The case for CSR/ Sustainability Reporting Done Responsibly


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Home / case studies / Case study: How ANZ promotes fairness and ethical conduct

Case study: How ANZ promotes fairness and ethical conduct

Headquartered in Australia, ANZ provides banking and financial products and services to approximately eight million retail, commercial and institutional customers in 34 markets around the globe, striving to behave fairly and responsibly so as to meet the expectations of customers, employees and society.

This case study is based on the 2017 Corporate Sustainability Review by ANZ published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Creating and maintaining an ethical corporate culture of fairness and transparency, is ANZ’s top priority.  Tweet This! In order to promote fairness and ethical conduct ANZ took action to:

  • promote responsible behaviour through a range of policies
  • provide ethics training for employees
  • implement a Whistleblower Policy

What are the material issues the company has identified?

In its 2017 Corporate Sustainability Review ANZ identified a range of material issues, such as fraud and data security, digital innovation, customer experience, responsible business lending. Among these, promoting fairness and ethical conduct stands out as a key material issue for ANZ.

Stakeholder engagement in accordance with the GRI Standards

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The organization should identify its stakeholders, and explain how it has responded to their reasonable expectations.”

Stakeholders must be consulted in the process s of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups ANZ engages with:

Stakeholder Group                Method of engagement


·         ‘Your Say’ Research Community online customer panel

·         Customer research and focus groups

·         ‘Voice of Customer’ platform

·         Customer Advocate Office

·         Complaints Resolution Centre

·         Social media

·         Australian Bankers’ Association (ABA) survey of trust in banks and banking industry reform program



·         ANZ Jam, a bank-wide digital conversation, engaging employees about ANZ’s purpose and values

·         ‘My Voice’ pulse survey of employee engagement

·         ‘ANZ Way’ People Leaders’ quarterly webcasts with CEO and Executive Committee members

·         ‘ANZ Way’ Podcast series

·         Direct communication and formal twice-yearly performance appraisals with line managers

·         ANZ intranet, MAX, a resource for employees to receive updates and information about developments and initiatives at ANZ

·         ANZ’s internal collaboration tool, MAX Connect, which connects ANZ’s people in real-time

·         Meetings with the unions representing ANZ employees, including the Finance Sector Union of Australia and FIRST Union in New Zealand

·         ABA survey of employees about trust in banks and banking industry reform program

Shareholders ·         Results briefings

·         Strategy briefings and other market updates

·         Annual General Meeting

·         Disclosure documents, including results announcements, investor presentations, annual reports and other ASX lodgements

·         Electronic communications and webcasts

·         Dedicated ANZ shareholder website

Government and regulators ·         Regular meetings with political stakeholders, officials and regulators by ANZ’s CEO and senior executives

·         Submissions to parliamentary committee inquiries and other government and regulatory consultations

·         Participation in industry engagement and forums

·         Meetings with trade negotiators regarding free trade agreements

·         Providing information and technical advice on international practices to regulators in developing countries

·         Meetings with departmental representatives responsible for implementation of programs aligned with or co-funded by ANZ

Industry associations ·         Participated in the development and implementation of the industry consumer protection reform program in Australia

·         Participated in industry discussions about sector issues and broad industry strategy

·         Participated on the Business Council of Australia’s (BCA) climate change policy working group

·         Provided input into industry association responses to parliamentary inquiries and government consultations

Non-government organisations (NGOs) ·         Direct engagement with relevant human rights, consumer and environment NGOs and academics

·         Regular engagement with peak bodies for professional community services such as financial counselling

·         Regular partnership meetings with community organisations delivering MoneyMinded, Saver Plus and MoneyBusiness programs

·         Engagement with NGOs providing oversight of key social commitments such as ANZ’s Reconciliation Action Plan, Accessibility and Inclusion Plan and Financial Inclusion Action Plan

·         A regular program of CEO and senior executive meetings with civil society leaders to exchange ideas and discuss material social, economic and environmental issues of mutual interest

·         Consultation with a wide variety of external stakeholders to refine ANZ’s approach to its purpose and with particular focus on financial wellbeing, environmental sustainability and housing

·         External steering committees for flagship programs and research related to financial capability and wellbeing

How stakeholder engagement was made to identify material issues

To identify and prioritize material issues ANZ carried out a survey among stakeholders, asking them to rank issues according to their importance. In addition, ANZ conducted one-on-one interviews with 25 stakeholders – 13 internal and 12 external stakeholders –, to inform its understanding of the current and future context of each issue.

What actions were taken by ANZ to promote fairness and ethical conduct?

In its 2017 Corporate Sustainability Review ANZ reports that it took the following actions for promoting fairness and ethical conduct:

  • Promoting responsible behaviour through a range of policies
  • ANZ implements a range of policies to detail expectations of employee behaviour, both internally and externally. These policies are regularly reviewed to make sure they reflect changes in legislative requirements and include the company’s:
    • Anti-Money Laundering and Counter-Terrorism Financing Policy
    • Economic and Trade Sanctions Policy
    • Use of Systems, Equipment and Information Policy
    • Fraud Policy
    • Expense, Travel and Entertainment Policy
    • Equal Opportunity, Bullying and Harassment Policy
    • Health and Safety Policy
    • Conflict of Interest Policy
    • Trading in ANZ Securities Policy
    • Trading in Non-ANZ Securities Policy
    • Anti-Bribery and Anti-Corruption Policy
    • Whistleblower Protection Policy
  • Providing ethics training for employees
  • All ANZ employees and contractors have to complete ANZ’s Essentials training courses, which comprise the following:
    • Living the Code: by completing this course, participants confirm they understand and have complied, in the past 12 months, with the principles of ANZ’s Code of Conduct
    • Equal Opportunity Essentials
    • Compliance (Compliance Essentials, Anti-Money Laundering, Operational Risk Essentials)
    • Preventing Fraud, Bribery and Corruption
  • Implementing a Whistleblower Policy
  • ANZ developed its Whistleblower Policy to make sure that every employee, contractor and external auditor can raise concerns about actual or alleged breaches of ANZ’s ethical and legal standards freely and without fear of repercussions. The policy provides various avenues for raising such concerns, internally through a Whistleblower Investigations Officer (WIO) and externally through confidential phone, email and web-based mechanisms, operated by a third party.

Which GRI Standards have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 102-16 Values, principles, standards, and norms of behavior

2) Disclosure 102-17 Mechanisms for advice and concerns about ethics

3) Disclosure 205-2 Communication and training about anti-corruption policies and procedures


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

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1) This case study is based on published information by ANZ, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:




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