Code of Conduct for Reserve Bank Staff

Note: Definition of Staff^[*]

1. Purpose

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.

As an employee of the Bank, or as someone who is involved in the Bank's activities in some other capacity, you are required to act consistently with these core values.

1.2 Who does this policy apply to?

This Code applies to you if you:

• are an employee of the Bank;
• occupy a position (whether as a contractor, consultant, agency employee or otherwise) within the organisational structure of the Bank;
• 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 When does it apply?

This Code applies to all of your dealings with people in the course of or in connection with your work for the Bank. This includes dealings that occur remotely or in person, verbally, in writing, or electronically and may include conversation, social media, instant messaging, email, telephone, video or on screen savers.

This Code applies regardless of where these activities occur, including at any Bank premises, where working remotely and at work-related social events. It also extends to work-related dealings that occur outside normal working hours and any circumstances where your behaviour is likely to be associated with or reflect on the Bank.

1.4 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.

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

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;
• have a personal or financial relationship with someone who is dealing with the Bank; or
• have a personal relationship with someone in your reporting line. 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 or could be perceived to exist, you must discuss the details of the interest with your Head of Department or relevant Governor. In the case of issues relating to personal relationships, you must discuss the details of the interest with the Head of Human Resources.

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, associates 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).

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 judgement 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 of a suitable candidate 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.

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 as soon as practicable to the Deputy Governor or report it through the FairCall service as outlined in Section 5 of this Code.

See also the Fraud Control Policy and the Reporting Wrongdoing 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 without permission.

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.

You should inform your Head of Department or relevant Governor of any other employment or external business activity you are considering accepting before undertaking it, and obtain their explicit approval for any exception to this policy.

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 relevant Governor.

You must always adhere to the Procurement and Disposal 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 or your Assistant Governor when the benefits are provided as part of university-based study or employment and made available to other students and staff.

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 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 $100 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 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 engage in insider trading^[2], nor gain, or seek to gain, a benefit or advantage for yourself or anyone else from information available to you that is not publicly available.

If you are satisfied that a proposed transaction is in accordance with this requirement, but that there is a possibility that other people might reasonably think that you could be gaining a benefit by virtue of your access to information, you should discuss the transaction with your Head of Department or relevant Governor before proceeding.

In addition to these general rules, 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 or person whose affairs 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. Role specific requirements
   

   If you are in:

   • Domestic Markets Department (excluding FMBSS), you must not transact in Funding Investments^[3] issued by:
     • 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,

     unless the relevant transaction is authorised in writing in advance by the Assistant Governor (Financial Markets);

   • Financial Stability Department, you must not transact in Funding Investments issued by an entity^[4] regulated by the Australian Prudential Regulation Authority (APRA) unless the relevant transaction is authorised in writing in advance by the Assistant Governor (Financial System);
   • Payments Policy Department and you are involved in supervision and oversight of the clearing and settlement facility licensees owned by ASX Limited or otherwise have access to confidential information about those licensees and other members of the ASX Limited Group, you must not transact in Funding Investments issued by ASX Limited unless the relevant transaction is authorised in writing in advance by the Assistant Governor (Financial System); or
   • Economic Analysis Department and you work in or have oversight of the Regional and Industry Analysis Section, you must not transact in Funding Investments issued by an entity whose confidential information you have obtained or have access to in the course of your work, unless the relevant transaction is authorised in writing in advance by the Assistant Governor (Economic).

   If you seek authorisation from an Assistant Governor, you cannot expect to receive approval if the Assistant Governor forms the view that the transaction is related to the management of your investment portfolio. Accordingly, approval is unlikely to be granted, for example, to enter into a security purchase plan or dividend or distribution reinvestment plan (or terminate any such plan entered into before you joined the relevant Department or Section). Approval would be considered, subject to conditions, for a sale to fund the purchase of a major asset, such as a house, provided that the transaction does not meet the test for insider trading.

   Before you move into a role where you will be subject to one of the above restrictions, it is important that you consider and, if necessary, re-arrange, your financial affairs taking into account the fact that once in the role you will not be able to transact in Funding Investments of relevant entities without approval.

2. Derivatives

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

3. Active trading

   Neither you nor any entity you control or person whose affairs 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.

4. Blackout periods
   

   The Bank has a Blackout Period in which you and any entity you control or person whose affairs 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, share futures, warrants, options, corporate bonds, foreign exchange (except for travel purposes), and active investment choice modifications to any superannuation fund account. 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 2.30pm (Sydney time) on the Wednesday prior to the monthly meeting of the Reserve Bank Board and ends at 2.30pm (Sydney time) on the Tuesday on which that meeting is held. During this Blackout 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 should approach your Head of Department or relevant Governor for guidance.

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 External Communications team. 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 damage the reputation of the Bank or its staff, or otherwise breach this Code.

See also the Media Policy, including Social Media.

2.11 External Presentation and Publication Policy

The Bank seeks to ensure that its intellectual property and communications objectives are managed properly. As a general rule, you must obtain approval from your Head of Department or relevant Governor before seeking to present or publish (including republish) content externally. In addition, there are specific rules for public appearances and education audiences outlined in the External Presentation and Publication Policy. This applies to all staff and those holding positions at the Bank, including those on extended leave with or without pay. Before agreeing to present or publish externally, you should consider and discuss with your Head of Department or relevant Governor. These issues are outlined in the External Presentation and Publication Policy.

3. Personal Conduct

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 your colleagues and everyone you deal with in the course of any work- related activity with respect and courtesy. The specifics of this requirement may vary from one situation to another, and will include:

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

These requirements apply in all of your dealings with people in the course of or in connection with your work for the Bank, including those that occur face-to-face, in writing, on Bank systems, on any form of social media, outside of normal working hours or in relation to non-work matters.

See also Information Systems Security and Acceptable Use Policy and the Media Policy, including Social Media.

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.

3.4 Avoiding discrimination, harassment and workplace bullying

Your work environment and relationships with others should be free from unlawful discrimination, harassment and workplace bullying where:

• Unlawful discrimination involves treating someone less favourably because of a person's sex, age, gender identity, disability, race, religion, sexual orientation or ethnic background. This includes establishing unreasonable conditions which imposes a requirement or condition which a person with a protected attribute is not able to comply with and which disadvantages that person.
• Harassment involves any form of unreasonable and unwelcome behaviour that offends, humiliates or intimidates another person. It may involve repeated or isolated behaviour.
• Workplace bullying involves one or more person repeatedly behaving unreasonably towards another person, and that behaviour creates a risk to physical or mental health and safety.
• Sexual harassment involves unwelcome conduct of a sexual nature in circumstances where a reasonable person would anticipate the possibility of the person harassed being offended, humiliated or intimidated. Sexual harassment can include conduct such as:
  • Inappropriate staring, leering or loitering
  • Unwelcome touching
  • Persistent unwanted invitations to go out on dates
  • Unnecessary familiarity, such as deliberately brushing up against a person
  • Intrusive questions or comments about a person's private life or body.

  Visit Fair Work Commission for full definition of Sexual Harassment.

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 the other person concerned directly, as they may not be aware that their behaviour troubled you;
• discuss your concerns with your manager, Head of Department, the Head of Employee Relations (Human Resources) or a Speak Up Network member if you do not feel comfortable raising these matters directly or you raise them directly and the behaviour continues;
• raise a formal concern as outlined in Section 5 of this Code;
• report such conduct through the FairCall service as outlined in Section 5 of this Code; or
• in the case of workplace bullying or sexual harassment, apply to the Fair Work Commission for an order to stop the bullying or sexual harassment.

A relationship with a work colleague in which you both genuinely welcome the attention of the other will not constitute sexual harassment. However, if the relationship is between people of different levels of seniority or people in the same team then it is important to ensure that each person genuinely welcomes the attention of the other and that potential conflicts of interest are managed. If the people in the relationship work together or there is a potential conflict of interest, they should disclose the relationship to the Head of Human Resources.

If you witness this conduct being directed to someone else, you should raise this matter as soon as practicable using one of the avenues referred to in Section 5 of this Code.

See also the Workplace Behaviour Policy, Reporting Wrongdoing Policy and Workplace Concerns Handling Procedure.

3.5 Obscene or abusive language, materials or messages

Obscene, abusive or disrespectful language, materials or messages are not acceptable in the course of your activities to which this Code applies. 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) and you are offended by it, you should 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 Information Systems Security and Acceptable Use Policy and the Media Policy, including Social Media.

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 that is given by the Bank - this includes arrangements and activities at any non-Bank premises (such as your home) where you may perform work including recreational activities such as the Interdepartmental Fun Run and other sporting activities; and
• cooperate with any reasonable policy or procedure of the Bank relating to health or safety 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 or relevant Governor.

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.

3.8 Criminal convictions and bankruptcy

It may be inappropriate for a person who has been convicted of certain criminal offences or who has been declared bankrupt to occupy certain roles in the Bank.

If you are convicted of a criminal offence, or bankruptcy proceedings have been commenced against you, you must report these matters to your Head of Department or the relevant Governor.

4. Bank Property, Information and Resources

4.1 Bank property, information and resources

The Bank's assets (including data, information, 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, its assets, you must:

• adhere to the Bank's safety and security practices and procedures;
• alert your manager if you become aware of any intrusion or other security threats or of any inappropriate use of the assets; and
• appropriately maintain the confidentiality, integrity and availability of the assets.

In using the Bank's assets, 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 Information Systems Security and Acceptable Use Policy.

Your use of the ICT Assets may be monitored in accordance with the Bank's Information Systems Security and Acceptable Use 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 Safeguarded 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;
• price sensitive, that is, which if it were generally available would reasonably be expected to have a material effect on the price or value of shares or other financial instruments (see Section 2.8(a));
• 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, no matter whether this information is the Bank's or a third party's:

• 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 information to which you have access in the course of your employment with the Bank, 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

5.1 Context and protections

It is important that the Bank is made aware of and investigates any potential breaches of the Code. It is also important that staff feel safe reporting any potential breaches. This section provides details on the range of options available to staff and the protections that are available.

5.2 How to raise a concern

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 aware of any conduct in breach of this Code, you are required to report it as soon as practicable. The Bank has established a number of formal avenues for you to raise concerns. These include raising your concerns with:

• your manager;
• your Head of Department;
• your Assistant Governor;
• an HR Business Partner;
• the Head of Employee Relations;
• the Head of HR;
• through the FairCall Service at https://rba.kpmgfaircall.kpmg.com.au/.

The FairCall Service is made available through a specialist independent provider, KPMG. Any concerns raised by this service are reported to the Deputy Governor. Reports to the FairCall Service can be made without disclosure of personal details, however, the option is also provided for the person to identify themselves and give permission to the provider to pass this information onto the Deputy Governor.

If you become aware of any conduct that is in breach of the Code and you want to have protections under the Public Interest Disclosure Act 2013 (Cth) (PID Act), then you should report your concerns by informing:

• your supervisor;
• the Chief Risk Officer;
• Andrea Brischetto (currently Head of Financial Stability);
• the Deputy Governor; or
• the Governor.

This can be done in person, by telephone or in writing, including by emailing one of these people directly or sending an email to disclose@rba.gov.au. The report can be made anonymously.

If you report a concern via the FairCall service the provisions of the PID Act will not apply.

Concerns about an Authorised Officer (including the Governor) or the Head of Human Resources should be referred directly to the Deputy Governor or another Authorised Officer. A serious allegation about the Governor should be referred to the Reserve Bank Board by the Deputy Governor (who should be notified of any such allegation by any other Authorised Officer to whom it is reported or referred).

The Reporting Wrongdoing Policy also contains details of how to report a concern in the course of your work at the Bank.

5.3 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.

5.4 Investigation of complaints or breaches

In most cases, it will be necessary for the Bank to investigate complaints or alleged breaches of this Code. An investigation involves collecting information about the complaint to determine what has occurred and how best to respond to it. A concern may be investigated by Human Resources, another suitable person from within the Bank, or by an external investigator. 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 PID Act applies, the requirements of that Act.

The person raising the concern and the person(s) to whom the concern relates to may be required to not report for work during the period of an investigation (with no loss of pay or other conditions) if the Bank considers this to be appropriate to undertake an effective investigation and to protect the individuals involved. Alternatively, the Bank may provide the persons involved with alternative duties during the investigation with no loss of pay or other conditions.

6. Code Management

6.1 Administration

This Code is administered by Human Resources.

6.2 Implementation

All staff with executive and managerial responsibilities are accountable for creating a culture and for managing workplace behaviour consistent with this Code.

6.3 Monitoring and review

The Code is reviewed annually by Human Resources.

Changes to the Code must be approved by the Risk Management Committee and the Executive Committee.

7. Resources

All related documents can be found in the Human Resources Policy Governance Register.

7.1 Reserve Bank

Policies

• Fraud Control Policy
• Reporting Wrongdoing Policy
• Procurement and Disposal Policy
• Media Policy, including Social Media
• External Presentation and Publication Policy
• Information Management Policy
• Information Systems Security and Acceptable Use Policy
• Workplace Behaviour Policy
• Work Health & Safety Policy

Procedures

• Disclosure of Material Personal Interests – Instructions
• Public Interest Disclosure Act Procedures
• Workplace Concerns Handling Procedure

Guidelines

• Gifts, Hospitality and Other Benefits Registers – Guidelines
• Privacy Guidelines
• Protected Information, Protected Documents and Maintaining Confidentiality – Instructions

Frameworks

• Protective Security Framework

8. 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 (HR). The following summarises contact details for specific issues.

9. 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.

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.

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 they 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 relevant Governor.

Restrictions on Trading

Q. I am working in DM. Before I joined DM I bought some bank shares and I still hold them. I would like to opt into a newly announced dividend reinvestment plan. Is this something I am allowed to do?

A. No, it is not appropriate for you to engage in any investment activity relating to your shares at any time while you are in your role, including voluntary participation in dividend reinvestment.

Before staff move into a role where they will be subject to a restriction on transactions in financial instruments, it is important that they consider and, if necessary, re-arrange, their financial affairs taking into account the fact that once in the role they will not be able to transact in financial instruments of relevant entities.

Q. I work in IT and provide support to FS relating to its database of information about banks that has been provided by APRA. I have just exchanged contracts on a new house. I have shares in a bank and would like to sell them to partly fund the purchase of the new house? Am I allowed to do this?

A. In your role you may have access to confidential information about banks. If the way you support the database means that you don't in fact have access to any confidential information, then you should speak to the Assistant Governor (Financial System) before you sell the shares. If the sale will be during the Blackout Period you will need permission, but even if it is outside the Blackout Period you should, for your own protection, discuss the sale and your role in supporting the database first to avoid any perception that you might have, and be using, confidential information.

If you do have access to confidential information you must not engage in insider trading or gain, or seek to gain, a benefit or advantage for yourself or anyone else using that information.

Q. I am working in Regional and Industry Analysis and have been engaging in liaison activities that have involved discussions about longer term planning in the mining industry. I have learned some highly confidential information about a planned divestment of a significant asset by a mining company that will likely affect the market price of shares in that mining company. I am administering the affairs of my elderly mother under a power of attorney and she holds shares in that mining company. She needs some cash and so I am thinking that I will sell her shares. That won't be a problem, will it?

A. Yes, that would be a problem – it would be illegal. Even though the shares are not in your name, you are the decision maker. You cannot sell or arrange a sale while you have information about that mining company that is not generally available, but which, if it were generally available, would likely have a material effect on the price or value of the company's shares. The Assistant Governor (Economic) would not be able to approve the sale until after the planned divestment was publicly announced.

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 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 generally must not exceed $100 in value. You need to consider this carefully and seek guidance from your Head of Department or 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 relevant 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 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. See Disclosure of Material Personal Interests – Instructions for more guidance.

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 they 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.

Respect and courtesy

Q. My work colleagues have set up a Facebook Group to share photos and comments about their non-work activities. I recently posted some photos of a cultural festival I attended. A couple of team members made disparaging comments about the event and the clothing I was wearing. These comments have upset me and made me feel I don't really fit in.

A. Staff (and others covered by the Code) are required to act with respect and courtesy. This applies when engaging with colleagues on social media platforms and in other settings, even if the subject matter is not work-related. Members of this Facebook Group should act with care and consideration for the feelings of others, and avoid antagonistic or harsh comments towards each other. Concerns about conduct like this can be raised with your Manager or with your HR Business Partner.

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 staff 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.

See also the Fraud Control Policy and the Reporting Wrongdoing Policy.

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.