You can read about what we are doing to bring this commitment to integrity to life in:
- Our corporate governance statement, which outlines the key aspects of the Commonwealth Bank’s corporate governance framework
- Our risk management framework and governance processes, also available in the latest Annual Report
- Our shareholder communication processes, which fully informs shareholders and the market about the Group’s activities and disclosures
- Our Code of Conduct, which sets out expectations for how we act, solve problems and make decisions
- Our anti-bribery and corruption policy and framework outlines the zero tolerance for bribery, corruption and facilitation payments and which extends to all employees, directors, contractors and suppliers who are working on behalf of the Group
- Our speak up program for our employees, service providers and suppliers to report concerns about unethical behaviour and corruption
CBA has acted to strengthen its anti-financial crime compliance programme and has invested significantly to ensure that it identifies, mitigates and manages financial crime risk across all business units and countries in which it operates. CBA continues to uplift its processes for monitoring, managing, reporting and controlling financial crime across all of its operations to ensure increased confidence in managing this area of risk.
CBA continues to work with AUSTRAC and other financial crime regulators to help protect the integrity of the Australian financial system.
- Anti-Money Laundering and Counter Terrorism Financing: We have adopted a Group AML/CTF Policy and Joint AML/CTF Program that sets out the Group’s AML/CTF compliance programme, in particular, how the Group identifies, mitigates and manages money laundering and terrorism financing risk
- Anti-Bribery and Corruption: We have zero tolerance for bribery, corruption and facilitation payments and all employees, contractors and suppliers are expected to act with integrity
- Economic and Trade Sanctions: Our Economic and Trade sanctions policy outlines the principles and measures we follow to ensure compliance with the requirements of different sanctions regimes
- Fraud: We do not tolerate fraud and we are committed to promoting and maintaining a sound, ethical culture
- FATCA: We are aware of our obligations under the US Foreign Account Tax Compliance Act (FATCA) and have taken steps to comply
- Our speak up program encourages employees, service providers and suppliers to report concerns about bribery and corruption and other unethical behaviour
- Commonwealth Bank Board policy explicitly precludes the Group from making political donations
- Donations must not be made to any political party on behalf of the Group
- There are some political events (e.g. party conferences) that cater for the attendance of business observers, which Group staff may attend
- The Group discloses the costs of attendance to the relevant Commonwealth and State electoral agencies on a regular basis
The Group has a broad range of diverse suppliers which presents a great opportunity to grow our social procurement commitments, supporting our suppliers and communities. We are building strong foundations which include:
- A commitment to responsible procurement practices within our supply chain through all competitive tenders
- Ensuring our suppliers are assessed and selected on criteria such as WH&S, commitment to Indigenous Australians and environmental performance
- Running competitive tenders through our centralised procurement system to assess sustainability
The Group also has a Procurement Policy requiring all employees to adopt strategies to avoid unnecessary consumption and manage demand as well as support suppliers who are socially responsible and adopt ethical practices.
We work with suppliers to remedy any minor issues identified during the compliance and audit process, however we will not use suppliers who do not meet minimum labour standards and health and safety requirements.
The Group is proud to be a founding member of Supply Nation (formerly AIMSC), a not-for-profit membership body supporting small-to-medium Indigenous suppliers. We work collaboratively with Supply Nation to help build capacity amongst Indigenous businesses, by:
- Including Indigenous suppliers on our preferred supplier list, and promoting these to Group employees
- Encouraging our suppliers to support Indigenous Australians by including a ‘Commitment to Indigenous Australians’ tender schedule in all formal tenders
- Mentoring Indigenous businesses
- Connecting Indigenous suppliers with larger organisations in our supply chain
