Anti-bribery and corruption, Anti-Tax Evasion Facilitation, and Speak Up.
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Anti-bribery and corruption
Bankwest is a division of the Commonwealth Bank of Australia (the Group). The Group's Anti-bribery and corruption (AB&C) Policy supports its zero appetite towards bribery, corruption and facilitation payments.
The Group's Policy serves as a single and consistent AB&C benchmark across the Group. It is designed to comply with the Australian Criminal Code Act 1995, the US Foreign Corrupt Practices Act 1977, the UK Bribery Act 2010 and all other AB&C related laws relevant to the locations in which the Group operates.
Amongst the key principles of the Policy, it should be noted that:
- The Group has zero appetite towards bribery, corruption and facilitation payments
- The giving, receiving, offering, promising, requesting or authorising of a bribe is expressly prohibited
- 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 is to be conducted on employees and on those who are doing business with, or on behalf of, the Group.
The Policy principles extend to all employees, directors, temporary staff, contractors, suppliers, service providers, agents and other third parties acting for or on behalf 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.
Our Gifts and Entertainment Policy and Procedures seek to ensure that employees do not offer or receive gifts or entertainment which could be seen as being inappropriate, constitute a breach of applicable regulatory obligations, and/or otherwise give rise to actual, perceived or potential conflicts of interest.
Anti-Tax Evasion Facilitation
We have zero appetite towards the facilitation of tax evasion and are committed to preventing this activity.
The Group's Anti-Tax Evasion Facilitation Policy prohibits the facilitation of tax evasion, which applies to all employees, directors and contractors of the bank. The principles outlined in the Group's Policy also apply to third parties acting or performing services for or on behalf of the Group.
The Group's Policy requires us to:
- Identify, mitigate and manage facilitation risks, which includes periodic risk assessments and implementation of controls where necessary
- Undertake due diligence on our employees and third parties, and escalate any tax evasion concerns or red flags
- Conduct ongoing training and awareness on tax evasion facilitation so employees understand the risks and their responsibilities
- Escalate and report any concerns, including suspicious matters
- We must comply with anti-tax evasion legislation in all jurisdictions we operate in including the UK Criminal Finances Act 2017, which introduced new corporate tax offences that prohibit the facilitation of tax evasion.
Speak 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.
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, which is designed to encourage and support individuals to report issues, knowing that it is safe to do so and that they will receive support.