Corporate Governance

The Group's internal management is governed by the Company's constitution (PDF, 237KB).

All NAB directors are expected to bring independent and unfettered judgement to Board deliberations. To qualify as ‘independent’, a director must be independent of management and free of any business or other association that could materially interfere with the director’s exercise of unfettered and independent judgement with respect to issues before the Board, and to act in the best interests of NAB and its shareholders.

In considering the independence of each director, the Board takes into account the factors outlined in the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations (3^rd edition).

The Board conducts regular (at least annual) reviews of the independence of each of the directors. Directors are expected to volunteer information as and when changes occur, and each non-executive director is required to make an annual disclosure to the Board of all relevant information.

To further assist in ensuring that the Board operates independently of management, non-executive directors meet in the absence of management at each scheduled Board and Committee meeting.

All non-executive directors of the Board are considered to be independent, as identified in the Report of the Directors in our 2018 Annual Financial Report.

For more information on the Independence Standards (part of the Board Charter) that are considered when assessing Director independence, see the Independent Director Standards (PDF, 49KB).

To assist in carrying out its responsibilities, the Board has established standing Board committees that cover each of Audit, Remuneration, Risk, and Nomination and Governance matters. Other committees are created, with specific remits, as and when required.

Board committees and their respective charters which include information on the composition, responsibilities and administration of each committee are set out below:

• Board Risk Committee Charter (PDF, 89KB)
• Board Audit Committee Charter (PDF, 125KB)
• Board Remuneration Committee Charter (PDF, 126KB)
• Board Nomination & Governance Committee Charter (PDF, 71KB)
  
• Board Customer Committee Charter (PDF, 85KB)

• Code of Conduct
• Code of conduct- NZ (PDF, 3.3MB)
• Code of conduct- UK (PDF, 6MB)
• Group Securities Trading Policy (PDF, 200KB)

We aim to be open and transparent with all stakeholders and we are committed to disseminating information to stakeholders in a fair, timely and cost-efficient manner.

The Group has adopted a disclosure policy that is designed to:

• ensure we comply with our legal and regulatory obligations; and
• promote investor confidence by ensuring that trade in our securities takes place in an informed market.

We will immediately notify the market on becoming aware of any information related to our businesses which a reasonable person would expect to have a material effect on the price or value of our securities. We do this by announcing such information to the relevant stock exchanges on which our securities are listed.

In certain limited circumstances, the applicable listing rules permit the Group not to disclose such market sensitive information. Our policy also provides that, in general, the Group will not respond to market speculation or rumours unless required to do so by law or the Australian Securities Exchange (ASX).

Where appropriate, we may request a trading halt from the ASX to prevent trading in the Group's securities by an inefficient and uninformed market.

The Chief Legal and Commercial Counsel is responsible for all communications with the relevant stock exchanges on which the securities of the Group are listed. All releases to the ASX are made available on our website.

For more information see the Group Disclosure & External Communication Policy (PDF, 158KB).

The Group aims to be open and transparent with all our stakeholders, including our shareholders, and to make all communications easy to access and in plain English.

Information is communicated to shareholders regularly through a range of forums, publications and online. These include:

• the Annual General Meeting
• notices and explanatory memoranda of Annual General Meetings
• the Annual Financial Report (for those shareholders who have requested a copy)
• the Annual Review (for those shareholders who have requested a copy)
• regular trading updates and market/investor briefings
• letters from the Chairman to inform shareholders of key matters of interest
• the Group's website, providing access to announcements, media releases, financial reports, previous years' financial results and investor presentations.

The Notice of Annual General Meeting (AGM) provides details of the location, time and date of the AGM, the business to be considered by shareholders and details about each candidate standing for election or re-election as a Director. For those shareholders unable to attend the AGM, a webcast is available on our AGM page. Our external auditors attend this meeting and are available to answer shareholder questions about the conduct of the audit and preparation and content of the auditor's report.

Our AGM page also includes responses to questions taken on notice at the AGM.

Creating an inclusive workforce is fundamental to maximising diversity and succeeding in today’s complex global environment. Our workforce should reflect our customers and the communities in which we operate. At NAB, diversity of thought, background and experience is respected, valued and promoted. The Board approved the enterprise Diversity & Inclusion Strategy (the Strategy) for 2017-2020.

The Strategy is directly aligned to our business strategy to ensure the evolving needs and expectations of our customers, people, shareholders and the community are acknowledged. The overarching priority of the Strategy is inclusion. The three imperatives of

the Strategy are:

• Gender equality.

• Life stage inclusion.

• Lesbian, gay, bisexual, transgender and intersex (LGBTI+) inclusion.

We are also focused on cultural inclusion and improving accessibility for our people and our customers. The three imperatives are underpinned by three key enablers:

• Leadership.

• Flexibility.

• Employee Resource Groups.

Through the inclusion measure in our annual employee engagement survey, 74% of our people told us that they experience an inclusive workplace, a 2% increase from 2018. Our aim is to reach 77% or higher, which represents the top quartile of organisations in Australia.

NAB’s Executive Leadership Team has direct accountability for the execution of the Strategy, and for actively promoting a culture that builds a diverse and inclusive workforce that will drive innovation, engage our people, build productivity and ultimately result in a great customer experience.

The Board receives an annual update on diversity and inclusion from senior leaders and regular updates on performance against the Strategy’s measurable objectives for achieving gender diversity. In August 2019, the Board approved an updated Group Diversity & Inclusion Policy. The Group Diversity & Inclusion Policy includes a requirement for the Board to set measurable objectives for achieving gender diversity and to assess, at least annually, the objectives and the progress towards them. These measures satisfy Recommendation 1.5 of the ASX Corporate Governance Principles.

The NAB Diversity & Inclusion Steering Committee, led by our Chief Legal and Commercial Counsel and our Group CFO, champion and enable the Strategy at a Group and divisional level, by being a voice for inclusion at NAB and by removing barriers to drive equality. The committee includes senior representation from each business area and our four employee resource groups.

Our 2020 Objectives

Gender equality remains a key priority for NAB. From our Board through to our entry level roles, we are striving for every level to have 40-60% of either gender represented by 30 September 2020. ‘Towards 2020: NAB’s road to gender equality’ outlines how we plan to achieve this, and is published in the Gender Equality section of our website. The Board has approved measurable objectives for achieving gender diversity for 2018, 2019 and 2020. Our progress during 2019 towards achieving our measurable objectives is set out below.

Despite an increase in representation of women in our senior levels of the bank, we have not met our 2019 targets. This is a concern for NAB’s Executive Leadership Team and the Board and we remain committed to our 2020 goal for achieving gender equality at every level

of the business. In 2019, we have continued our focus on lifting female representation at every level. Some of the initiatives that will occur in 2020 include:

• Increasing senior leadership accountability for achieving NAB’s gender equality targets through continued emphasis on gender diversity in senior leaders’ 2020 performance goals.

• Encouraging participation in our Breakthrough development programs for women.

• Striving to have women equally represented during our talent assessment process.

We are also committed to ensuring equal pay for work of equal value, and reducing the gender pay gap. NAB has complied with our reporting requirements under the Workplace Gender Equality Act 2012 (Cth) for the period from 1 April 2018 to 31 March 2019 (PDF, 422 KB) and has achieved the 2018-2019 Workplace Gender Equality Agency Employer of Choice for Gender Equality citation. NAB has also met the minimum standards in relation to specified gender equality indicators, as set out in the Workplace Gender Equality (Minimum Standards) Instrument 2014.

1 NAB’s 2020 gender equality targets were set in FY17. ‘-‘ denotes no FY19 interim target was set. Calculated using population of permanent full-time and part-time employees. Actuals and targets are stated as at 30 September for each respective year.

2 The Australian Talent population includes employees who have been objectively assessed against evidence-based criteria, and selected by Divisional Leadership Teams as having upward potential.

3 As at 30 September 2019, 46% of the graduates who have accepted positions in NAB’s 2020 Australian graduate program are female.

Diversity and Inclusion Areas of Focus

Our focus on gender equality during the 2019 financial year included:

Pay Equity: Many factors determine a person’s pay including their skills, experience, qualifications, performance and work hours. NAB regularly reviews gender pay equity and is committed to:

• Conducting regular pay reviews across roles, and the organisation.

• Making sure annual remuneration recommendations for specific roles are gender neutral.

• Examining performance and reward outcomes on a yearly basis to spot any potential gender bias.

• Reviewing remuneration for our people who return from parental leave to ensure their remuneration remains aligned.

At an organisational level, the Workplace Gender Equality Agency’s Analysis (2017 – 2018) indicates that when comparing the base salary of all women to men at NAB, our gender pay gap is 21.1%.1 This is lower in comparison to the average pay gap for the financial and insurance services industry at 22.9%. For NAB specifically, this score has reduced from 22.7% in the previous year.

Breakthrough Program: Women are encouraged to focus on their career development by participating in Breakthrough, a comprehensive suite of development programs for women designed to equip them with the skills, knowledge and tools they need to transition into more senior roles. In 2019, approximately 400 NAB women participated in the program.

Talent Acquisition: We endeavour to provide 50:50 gender representation for all roles at all levels at recruitment shortlist stage.2

NAB AFL Women’s Competition: NAB is the naming rights partner of the NAB AFL Women’s Competition and the NAB AFL Women’s Rising Stars Program. Since the inaugural NAB AFL Women’s Competition in 2017, there has been a significant increase in females playing the game, now representing 32% of all participation in the AFL.3

Bloomberg Gender-Equality Index: NAB was included in the 2019 Bloomberg Gender-Equality Index, having disclosed data points across four dimensions – workforce statistics, policies and benefits, external impact, and support for women in the community.

Women on Boards: We encourage women at senior levels within NAB to join the Group subsidiary and not-for-profit boards. In 2019 we held workshops for our people in collaboration with Women on Boards, which allowed women who are interested in holding board positions to gain an understanding of what these positions involve, how to recognise transferable skills and experience, and how to best position themselves through the application process for board positions.

Women in Banking and Finance (WiBF): We are a ‘Ruby’ Corporate Member of Women in Banking and Finance (WiBF), a non-profit organisation, which provides mentoring, education programs and professional development events tailored to women in financial services and related industries.

In addition, the Group's broader inclusion initiatives during 2018 included:

Principal Partner of Special Olympics Australia until 2022: We announced our expanded support of Special Olympics Australia, to become Principal Partner until 2022. The partnership builds on NAB’s role as Presenting Partner of the 2018 Special Olympics National Games hosted in Adelaide.

Diversity Council Australia (DCA) – Championing Indigenous Women: Showing leadership and support for Indigenous women leaders and our Aboriginal and Torres Straight Islander Peoples, NAB was the proud sponsor of the Diversity Council Australia’s ‘Championing Indigenous Women’ event in August 2019.

Elevate Reconciliation Action Plan (RAP) 2019 – 2021: We launched our new Elevate Reconciliation Action Plan 2019-2021, designed to create real outcomes and positive change in partnership with Aboriginal and Torres Strait Islander people, organisations, and communities. Our key areas of focus are Economic Participation, including financial inclusion initiatives and business partnerships, People, and Cultural Intelligence. We continued core Indigenous employment programs, which included offering 76 Indigenous Australian traineeships. In 2019, 1.45%4 of our Australian employee base identify as Aboriginal or Torres Strait Islander.

Cultural inclusion alliances: Our alliance with the Asian Leadership Project and Culturally Diverse Workforces continues. The alliance is committed to driving greater representation of culturally diverse people in leadership within Corporate Australia.

African-Australian Inclusion Program (AAIP): We continue to attract diverse talent through our AAIP, welcoming 465 participants as we celebrate the program’s 10th year anniversary. 52.9% of AAIP Alumni across the 10 years remain employed at NAB.

Accessibility Action Plan (AAP) 2019 – 2020: We worked with the Australian Network on Disability (AND) to create and launch our new

‘Better Together’ Accessibility Action Plan (2019-2020). The plan has led to an increase in the number of our people who feel comfortable sharing information about their disability. As leading practice in Australia, we launched the ‘Better Together’ Plan in Easy English format on our new Accessibility Hub.

Valuing a neurodiverse workforce: In partnership with DXC Technology, NAB introduced its ‘Neurodiversity at NAB’ Program, which sits within our Enterprise Security team and is designed to provide meaningful and sustainable employment for people on the autism spectrum.

Gold Employer Status in the Australian Workplace Equality Index Awards (AWEI): The AWEI is the definitive national benchmark on LGBTI+ workplace inclusion, which drives best practice in Australia and sets a comparative benchmark for Australian employers across all sectors. Due to our increased focus on LGBTI+ inclusion, this year we achieved Gold Employer Status in the Awards, which is the highest result within the current year.

LGBTI+ in the community: We support and advocate inclusion for sexually and gender diverse communities and their allies. Since 2013, NAB has been the Principal Partner of Midsumma Festival, we have extended our support to rural and regional communities through LGBTI+ community events and partnerships including Chillout Festival Daylesford, and we are committed to inclusion in sport through a multiyear major partnership with Pride Cup Australia.

Supporting our people with caring responsibilities: NAB partners with Care Corporate to assist our people to balance work with caring responsibilities. Through this program, we offer support and resources to assist those caring for young children, teenagers, persons with disability or the elderly.

1 Workplace Gender Equality Agency (WGEA) 2017-2018 benchmarking report.

2 This applies to both internal and external sourced positions (with the exception of volume based recruitment which already has steps in place to reduce gender bias).

3 2019 NAB AFL Women’s End of Season Report.

4 Calculated based on a combination of responses to NAB’s 2019 Employee Engagement Survey (managed by AON Hewitt) and NAB’s total number of employed Indigenous Australian trainees (trainees do not participate in the employee engagement survey so are added to the overall response rate from that survey to ensure we appropriately include this population).

Our focus on having a positive social impact helps us to be the bank that our customers, people, shareholders and the community want us to be.

This year, the Board endorsed a new Social Impact (SI) strategy. It enables us to create positive impacts for the community and business where we have unique strengths to drive sustainable change for good.

This means we assess and balance risks and opportunities to drive long term value for our customers, people, shareholders and the communities in which we operate.

We use a range of tools and approaches including strategic giving, corporate responsibility and shared value – leveraging our core assets and expertise as a bank to address social and environmental challenges at scale.

An annual materiality assessment identifies the environmental, social and governance (ESG) themes that matter most to our stakeholders and where NAB can drive the greatest impact. This assessment process is detailed in our 2019 Sustainability Report and on our website.

Social Impact is embedded across the Group by:

• Engaging with stakeholders to identify current and emerging material issues, challenging NAB to develop mutually beneficial solutions and helping to define strategic direction.

• Implementing a SI program that sets clear objectives, establishes appropriate policies, procedures and activities and measures and reporting on progress.

• Integrating ESG management and reporting into governance structures and internal communications to ensure that SI is understood by the Board, executives and our people.

• Focusing on four key social impact areas – financial health, stronger communities, banking on nature and climate action.

The Board has oversight of SI initiatives and ESG risks, including climate-related risk. The Board is provided with updates on SI and ESG risks, and other SI-related matters as appropriate.

Social Impact performance
Further information on the Group’s SI approach and performance is provided in the 2019 Annual Review, the 2019 Sustainability Report and Data Pack and on the Group’s website at www.nab.com.au/si. External assurance is provided over the SI data contained in the 2019 Annual Review and 2019 Sustainability Report.

You can view our relevant policies at our Resource Library.

Risk is an inherent part of NAB’s business and the effective management of risk is a fundamental enabler of our strategic plan. The strategy for managing risk is to protect customers and enable sustained performance. This is achieved through applying a Risk Management Framework, documented as part of the Risk Management Strategy, which is provided at least annually to the Australian Prudential Regulation Authority to meet our prudential requirements.

NAB applies a Three Lines of Defence operating model in relation to the management of risk. The overarching principle of the model is that risk management capability must be embedded within the business to be effective. The role of each line of defence is:

• 1st Line of Defence – Businesses own risks and obligations, and the controls and mitigation strategies that help manage them.
• 2nd Line of Defence – A functionally segregated Risk function develops risk management frameworks, defines risk boundaries, provides objective review and challenge regarding the effectiveness of risk management within the first line businesses, and executes specific risk management activities where a functional segregation of duties and/or specific risk capability is required.
• 3rd Line of Defence – An independent Internal Audit function reporting to the Board monitors the end-to-end effectiveness of risk management and compliance with the Risk Management Framework.

Our material risks are:

The Risk Management Framework is the sum of the Group’s approach to risk management. It is underpinned by consideration of the impacts of our business decisions on our customers, our community and our people. As a Group, responding effectively to those material risks with Environmental, Social and Governance (ESG) implications is important to maintaining our financial performance, reputation, long-term strategy and vision.The Group has a set of Environmental, Social and Governance (ESG) Risk Principles (PDF, 433KB), which help integrate ESG risk considerations into the Risk Management Framework.

Risk Governance

Risk governance refers to the formal structure used to support risk-based decision-making and oversight across all our operations. This consists of Board committees and management committees, delegations of authority for decision-making, management structures and related reporting.

The Board provides strategic direction for our business and represents the interests of our shareholders through the creation of sustainable value. This is achieved through a focus on customers, employees and the broader community. The Board is supported by its committees in carrying out its responsibilities (Charters are available on nab.com.au).

The Board delegates responsibility for the day-to-day management of the Group’s operations to the Group Chief Executive Officer (CEO). The Group CEO delegates authority to members of the Executive Leadership Team (consistent with their BEAR accountabilities) and to executive risk management committees.

The Group CEO oversees enterprise-wide risk management (under delegation from the Board) through the Executive Risk Committee and its supporting sub-committees. At the divisional level, the business risk management committees have been established to provide customer oriented risk review and challenge across the value chains and support the discharge of risk-related BEAR accountabilities for relevant members.

NAB recognises that it has an important role to play in the Australian political process and in the development and promotion of policy.

Since 2016, NAB has not made individual donations to any political party, Parliamentarian, elected official or candidate for political office. From time to time, NAB representatives may attend business forums hosted by major political parties. Any payments for event attendance received by political parties will be included in the Australian Electoral Commission register.

You can also view the below:

• Group Political Contributions Policy (PDF, 402KB)

The Board is responsible for the Group's remuneration policy and strategy. In particular, the Board:

• Approves remuneration policy and remuneration arrangements for the Group including the Group CEO and Executive Leadership Team;
• Evaluates the performance of the Group CEO, Executive Leadership Team and other senior executives; and
• Approves remuneration arrangements for non-executive Directors.

The Board has established a Remuneration Committee to assist it in governing remuneration across the Group. The Remuneration Committee supports the Board in relation to NAB’s remuneration policies and practices with the objective that these:

• are reasonable and fair, in line with legal and regulatory requirements and shareholder expectations;
• responsibly reward individuals for performance; and
• in respect of performance-based remuneration, encourage behaviour that supports NAB’s long-term financial soundness and aligns with prudent risk-taking.

In fulfilling this role, its principal activities include the following:

• Recommending to the Board annually the fixed remuneration and variable reward outcomes for the Group CEO, Executive Leadership Team and other senior executives based on both NAB’s performance (including a mix of customer, risk and financial metrics) and each executive’s individual performance.
• Monitoring and making recommendations regarding deferred equity vesting outcomes.
• Oversight of NAB’s consequence management framework and management of underperformance and impact on remuneration outcomes.

In 2018 NAB made significant changes to remuneration – to encourage performance that represents the interests of all NAB stakeholders. As a result, the Board introduced a new executive remuneration framework for the Group CEO and Executive Leadership Team. The new framework is compliant with the Banking Executive Accountability Regime. It applies with effect from 1 October 2017. The Board used the new framework to assess the 2018 performance outcomes for the Group CEO and Executive Leadership Team.

Those outcomes and information on the Group’s remuneration and performance frameworks are set out in NAB’s 2018 Remuneration Report.

• Remuneration Report in the Report of the Directors in the Annual Financial Report (PDF, 737KB)
• Financial Services Companies Peer Groups (PDF, 9KB)
• Top 50 Companies Peer Groups (PDF, 18KB)

We're committed to protecting the bank and our customers by meeting our legal and regulatory requirements in the areas of financial crime. This includes anti-money-laundering and counter-terrorism financing (AML/CTF), anti-fraud, anti-bribery and corruption, and sanctions and embargoes.

Good corporate governance is a fundamental part of our culture and business practices in the prevention of financial crime. Our corporate governance framework along with effective risk management is a key capability of a successful financial services provider in the prevention of financial crime. Find out more about our approach to the management of financial crime and how customer due diligence helps us to combat our fight against criminal activity.

External commitments and activities in financial crime prevention include:

• reflecting in our policies and procedures Australia’s adoption of the FATF Recommendations (International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation)
• adoption and commitment to the Wolfsberg Group AML Principles and Questionnaire (PDF, 365KB) also available from Bankers Almanac
• maintaining and making publicly available NAB’s Patriot Act Certification (PDF, 407KB) regarding correspondent accounts for Foreign Banks. The Patriot Act Certificate is available to any financial institution that requires a Patriot Act Certificate from the NAB Group. This certification covers all branches listed in this file (PDF, 57KB).
• compliance with international AML/CTF rules and regulations
• adhering to relevant international Sanctions & Embargoes legislative requirements including relevant watch lists issued by certain competent authorities
• compliance with local and international anti-bribery and corruption rules and regulations
• compliance with the Foreign Account Tax Compliance Act (FATCA) (PDF, 11KB).

We're a signatory to the UN Global Compact (UNGC) which includes a commitment to work against corruption in all its forms, including extortion and bribery. See our latest UNGC Communication on Progress.

NAB commits to act as a model litigant and has adopted a Model Litigant Policy.

We recognise our responsibility to act honestly and fairly in the conduct of litigation and make commitments on the way we will conduct ourselves in the handling of claims and litigation.

Those commitments include:

• dealing with claims promptly and not causing unnecessary delay;
• endeavouring to avoid, prevent and limit the scope of legal proceedings wherever possible;
• where it is not possible to avoid litigation, facilitating the just resolution of the litigation as quickly, inexpensively and efficiently as possible;
• not taking advantage of a claimant who lacks the resources to litigate a legitimate claim; and
• not relying on technical defences unless NAB’s interests would be prejudiced.

It is not limited to particular customer segments nor is it limited to any particular type of claim or litigation.

The Financial Claims Scheme (FCS) is an initiative by the Australian Government to provide protection and quick access to your deposits in financial institutions in the unlikely event that one fails.

How the Financial Claims Scheme works

Under the FCS, certain deposits are protected up to a limit of $250,000 for each account holder at any bank, building society, credit union or other authorised deposit-taking institution that’s incorporated in Australia and authorised by the Australian Prudential Regulation Authority (APRA).

The FCS can only come into effect if it’s activated by the Australian Government when an institution fails. Once activated, the FCS will be administered by APRA who would aim to pay the majority of customers their protected deposits within seven calendar days.

Application of the FCS limit

The FCS limit of $250,000 applies to the total of an account holder's deposits under the one banking license.

This means, all deposits held by an account holder with a single banking institution, including accounts with parts of the business operating under a different trading name, count towards the limit. For example, deposits you have with NAB, nabtrade and Ubank would count towards the $250,000 limit.

NAB businesses covered by the Scheme

The FCS applies to NAB, nabtrade and UBank.

Deposits covered by the Scheme

The FCS applies to a wide range of deposits held with NAB, including:

• savings accounts
• call accounts
• term deposits
• current accounts
• cheque accounts
• debit card accounts
• transaction accounts
• personal basic account
• cash management accounts
• farm management deposits
• pensioner deeming accounts
• mortgage offset accounts, either 100 per cent or partial offset, that are separate deposit accounts
• trustee accounts
• retirement Savings Accounts
• first home saver accounts that are deposit accounts

Further information on the FCS

If you’d like to know more about the FCS there’s information available on the FCS website.

Our core behaviours encourage our people to speak up and have open, honest conversations. Our Code of Conduct, compliance standards, and policies guide our day-to-day decisions, actions and behaviours and govern our business.

Our Group Whistleblower Protection Policy (PDF, 344KB) is applicable to all employees (including all directors, officers, employees, former employees, contractors, subcontractors and agents of the Group) and subsidiaries across our operations. The Policy complements the normal communication channels that exist for raising concerns between people leaders and employees without fear of reprisal. All employees (and former employees) have access to the independently managed KPMG FairCall Service.

The Group Whistleblower Protection Policy and Group Whistleblower Program are part of the Group Corporate Governance and Risk Framework. Overall governance of the Group Whistleblower Program is undertaken by the Board Audit Committee with day-to-day operation of the Program managed by Internal Audit.

The Group Whistleblower Committee is chaired by our Chief Audit Officer and meets bi-monthly. The Whistleblower Committee is comprised of senior leaders from across the business and is responsible for oversight of the Whistleblower Program and decisions and activities of Program officers, ensuring appropriate activities are undertaken to raise awareness of the Program across the business and ensure effective and regular reporting to Board Audit Committee in relation to the work of the Program.