Code of Conduct Policy¶


Code	`PPL-001`
Domain	People & Culture
Owner	Chief People Officer
Status	Draft
Applicability	External — Code of conduct for the operating entity's own employees. Managed through HR and people management processes external to the platform.
Jurisdiction	NZ + AU
Business domain	BD11
Review date	2027-03-25

Outside platform boundary

Code of conduct for the operating entity's own employees. Managed through HR and people management processes external to the platform.

Regulations: CoFI Act 2022 · NZ Employment Relations Act · Fair Work Act 2009 ¶

Purpose¶

This policy establishes the behavioural standards and ethical obligations that all employees, directors, contractors, and secondees of the bank must meet in the conduct of their duties. It protects the bank's integrity, its customers, and its regulatory standing across New Zealand and Australia.

Scope¶

This policy applies to all individuals engaged by or on behalf of the bank, including permanent and fixed-term employees, temporary workers, contractors, and non-executive directors. It covers conduct in all work-related contexts, including remote work, client interactions, and the use of bank systems and communication channels.

Policy statements¶

The bank operates with the expectation that all personnel act with honesty, integrity, and professionalism at all times. This policy records the minimum standards required and the obligations each individual carries as a condition of their engagement.

All employees SHALL conduct themselves in a manner consistent with the bank's values and in compliance with applicable laws, regulations, and internal policies. Where a conflict exists between commercial interest and ethical obligation, the ethical obligation SHALL prevail.

Employees SHALL not engage in any conduct that constitutes a conflict of interest without prior written disclosure to their manager and, where required, approval from the Chief People Officer or the Board. Conflicts of interest include, but are not limited to, holding external directorships, maintaining financial interests in competitors or suppliers, or participating in transactions that benefit a related party. All disclosed conflicts SHALL be recorded in the conflicts register and reviewed at least annually.

All personnel SHALL comply with the bank's information security and data handling standards. Access to customer data, financial records, and proprietary systems SHALL be used solely for legitimate business purposes and not for personal gain, competitive advantage, or any purpose outside the employee's defined role.

Employees SHALL observe confidentiality obligations in respect of customer information, business strategy, pricing, and any non-public information received in the course of their duties. These obligations continue after the employment relationship ends, in accordance with applicable employment agreements and law.

The bank SHALL not tolerate harassment, bullying, discrimination, or victimisation of any kind. All personnel SHALL treat colleagues, customers, and counterparties with respect and dignity. Employees who experience or observe such conduct SHALL report it through the bank's internal reporting channels without fear of reprisal.

Employees who engage in public communications, including social media activity, SHALL ensure they do not make statements that could be attributed to the bank, disclose confidential information, or bring the bank into disrepute. Employees with social media profiles that reference their employment SHALL make clear that views expressed are personal and not those of the bank.

All employees SHALL complete mandatory conduct training upon onboarding and annually thereafter. Completion records SHALL be maintained to demonstrate regulatory compliance under the Conduct of Financial Institutions Act (NZ) and equivalent obligations in Australia.

Breaches of this policy SHALL be investigated and may result in disciplinary action, up to and including termination of employment. Serious breaches involving regulatory obligations or criminal conduct SHALL be escalated to the Chief People Officer, General Counsel, and, where required by law, to the relevant regulator.

Satisfying modules¶

(No modules assigned yet — manual process)

Part of People & Culture · Governance overview Compiled 2026-05-22 from source/entities/policies/PPL-001.yaml