OUR CODE OF COND UCT
ANZ’s Purpose is to shape a world where people and communities thrive. Our people and communities expect us to do the right thing and to exercise goodjudgement. Our Code of Conduct describes how we work at ANZ and sets expected standards of behaviour consistent with our Purpose. The Code supports
our Values of Integrity, Collaboration, Accountability, Respect and Excellence and helps us to make fair, balanced and ethical decisions in our day-to-day work.
It is important to understand our Code in letter and spirit. The Code applies to all employees, contractors and consultants working for the ANZ Group.
Code guiding principle

This means that we…

WE ARE ETHICALAND PROFESSIONAL• Are trustworthy and create confidence and goodwill
with customers• Always put the interests and needs of customers first whenproviding advice on products and services• Undertake our duties with care and diligence and always
consider the risks to our customers, communities and ANZ.
• Help protect ANZ, its customers and our community against
financial crimes including fraud, tax evasion, money laundering,terrorist financing or breaches of economic sanctions• Never engage in anticompetitive conduct• Behave professionally and appropriately at work and workrelated functions• Only provide advice to customers that we are qualified andauthorised to provide• Never engage in conduct (including outside of work) that may
cause damage to ANZ’s reputation or is incompatible with
our employment at ANZ. This includes communications orstatements on social media or in other forums

WE ACT WITH
INTEGRITY• Are honest and transparent in our dealings with others• Never act illegally or conceal breaches of the law or ourCode (or help anyone else to do so)• Use ANZ technology, systems, assets, information and funds
appropriately and for approved purposes• Ensure any expenditure is allowable and reasonable (and if you
are a people leader ensure that you appropriately monitor thediscretionary expenses of your team)

WE TREAT ALL PEOPLE
WITH DIGNITY AND RESPECT• Treat customers, colleagues, suppliers and other stakeholders
with respect and dignity• Value diversity and difference and never harass, bully or
unlawfully discriminate• Make employment decisions based on merit• Create a safe working environment. If we see something –we do something

Last updated 22 August 2024.

21646

OUR CODE OF COND UCT
Code guiding principle

This means that we…

WE MANAGE CONFLICTS
OF INTEREST• Don’t make or receive improper payments, benefits or gains• Never do anything that puts, or appears to put, a personal
interest before those of customers or ANZ• Never view, maintain or perform transactions on our own
accounts or those of friends or relatives• Disclose relationships, or associations with customers, suppliers
or other parties (including colleagues) that might give rise to aconflict of interest• Obtain approval for and record all donations, sponsorships, orfinancial contributions• Only accept gifts, reward or entertainment in line with ANZ policy• Never trade in securities with inside information, or pass suchinformation to others• Seek approval for any non-ANZ work (paid or unpaid), businessinterest or directorship

WE PROTECT PRIVACY AND
CONFIDENTIALITY• Only collect, access, use and disclose confidential or personal
information for legitimate business purposes, whereauthorised, or as required by law• Don’t access or view any customer accounts unless it isnecessary for legitimate business purposes• Only provide confidential or personal information to other
employees where it is required for work purposes• Never allow others to log on to ANZ systems using ourpersonal credentials• Always follow ANZ’s information handling and security
procedures

WE COMPLY WITH OUR CODE,
THE LAW AND ANZ POLICIESAND PROCEDURES• Know and comply with all laws, policies (including policy
requirements and standards) and procedures that apply toour roles• Complete all mandatory training as directed by ANZ• Seek guidance if unsure whether or how a particular law, policy
or procedure applies• Immediately disclose any criminal charges or convictions toline management

WE CALL OUT UNACCEPTABLEBEHAVIOUR AND STAND UP
FOR WHAT IS RIGHT• Immediately report any unacceptable, dishonest orunethical behaviour by others (including colleagues,customers or suppliers)• Make sure people feel safe to speak up, encourage themto do so and don’t victimise anyone who does• Report suspected breaches and concerns to your people
leader, People Assist, Operational Risk and Compliance orto the Whistleblower Program (contact details are in theWhistleblower Policy). If we see something –we say something

OUR CODE OF COND UCTOur Code does not anticipate every situation. If unsure, ask yourself – is this aligned with our Purpose and Values? Is it legal? Is it ethical? Use the following‘Conduct Sense-Check’ questions to assist with the thinking behind your everyday decisions and actions.
You may also use ANZ’s Ethical Decision Making Framework to help guide your decisions, especially if you are facing a complex situation.

’ TO AL L OF
CA N YO U ANSW ER ‘Y ES
Would I be
comfortable speaking
publicly about this?
Am I
being clear andauthentic?

T HE BE LO W…?

NO/ NOT SUR E
Will theconsequences ofmy actions drivea fair customer
outcome?
Am I complying with
ANZ’s policies andprocedures?

If you’ve answered ‘No/Not Sure’to one or more of these questions,seek advice from:• Your People Leader• People Assist• Legal• Operational Risk and/or Compliance• Whistleblower Program

YES
If you’ve answered Yes toall of the questions, then it’s
likely that you are aligned
to ANZ’s Code of Conduct,
Purpose and Values.

How are breaches dealt with? Reported breaches of the Code will be investigated and if substantiated will result in action being taken, which can include
formal warnings or termination of employment. No one wants to see that happen, so please treat our Code seriously.

OUR CODE OF COND UCTMORE INFORMATION ABOUT SOME OF YOUR KEY OBLIGATIONSCAN BE FOUND IN THE FOLLOWING POLICIES:ALL STAFF POLICIESANZ STAFF POLICIES• Conflict of Interest Policy• Anti-Bribery andAnti-Corruption Policy• Customer Tax TransparencyPolicy

SUNCORP BANK STAFF
POLICIES AND STANDARDS• Anti-Bribery andCorruption Policy• Equal Opportunity, Bullying
and Harassment Policy• Anti-Money Launderingand Counter-Terrorism
Financing Policy• Expense Policy• Sanctions Policy• Anti-Money Laundering,Counter-Terrorism Financing
and Sanctions Policy• Trading in ANZ Securities Policy• Competition Policy• Competition Risk Policy• Trading in Non-ANZSecurities Policy• Data Management Policy• Data Governance Standard• Fraud Policy• Anti-Fraud Policy• Use of Systems, Equipmentand Information Policy• Information Security Policy• Security Management Policy• Privacy Policy• Privacy Management Policy• Wellbeing and Safety Policy• Whistleblower Policy

IF YOU ARE A PEOPLE LEADER OR MANAGE,
SUPERVISE OR DIRECT THE WORK OFOTHERS, WE ALSO EXPECT THAT YOU:
• Lead in accordance with ANZ’s purpose andour behaviours• Role model the behaviour we expect under
the Code and our Values• Set clear expectations for your team about
the standards of behaviour required under
the Code and the potential consequences of
unacceptable behaviour• Are accountable for ensuring that the actions
and decisions of your team are consistent with
the Code and ANZ’s Values• Promote speaking up and ensure that yourpeople feel safe to raise any issues or concerns• Identify any breaches of the Code andaddress these in accordance with ANZ policies
and processes