Anti-bribery, corruption and whistleblowing

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.

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.