Why Anti-Bribery and Corruption is important to us

Our purpose is to improve the financial wellbeing of our customers and communities. We expect at all times our people to behave in a manner consistent with our values expectations: we do what is right, we are accountable, we are dedicated to service, we pursue excellence and we get things done. We recognise that behaviours that lead to bribery and corruption have an adverse effect on communities wherever they occur. That’s why we have zero risk appetite towards bribery, corruption and facilitation payments across all parts of the Commonwealth Bank Group. 

Scope of this policy

This policy applies to the Commonwealth Bank of Australia and its controlled entities in Australia and overseas (the Group). It is applicable to all directors, employees, temporary staff, contractors, suppliers, service providers, agents and other third parties acting for or on behalf of the Group. 

About 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, investment and share-broking.

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). 

Understanding and managing our exposure to bribery and corruption risks

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 implement controls to manage those risks. Monitoring of key risk indicators and an assurance program to test the ongoing effectiveness of the control environment must also be applied. 

Transparency in our dealings

The Group is committed to transparency in all its dealings. This includes transparency in managing actual, potential or perceived conflicts of interest, 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. All records of financial and non-financial dealings must be appropriately maintained, accurate and protected against dishonest use or loss of integrity.

Knowing our partners

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. 

Knowing and training our people

The Group’s hiring processes require that due diligence be conducted on all prospective and existing employees, including contractors and temporary employees. All employees also undertake mandatory training on this policy. Employees in high risk roles undertake further training on anti-bribery and corruption measures. 

Communicating our commitment

The Group’s business units and subsidiaries are required to comply with this policy. This commitment applies from the top down. The Group’s Code of Conduct sets the standards of behaviour, actions and decisions expected of our people. It connects our purpose, values expectations and key Group policies, including this policy, to help us deliver the right outcomes for all our stakeholders. A breach of the Code is serious and may have various consequences, including disciplinary action and dismissal.

Speaking up

The Group places great importance on fostering a culture that encourages employees and others to speak up about issues or conduct that concerns them. This could be anything from serious misconduct to noticing something which just doesn’t feel quite right. Our people are regularly encouraged to speak up on any issues of concern through ongoing internal communications and training.

The Group Whistleblower Policy is designed to encourage and support individuals to report issues, knowing that it is safe to do so and that they will receive support. Individuals are also free to make a disclosure directly to our regulators at any time. The Group Whistleblower Policy aligns to the Australian Bankers’ Association’s “Guiding Principles – Improving Protections for Whistleblowers”, in addition to other relevant requirements.

Notifying us of bribery, corruption or other unethical behaviour

The Group has a dedicated SpeakUP Hotline, which is a service that is available to any director, manager, employee (current and former), contractor, consultant, supplier, service provider, secondee, broker or auditor of the Group who wishes to raise a concern about any reportable conduct.

The SpeakUP Hotline can be contacted by: