Anti-bribery, corruption and whistleblowing

Anti-bribery and corruption

Policy

We are committed to securing the financial wellbeing of people, businesses and communities by embedding a culture of zero tolerance to bribery, corruption and facilitation payments across all areas and levels of the business.

Our policy serves as a single and consistent anti-bribery and corruption standard across the Commonweath Bank Group. It is designed to comply with the Australian Criminal Code Act, 1995; the US Foreign Corrupt Practices Act, 1977 and the UK Bribery Act, 2010.

Amongst key principles of the policy, it should be noted that:

  • the Group has a zero tolerance to bribery and corruption
  • the giving, receiving, offering or promising a bribe or facilitation payment are expressly prohibited
  • training and awareness about our zero tolerance for bribery and corruption is conducted across the Group and all relevant third parties
  • all senior managers in the Group must commit to supporting the policy across their teams. Communication about the policy is undertaken by the CEO and the executive team.
  • business activities must be transparent, sufficiently documented and above suspicion
  • the Group has a SpeakUP (“whistleblowing”) hotline available for any concerns to be raised
  • due diligence must be conducted and documented with those who are doing business with, or on behalf of, the Group
  • the policy principles extend to all employees, directors and contractors.

Note: contractors are defined as entities or individuals under contractual arrangements with the Group, such as third-party contractors, suppliers, vendors, agents, consultants, introducing brokers and service providers that are conducting business on behalf of, or at the request of the Group.

Gifts and entertainment

Customers and business associates may offer to show their appreciation by providing gifts and entertainment to Bankwest employees. Accepting or offering gifts and entertainment can be problematic because it may lead others to believe that decisions have been improperly influenced. In some cases, where high-value gifts or entertainment have been offered, received, given or promised, this could be perceived as offering or accepting a bribe.

Our Gifts and Entertainment Policy and procedures are in place to ensure that employees do not offer or receive gifts or entertainment which could be seen as being inappropriate, be a breach of regulatory obligations, and/or which may give rise to actual or potential conflicts of interest.

Whistleblowing

Speaking up

We place great importance on fostering a culture that encourages employees and others to speak up about issues or conduct that concerns them. This could be anything from serious misconduct, to noticing something which just doesn’t feel quite right.

This doesn’t just apply to our employees – we have a dedicated SpeakUP Hotline, which is a service that is available to any director, manager, employee (current and former), contractor, consultant, supplier, service provider, secondee, broker or auditor of Commonwealth Bank Group (the Group) who wishes to raise a concern about any reportable conduct.

We encourage everyone who works with the Group to speak up, and we provide them with trusted avenues to go to if they want to raise a concern. This could be as simple as one of our employees having an informal discussion with their manager, or through to using the formal channels we have set up to make speaking up simpler.

The Board and senior management encourage people to speak up and report any conduct they believe to be inappropriate; and have put in place processes to provide the appropriate support to those who raise concerns. Identifying potential problems and risks allows the bank to continue to improve the way it does business and provide the best possible service to customers.

The Group Whistleblower Policy defines what type of conduct can be reported. This includes actions which are:

  • Dishonest
  • Fraudulent
  • Corrupt
  • Illegal
  • In breach of legislation
  • In serious breach of internal policy
  • Unethical
  • Improper
  • Bullying and harassment
  • Unsafe work practices
  • Any other conduct which may cause financial or non-financial loss to the Group or be otherwise detrimental to the interests of the Group and its customers, including environmentally unsound practices.

Importantly, the conduct of third parties, such as a supplier or a service provider, is also reportable. By the same token, channels are also available for certain third parties to report concerns they may see in their interactions with the Group.

Group policy

Sometimes individuals speaking up or making a disclosure may be concerned about being identified, or any potential repercussions which may come from reporting the conduct. This is why we have a comprehensive Group Whistleblower Policy. When contacting the SpeakUP Hotline, eligible persons can elect to be treated as a Protected Person, meaning that their concerns will be managed through the processes outlined in the Group Whistleblower Policy.

Our Group Whistleblower Policy is designed to encourage and support individuals to report issues, knowing that it is safe to do so and that they will receive support. Individuals are also free to make a disclosure directly to the regulator at any time.

The Group has a Whistleblower Protection Officer, whose role it is to oversee the protection of whistleblowers as part of the Group’s policies. The Group also has a Misconduct Governance Committee, which includes senior executives who report to the CEO, to oversee the effectiveness of the whistleblower program.

In March 2017, the Group enhanced the Group Whistleblower Policy including to make it simpler to use and more easily available. An important part of this was broadening the scope of eligible persons who can report concerns as a whistleblower, which now includes individuals outside, but associated with the Group, such as suppliers, contractors, consultants, secondees, brokers, auditors and former employees.

The updated policy has been approved by both the Executive Committee and the Board and aligns to the Australian Bankers’ Association’s “Guiding Principles – Improving Protections for Whistleblowers”, in addition to other relevant requirements. The Guiding Principles are part of the ABA’s Better Banking program, and ensures that all banks’ whistleblower policies meet the highest standard.

How to get in touch

There are a number of ways our people and others associated with the Group can report any concerns about conduct they believe doesn’t feel right. These include:

  • Our people having a conversation with their Manager
  • Speaking with a senior leader at General Manager level or above if they wish to report concerns under the Group Whistleblower Policy
  • Contacting the Group’s SpeakUP Hotline if they are uncomfortable going through internal channels, or would like to report concerns anonymously or under the Group Whistleblower Policy
    Call: 1800 773 258 (free call) or +61 2 9151 9156 (from overseas)
    Email: speakup@speakuphotline.com.au


Read a summary of the Group Whistleblower Policy

How can we help?

If you have any questions about our Anti-Bribery, Corruption and Whistleblowing policy, give us a call.