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Our approach

Code of Conduct

Our employee Code of Conduct and Ethics (PDF 600kB) applies to everyone 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.

Our employee Code and its supporting policy framework set the standard for the way we do business at ANZ and, along with our values, provide guidance to everyone working at ANZ on how to successfully navigate ethical challenges that may be encountered in our 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.

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, 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 and Ethics Declaration 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 Conduct 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 the Operational Risk Executive Committee.

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.3

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.