It is recognised that bribery and corruption have an adverse effect on communities wherever they occur. If endemic, they impede economic growth and undermine accountability, threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, on occasions, the financing of terrorism.
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 Anti-Bribery and Corruption Policy supports our zero tolerance approach to bribery and corruption.
Our policy serves as a single and consistent anti-bribery and corruption standard across the 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 of a bribe or facilitation payment are expressly prohibited
Training and awareness about our zero tolerance for bribery and corruption is conducted across the Group
All senior managers in the Group are committed 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 Speak up (“whistleblowing”) hotline available for any concerns to be raised
Due diligence is 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 and third parties
Note: third parties are defined as entities or individuals under contractual arrangements with the Group, such as but not limited to 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 Commonwealth Bank Group 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.
We are committed to embedding a culture of speaking up.
Our Speak Up hotline is available to any employee who wishes to raise a concern. Reports can be made in confidence and without fear of reprisals via a dedicated telephone number or email address. All reports raised are taken seriously and where appropriate, investigated in more depth. No employee is discriminated against in any way as a result of reporting a concern in good faith.
We have policy and procedures to ensure that reports are treated with appropriately and that the employee raising the concern is protected.