Please familiarise yourself with NAB’s Conflicts of Interest Policy.
The NAB Group's corporate governance framework plays a key role in supporting our business operations. It provides clear guidance on how authority is exercised within the group.
As a fundamental element of our culture and business practices, our corporate governance framework provides guidance for effective decision making in all areas of the Group through:
- strategic and operational planning
- risk management and compliance
- financial management and external reporting
- succession planning and culture
- managing customer experiences and outcomes.
The Group's corporate governance framework plays a key role in supporting our business operations.
You can read about the key aspects of our corporate governance framework and practices for the 2019 year in the Corporate Governance Statement (PDF, 2.7MB), and our compliance with the ASX Corporate Governance Council's Corporate Governance Principles and Recommendations is shown in our 2019 Appendix 4G (PDF, 102KB).
Key documents and policies which form part of our corporate governance framework and highlight the Group's significant commitment to corporate governance are set out below.
Summary of National Australia Bank's Policy on conflicts of interest applicable to National Australia Bank Limited and its controlled entities
Overview
The National Australia Bank Group (NAB) operates in a number of jurisdictions across the globe, providing a wide range of financial services to a broad customer base. NAB will face actual, potential or apparent conflicts of interest on a regular basis in the course of its normal business activities.
NAB has internal policies and procedures in place to identify and manage conflicts of interest, and to prevent those that cannot be managed. This document provides a description of those policies and procedures in summary form.
Identification of conflicts of interest
Conflicts may arise in a number of circumstances in the course of NAB’s business, including where:
- NAB’s interests conflict with those of its customers;
- the interests of NAB’s directors, offices, employees and secondees or contract hires of NAB (a “NAB Person”) conflict with those of its customers;
- the interests of NAB and a NAB Person conflict;
- the interests of differing NAB entities conflict; or
- conflicts of interest may occur between different customers of NAB.
NAB also has principal interests of its own and maintains procedures appropriate to keep separate these interests from those of its customers.
Management of conflicts of interest
NAB’s policies and procedures describe the methods which NAB may use to manage actual, potential or apparent conflicts of interest. These include (but are not limited to) physical, technological and organisational arrangements to protect customer interests and to manage actual or potential conflicts of interest. Most importantly, NAB Persons who undertake different business activities must do so with an appropriate degree of independence.
NAB also maintains certain arrangements that prevent or control the flow of information between NAB Persons performing particular roles involving a risk of a conflict of interest where the exchange of information may harm the interests of one or more of NAB’s customers.
In certain instances, where NAB determines that a conflict cannot be adequately managed, NAB will decline to proceed with the proposed service or transaction. Alternatively, NAB may determine that it is possible to proceed, but that additional disclosure regarding conflicts is required as per the “Disclosure” section below.
Disclosure
There may be occasions when NAB’s procedures and controls are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a customer will be prevented. Should this occur, and in accordance with applicable regulatory requirements, before undertaking the business on the customers behalf, NAB shall clearly disclose the general nature and/or sources of the potential conflict to the customer and steps taken to mitigate the potential conflict in sufficient detail to enable the customer to make an informed decision and, in appropriate circumstances, NAB may obtain the customer’s written consent before proceeding.
Further information
Detailed internal NAB policy documents and operating procedures may not be fully represented in the summary description set out above. If you would like further information regarding NAB’s conflicts of interest policies and procedures, please get in touch with your usual NAB contact.
