Code of Conduct for Reserve Bank Staff

Note: Definition of Staff[*]

1. Purpose and Application

The Reserve Bank pursues national economic policy objectives and undertakes a range of associated activities in financial markets and banking. It also issues Australia's banknotes and operates infrastructure critical to the payments system.

You, and others who are involved in the activities of the Bank, have a critical role to play in achieving these objectives, whether directly or in a supporting role. You have a responsibility to conduct yourself with a high degree of integrity, to strive for excellence in the work you perform and the outcomes you achieve and to promote the public interest.

The purpose of this Code is to set out the Bank's requirements of its employees and others who are involved in its activities.

1.1 Values

This Code sets out the Bank's requirements of you and your colleagues. These requirements focus on a wide range of matters, some of which are supplemented by more detailed policies (see Section 7.1).

All of the requirements of this Code result from applying the Bank's values to situations that may arise in your work or the activities of the Bank.

Our core values are:

  1. Promotion of the public interest

    We serve the public interest. We ensure that our efforts are directed to this objective, and not to serving our own interests or the interests of any other person or group.

  2. Integrity

    We are honest in our dealings with others within and outside the Bank. We are open and clear in our dealings with our colleagues. We take appropriate action if we are aware of others who are not acting properly.

  3. Excellence

    We strive for technical and professional excellence.

  4. Intelligent inquiry

    We think carefully about the work we do and how we undertake it. We encourage debate, ask questions and speak up when we have concerns.

  5. Respect

    We treat one another with respect and courtesy. We value one another's views and contributions.

1.2 Who does this Code apply to?

This Code applies to you if you:

  • are an employee of the Bank; or
  • occupy a position (whether as a contractor, consultant, agency employee or otherwise) within the organisational structure of the Bank; or
  • have access to the information and communications technology systems (ICT Assets) of the Bank and we have informed you that you are required to comply with some or all of this Code; or
  • are a contractor, consultant or visitor to the Bank and we have informed you that you are required to comply with some or all of this Code.

1.3 Familiarisation with this Code

This Code may change as the Bank's practices and activities change. You are required to review and familiarise yourself with the requirements of this Code, as updated from time to time. This Code is available on the intranet, along with the Bank's policies.

You are required to acknowledge that you have read and understood this Code at least annually, and undertake training on its requirements as necessary.

2. Professional Conduct

You are a representative of the Bank, and the way you perform your work reflects on the Bank. It is essential that you perform your work professionally, to a high standard, with integrity, and to the highest ethical standards.

2.1 Duties

You have a range of duties to the Bank. Some of the more important general duties are:

  • to conduct yourself honestly and with integrity in all dealings you have in the course of your work for the Bank both within and outside of the Bank;
  • to perform your role to the best of your ability;
  • to exercise your powers and discharge your duties with care and diligence, honestly, in good faith, in the best interests of the Bank and for a proper purpose;
  • not to use your position to gain, or seek to gain, an advantage for yourself or someone else, or to cause, or seek to cause, detriment to the Bank or another person;
  • not to use any information obtained by you in the course of your work with the Bank to gain, or seek to gain, an advantage for yourself or someone else, or to cause, or seek to cause, detriment to the Bank or another person; and
  • to comply with laws that apply to you and the Bank as well as the policies and lawful directions of the Bank.

2.2 Avoiding conflicts of interest

It is possible that a conflict can arise between your personal interests and your duties to the Bank. This can include situations where:

  • you may have an interest in a transaction with the Bank; or
  • you have a personal or financial relationship with someone who is dealing with the Bank.

You are required to recognise and properly manage situations which could, or could be seen to, involve a conflict between your interests and your duties to the Bank. If there is a reasonable basis to believe that such a conflict of interest and duty exists, you must discuss the details of the interest with the relevant Head of Department or Governor.

Should the conflict be a material personal interest that relates to the affairs of the Bank, then you are required to disclose the details of the interest. Guidance for staff on disclosure requirements is contained in the Disclosure of Material Personal Interests - Instructions.

2.3 Appropriate use of position

You must always use your position honestly, in good faith and in the interests of the Bank. You must conduct yourself in a manner that does not bring you or the Bank into disrepute.

You must always exercise your powers and discharge your duties with care and diligence. This means that when you make a judgement:

  • the judgement is made in good faith and for a proper purpose;
  • you are reasonably informed about the subject matter of the judgement; and
  • you believe on a rational basis that the judgement is in the best interests of the Bank and, where applicable, the public interest.

You must not:

  • show any favour towards friends or relatives in your dealings with or on behalf of the Bank or misuse your position in any other way; or
  • receive payment or other benefits for activities outside of the Bank, which are offered to you as a result of your position in the Bank (except for payments or benefits that are approved by your Head of Department or the relevant Governor in accordance with Sections 2.6 and 2.7 below).

2.4 No bribery or corruption

You must not engage in any form of bribery or corruption. You must also take reasonable steps to ensure that any person who reports to you does not engage in any form of bribery or corruption in connection with their employment at the Bank. This extends both to bribery and corruption of others, and bribery or corruption of you or any other person this Code applies to.

Bribery is not limited to cash or other payments in return for favours or favourable decisions. It includes offering, giving, promising, asking for or receiving (whether directly or indirectly) anything of value for the purpose of inducing or rewarding a discretionary action or the exercise of influence, regardless of whether the person concerned is from the public or private sector or what country they are in or from. ‘Value’ can include cash, gifts, hospitality, personal, family, social or educational favours or other financial or non-financial benefits or advantages. Exchanges of gifts or hospitality (including travel and accommodation) may compromise – or appear to compromise – the exercise of objective business or policy judgment and could amount to bribery or corruption. Staff must only offer or receive gifts or hospitality where Section 2.7 permits them to do so.

Some examples of conduct that would amount to bribery or corrupt behaviour include:

  • accepting money or another benefit in return for information which you have as a result of your work for the Bank;
  • inappropriate allocation of trading business to a counterparty for personal gain;
  • receiving a benefit to give preferential treatment in the selection or use of a recruitment agency that supplies candidates to the Bank; or
  • paying or offering an amount of money or other benefit to a government official with an intention to influence them in a decision about planning approval for a refurbishment of one of the Bank’s offices.

You are not permitted to make facilitation payments. These are payments to government officials personally to expedite or secure performance of a routine government action of a minor nature. You must not make these payments, irrespective of the amount involved and even if they would not breach the law.

You must report any suspected or known bribery or corruption to the Deputy Governor or report it through the FairCall service as soon as practicable (see Section 7.2).

See also the Fraud Control Policy and the Reporting Fraud and Unethical Behaviour Policy.

2.5 Involvement in other employment or business

You must not engage in other employment or business activities (including paid or unpaid activities) which are offered to you as a result of your position in the Bank, or which may create a conflict of interest with, or otherwise impact on, your obligations to the Bank.

You must not perform any paid or unpaid work in any capacity for:

  • an authorised deposit-taking institution;
  • a holder of an Australian credit licence; or
  • any private sector entity operating in Australia whose main business is the provision of finance.

It can be difficult to anticipate whether an external role or business activity might conflict with your duties to the Bank. Accordingly, you should inform your Head of Department or the relevant Governor of any other employment or external business activity you are considering accepting before undertaking it.

2.6 Fair dealings with third parties

You must act honestly and fairly in all your dealings for and on behalf of the Bank. Any actual or perceived conflicts of interest should be disclosed to your Head of Department or the relevant Governor.

You must never receive a gift or personal benefit from suppliers or potential suppliers of the Bank if the gift or benefit would fall outside the guidelines set out in this Code.

Similarly, you must never give a gift or personal benefit to a supplier or potential supplier if it would fall outside this Code. These requirements are outlined further in Section 2.7.

You must always adhere to the Procurement Policy in any procurement you are engaged in on behalf of the Bank.

2.7 Gifts, hospitality and other benefits

In the course of your work at the Bank, you must exercise care when giving or receiving gifts, hospitality and other benefits. You must not:

  • give (whether from your own or from Bank funds) or receive a gift, hospitality or other benefit that may (or may appear to) compromise your judgement in your official capacity at the Bank, damage relationships with other persons or organisations or indicate favouritism towards a person or group of people;
  • accept any personal monetary payment, including in cash, from a third party you deal with in the course of your work with the Bank; or
  • accept any airfare or accommodation paid for by a third party, unless you have the prior approval of the Deputy Governor to do so.

In circumstances where it may be reasonable to give or receive gifts, hospitality or other benefits, the following must be observed:

  • any gifts received must not exceed $100 in value (other than as provided below);
  • approval from the Secretary must be sought before giving any gift on behalf of the Bank that exceeds $100 in value;
  • any hospitality given or received should not ordinarily exceed $100 (other than as provided below);
  • all gifts, hospitality and other benefits you receive or provide in the course of your work with the Bank must be recorded on a register kept by your Head of Department or the relevant Governor.

In some circumstances, it may be inappropriate to decline a gift, an offer of hospitality or other benefit which may otherwise be inconsistent with the guidelines set out above. Similarly, hospitality costs in the overseas offices may be above AUD100 due to exchange rate fluctuations; the relative costs of living in those cities also need to be considered to ensure that the amount remains appropriate. In these circumstances, you should seek guidance from your Head of Department or the relevant Governor and (in the case of a gift) hand the gift to Secretary's Department as soon as practicable.[1]

See also Gifts, Hospitality and Other Benefits Registers – Guidelines.

2.8 Transacting in financial instruments

As a result of your position with the Bank, you may have access to information that is not publicly available. You must not profit, or enable others to profit, from information available to you which is not publicly available. In addition to this prohibition there is a need to limit the circumstances in which you may transact in financial instruments so as to protect both you and the Bank.

The following transacting rules apply to you and any entity you control. They encompass transactions you are involved in directly, as adviser, or in any other capacity where you are making or influencing a decision to buy, sell or otherwise deal in a financial instrument.

  1. Derivatives
    Neither you nor any entity you control may enter into, arrange, buy, sell or otherwise deal in interest rate or foreign exchange derivatives.

  2. Active trading
    Neither you nor any entity you control may engage or be involved in active trading in any financial instrument. Active trading is regarded as trading which is frequent and speculative. If you have any uncertainty about this, your Head of Department or relevant Governor can provide you with specific guidance as to whether a particular form of trading would be regarded as active trading.

  3. Blackout periods
    The Bank has a blackout period in which you and any entity you control are not permitted to undertake any discretionary transactions in Blackout Financial Instruments. ‘Blackout Financial Instruments’, for the purposes of this Section, mean interest rate products (including but not limited to bonds, bills, notes, certificates of deposit and term deposits), shares, warrants, options, corporate bonds, foreign exchange (except for travel purposes), active investment choice modifications to any superannuation fund account, and the rolling over of superannuation funds into a complying fund. These requirements apply to all discretionary acquisitions or disposals of, or other dealings in, Blackout Financial Instruments. They do not apply to passive, predetermined investment (for example, the rollover of a pre-existing term deposit, a regular prearranged contribution to a managed investment scheme or shares purchased under a dividend reinvestment plan).

    The blackout period begins at the time set for the start of the Policy Discussion Group meeting and concludes when the Board's monetary policy decision is announced publicly. That period, unless notified otherwise, commences at 2.30 pm (Sydney time) on the Wednesday prior to the monthly meeting of the Reserve Bank Board and ends at 2.30 pm (Sydney time) on the Tuesday on which that meeting is held. During this period you and any entity you control must not undertake discretionary transactions in any Blackout Financial Instruments.

    Where the blackout period would create genuine hardship, you may approach your Head of Department or relevant Governor for guidance.

  4. Role-specific restrictions
    You may be required to adhere to additional restrictions if you work in certain roles or areas of the Bank due to the information you will have access to. This includes, for example, the Financial System Group, parts of the Financial Markets Group and employees with access to restricted liaison information.

2.9 Gambling on monetary policy decisions

You are not permitted under any circumstances to engage in any form of gambling (including casual bets with friends or family) on monetary policy decisions.

2.10 Media comment and use of social media

Media enquiries should be referred to the Media and Public Relations Office. In dealing with the media, only authorised staff are permitted to speak ‘off the record’, ‘on the record’ or ‘for the Bank’.

Comments about your colleagues, the person you report to, your experiences at work and your views about your work have the potential to adversely affect your reputation as well as the reputation of others and the Bank. When using social media, you must ensure that your communications do not lead to any unauthorised disclosure of the Bank's operations or views and do not bring the Bank or any of its staff into disrepute.

See also the Media Policy and the Social Media Policy.

2.11 External Presentation and Publication Policy

The Bank seeks to ensure that its intellectual property, communications objectives and reputation are managed properly. As a result, employees must seek permission from their Head of Department or above before seeking to present, publish or republish material externally, with the Head of Department reviewing the material (unless otherwise previously agreed). This includes material produced by staff in the course of employment at the Bank, prior to commencing employment at the Bank or outside work hours. This applies to employees and those holding positions at the Bank – including those on leave without pay or other forms of extended leave – who wish to publish in any outlet, or present in any external forum, including those where content will be reproduced, or is likely to be reproduced by third parties.

Employees must consider the copyright issues when submitting material that was produced for publication externally.

See also the External Presentation and Publication Policy.

3. Personal Conduct

In the course of your work with the Bank, you are required to conduct yourself with a high degree of professionalism, and with respect and courtesy for the people you deal with.

3.1 Professionalism

The Bank performs functions which are critical to the Australian economy and the Australian community. This work is best achieved to the high standard that is expected of the Bank if everyone involved in the activities of the Bank performs to a high standard.

In all of the work you perform (including working alone or with others in a team), you are required to utilise and demonstrate the skills, competence and professionalism reasonably expected of a person in your role. This includes:

  • the technical competence you utilise and demonstrate in your work;
  • the outcomes you achieve in your areas of responsibility; and
  • the relationships you establish and maintain within the Bank and with others you deal with in the course of your work for the Bank.

3.2 Respect and courtesy

You are required to treat everyone you deal with in the course of your work for the Bank with respect and courtesy. The specifics of this requirement may vary from one situation to another, but generally this will involve:

  • acting with care and consideration for the feelings, situation and circumstances of others;
  • politeness in your dealings with others; and
  • avoiding an antagonistic, aggressive or unnecessarily harsh approach towards others.

See also Acceptable Use of Technology Policy and the Social Media Policy.

3.3 Working effectively with others

All of us will from time to time (and sometimes regularly) have to work in teams, work with people from other parts of the Bank, and work with people outside of the Bank. You must approach your work with others cooperatively, sharing information and guidance as appropriate, respect the role and contribution of others, and ensure that the people you are working with are properly included in joint work activities.

You must perform your work to a high standard, whether you are working in a team or individually.

3.4 Avoiding discrimination, harassment and workplace bullying

You have a right, and must take reasonable steps, to ensure that your work environment and relationships with others in the Bank are free from unlawful discrimination, harassment and workplace bullying.

Unlawful discrimination involves making decisions on the basis of irrelevant and unfair attributes such as a person's age, gender, disability, race, religion, sexuality or ethnic background. It includes establishing unreasonable conditions which are more difficult for someone with the relevant attribute to satisfy than someone without that attribute.

Harassment is any form of unreasonable and unwelcome behaviour that offends, humiliates or intimidates another person. It may involve repeated or isolated behaviour.

Workplace bullying occurs where one or more people repeatedly behave unreasonably towards another person, and that behaviour creates a risk to physical or mental health and safety.

There are many ways in which unlawful discrimination, harassment or workplace bullying can occur. You are required to familiarise yourself with the Bank's Workplace Behaviour Policy, undertake training on workplace behaviour as required and to adhere to the requirements set out in that Policy/training.

If you experience this sort of conduct, you can:

  • address the issue with other person concerned directly, as they may not be aware that their behaviour troubled you. You can also discuss your concerns with your manager, Head of Department, the Head of Employee Relations and Work Health & Safety (Human Resources) or a Grievance Contact Officer if you do not feel comfortable raising these matters directly or you raise them directly and the behaviour continues; or
  • raise a formal, written complaint with your Head of Department or the Head of Human Resources; or
  • report such conduct through the FairCall service (see Section 7.2); or
  • in the case of workplace bullying, apply to the Fair Work Commission for an order to stop the bullying.

If you witness this conduct being directed to someone else, you should bring this to the attention of your Head of Department, the Head of Human Resources or a Grievance Contact Officer as soon as practicable. Alternatively, you can report such conduct through the FairCall service (see Section 7.2).

See also the Workplace Behaviour Policy, Reporting Fraud and Unethical Behaviour Policy and Handling Grievances.

3.5 Obscene or abusive language, materials or messages

Obscene or abusive language, materials or messages are not acceptable in the workplace. This includes material or messages that include:

  • harsh or inappropriate language;
  • pornographic or degrading images;
  • violent or threatening images; and/or
  • racially offensive or sexist images or materials.

You must not use language or materials of this kind or encourage or be involved with any other person in any form of communication which contains this sort of material. If you receive a communication containing this sort of material (whether from within or outside the Bank), you must immediately inform your Head of Department or relevant Governor. The only exception to this relates to spam email that you receive which should be immediately deleted and not distributed.

See also the Acceptable Use of Technology Policy and the Social Media Policy.

3.6 Safe work environment

The Bank has an obligation to ensure, so far as is reasonably practicable, the physical and mental health and safety of people who are working in its business while they are at work.

Similarly, you have an obligation to:

  • take reasonable care for your own physical and mental health and safety;
  • take reasonable care that your acts or omissions do not adversely affect the health and safety of other persons;
  • comply, so far as you are reasonably able, with any reasonable instruction relating to health or safety at the workplace that is given by the Bank; and
  • cooperate with any reasonable policy or procedure of the Bank relating to health or safety at the workplace that has been notified to you.

See also the Work Health & Safety Policy.

3.7 Drugs and alcohol

You must not attend work affected by alcohol or drugs, other than prescription or over-the-counter medication. If you take prescription or over-the-counter medication that may impact on your ability to perform your work, you must discuss this with your Head of Department, relevant Governor or with Human Resources.

You must not consume drugs (other than prescription or over-the-counter medication) at work, and must not consume alcohol at work other than at functions arranged or sponsored by the Bank at which reasonable alcohol consumption is permitted.

4. Bank Property, Information and Resources

The Bank has valuable and sensitive information and property which you will have access to. You are required to use it appropriately and protect it. You must use the Bank's resources in a way that is secure, efficient, effective, economical and ethical.

4.1 Bank property, information and resources

The Bank's assets, equipment, systems, facilities and services are provided for business purposes. You must take all reasonable steps to appropriately safeguard and protect them, and you must not use them inappropriately.

Examples of inappropriate use include:

  • excessive use of the Bank's phones, electronic mail or computing systems for personal use;
  • using the Bank's letterhead for personal correspondence;
  • sending a personal email using the Bank's email system in your professional capacity as a representative of the Bank (and not in your personal capacity); or
  • using the Bank's resources for activities that are prohibited under this Code or any other policy of the Bank.

To help the Bank provide a safe and secure environment for people and prevent unauthorised access to, or loss of, assets and information, you must:

  • adhere to the Bank's safety and security practices and procedures;
  • alert your manager if you detect any intrusion or other security threats; and
  • appropriately maintain the confidentiality, integrity and availability of information held by the Bank (see Sections 4.2 and 4.3).

In using the Bank's property, equipment, systems, facilities and services, you must familiarise yourself with the policies detailed in Section 7.1.

4.2 The Bank's Information and Communications Technology Systems (ICT Assets)

You may have limited use of the Bank's ICT Assets for personal internet browsing or emails. However, any such use must comply with the Bank's Acceptable Use of Technology Policy.

Your use of the ICT Assets may be monitored in accordance with the Bank's Acceptable Use of Technology Policy. The Bank may use the results of any such monitoring for the purpose of raising with you any concerns it may have with your use of the ICT Assets.

4.3 Confidential, sensitive, privileged, personal or protected Information

In the course of your employment with the Bank, you will have access to a range of information, some of which may be information that is:

  • confidential to the Bank, that is, which is not generally available outside of the Bank;
  • confidential to a third party, that is, which is not generally available outside of that third party;
  • sensitive, that is, which has the potential to be valuable in the hands of someone outside of the Bank;
  • privileged, that is, in respect of which the Bank enjoys a legal protection;
  • personal, that is, relating to an individual; or
  • otherwise specifically protected by legislation (for example, information relating to financial institutions protected under one of the secrecy provisions in the Reserve Bank Act 1959).

Your access to any information of this kind, or any document containing information of this kind, is solely to enable you to perform your role for the Bank. You have a legal obligation:

  • not to use this information for any purpose other than in the proper course of your work for the Bank and, where it is specifically protected by legislation or the terms of a contract with a third party, other than in accordance with the relevant legislation or contract;
  • not to disclose this information unless you are satisfied that the disclosure is permitted or required by relevant legislation or a relevant contract with a third party, will not waive or remove any legal privilege that exists and is in the proper course of your work for the Bank;
  • to take reasonable steps to preserve the confidentiality of this information; and
  • to take reasonable steps to ensure that others who have access to this information:
    • do not use or disclose it other than in the circumstances referred to above; and
    • preserve the confidentiality of it.

Without limiting these obligations, you must protect this information from intentional or unintentional disclosure to foreign officials or other people not entitled to it. Foreign officials include embassy or foreign government officials within Australia, and foreign officials or nationals outside of Australia (including trade or business representatives). You should report to your Head of Department or relevant Governor any instances when:

  • a foreign official or any other individual or group, regardless of nationality, seeks to obtain information which, under the rules set out above, should not be disclosed to them; and
  • any contact you have with any foreign official that seems suspicious, persistent or unusual in any respect. This contact could be in either an official or social capacity.

For further information on the appropriate use and protection of the Bank's information, and the steps to take in the event of an unlawful disclosure of such information, see Section 7.1.

4.4 Intellectual property

In the course of your employment with the Bank, you may be involved (directly or indirectly) in creating or developing materials in relation to which intellectual property rights may arise. The Bank will own all right, title and interest in all such materials. Your employment agreement with the Bank may deal with these matters in more detail.

5. Breaches of this Code of Conduct

5.1 Obligation to prevent and report breaches

You are required to comply with this Code and take reasonable steps to ensure that others who report to you or who you are working with comply with it.

If you are unsure whether proposed conduct may be in breach of this Code, you should speak to your supervisor or Head of Department before engaging in the conduct.

If you are aware of any conduct in breach of this Code, you are required to report it as soon as practicable. You can do so by informing your supervisor, the Head of Human Resources, the Assistant Governor (Financial System), the Deputy Governor or the Governor. You can do this in person, by telephone or in writing, including by emailing one of these people directly or sending an email to the following address: disclose@rba.gov.au. You can make a report anonymously if you wish (for example, by a typed note that does not identify you). You can also use the FairCall service (see Section 7.2).

Further details can be found in the Reporting Fraud and Unethical Behaviour Policy. See also the Fraud Control Policy.

5.2 Consequences of breach

The Bank takes seriously any instances where this Code is breached.

The Bank will determine by reference to the circumstances of each case how to respond to a breach or alleged breach of this Code. The Bank's response may include disciplinary action up to and including termination of employment and, in appropriate cases, referral to the police.

The Bank will consider dismissal without notice in cases involving serious misconduct. Serious misconduct includes wilful or deliberate conduct that would be inconsistent with continuation of your employment, or conduct that would cause serious and imminent risk to health or safety, or to the reputation of the Bank.

5.3 Investigation of complaints or breaches

In most cases, it will be necessary for the Bank to investigate complaints or alleged breaches of this Code. If in a particular case an investigation is required, the Bank will determine the form and timing of the investigation and the person to conduct the investigation having regard to:

  • the general desirability of confidentiality of investigations into employee matters;
  • the need to ensure that the investigation is conducted fairly;
  • the circumstances of each party;
  • the desirability of conducting the process quickly and efficiently;
  • the need to ensure that any outcome of the investigation is accurate and reliable; and
  • if the Public Interest Disclosure Act 2013 (Cth) applies, the requirements of that Act.

The Bank may suspend your employment while an investigation is undertaken if it believes on a reasonable basis that it is appropriate to do so.

6. Code Management

6.1 Administration

This Code is administered by Human Resources Department.

6.2 Implementation

The Head of Employee Relations and WHS is responsible for the implementation of this Code.

6.3 Monitoring and review

The Code is reviewed annually by Human Resources Department. Changes to the Code must be approved by the Risk Management Committee and the Executive Committee.

6.4 Communication

The Code is published on the Bank's Intranet, with changes to the Code being communicated to all employees where applicable.

7. Resources

7.1 Relevant policies and guidelines

There are a number of other internal documents which you need to be familiar with, including:

  • Acceptable Use of Technology Policy
  • Disclosure of Material Personal Interests – Instructions
  • External Presentation and Publication Policy
  • Fraud Control Policy
  • Gifts, Hospitality and Other Benefits Registers – Guidelines
  • Handling Grievances
  • Information Management Policy
  • Information Systems Security Policy
  • Media Policy
  • Privacy Guidelines
  • Procurement Guidelines
  • Procurement Policy
  • Protective Security Policy
  • Reporting Fraud and Unethical Behaviour Policy
  • Social Media Policy
  • Work Health & Safety Policy
  • Workplace Behaviour Policy.

7.2 Reporting concerns through FairCall

Staff are able to report concerns through a specialist, independent provider, KPMG. The service is known as ‘FairCall’ and any concerns raised via this service are reported directly to the Deputy Governor. The FairCall numbers are:

  • Australia: 1800 077 109 (toll free)
  • UK, USA, China: + 61 2 9335 8785

You also have the option of:

  • using an internet ‘drop-box’ facility which enables you to supply information, whilst remaining totally anonymous. The address for the ‘drop-box’ is http://faircall.kpmg.com.au; or
  • sending an email to faircall@kpmg.com.au.
  • You may make the report without disclosing your details. However, you also have the option of identifying yourself and giving permission to the provider to pass this information to the Deputy Governor.

If you report a concern via the FairCall service the provisions of the Public Interest Disclosure Act 2013 (Cth) will not apply.

7.3 Who do I speak to for more information?

In general, if you have any questions or concerns relating to the Code or its application, contact your manager, Head of Department or relevant Governor.

For more general enquiries or clarification about the Code or associated documents, contact the HR Service Desk in the first instance, or otherwise the Head of Employee Relations & WHS (HR).

Appropriate use of position Head of Department or relevant Governor
Avoiding conflicts of interest Head of Department or relevant Governor
Avoiding Discrimination, harassment and workplace bullying Manager or Head of Department or the Head of Employee Relations & WHS (HR) or Grievance Contact Officer
Bank property, information and resources Information Technology Department, Facilities Management Department
Breaches of the Code Supervisor, Head of Department, the Head of Human Resources, the Assistant Governor (Financial System), the Deputy Governor or the Governor, FairCall Service
Confidential, sensitive, privileged, personal or protected information Head of Department or relevant Governor
Drugs and alcohol Head of Department or relevant Governor
External Presentation and Publication Policy Head of Department
Fair dealings with third parties Head of Department or relevant Governor
Gifts, hospitality and other benefits Head of Department or relevant Governor or Secretary's Department
Involvement in other employment Head of Department or relevant Governor
Media comment and use of social media Secretary's Department
No bribery or corruption Deputy Governor
Obscene or abusive language, materials or messages Head of Department or relevant Governor
Safe work environment Head of Employee Relations & WHS (HR)
The Bank's information and communications technology systems (ICT Assets) Information Technology Department
Transacting in financial instruments Head of Department or relevant Governor

Illustrative Questions

To assist your understanding of the way this Code operates, answers to some frequently asked questions are included below. These are intended to illustrate the way this Code might work in a particular case and are not exhaustive. The particular circumstances in one case may lead to a result that is different from another, even though in some respects the two cases might appear similar.

Harassment

Q. I have noticed that a colleague regularly greets a new employee in our section with comments like ‘Hi Sweetheart’, and asks her personal questions about her social life. The new employee is obviously uncomfortable about this. Should I confront the colleague and let him know the impact his conduct is having?

A. This is a serious matter that might have a substantial impact on both parties. You should let your manager or Head of Department know so that she or he can determine how to deal with the situation having regard to any other factors that may be relevant. You should not seek to address the situation yourself.

Social Media

Q. I just joined the Bank and some of my new colleagues invited me to be friends with them on Facebook. Since accepting their friendship on Facebook, I have seen that they have been posting derogatory comments about our manager. I am worried that if I de-friend them on Facebook they will start saying offensive things about me too. I don't want to make a formal complaint about them as I don't want to make enemies at work. What should I do?

A. This is a serious matter that might have a substantial impact on those individuals involved and also on the reputation of the manager and the Bank. You should report this to your Head of Department or relevant Governor. At the time of reporting this, you should let your desire to keep your name confidential be known.

Other Employment

Q. I have been asked to tutor two evening economics classes per week by the University of Sydney. I am interested in taking this additional employment but I am not sure if it falls outside of the Code. What should I do?

A. Although working as a tutor for a university is unlikely to create a conflict with your duties to the Bank or impact on your obligations to the Bank, you should nonetheless inform your Head of Department or the relevant Governor before accepting this offer of paid employment. If you are authorised to undertake this work, you will be required to make it clear that you are doing it in your personal capacity and not as a representative of the Bank. You also need to ensure that any outside work you perform does not adversely affect your ability to perform your duties at the Bank.

Hospitality

Q. I have dealt with Jenny Lo from XYZ Pty Ltd (a consulting company) for many years. She has invited me to her retirement lunch. Her colleague, who will be taking over her role, will also be there. The meal is likely to cost over $100 per head. What should I do?

A. Any hospitality that you receive in the course of relationship building normally must not exceed $100 in value. You need to consider this carefully and seek guidance from your Head of Department or the relevant Governor in circumstances where it could be detrimental to a business relationship to decline such an offer of hospitality. If accepting hospitality could, or could be seen to, involve a conflict between your interests and your duties to the Bank, you must discuss the situation with the relevant Head of Department or Governor. This might be the case, for example, if the Bank is about to tender for consulting services and XYZ Pty Limited is a likely tenderer.

Conflict of Interest

Q. I have been asked by the Bank to manage a tender process to find an appropriate supplier of a new IT system for the Bank. Through the process, I became aware that the director of one of the companies that has been shortlisted as a potential supplier is best friends with my wife. I am worried that it may look as though I have not acted fairly, should this company be the chosen supplier. What should I do?

A. You must ensure that when you are involved in procurement on behalf of the Bank, you declare any actual or perceived conflict of interest. You must immediately contact your Head of Department or the relevant Governor to ensure that the conflict of interest is appropriately declared and associated control measures are identified and implemented. In this situation your wife's close friendship with the director is a ‘material personal interest’ that must be declared.

Transactions during the Blackout Period

Q. I have just agreed to buy a house and need to liquidate part of my share portfolio to raise enough money for the deposit. The deposit needs to be paid during the blackout period. Is this in breach of the Code? What should I do?

A. You should discuss this with your Head of Department or the relevant Governor. It is likely that he or she will require you to set out your situation in writing.

Discussions during the Blackout Period

Q. I have a friend who keeps asking me questions about the next interest rate decision, both in person and on Facebook. I know the Blackout Period is in effect. I am not sure how I should respond. What should I do?

A. As a result of your position with the Bank, you may have access to information that is not publicly available. You must not profit, or enable others to profit, from information available to you which is not publicly available. You should not discuss any information which can be perceived to be non-public information, whether in person or on social media. Additionally when using social media, you must ensure that your communications do not lead to any unauthorised disclosure of the Bank's operations or views. You should tell your friend to stop asking these questions. If your friend continues with these requests you should discuss this with your Head of Department or the relevant Governor.

Confidential Information

Q. I left my laptop on the plane. It has various files on it containing confidential Bank information. I don't want to tell my supervisor, because she will be very upset. What should I do?

A. Your duty is to protect the Bank's confidential information. You need to report breaches of this Code to your Head of Department or relevant Governor and take steps to protect against disclosure of the Bank's confidential information. You should inform your Head of Department or relevant Governor as soon as possible, and (if you have not already done so) contact the airline to see if the laptop has been handed in.

Unethical Behaviour by a Third Party

Q. I have been dealing with a third party provider on a project for the last year or so. One of the employees of the company has told me that they have been falsifying invoices on another non-Bank project in order to get additional ‘performance payments’ because they think they are underpaid. This person works closely with me on the Bank's project. This worries me. What should I do?

A. This is unethical behaviour because the employee of the company is falsifying information and dishonestly obtaining a benefit from their employer. This should be raised with the Deputy Governor or reported to the FairCall service as soon as practicable.

Bribery and Corruption

Q. I chair an international policy working group. The working group has been developing a set of important recommendations. One vocal and influential member of the working group (a senior executive at another central bank) is opposed to one of the key recommendations that I and the senior members of my department at the Bank believe is critical to achieve the desired policy outcome. After one working group meeting this senior executive pulls me aside and suggests that if I could help his son get into a school in Australia he will change his stance on the key recommendation and support it. He needs a letter from the Bank inviting his son to undertake work experience with the Bank in Australia so that his son can get a visa. He asks if I could use my personal bank account to pay a deposit to the school, with a promise to pay me back. I would like to help him out whether or not he changes his mind about the recommendation. What should I do?

A. If you provide assistance with a visa and school admission you are providing something of value to the senior executive, who is a foreign public official. Given he is currently influential on the working group the assistance that he has requested could be a breach of anti-corruption law and should not occur in these circumstances.

Theft and Fraud

Q. I work in an area of the Bank that handles cash. I am concerned that one of my colleagues is taking cash and falsifying the records of cash receipts to cover this up. What should I do?

A. You should report your concerns immediately to your Manager or Head of Department. Alternatively this could be reported through the FairCall service. This matter will be fully investigated and possibly be referred to the police. If founded, this would constitute serious misconduct. In addition to any criminal charges which may be laid, the employee’s employment will potentially be terminated without notice.

Endnotes

Employees of the Bank; those who occupy a position (as a contractor, consultant, agency employee or otherwise) within the organisational structure of the Bank; those who have access to the information and communications technology systems of the Bank and have been informed that they are required to comply with some or all of this Code; and contractors, consultants or visitors to the Bank who have been informed that they are required to comply with some or all of this Code. [*]

Depending on the nature of the gift, and subject to the Secretary's approval, the gift may be donated to the Benevolent Fund or returned to the recipient. [1]