We're committed to protecting the bank and our customers by meeting our legal and regulatory requirements in the areas of financial crime. For us, this includes:
- Anti-Money-Laundering and Counter-Terrorism Financing (AML/CTF)
- Anti-Fraud, Anti-Bribery and Corruption
- Economic and Trade Sanctions.
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.
The Board and Executive Management Committees receive regular reporting on risks relating to financial crime and have ultimate accountability.
Our policies and processes
Our AML/CTF, Economic and Trade Sanctions, Anti-Fraud, and Anti-Bribery and Corruption policies set the governance and appetite to identify, manage and mitigate the risk of opportunities for financial crime across the organisation. We require all of our subsidiaries and majority-owned joint venture entities to comply with the law, our Code of Conduct and policies, including the policies dedicated to the prevention of financial crime. These policies apply, at a minimum, to all NAB directors, employees, contractors and consultants.
The policies outline the responsibilities for all persons to act honestly and adhere to internal controls and procedures designed to prevent any form of financial crime and to report such acts if they're identified. This includes, but is not limited to:
- The prohibition of facilitation payments and bribes disguised as political, charitable donations and sponsorships. Political donations by or on behalf of NAB are prohibited.
- NAB has a clear process for PEP customers, which includes Senior Management Approval. This process also extends to existing customers, that become PEPs.
- NAB has a risk-based approach for customer due diligence, commensurate to the customer’s risk profile. This includes appropriate controls in place for non face-to-face customers.
Our approach to managing financial crime also extends to our supply chain. We're committed to responsible procurement and we maintain a Supplier Sustainability Program to monitor and manage sustainability risks within our supply chain. A key component of this program is our Group’s Supplier Sustainability Principles, which specify the sustainability requirements for suppliers providing goods and services to our businesses. All suppliers to the NAB Group must comply with all relevant local and national laws and regulations in relation to bribery, corruption and other prohibited business practices.
Oversight and assurance of our Anti-Financial Crime framework is undertaken by:
- Specialist Assurance teams
- Group Operational Risk and Compliance
- Internal Audit
- Independent organisations are engaged to undertake independent assessments.
Supporting our people when raising concerns
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 Policy 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 Policy and 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 via Internal Audit. Day-to-day operation of the Group Whistleblower Program (Program) is 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 representatives from across the business, including Group Governance and Legal, People & Culture (Human Resources), Group Risk and Internal Audit.
The Whistleblower Committee is responsible for oversight of the Whistleblower Program, ensuring appropriate measures are taken to address allegations received by the program, providing a forum for the resolution of matters and ensuring that there is effective and regular reporting to Board Audit Committee.
Training and education
We have a range of training, awareness-raising, monitoring and review activities to support adherence to NAB’s various financial crime policies and practices, which includes mandatory training on matters such as AML/CTF, Economic and Trade Sanctions and Anti-Bribery & Corruption.
All employees are reminded on our Whistleblower Program in the annual mandatory Code of Conduct ‘e-learn’. Additionally, direct education and communication to assist in the identification and prevention of financial crime is undertaken with frontline staff upon joining the organisation.
NAB employee reward and performance is directly linked to adherence with the Code of Conduct and the completion of mandatory annual compliance training. Breaches in Group policy and compliance are investigated and, depending on the nature of the breach can result in adverse performance outcomes and/or termination of employment.
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 Financial Crime Compliance Questionnaire (PDF, 181KB).
- developing AML/CTF and Sanctions Policies and Framework to comply with applicable laws and regulations, articulated in NAB's Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) and Sanctions Policy Statement (PDF, 405KB).
- maintaining and making publicly available NAB’s Patriot Act Certification (PDF, 261KB) 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.
- communicating and making publicly available our Anti-Bribery and Corruption Policy Summary (PDF, 74KB)
- compliance with local aid and international AML/CTF rules and regulations
- compliance with all sanctions laws and regulations in the jurisdictions in which NAB operates
- compliance with international Anti-Bribery & Corruption rules and regulations.
We are also 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.
We publicly report on an annual basis compliance against our Code of Conduct (including corruption incidents), and allegations received under our Whistleblower Policy. See our most recent performance. We also meet our regulatory reporting obligations to Australian Regulators as well as other domestic and international competent authorities.