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MBA402 Governance, Ethics, and Sustainability

Kaplan Business School Australia

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Assessment Title: Code of Conduct

Assessment Question

You are required to research recent news articles and other information about National Australia Bank. You must then draft a Code of Conduct for National Australia Bank that specifically addresses: A. Discrimination, B. Exploitation, C. Corruption, D. Dishonest and Fraudulent Behaviour, E. Whistleblower Protections, F. Enforcement.

Answer :

Introduction:

National Australia bank is one of Australia's premier banking forms catering ot a wide financial needs of the Australian community .Established and having its presence in Australia for over 160 years NAB employs over 30,000 people and serves more than 9,000,000 customers worldwide .It has a global presence with operations being mainly concentrated in Australia and new Zealand .

NAB is the largest bank of Australia and works with different sized banks and businesses .The bank is known to support the businesses through every stage of the lifecycle. With a tag line of responsible inclusive and innovative, NAB has a very transparent and well designed code of conduct which guide the bank in its operations and strategies to serve communities better and strengthen the triple bottom line of people, planet and profits .Understanding that growth cannot be separated from communities, NAB works with people and communities and try to be good with the money given in safe keeping .NAB is more than money

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Code of conduct:

The code of conduct of the leading bank of Australia is supported by community and depositor's interest.

Nab is committed to contributing to the growth and prosperity of the country and help small businesses to start and grow. The bank has an onerous responsibility towards customers, investors and the government and is guided very closely with its corporate governance charter which includes a very disciplined and well thought out code of conduct .this ensures the very important trust that needs ot be created in the stakeholders .Engagement with communities and the external environment depends on how NAB conducts itself. (Nab.com.au, 2019)

Principles of NAB:

The Directors and Management and all officers of NAB are expected to act with integrity and to comply with the following principles.

1 NAB officials and employees wil conduct themselves in a very professional manner

2 To act in every dealing without prejudice and in all fairness and with high levels of integrity.

3 To not indulge in any transaction or act that leads to conflicts of interest.

4 To comply in totality with all legal and regulatory procedures, voluntary commitments and adhere to the highest standards of internal controls and standards.

5 To maintain confidentiality and privacy requirements of all parties concerned directly and indirectly.

6 The report every kind of breach and deal with it in the best manner

These broad guidelines are further substantiated so as to enable communities ot understand the role played by NAB in enriching the banking environment and adhering to the highest  professional conduct as prescribed by te Banking Act of Australia .

Dishonest & Fraudulent Behaviour Professional code of conduct:

NAB officials and employees will conduct themselves in a very professional manner

Every officer and employee of NAB wil behave in a manner that fosters trust, confidence and creates the necessary goodwill in all internal and external stakeholders and respects all human rights issues as prescribed in the bank's GROUP HUMAN RIGHTS POLCY.

a. To treat everyone with due respect and dignity

b. Compliance with all policies regulations and procedures both in spirit and working and not indulge in any behavior that gives way to compromises on actions and work beyond reproach.

c. To secure only such information of customer that relates to work and only with specific authorization

d. Work in compliance with terms and conditions that are applicable to all products and not to deviate from policies .In case of non compliance The Employee Assistant Program (EAP) can be referred to. 

e. Use of information systems must be done appropriately as per usage polices given by NAB .The systems cannot be used in any abusive manner or spread profane material. Employees must not know that the information system activities are under surveillance always and hence there can be no private issues regarding this nor can any employee sue NAB for lack of privacy in word k.

f. Social media must be used appropriately, lawfully and transparently while putting out information of NAB. Unless otherwise specified and given responsibility employees cannot post anything regarding NAB on the social media.

g. No media discussion or publicity can be engaged in by any employee unless specifically authorized by the corporate communications team.

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Discrimination:

To act in every dealing without prejudice and in all fairness and with high levels of integrity.

To act with honesty and integrity in all actions .Not to trade information or misappropriate money and to use the best judgement while dealing with customers and colleagues .for any further guidance with regard to employee relations, the guidance of the Group Whistle Blower program can be used.

NAB vouches to act with all fairness to customers by giving them products that are in compliance with laws and regulations and to not indulge in any false or misleading claims regarding products. Not to use any customer information without the knowledge of the customer and be fair .Refer to the ANTI Fraud policy can be used as guidance.

Prevention of corruption and fraud and all dishonest actions is the highest commitment given by NAB. Any Activity that lends itself to any kind of theft of money or property or information will be dealt with very severely .falsifying or destroying documents amounts to fraud and every act of bribery will be dealt with severely.

The bank does not discriminate in any of its hiring policies and believes in fair hiring .The recruitment and promotion police are as per the guidelines pronounced in the employee hand book.

Exploitation:

To act in every dealing without prejudice and in all fairness and with high levels of integrity

NAB conducts its business in the most  transparent manner making sure that the customer are fairly treated and market integrity is protected .caution is exercised in every dealing of the bank ensuring that there is no conflict of interest of either relationship or duties lending ot sound business policy .

Employees have to exercise caution while receiving gifts and charitable donations.

NAB Does not contribute to any political donation. (Exploring the Conduct of Ethiopian Banks: The Structure- Conduct-Performance Approach, 2019)

To comply in totality with all legal and regulatory procedures, voluntary commitments and adhere to the highest standards of internal controls and standards.

NAB complies with all laws voluntary codes and regulations that are applicable to banking and financial services to protect the investors, the customers and most importantly the community. Customers, employee's ad stakeholders are trained n compliance processes .any suspected non compliance can always be reported to the FAIR CALL SERVICE or THE WHIATLEBLOWER PROGRAM.

Privacy:

To maintain confidentiality and privacy requirements of all parties concerned directly and indirectly.

NAB adheres to the highest confidentiality with regard to all kinds of private information and in cognizance of laws and regulations pertaining ot privacy .insider trading and all other activities dealing with inside information is to be trusted with strict confidentiality an can be an offence if proved otherwise .The CONFLICT OF INTEREST policy guides the policy on managing information . Employees are expected to act within authority and to report any kind of breach of compliance in a timely manner and to the right authority .the people leaders are expected to manage the conduct of the employees and train them appropriately so as to function in an exemplary manner. NAB undertakes detailed investigation with regarding to every kind of trading activity by an employee or anyone related to an employee. Criminal changes can be pursed on employees found trading in very confidential information.

Breach

To report every kind of breach and deal with it in the best manner

NAB adheres to high levels of security of information and any breach of information or suspected breach may lead to disciplinary action on the person who breaches the code of conduct .Every employee is guided by the Employee conduct and Management policy to understand breach and the resultant penalty on breach.

Breach in professional conduct or in discharging professional duties calls for punitive action by NAB.

Employees are expected to conduct themselves befitting the stature and duties as imposed by the bank and shall not lend themselves to dubious standards of behaviour which may lead to breach of confidence.

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NAB Whistleblower program:

This program reflects the banks' commitment to the highest standards of ethics .the bank encourages people ot report any wrong doing .It also protects and supports the dignity of the person who whistle blows and thereby contributes ot the philosophy of reporting wrongdoings .The NAB also gives the necessary protection which is statutorily available ot the whistle blowers .

Who can be called a whistle blower?

A director, an officer, and employee of the NAB group including a contractor working for the group any subcontractor and the agent of the group.

Whistle blowers can report instance of fraud which are dishonest practices which can either bring in an unjust advantage or a potential loss in terms of finances. Those accounting and auditing practices that could be legal but do not comply with current regulations and standards.

Corrupt behaviour is that dishonest practice which allows the employee to take advantage of his position to make a profit out of a deal and cause a loss to another party or the group. Park and (Lewis, 2019)

Legal or regulatory non-compliance which could be an illegal and be of criminal intent.

Charges of bribery causing a benefit which is meant to advantage an employee at the cost of providing substandard services to the group. An Adverse behaviour and serious misconduct and wrong doing which is unethical and can be called a breach.

NAB commits itself ot supporting the whistle blowers with confidentiality and anonymity and protects them from possible threats and intents ot harm the well being of the whistle blower .Any adverse action dealt to the whistle blower will be dealt with in the correct  manner as suggested  by NAB .

Enforcement:

NAB follows the banking regulations and enforcements to the highest level giving great importance to every regulation. (Singh, 2003)

The bank adheres to every policy of the act which safeguards the intents of all stakeholders.

The bank assures that it enforces all provisions with regard OT market regulations nd the Securities board.

The mandatory enforcements and disclosures are prepared meticulously and are available in the public domain.

The bank has a very purposeful and forward looking financial statement which can enable investors and regulatory agencies to study the work off the bank.

The bank enforces the strictest discipline in its policies of employees.

The bank sets a moral code of conduct and trains employees extensively on the same so as to not fall behind in its regulatory policies.

The bank takes all steps to ensure that every aspect of bank functioning falls within the purview of the acts which regulate it.

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Adherence to the code:

Employees and officers are trained in the code of conduct extensively and are expected to understand the contents and points of good governance from the code manual. Officials are expected to guide employees in discharging their duties and responsibilities honourably and to the best interest of the customers and communities.

Governance is said to be the hall mark of performance of NAB and makes the bank function in all its interests with integrity and good faith.

NAB is guided by the Australian banking commission's guidelines while discharging its duties as a premier banking institute of Australia. NAB is expected to take on challenges and deliver expectations of the people to a higher level. The rights of customers which can be enforced make it all the more necessary for NAB to follow its code of conduct rigorously.

The code of conduct of NAB has been approved by Australian Securities and Investments Commission under their industry code approval powers.

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