Whistleblower Policy Aims for Fair Treatment of Individuals

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ANZ has implemented a whistleblower policy designed to ensure fair treatment of individuals involved in reports of misconduct. The policy guarantees that all reports will be handled confidentially and sensitively, with respondents having an opportunity to respond to allegations before any adverse findings are made.

Reporting Process

The Whistleblower Protection Officer (WPO) receives reports and protects the interests of reporters. Reports may involve individuals who have not yet come forward as whistleblowers, known as “Other Eligible Recipients” (OER). The WPO assesses each report to determine whether it falls within the scope of the policy and whether an investigation is warranted.

Key Steps in the Reporting Process:

• Receipt of reports by the WPO
• Assessment of reports by the WPO to determine scope and necessity of investigation
• Protection of reporter’s interests

Investigation Process

If a report is deemed worthy of investigation, a Whistleblower Investigator (WI) is appointed. The WI maintains confidentiality throughout the investigation process, gathering evidence and interviewing witnesses as needed. The investigator provides regular updates to the WPO on progress and draws conclusions based on an objective assessment of the evidence.

Key Steps in the Investigation Process:

• Appointment of Whistleblower Investigator (WI)
• Gathering of evidence and witness interviews
• Provision of regular updates by WI to WPO
• Objective assessment of evidence

Recommendations and Disciplinary Actions

The WI makes recommendations for disciplinary actions or contractual actions with respect to respondents, as well as steps to stop, prevent, or mitigate future misconduct. The WPO reviews these recommendations before presenting them to management or relevant authorities.

Key Steps in the Recommendation and Disciplinary Action Process:

• Preparation of recommendations by WI
• Review of recommendations by WPO
• Presentation of recommendations to management or relevant authorities

Training and Support

All employees involved in the whistleblower process receive training on their roles and responsibilities. The Whistleblower Program Team (WP Team) provides support and advice to OERs, First Line Risk Owners, and Business Governance and Controls staff throughout the reporting and investigation processes.

Key Steps in the Training and Support Process:

• Provision of training to employees involved in whistleblower process
• Provision of support and advice by WP Team

Reporting Requirements

The WP Team reports regularly to the Chief Compliance Officer on active reports, including de-identified details of reports made and actions taken. Quarterly reports are also submitted to the ANZ Board Ethics, Environment, Social and Governance (EESG) Committee and bi-annually to the Operational Risk Executive Committee (OREC).

Key Reporting Requirements:

• Regular reporting to Chief Compliance Officer
• Quarterly reporting to ANZ Board EESG Committee
• Bi-annual reporting to OREC

Annual Review

The Whistleblower Policy is reviewed annually by the WP Team to ensure its effectiveness and compliance with relevant laws and regulations. The review process includes assessments of training programs, reporting requirements, and investigation procedures.

Key Steps in the Annual Review Process:

• Review of policy by WP Team
• Assessment of training programs, reporting requirements, and investigation procedures

Conclusion

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ANZ’s whistleblower policy aims to create a culture of transparency and accountability within the organization. By providing a safe and confidential channel for reports of misconduct, the policy promotes ethical behavior and encourages employees to speak up when they witness wrongdoing.