 ANZ Conduct and Ethics Policy Framework.

The Employee Code and its supporting policy framework set the standard for the way we do business at ANZ, and provides guidance to anyone working at ANZ on how to successfully navigate ethical challenges they may encounter in their work.

ANZ has also developed a new training course, called the Code of Conduct and Ethics Declaration, which covers the detail of the Code and underlying policy framework. Everyone who works at ANZ is required to complete the new Code of Conduct and Ethics Declaration training course annually. This Declaration confirms that each employee understands the Code's principles, has complied with them over the previous 12 months and agrees to comply with them in the future.

ANZ has also introduced a new Non-Executive Directors' Code of Conduct (PDF 446kB) that guides ANZ non-executive directors in pursuing the highest ethical standards in the interests of shareholders, our people, customers and the communities in which ANZ operates. Other Codes also in place at ANZ include a Code of Conduct for Financial Officers (PDF 23kB) that guide specialist finance and legal staff in their everyday dealings at work.

In addition to ANZ's compulsory Employee Code of Conduct course, we have issue-specific training for employees on topics such as money laundering, identification of terrorist money, fraud and privacy.

Compliance

All staff are required to comply with ANZ's Codes of Conducts and relevant policies pursuant to their contracts of employment at ANZ. Advice on ANZ policies, practices and management systems is available via our staff hotline, People Assist.

Breaches of operational, regulatory and compliance requirements are tracked using an online reporting system and case management, with corrective action closely monitored.

Breaches of the Code of Conduct are reported quarterly to ANZ's Management Board and form part of regular risk reporting to Operational Risk Executive Committee.

Progress in 2008

More than 19,000 employees completed training related to ANZ's previous Employee Code of Conduct during 2008.

Specific training courses completed by employees 2008 2007
Code of conduct training globally 19,919 9,000
Code of Conduct Declaration course 30,121 8,000
Courses related to discrimination, harassment and bullying 18,700 18,000
Courses related to human rights 18,700 -
Courses related to anti-corruption 61,372 -

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:

Breaches of code of conduct 2008 2007
Australia 251 282
New Zealand 66 135
Asia Pacific 187 -
India 21 -
Other 0 -
Total 525 417

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