NATIONAL

AUSTRALIA BANK
Code of Conduct
NATIONAL AUSTRALIA BANK GROUP COMMITMENTS
We behave in a professional manner that fosters trust,
We conduct ourselves professionally confidence and goodwill in customers, colleagues,
suppliers and the community and respects human rights.

We act with honesty, integrity and fairness; we speak

We act with honesty, integrity up, escalate any concerns and admit when we have
and fairness made mistakes. We consider customer fairness in every
decision.

We ensure our personal and business interests

We manage conflicts of interest never interfere with our ability to make sound,
objective decisions.

We meet our legal and regulatory We comply with all laws, regulations and Codes that
obligations, voluntary commitments are applicable to us, including internal NAB policies
and internal standards and voluntary commitments.

We protect confidential information regarding

We adhere to confidentiality and
customers, suppliers, colleagues and our
privacy requirements business affairs.

We deal with, and report on, We investigate, deal with and appropriately report on
suspected breaches suspected breaches of our Code.


CONTENTS
CODE OF CONDUCT – AUSTRALIA
We conduct ourselves professionally 4
1. Personal conduct  4
2. Use of information and information systems  5
3. Social media  6
4. Media discussions/publicity  6

We act with honesty, integrity and fairness 7

5. Honesty and integrity  7
6. Fairness 8
7. Prevention of fraud and corruption 8

We manage conflicts of interest 9

8. Conflicts of interest and relations with customers and/or third party providers 9

We meet our legal and regulatory obligations, voluntary commitments and internal standards 10
9. Complying with legal and regulatory obligations, voluntary commitments and internal standards 10

We adhere to confidentiality and privacy requirements 11

10. Market information 11
11. Confidentiality, access and disclosure  12

We deal with, and report, suspected breaches 13

12. Consequences of breaching the Code of Conduct  13

National Australia Bank Limited policy declaration  14

We conduct ourselves professionally

1. PERSONAL CONDUCT
You must behave in a professional manner that fosters trust,
confidence and goodwill in customers, colleagues, suppliers Sexual Harassment - David crosses the line
and the community and respects human rights in keeping with
David was at a work-organised function. During the
the Group Human Rights Policy.
function he consumed a lot of alcohol and at one point
At all times, both in and out of work you must: he tried to grab Priya around the waist and kiss her.
Later in the night, he again approached Priya and made
• Treat customers, colleagues and members of our community
sexually explicit comments to her.
with dignity, fairness and respect
• Comply with the spirit and requirements of all policies, Priya raised a complaint about David to Employee
Relations, via the People Advisory Centre. Following a
procedures, laws and regulations applying to your role.
full investigation into the matter, David was found to
Hold yourself and others accountable and, be beyond
have breached NAB’s Discrimination and Harassment
reproach for your actions
Policy and his employment was terminated. NAB’s
• Only access information relating to a customer or work Discrimination and Harassment Policy applied to David
colleague with specific authorisation based on a work- and his conduct even though the function was outside
related need the office because it was a work-related function.
• Keep your accounts in order at all times and comply with As a result of the incident, David’s people leader was
the terms and conditions applying to any product you issued with a warning for failing to ensure alcohol was
use. Employee’s Choice benefits may be withdrawn where served responsibly and for not immediately addressing
there is continued non-compliance with product terms and David’s unacceptable behaviour.
conditions. Disciplinary action may also apply.

Where to seek assistance Not “just a joke”

If you are experiencing any financial or personal A team of employees often engaged in what some
difficulties that may result in non-compliance, thought was innocent and jovial ‘banter’ to make
there is support available. You should speak with their workplace fun and make it easier to deal with
your people leader or Employee Relations via the challenging work. One day a group of employees from
People Advisory Centre, who will assist and may the team engaged in ‘banter’ about Tony, including
direct you to suitable resources. The Employee impersonating his supposed feminine characteristics.
Assistance Program (EAP) is also available to provide One of the team, Arun, also commented about Tony’s
independent and confidential counselling services shirt saying that he was “wearing his gay shirt today”.
for any work or non-work-related difficulties you Tony didn’t take offence to the comments as he knew
may be facing. the group were only joking, as they often do. Isabella,
however, felt the banter was offensive so she spoke
to some of the group about their comments. Their
response was “they were only joking”.
Greg uses NAB tools to harass Not satisfied with this response, Isabella spoke to her
Greg has recently gone through a messy separation people leader, who counselled the offending
from his partner. He sent numerous abusive texts employees and advised that behaving in such a
and emails to his ex-partner threatening to harm her manner was unacceptable.
and her family. The texts and emails were sent using
The employees were required to apologise to Tony and,
his NAB email account and his work-supplied mobile
to read the Code of Conduct and NAB’s Discrimination
telephone. Greg’s people leader, Rosa became aware of
and Harassment Policy. They were also warned that
the threatening behaviour after being contacted by the
any further instances of such behaviour would lead to
Police.
further consequence management.
After a thorough investigation, it was found that
Greg’s actions breached both the Serious Misconduct
Policy and the Information Risk Policy. As a result Greg’s
employment was terminated with immediate effect. He
was provided with access to the Employee Assistance
Program.


 2. USE OF INFORMATION AND INFORMATION SYSTEMS
You must use computer, telephone, other devices and network
systems appropriately at all times. Steve tries to help
You must never use these devices and systems to: Feng-Li, a NAB customer, phones her banker Steve, to tell him
an email she sent to him has bounced back with a message
• C
 ommunicate, view or distribute inappropriate, sexually stating it cannot be delivered. Steve believes the reason for
explicit or offensive material this may have to do with the file type or size of the email
• S pread profane, derogatory, discriminatory or harassing attachment. To help her out, Steve gives Feng-Li his personal
comments, or threatening or abusive language email address and asks her to send it there instead. Feng-Li
resends the email to Steve’s Gmail account. Steve responds to
For more information, see our Information Risk Policy and for Feng-Li from his Gmail account to let her know he received
specific details and examples refer to Information Risk Policy - her email and advise the next steps regarding her account.
Use of Information and Information Systems.
By undertaking this action, Steve has breached the Information
If you receive inappropriate material, you should immediately Risk Policy which prohibits corresponding with customers
delete it and notify the sender to stop sending such material. from personal email accounts. Steve should have spoken to his
You should also notify your people leader. Accidental connection people leader about these system issues he was having.
to an inappropriate website must be disconnected immediately. It is important to keep customer and NAB information on
the NAB network. Personal email accounts do not have the
Your login details must not be provided to anyone. Sharing
same security controls in place as the corporate network.
login details and passwords contravenes our policies and
Steve has jeopardised the security of Feng-Li’s information
procedures. You are presumed responsible for all actions
by using his personal email account to correspond with her
undertaken using your identity/login and must protect these
and received a warning and Conduct Gate as a result.
from use by others.

Systems such as Outlook, SAP and FlexiPurchase have delegation

functions which must be used when access by another colleague
is required. Inappropriate access using NAB’s systems
Hugo stepped away from his computer briefly without
Employees should be aware that NAB conducts surveillance locking it. When he returned to his desk he found Kate
by accessing and monitoring Group Information Systems on sitting at his desk entering in a loan application. Hugo didn’t
an ongoing, continuous basis. Therefore you should have want to say anything as he was friends with Kate and didn’t
no expectation of privacy regarding your access to and use want to rock the boat.
of Group Information Systems. For more information, see
email and internet monitoring at NAB. It was later found that Kate was entering a loan application
for herself and her employment was terminated.
Unauthorised distribution or copying of NAB business
Hugo’s actions were also found to have breached the
information, including personal, customer and market
Information Risk Policy and the Code of Conduct as he is
information, contravenes our policies and procedures and
responsible for what happens using his login and did not
may cause NAB to breach its legal and regulatory obligations.
escalate the issue appropriately. Hugo received a warning
and Conduct Gate.

Inappropriate Banter Using Instant Messaging

Tiffany, Van and Paul use instant messaging to communicate
with each other at work throughout the day. During their
communications they make offensive comments about
sex, religion and race. They also make offensive comments
regarding other employees, about physical appearance,
sexuality and work performance. Another employee, Helen,
approached Tom and told him she saw part of an instant
message being typed by Paul which appeared to contain
offensive and aggressive language.
A review of Tiffany, Van and Paul’s instant messages was
undertaken. Their use of instant messaging was found to
breach NAB’s Information Risk Policy and Code of Conduct.
Further, their inappropriate and offensive comments
regarding physical appearance, sexuality and race breached
NAB’s Discrimination and Harassment Policy. All three
employees were terminated.

3. SOCIAL MEDIA 4. MEDIA DISCUSSIONS/PUBLICITY
While we encourage you to make appropriate use of social You must not make public statements about NAB unless you are
media, you must act lawfully and be transparent, responsible authorised to do so by our Corporate Communications team.
and respectful of us, our customers, your colleagues and
everyone you interact with online. Unless specifically authorised You are not permitted to allow external photographers to
to do so, you must not post on social media as a representative photograph the interior of NAB premises without approval
of NAB. Be aware that even if you do not post on social media from our Corporate Communications team.
as a representative of NAB, your interactions on social media
You must not put your personal agenda ahead of our
may affect NAB’s reputation.
customers or our organisation or make public comments
When using social media, you must: which could prove damaging to NAB’s reputation.

• R
 ead and comply with our Social Media Guidelines If you use Social Media, ensure your comments cannot
and NAB policies be misconstrued as representing NAB’s views unless
you are specifically authorised to be making comments
• Ensure your personal use does not interfere with your work on behalf of NAB. NAB’s policy for communicating with
media is outlined in our Group Disclosure & External
Communications Policy.
Gareth vents on social media
Gareth was having a bad day and expressed his
frustration with his customers on his Facebook page,
making derogatory comments about how demanding
they were and how nothing he did was good enough.
One of his Facebook friends, also a NAB colleague,
saw the comments and notified her people leader.
This action was not in line with our Social Media
Guidelines and breached our Code of Conduct, resulting
in Gareth receiving a Conduct Gate.

Zara tries to help

NAB experienced a system error with our ATM network
which resulted in negative publicity. Zara, who works at
NAB, posted updates on Twitter about our progress in
rectifying the error, and also posted on Twitter when
the error was rectified.
Although not intended to be harmful to NAB, the
information on Twitter was NAB’s confidential
information, known only by Zara because of her
employment with NAB. As such, the information should
not have been posted on Twitter or disclosed outside
of NAB. Also, Zara was not authorised by NAB to speak
about such issues to the general public.
A Conduct Gate was applied. Zara was also reminded of
the confidentiality obligations that apply to our people.


 We act with honesty, integrity and fairness

5. HONESTY AND INTEGRITY

You may have access to money, information, goods and
documents belonging to us or our customers. Aaron uses his corporate purchasing card
for personal expenses
You must not steal or misappropriate. You must not borrow
or convert items to private use or access information without Aaron, an employee, used his corporate purchasing
proper authority. card to make personal low value purchases over the
course of a month and in some instances deliberately
If you make any business related purchases, you must miscoded the spend categories in Flexipurchase to
comply with the National Australia Bank Ltd Expense mask the transactions.
Management Policy.
Aaron’s people leader, Sue, had delegated her approval
You must act with honesty and integrity in your dealings with to another team member who was not across the detail
customers and colleagues. of Aaron’s purchases and didn’t query them.

Where mistakes are identified, we must admit them to our As part of NAB’s automated transaction analysis, Aaron’s
customers and colleagues. You must not conceal errors and personal purchases were identified. Sue was informed
omissions, or attempt to protect your colleagues who have of the personal nature of Aaron’s transactions and the
breached our regulations. If you become aware of, or suspect any matter was referred to Employee Relations and Financial
inappropriate conduct, wrongdoing or unfair customer outcomes, Crime Services for further investigation.
you have a duty to report the concerns or seek guidance from: The investigation determined Aaron had used his
• Your people leader or, corporate purchasing card for personal items. Aaron’s
• Employee Relations via the People Advisory Centre or, employment was terminated for breaching the Expense
Management Policy and he was required to repay the
• Group Whistleblower Program via the FairCall Service. cost of these personal items.
NAB does not tolerate any reprisals, or threats of reprisals, Corporate Purchasing Card transactions will be subject
against any employee who reports known or suspected to random audits. Cardholders and approvers may be
misconduct. The Whistleblower Program provides support and asked to substantiate all purchases and demonstrate
protection to employees who report concerns to the Program. adherence to the Expense Management Policy.

Chloe amends NAB’s systems

Chloe needed some extra funds to cover some Pauline’s expenses
unexpected expenses that came up at the end of the Pauline, an Executive Assistant, used her corporate
month. Chloe’s account was in debit and she decided purchasing card to buy items including presents, flowers
to use NAB’s systems to put a temporary excess on her and other general items on behalf of her people leader,
account as she knew without making the amendment Sonya. Some of Pauline’s colleagues noticed the purchases
on the system her name would show up on a report and questioned whether the expenses were appropriately
detailing the unauthorised excess. Chloe didn’t think this authorised and in line with our Expense Management Policy.
would be an issue as she paid the amount back at the
end of the month and her account was back in credit. An investigation was conducted and concluded that
Pauline had breached the Expense Management Policy by
Chloe’s actions were discovered as part of NAB’s regular purchasing non-permitted items. Further, Sonya, who had
checks and her employment was terminated. directed her to purchase such items, also breached the Policy.
Both Pauline and Sonya received a Conduct Gate.
They were also required to read and acknowledge
Jason is unwell their understanding of and agree to comply with
Jason telephoned to advise that he was sick and the Expense Management Policy.
would not be at work for three days. On his return,
he provided a medical certificate relating to his
absence to his people leader, Heather, who noticed
what appeared to be alterations to the dates on
the certificate.
Heather made contact with Jason’s treating doctor, who was
unable to confirm the dates on the certificate presented.
Jason later admitted to changing the dates on the certificate
to avoid paying for an additional consultation.
Jason’s actions in falsifying a medical certificate were
dishonest and a breach of NAB’s Code of Conduct.
Jason’s employment was terminated.


6. FAIRNESS
Fairness to our customers
Our Financial Crimes requirements provide guidance on
You must treat all existing and potential customers fairly.
our responsibilities and processes.
Customer fairness means that where NAB provides products • Our Anti-Fraud Policy outlines our responsibility
or services they must be lawful, ethical, and ‘not inappropriate’ to act honestly and adhere to internal controls and
to a customer’s needs. procedures designed to prevent fraud activities.
You must always ensure when dealing with customers that • Our Anti-Bribery and Corruption Policy sets out the
products, services and advice are provided in accordance with Group’s approach and employee responsibilities
local laws and regulations. You should provide information for complying with applicable legal and regulatory
in a way the customer will understand and in a manner that requirements in relation to Bribery and Corruption.
allows for an informed choice. • Our Anti Money Laundering and Counter Terrorist
Financing Policy and Economic and Trade Sanctions
You must not make false, misleading or deceptive representations
Policy set out how the Group meets its legal
to induce a customer to enter a transaction or enter into a
transaction without the customer’s approval. and regulatory obligations in these areas.

You must not use the confidential information of customers

for the benefit of anyone else, including another customer, All employees should remain alert to unusual customer
NAB or for yourself. activity and must follow correct procedures to ensure
All dealings with customers must reflect NAB’s values instances of fraud, corruption and bribery and the
and behaviours. subsequent risks to customers and/or NAB are minimised.

Customer complaints must be handled with sensitivity and

in a timely manner. The Customer Complaints Policy provides
guidance on effective and efficient complaints handling to Olivia causes financial difficulty
meet the needs of both NAB and its customers. Olivia is meeting with a customer to finalise paperwork
for a loan. The customer does not have payslips to support
Fair competition their income which Olivia knows will be a problem in
You must never engage in collusive behaviour with our getting the loan approved. Olivia has known the customer
competitors. You must act in a way that ensures NAB competes for a long time and believes there won’t be a problem
freely and fairly, abiding by the laws and regulations which with them being able to afford the repayments. Olivia
apply in all regions in which we operate. wants the customer to get the loan so she makes up
some payslips to put with the loan documents. The loan is
approved however three months later the customer is in
default as they cannot afford the repayments. A review of
7. PREVENTION OF FRAUD AND CORRUPTION the file identifies the fake payslips and that the customer
was put in financial difficulty due to being granted a loan
We are all responsible for the prevention of fraud
they could not afford. Olivia’s employment is terminated.
and corruption.

Fraudulent or corrupt activity involves dishonest actions, or

dishonestly failing to act, that cause actual or potential financial
loss, or an unjust advantage. This includes: Emma takes a shortcut
Emma is completing a loan for a customer. When putting
• Theft of money, data or property the documents together Emma realises the customer
• Deliberately falsifying, concealing or destroying documents did not sign a section of the consent form. Emma tries
• Acts of bribery to contact the customer to arrange them to sign the
document however she cannot reach them. Emma
Products and services must not be made available if you knows that by not having the form finalised the loan
become aware, or have reason to suspect, they will be used will be delayed. Not wanting to cause a problem for the
for criminal or illegal activity. If you suspect fraud or corrupt customer, Emma scans the customer’s signature from
activity may be occurring, or you are pressured by a customer another document and pastes it into the form with the
or colleague to depart from our policies/procedures, tell your missing signature.
people leader or report it through the Group Whistleblower
Whilst Emma was trying to ensure a good experience
Program via the FairCall service.
for the customer, she has created a false document.
Failure to report fraud or corruption may be regarded as Emma’s employment was terminated.
seriously as the fraud itself.


 We manage conflicts of interest

8. CONFLICTS OF INTEREST AND RELATIONS WITH CUSTOMERS AND/OR THIRD PARTY PROVIDERS
You must conduct business in a way that ensures customers make donations or contribute funds to any political party,
are treated fairly and that you help safeguard market integrity. Parliamentarian, elected official or candidate for political office.
NAB’s commercial interests and your personal interests must
be managed so not to compromise your ability to make sound, Employees may participate outside of work as an individual in
objective business decisions. You must understand and comply the political process provided it is made clear they are not acting
with the Conflicts of Interest Policy. on behalf of or representing NAB.

Conflicts of interest Colin’s conflict of interest

You must always exercise caution in your commercial and Colin, a Banker, was also Treasurer of his local cricket club.
personal relationships with customers, colleagues, product At that time, the club was seeking to obtain a loan to
providers and others to ensure they do not involve obligations build new clubrooms. Despite Colin’s apprehension about
that may prejudice or influence your business relationship the ability of the club to meet the loan commitments,
or conflict with your duties. he reluctantly approved the loan. Shortly after, the club
experienced some liquidity problems and was unable to
Conflicted remuneration meet the loan repayments. Sadly the Club had to be wound
up which had an impact on the local community. Colin’s
If you advise on financial products or sell, refer with information conduct also resulted in a large loss for NAB.
or deal in life insurance products, you must ensure you do not
accept a benefit in connection with that advice, sale, referral After a thorough investigation into the matter it was found
with information or dealing, that does not comply with NAB that Colin had misused his position of responsibility, which
Group policies on remuneration and benefits. Consult with your constituted a conflict of interest and a breach of the Code of
people leader if unsure. Conduct. Colin’s employment was terminated.

Participating in outside business interests

and outside employment All expenses paid
Jack, a Relationship Manager, accepted an all expenses paid
If you participate in non-NAB business ventures or employment, trip offered by a customer, the value of which was likely to
speak with the person responsible for personal conflicts of interest amount to several thousand dollars. Jack did not disclose the
management in your business area. If you are involved in voluntary gift to his people leader, Ryan. On his return from the trip,
activities, and you believe these activities may lead to a conflict Jack was approached by Ryan, who had been informed that
of interest with your work, before you participate consult your the trip had been funded by a customer.
people leader and the person responsible for conflicts of interest
After a thorough investigation, Jack’s employment was
for your business area or email the Control Room.
terminated. The acceptance of such a gift could be
If you make important purchasing decisions for NAB and people reasonably perceived as having the potential of unduly
close to you (e.g. partner, relative or friend) have an interest influencing Jack or creating a business obligation.
in, or are the actual suppliers of, the goods and services being When you are offered, or wish to provide a gift you must
purchased, you must advise your people leader or the person discuss the details of the proposed gift with your people
responsible for personal conflicts of interest in your business leader. Gifts of a determined value are required to be
area and document in the Gifts, Entertainment & Personal entered into the Gifts, Entertainment & Personal Conflict of
Conflict of Interest Register or with the Control Room. Interest Register.

Benefits, gifts and entertainment

You must exercise care in the giving and receiving of business- Natalie’s broking business
related benefits, gifts or entertainment to/from potential and Natalie, a NAB Banker with responsibility for loan approvals,
existing customers and product providers and obtain approval had a financial interest in an external broking business which
from your people leader above specified threshold values. introduced potential borrowers to financial institutions,
including NAB.
You are responsible for identifying personal or business
circumstances that may give rise to potential, actual or perceived On occasion, Natalie would refer customers to the broker
Conflicts of Interest and for recording those details in the Gifts, company explaining their loan was more likely to be
Entertainment & Personal Conflict of Interest Register. approved if the application was made through the broker.
At other times, instead of suggesting the customer apply
Charitable donations through the broker, she would simply note on their
application the customers had been referred to NAB through
You must obtain approval for any donations, sponsorships or the broker.
charitable contributions you accept from, or give to, a third
party on behalf of NAB and record these appropriately. Natalie’s people leader, Wendy, became aware of these
practices and a full investigation was conducted. It was
Political donations found Natalie’s actions were a clear conflict of interest
and a breach of the Code of Conduct resulting in the
In line with our Group Political Donations Policy and termination of her employment.
Political Contact & Communications Policy NAB does not

We meet our legal and regulatory obligations, voluntary commitments and internal standards

9. COMPLYING WITH LEGAL AND REGULATORY OBLIGATIONS, VOLUNTARY COMMITMENTS

AND INTERNAL STANDARDS
You must comply with all laws, regulations and voluntary Breaches may include:
codes that are applicable to NAB, including laws, regulations
• Failure to give priority to the interests of the customer over
and codes that are applicable to NAB as a financial services
your or NAB’s interests
and credit provider and laws and regulations relating to
competition. Failure to meet our legal and regulatory • Providing credit advice or recommendations to a customer
obligations can impact our customers, and our credit and/or which are unsuitable for their needs
financial services licences and/or result in penalties. You must • Failure to report cash transactions of $10,000 or greater or
also comply with NAB’s internal policies and processes, which matters that you believe are suspicious or unusual
often exceed standards expected by law, as they take into
• Providing advice or recommendations to customers when
account our voluntary commitments which guide our approach
you are not trained or authorised to do so
to responsible business.
• Failure to disclose and document all conflicts of interest, gifts
Our compliance procedures and training protect our customers, & entertainment and personal shares/securities trading as
you and our organisation. required and in line with policy and industry standards

You must immediately report any suspected, potential or • Failure to identify, record, escalate and manage events to
actual non-compliance to your people leader, divisional reduce the risk of reoccurrence. This includes failure to
compliance team or the Group Whistleblower Program via complete remedial actions by the due dates
the FairCall Service. • Acting outside your authorisations on behalf of NAB or
your business unit, including Governance and Investment
Committees of which you are a member
• Failing to complete and close out any audit issues assigned
to you by the due date
• Non completion of assurance and declaration questionnaires
in an honest and timely manner
• Accepting a conflicted remuneration benefit
• Not completing mandatory risk training by the due date
• Failure to maintain a customer’s confidentiality, especially
if they have advised they are experiencing domestic and
family violence.
People leaders must ensure their employees are aware of,
and have met, their compliance requirements. Any instances
of non-compliance must be addressed in a timely manner.
People leaders are reminded that their own Conduct Gate may
be impacted where they do not appropriately manage a breach
of the Code by one of their team members.


 We adhere to confidentiality and privacy requirements

10. MARKET INFORMATION

You may obtain sensitive information about NAB or another
company that is not generally known to others. The receipt of William’s inside information
all confidential information by NAB must be carefully managed
William purchased shares in a company he knew would
in order to comply with laws and policy, and to preserve market
be the subject of a takeover. As a result of the takeover,
integrity. This includes storing the information so that only
it was expected the share price would increase rapidly
those who are required to use it may do so.
and significantly. William knew this information because
Confidential information must only be used for the purpose for he worked with NAB.
which it is supplied and in accordance with law. Following the takeover, William sold his shares, making
a healthy profit. Aware of the inappropriate nature of his
It is a criminal offence to trade stock or encourage another
activities, William also took steps to conceal his actions.
person to trade or to tip a person off in relation to market
listed shares or other securities or debt instruments if you have However, William’s activities were identified by the
information not publicly known that could affect the value of Regulator and, following a thorough investigation,
those shares or securities. he was charged with offences under the Corporations
Act relating to the use of inside information and
The Group Securities Trading Policy requires us to comply with consequently found guilty of the charges laid against
the law and to be beyond reproach when: him. William’s employment was terminated, he
was required to forfeit the benefits obtained and
i. d
 ealing with information relating to NAB and other
subsequently sentenced to a term of imprisonment.
entities we deal with, and
ii. trading in NAB or other securities

This policy prohibits insider trading and requires adherence to

blackout period restrictions including not trading before half and Franco checks before trading
full year results. During these periods you or your immediate
Franco is on leave and decides he wold like to sell
family are not permitted to trade in NAB securities. It is your
some NAB shares to cover the costs of renovations
responsibility to be aware of blackout periods and your
he is completing. Before trading, Franco remembers
obligations during this time.
reading somewhere that he is not allowed to trade
The Conflicts of Interest Policy also precludes the trading of during blackout periods, as there are restrictions for
non NAB securities when in possession of inside information. employees. Franco is not sure when the blackout
period is and decides to call his people leader to check.
Franco’s people leader lets him know that a blackout
Any allegation of misuse of confidential information,
period is in place and therefore cannot trade.
including inside information, will be thoroughly
investigated by NAB. Schemes to avoid detection, Had Franco not checked and traded during the blackout
such as passing the information to friends or relatives period, he would still have been accountable even if he
for them to undertake unlawful trading, will be could not remember his obligations. If Franco had traded,
discovered in such an investigation. Such offences can consequence management would have applied, including
be found to be in breach of the Code of Conduct and the application of a Conduct Gate.
could possibly lead to criminal charges.


11. CONFIDENTIALITY, ACCESS AND Omar sends confidential material home
DISCLOSURE Omar has been offered a role externally and is planning
You may have access to confidential information regarding to tell his people leader he will be finishing up at NAB.
customers, suppliers, your colleagues and our business affairs. He is really proud of the work he has done at NAB and
wants to use the templates and content he developed
Your access and use of this confidential information is limited in his future role. Omar decides to send multiple files,
to work-related tasks. Access, use of, or disclosure for any other including papers and presentation packs he had put
purpose is prohibited without proper authorisation, unless together to his personal email address so he can refer
required by law. You must not send any of NAB’s confidential to these once he has left NAB.
information (including customer information) to your personal
Sending this material was identified as part of NAB’s
email address.
regular surveillance checks and his people leader was
Our internal systems must not be used to access your own advised. Given the confidential nature of the material
personal customer profile or those of your family, friends, and the number of files sent, Omar’s employment was
colleagues or public figures. Our standard customer channels terminated.
must be used by you and your family and friends for
banking arrangements.

Personal information is any information or opinion about A footy fanatic

individuals, including customers and contractors (whether
Lachlan, a Customer Adviser with an interest in football
true or not), whose identity is apparent or can reasonably be
would access the address details and account types of
ascertained from that information or opinion. This information
his favourite footballers and openly share the details
must only be viewed, collected, used, disclosed, updated,
with other staff. A colleague was concerned about
stored securely and destroyed in accordance with the Privacy
Lachlan’s actions and reported the behaviour to her
Act 1988 (Cth) [Privacy Act].
people leader.
If you suspect that personal information is being misused, Lachlan’s employment was terminated for accessing
you must advise your people leader or report it through the and disclosing the customers’ personal and confidential
Group Whistleblower Program via the FairCall Service. information for non-work related purposes in breach
of NAB’s Information Risk Policy, obligations under the
Privacy Act and our Code of Conduct.
NAB has made certain commitments to our customers
and others to protect their personal information.
These commitments are set out in the NAB Privacy
Policy and Privacy Notification.
Sam’s inappropriate access
The Information Risk Policy applies to all employees Sam, a Mobile Banker, was in a personal relationship
of NAB and explains how employees must comply with Sarah which ended badly. At the time of the
with privacy and data protection obligations. relationship breakdown, Sarah owed Sam a large
amount of money and it was agreed she would repay
him an amount each week.
Sam was unhappy as Sarah stopped making payments
due to having financial problems. Sam wasn’t convinced
Sarah was experiencing any financial problems and used
NAB’s systems to look at Sarah’s accounts. Sam then
called Sarah to demand that she make payment or
he would commence legal proceedings against her.
Sarah raised a complaint about Sam’s inappropriate
access of her accounts. Sam’s employment was
terminated for breaching the Code of Conduct.


 We deal with, and report on, suspected breaches

12. CONSEQUENCES OF BREACHING THE CODE OF CONDUCT

Our Code includes particular examples of misconduct identified
by NAB; however, it does not cover every situation you may
encounter while you work at NAB.

A relationship based on trust is important. All suspected

breaches of our Code will be thoroughly investigated, by
your people leader, supported by relevant specialist areas.

If these investigations reveal breaches, appropriate disciplinary

and remedial action will be taken. This may range from providing
training, coaching and counselling, impacting your performance
review, through to reduction or loss of variable reward
payments to which you may be eligible, formal warnings
or termination of employment. We will also comply with
our obligations to notify the appropriate authorities where
breaches of the law have been identified.

Any employee’s breach of the Code or our policies will

be managed in accordance with the Employee Conduct
Management Policy.

The scenarios provided in the Code of Conduct

are examples only. Each situation will be assessed
in terms of the particular circumstances and facts.
Appropriate action will be taken by NAB after
consideration of all relevant details.


NATIONAL AUSTRALIA BANK LIMITED POLICY DECLARATION
I,

fully understand the standards of responsibility and ethical

conduct outlined in the Code of Conduct and related policies
which are expected of me when working on behalf of NAB.

I understand that my people leader or Employee Relations via

the People Advisory Centre are available to answer any queries
I have and/or have satisfactorily addressed any queries that I
have raised.

While I work at NAB, I will ensure that at all times I adhere

to the standards and policies required by NAB.

I am fully aware that my employment may be reviewed and

disciplinary action may be taken should I not adhere to
these requirements.

Employee Number

Employee Name

Signed

✕
Date

/ /


©2019 National Australia Bank Limited ABN 12 004 044 937 AFSL and Australian Credit Licence 230686 A133511-0219 