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Anti-Bribery and Corruption Policy

Our vision is to excel at securing and enhancing the financial wellbeing of people, businesses and communities. We expect at all times our people to behave in a manner consistent with our values of integrity, collaboration, excellence, accountability and service. We recognise that behaviours that lead to bribery and corruption have an adverse effect on communities wherever they occur. That’s why we have a zero tolerance to bribery, corruption and facilitation payments across all parts of the Group. 

This policy applies to all businesses within the Group, including subsidiaries and joint ventures where the Group has a controlling interest, in Australia or overseas. It is applicable to all directors, employees, temporary staff, contractors, suppliers and service providers. 

The Commonwealth Bank Group (the Group) is Australia’s leading provider of integrated financial services with established businesses in Australia, New Zealand, Europe, USA and the Asia-Pacific region. Our products and services include retail banking, premium banking, business banking, institutional banking, funds management, superannuation, insurance and investment.

Our brands include Commonwealth Bank, Colonial First State, Colonial First State Global Asset Management, First State Investments, CommInsure, CommSec, Bankwest, ASB, Sovereign, PT Bank Commonwealth, PT Bank Commonwealth Life and PT First State Investments Indonesia.

For more information about the Group, including a complete list of material Group members, see our latest Annual Report, available through the CommBank website (search on Annual Report). 

The Group’s business units and subsidiaries are required to consider and understand the risk of bribery and corruption throughout their operations. Through risk and control assessments, all parts of the Group must identify bribery and corruption risks and the controls that are applied to those risks. Monitoring of key risk indicators and an assurance program to test the ongoing effectiveness of the control environment must also be applied. 

The Group is committed to transparency in all its dealings. This includes transparency in managing actual, potential or perceived conflicts of interests, and transparency in our dealings with our customers. Transparency also extends to the way in which we manage relationships with people who are politically exposed, our recruitment and remuneration processes, and our dealings with regulators.

The Group’s business units and subsidiaries must know who they are doing business with and who is conducting business on their behalf. All parts of the Group must conduct appropriate due diligence prior to engaging contractors, making donations, entering into business relationships with, or acquiring other entities. The Group’s business units and subsidiaries must ensure that gifts and entertainment, payments to contractors or payments for other goods and services are proportionate, appropriate and in line with market rates. 

The Group’s business units and subsidiaries are required to comply with this policy. This commitment applies from the top down. A Statement of Professional Practice has been established and applies across the Group. This Statement must be adhered to by all staff. A breach of the Statement constitutes misconduct and employees may face disciplinary action, including termination of employment and/or legal action.

All Group employees are required to undertake mandatory training on this policy. In addition, there is a requirement for high risk roles to undertake further training on anti-bribery and corruption measures. 

The Group is committed to maintaining an ethical work environment and embedding a culture of “speaking up”. Our SpeakUP Hotline is available for any employee, temporary staff, contractor, supplier or service provider to raise a concern relating to any suspicion or act of unethical behaviour, via a dedicated telephone number or email address.

Our Whistleblower Protection Policy and procedures ensure that reports are treated appropriately and that the person raising the concern is protected. It reinforces the message from the Group’s senior management and Board that those making a disclosure can trust the matter will be dealt with honestly, professionally and confidentially.

The policy complies with the Australian Standard AS 8004-2003 - Whistleblower Protection Program for Entities, and ensures that any person making a disclosure is not personally disadvantaged or discriminated against.

Also, through ongoing internal communications and training, our people are regularly encouraged to report any suspicions or incidents of unethical behaviour and speak with their line manager should they have any concerns.

Service providers, suppliers and their employees with information relating to any suspicion or act of unethical behaviour by Commonwealth Bank staff should report the issue to the SpeakUP Hotline on: