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Speaking up

We place 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. 

This doesn’t just apply to our employees – we have 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 Commonwealth Bank Group (the Group) who wishes to raise a concern about any reportable conduct.

We encourage everyone who works with the Group to speak up, and we provide them with trusted avenues to go to if they want to raise a concern. This could be as simple as one of our employees having an informal discussion with their manager, or through to using the formal channels we have set up to make speaking up simpler.

The Board and senior management encourage people to speak up and report any conduct they believe to be inappropriate; and have put in place processes to provide the appropriate support to those who raise concerns. Identifying potential problems and risks allows the bank to continue to improve the way it does business and provide the best possible service to customers.

The Group Whistleblower Policy defines what type of conduct can be reported. This includes actions which are:

  • Dishonest
  • Fraudulent
  • Corrupt
  • Illegal
  • In breach of legislation
  • In serious breach of internal policy
  • Unethical
  • Improper
  • Bullying and harassment
  • Unsafe work practices
  • Any other conduct which may cause financial or non-financial loss to the Group or be otherwise detrimental to the interests of the Group and its customers, including environmentally unsound practices.

Importantly, the conduct of third parties, such as a supplier or a service provider, is also reportable. By the same token, channels are also available for certain third parties to report concerns they may see in their interactions with the Group.

Group Whistleblower Policy

Sometimes individuals speaking up or making a disclosure may be concerned about being identified, or any potential repercussions which may come from reporting the conduct. This is why we have a comprehensive Group Whistleblower Policy. When contacting the SpeakUP Hotline, eligible persons can elect to be treated as a Protected Person, meaning that their concerns will be managed through the processes outlined in the Group Whistleblower Policy.

Our 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 the regulator at any time.

The Group has a Whistleblower Protection Officer, whose role it is to oversee the protection of whistleblowers as part of the Group’s policies. The Group also has a Misconduct Governance Committee, which includes senior executives who report to the CEO, to oversee the effectiveness of the whistleblower program.

In March 2017, the Group enhanced the Group Whistleblower Policy including to make it simpler to use and more easily available. An important part of this was broadening the scope of eligible persons who can report concerns as a whistleblower, which now includes individuals outside, but associated with the Group, such as suppliers, contractors, consultants, secondees, brokers, auditors and former employees.

The updated policy has been approved by both the Executive Committee and the Board and aligns to the Australian Bankers’ Association’s “Guiding Principles – Improving Protections for Whistleblowers”, in addition to other relevant requirements. The Guiding Principles are part of the ABA’s Better Banking program, and ensures that all banks’ whistleblower policies meet the highest standard.

How do individuals get in touch?

There are a number of ways our people and others associated with the Group can report any concerns about conduct they believe doesn’t feel right. These include:

  • Our people having a conversation with their Manager
  • Speaking with a senior leader at General Manager level or above if they wish to report concerns under the Group Whistleblower Policy
  • Contacting the Group’s SpeakUP Hotline if they are uncomfortable going through internal channels, or would like to report concerns anonymously or under the Group Whistleblower Policy
Read a summary of the Group Whistleblower Policy

Related information

Our anti-bribery and corruption policy supports our zero tolerance approach to bribery and corruption.

Learn more

Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) program sets out how the Group identifies, mitigates and manages money laundering and terrorism financing risk.

Learn more

Read about our sustainability initiatives, focus areas and performance in the 2012-2013 financial year. 

Learn more