Code of Conduct for Reserve Bank Staff
Note: Definition of Staff[*]
Message from the Governor
Our vision is to be an open and dynamic central bank, trusted for our analysis, policy, and service delivery. The Code of Conduct is your guide to harnessing our open and dynamic culture and core values in all your actions. It clarifies your responsibilities and the RBAs expectations, ensuring accountability.
The Code sets clear standards for everyone at the RBA, guiding our interactions and decision-making processes. It encourages you to consider the broader impact of your actions on colleagues, the public, stakeholders, and the RBAs reputation.
By prioritising transparency, fairness, and accountability, we ensure that our decisions uphold the highest ethical standards.
Importantly, the Code fosters a culture where every individual can achieve their potential. A thriving central bank depends on diverse perspectives and an inclusive environment. To address complex challenges, we need individuals from varied backgrounds and a safe space for all voices. Our workforce should reflect the Australian community we serve.
We expect our leaders to exemplify the Code in all they do, showcasing our culture and values and supporting others to do the same. They also have the duty to create a supportive environment where everyone feels comfortable seeking help, learning from mistakes, and raising concerns when needed.
Additionally, the Code provides information on resources and contacts to help you find further guidance. This comprehensive document ensures that all RBA employees are aware of their responsibilities and the standards expected of them, promoting a culture of integrity and excellence.
Please use the Code as a compass for your actions and decisions. Embrace our values and open and dynamic behaviours, act with integrity, maintain the highest ethical standards, and voice any concerns you may have.
By doing so, we can foster a workplace where everyone feels empowered to deliver their best.
Michele Bullock
Governor
1. Purpose of the Code
As the Reserve Bank of Australia our role is to serve the community. We strive to deliver our mission of promoting the economic welfare of all Australians through our monetary and financial policies and operations, both now and in the future. We do this through various means, such as setting monetary policy to ensure price stability and full employment, enhancing the efficiency and stability of the payments system and the financial system, and providing banking services to the Australian Government and issuing the nations banknotes. At our core we are guided by our Values, act as an Open & Dynamic central bank, and seek to continually enhance the quality of our analysis, policy, and service delivery.
Our community relies on us to act with integrity and to serve the best interests of the public. Our Code of Conduct sets out how we do this and describes the standards of behaviour that we require from our people.
Every one of us plays a critical role in achieving our objectives and continually shaping and strengthening our Open & Dynamic culture. This Code guides how we make decisions and behave at work and externally, as representatives of the RBA with a responsibility to act in the best interest of the community we serve.
1.1. What it means for you
To meet our expected standards of behaviour, you are required to read the Code of Conduct and ensure you understand what is required of you, as well as what you should expect from others.
Our Code may change as the RBAs practices and activities evolve. Recognising this, you are required to acknowledge you have read and understood our Code of Conduct at least annually.
We expect you to:
- Use the Code to guide your behaviour and decisions.
- Understand our Values and our Open & Dynamic behaviours and observe them.
- Speak with your People Leader if anything is unclear.
- Speak up about any concerns, including if you observe others breaching this Code, or if something doesnt reflect our Values.
Compliance with our Code of Conduct is mandatory and applies to everyone at the RBA. Consistently and authentically embedding the Code will help us achieve great outcomes, but not following the Code can have serious consequences for you, and for the RBA.
1.2. Our Culture and Values
Weve designed this Code to clearly set out the RBAs expectations and make it easy for everyone to understand their requirements across a wide range of matters. Some of these matters are supplemented by more detailed policies that guide us on meeting our legal and regulatory obligations.
All the requirements in our Code result from applying the RBAs Values and our Open & Dynamic culture to your everyday work or the activities of the RBA.
Our core Values are:
- 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.
- 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.
- Excellence
We strive for technical and professional excellence.
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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.
- Respect
We treat one another with respect and courtesy. We value one anothers views and contributions.
As an RBA employee, or as someone who is involved in the RBAs activities in some other capacity, you must act consistently with these core Values.
Alongside our Values, our ambition is to have an Open & Dynamic culture.
- Being Open means considering and incorporating different perspectives, internally and externally, working across teams, and being transparent with one another.
- Being Dynamic means delivering quality efficiently and effectively, by focusing on outcomes and prioritisation, and testing, learning, and refining as we go.
Together, being Open & Dynamic means doing more of the things that contribute positively to our culture to help us achieve our mission and strategic priorities, and less of the things that no longer serve us well.
As part of our Open & Dynamic ambition, we have three key behaviours – inspire trust, open minds and work dynamically. These behaviours represent how our Values come together to help us become a more Open & Dynamic central bank. Our Open & Dynamic ambition and behaviours are underpinned by our strong and ongoing commitment to nurturing an environment that is inclusive, diverse and fosters belonging.
1.3. Who does the Code of Conduct apply to?
This Code applies to:
- employees, the Governor and Deputy Governor;
- other workers at the RBA including contractors, consultants and agency employees who occupy a position within the organisational structure of the RBA; and
- others such as those with access to information and communication technology systems (ICT Assets) of the RBA, who have been informed they are required to comply with some or all of this Code.
1.4. When does it apply?
This Code covers all your interactions with people while working for the RBA. Whether youre connecting with someone remotely or in person, talking, writing, or using electronic communication like social media, instant messaging, email, phone, video, or even screen savers, this Code applies to every interaction.
It doesnt matter where these activities happen—at any Bank premises, in the office, working remotely, or at work-related social events. It also includes work-related interactions outside normal working hours and any situation where your behaviour might be linked to or reflect on the Bank.
2. Professional Conduct
How we make decisions, collaborate with others, and deliver our work reflects on ourselves, our broader team, and the RBA. Its crucial that we all work professionally, maintain high standards, act with integrity, and uphold the highest ethical principles.
2.1. Duties
As an RBA staff member, you have a range of duties to the Bank, including
- 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 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;
- to comply with all lawful and reasonable directions of the RBA, including but not limited to the Banks policies, guidelines, and procedures (including this Code). You must also regularly review these policies, guidelines, and procedures to ensure you are aware of them and any amendments to them;
- 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 your position and the duties assigned to you.
2.2. Avoiding conflicts of interest
It is important that you act with professionalism and integrity in all of your business dealings and stakeholder relationships. Conflicts of interest can arise when your personal interests or activities create an actual, potential, or perceived conflict with the interests of, or your responsibilities to, the Bank. This can include situations where you:
- have an interest in a transaction with the Bank.
- have a personal or financial relationship with someone dealing with the Bank.
- have a personal relationship with someone in your reporting line.
To continually strengthen our Open & Dynamic culture and set us up to successfully deliver our mission, we are all required to recognise and manage situations which could, or could be seen to, involve a conflict between our interests and our responsibilities to the RBA. If theres a reasonable basis to believe that a conflict of interest exists or could be perceived, you must discuss it with your Head of Department, relevant Governor, or the Chief Operating Officer. For issues related to personal relationships, you should talk to the Chief People Officer.
If the conflict is a material personal interest that relates to the affairs of the RBA then, in addition to the above, you are required to disclose the details of the interest in accordance with the Disclosure of Material Personal Interests – Instructions.
2.3. Using your position appropriately
In line with our Values and Open & Dynamic culture we require everyone to always use their position honestly, in good faith and in the best interests of the RBA. As part of this, you must conduct yourself in a way that upholds your reputation and that of the Bank.
You must always exercise your powers and fulfil 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, relevant Governor or the Chief Operating Officer in accordance with Sections 2.6 and 2.7).
2.4. No fraud or corruption
Integrity is one of our Values and we rely on you to continuously uphold the highest standards of integrity to protect the RBA. You must not engage in any form of fraud or corruption, and you must take reasonable steps to ensure that any person who reports to you does not engage in any form of fraud or corruption (including fraud and corruption of others).
Corruption includes bribery, which 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, your ability to make objective business or policy judgement and could be unlawful. You can only offer or receive gifts or hospitality where permitted under Section 2.7.
Corruption isnt just about bribery. It includes any conduct that could adversely affect the honest or impartial work of anyone at the Bank, or those providing services to the Bank. It includes misuse of RBA information or documents, breach of public trust or abuse of ones position by someone at the Bank or providing services to the Bank. Even if there is no personal benefit involved, conspiring, or attempting to do any of these things is itself corrupt behaviour.
Some examples of conduct that would amount to fraudulent or corrupt behaviour include:
- misuse of information which you have as a result of your work for the Bank, whether or not you receive money or another benefit in return;
- inappropriate allocation of trading business to a counterparty for personal gain;
- receiving a benefit to give preferential treatment in the selection of an external third party that supplies goods (e.g. construction or technology equipment), or services (e.g. recruitment) 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 allowed 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, regardless of the amount involved and even if they would not breach the law.
You must report any suspected or known fraud or corruption as soon as practicable to any Authorised Officer or report it through the FairCall service as outlined in Section 5 of this Code. You may refer a corruption issue directly to the National Anti-Corruption Commission (NACC) and in some circumstances a corruption issue you report internally must be referred by an Authorised Officer to the NACC (see Section 5.2).
See also the Fraud and Corruption Control Policy and the Reporting Wrongdoing Policy.
2.5. Involvement in other employment or business
You must obtain prior written consent from the Bank before engaging in other employment or business activities (whether paid or unpaid) which are offered to you as a result of your position at the Bank, or which might create a conflict with 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.
Before accepting any employment, or engaging in any external business activity, that is not prohibited and that does not require the Banks prior written consent, you must inform your Head of Department, relevant Governor, or the Chief Operating Officer, who will raise any concerns with you.
2.6. Fair dealings with third parties
You must act honestly and fairly in all your dealings for and on behalf of the RBA. Any actual or perceived conflicts of interest should be disclosed to your Head of Department, relevant Governor, or the Chief Operating Officer.
You must always adhere to the Procurement and Disposal Policy in any procurement activities on behalf of the Bank.
2.7. Gifts, hospitality, and other benefits
In the course of your work at the RBA, 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 relevant Governor or the Chief Operating Officer, including 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 $150 in value (other than as provided below);
- approval from your Head of Department, relevant Governor or the Chief Operating Officer must be sought before giving any gift on behalf of the Bank that exceeds $150 in value;
- any hospitality given or received should not exceed $150 (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, relevant Governor or the Chief Operating Officer.
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 $150 due to higher costs and/or 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, seek guidance from your Head of Department, relevant Governor, or the Chief Operating Officer and, in the case of a gift, hand the gift to Secretarys Department as soon as practicable.[1] Where any doubt exists in relation to the application of these guidelines, the Head of Department should seek guidance from Secretarys Department.
See also Gifts, Hospitality and Other Benefits Registers – Guidelines.
2.8. Transacting in financial instruments
As a result of your position with the RBA, 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.
Even if you are satisfied that a proposed transaction complies with this requirement, if 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, relevant Governor, or the Chief Operating Officer before proceeding.
To protect both you and the Bank, there are specific rules about when you can transact in financial instruments. These rules apply to you, any entity you control, or anyone whose affairs you manage. They include transactions you are involved in directly, as an adviser, or in any other capacity where youre making or influencing decisions to buy, sell or otherwise deal in a financial instrument.
a) Role specific requirements
If you are in:
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Domestic Markets Department (excluding Financial Markets Business Support Services), 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 Group;
- 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 Group;
- 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 Group; 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 Group.
If you seek authorisation from an Assistant Governor, you wont receive approval if the Assistant Governor forms the view that the transaction is related to the management of your investment portfolio. As such its unlikely youll receive approval for things like joining or ending a security purchase plan, or a dividend or distribution reinvestment plan, including terminating any plans entered into before joining 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 start a role where youre subjected to these restrictions, its important to think about and, if needed, adjust your finances. Once youre in the role, you wont be able to make transactions in Funding Investments of relevant entities without approval.
b) 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.
c) 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, relevant Governor, or the Chief Operating Officer can support you by providing specific guidance as to whether a particular form of trading would be regarded as active trading.
d) Blackout Periods
To manage the risk, or perception, that any party is privy to the RBAs view, or advice to the Monetary Policy Board, on a monetary policy decision, a Blackout Period applies.
The Blackout Period is a 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 meeting (unless notified otherwise 2.00pm Sydney time on the Wednesday prior to a Monetary Policy Board meeting) and concludes at 5.00pm Sydney time on the day that the Monetary Policy Boards monetary policy decision is announced. 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, relevant Governor, or the Chief Operating Officer 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 rbainfo@rba.gov.au. In engaging proactively or reactively with media, only authorised employees can speak off the record, on the record or for the RBA.
Comments about your colleagues, your People Leader, or your work experiences can impact your reputation as well as the reputation of others and the RBA. When using social media, make sure your posts dont reveal any confidential information about the RBAs operations or views. Also, ensure they dont harm or have the potential to harm the RBAs reputation or its people, or breach this Code in any way.
See also the Media and Social Media Policy
2.11. External Presentation and Publication Policy
We all have a responsibility to manage the RBAs intellectual property and communications objectives properly. As a general rule, you must obtain approval from your Head of Department, relevant Governor, or the Chief Operating Officer before seeking to present or publish (including republish) RBA information or 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 at the RBA, 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, relevant Governor, or the Chief Operating Officer. These issues are outlined in the External Presentation and Publication Policy.
3. Personal Conduct
In your role at the Bank, its important to always act professionally, and treat everyone you engage with, with respect and courtesy.
3.1. Professionalism
The Bank plays a pivotal role in supporting the Australian economy and community. To meet the high standards expected of us and in service of our purpose, its essential that everyone delivers their highest performance.
In your work, whether working alone or as part of a team, you must demonstrate the skills, competence and professionalism expected in your role. This includes the:
- technical competence you demonstrate in your work;
- outcomes you achieve in your areas of responsibility; and
- relationships you build and maintain within the Bank and with others you interact with in your work.
3.2. Respect and courtesy
One of our Values is Respect and at the RBA we treat one another with respect and courtesy. We value one anothers views and contributions. This means:
- being considerate of others feelings, situations and circumstances;
- being polite in your interactions; and
- avoiding antagonistic, aggressive, or unnecessarily harsh behaviour.
These requirements apply to all your interactions with people while working for the RBA. This includes face-to-face meetings, written communication, using Bank systems, social media, outside normal working hours, or even in non-work-related matters. See also Information Systems Security and Acceptable Use Policy and the Media and Social Media Policy.
3.3. Working effectively with others
As part of our Open & Dynamic culture, we all work in teams, collaborate with colleagues from other parts of the RBA, and engage with people outside of the Bank. In line with our Values, you must take a collaborative approach, sharing information and guidance when needed, respect the role and contribution of others, and practice inclusivity by ensuring the people you are working with are properly included in joint work activities.
3.4. Appropriate workplace conduct and behaviour
The RBA has no tolerance for discrimination, harassment, bullying, victimisation, and other inappropriate workplace conduct. You must treat others with dignity, courtesy and respect and conduct yourself in a way that reflects positively on you and the Bank including not engaging in any conduct or behaviour that may amount to unlawful discrimination, harassment (including sexual harassment), bullying and victimisation or otherwise be inappropriate workplace conduct.
There are many ways in which unlawful discrimination, harassment, bullying, victimisation, or other inappropriate workplace conduct can occur. To support positive outcomes and continuously strengthen our Open & Dynamic culture, you are required to familiarise yourself with the Banks Workplace Behaviour Policy, undertake training on workplace behaviour as required and to adhere to the requirements set out in that Policy and training.
If you experience this sort of conduct, you are encouraged to:
- raise the issue with the other person directly if you feel comfortable to do so;
- if you dont feel comfortable, or if the above does not sufficiently address the matter or is not appropriate, raise your concerns as outlined in Section 5 of this Code.
A relationship with a work colleague in which you both genuinely welcome the attention of the other will not constitute sexual harassment. If youre in a consensual personal relationship with someone in your direct reporting line, it creates a conflict of interest and must be disclosed to the Chief People Officer. If theres no reporting hierarchy, you only need to disclose the relationship if theres an actual, potential, or perceived conflict of interest.
If you witness or become aware of inappropriate conduct being directed at someone else, you are required to 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 and Reporting Wrongdoing Policy.
3.5. Obscene or abusive language, materials, or messages
Using obscene, abusive, or disrespectful language, or viewing inappropriate content, is unacceptable during your employment or engagement with the Bank. Inappropriate content includes:
- harsh or inappropriate language;
- pornographic or degrading images;
- violent or threatening images;
- racially offensive or sexist images or materials.
If you receive a communication containing this sort of material (whether from within or outside the Bank), you should inform your Head of Department, relevant Governor, or the Chief Operating Officer. The only exception to this relates to spam email that you receive which should be reported to Information Technology, immediately deleted, and not distributed.
See also the Information Systems Security and Acceptable Use Policy and the Media and Social Media Policy
3.6. Safe work environment
The Bank is committed to providing a safe and healthy workplace that enhances the wellbeing of our people. We have an obligation to ensure the health and safety of our staff and other persons (for example visitors) in the workplace.
Similarly, you have an obligation to:
- take reasonable care for your own physical and psychosocial health, safety, and wellbeing. You should ensure that you present for work in a state which enables you to perform your role competently and in a manner which does not compromise or threaten the health or safety of you or others;
- take reasonable care that your acts or omissions do not adversely affect the health and safety of others;
- 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 and includes recreational and social activities undertaken as part of your role at the Bank; and
- co-operate 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 work under the influence of alcohol or drugs, except for prescription or over-the-counter medication. If youre taking prescription or over the counter medication that might affect your ability to do your job, talk to your Head of Department, relevant Governor, or the Chief Operating Officer. 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 may be permitted.
3.8. Criminal and civil offences and bankruptcy
It may be inappropriate for a person who has been convicted or found guilty of certain criminal or civil offences or who has been declared bankrupt to occupy certain roles in the Bank.
If you are convicted or found guilty (whether or not a conviction was recorded), of a civil or criminal offence (excluding minor traffic and driving offences in respect of which a penalty notice is issued), or bankruptcy proceedings have been commenced against you, you must report these matters to your Head of Department, relevant Governor or the Chief Operating Officer.
4. Bank Property, Information and Resources
As part of your role, you will have access to valuable and sensitive information and property. Its important to use and protect these resources appropriately. You must use the Banks resources in a secure, efficient, effective, economical, and ethical manner.
4.1. Bank property, information and resources
The Bank provides assets like data, information, equipment, systems, facilities and services for business purposes. Its important to safeguard and protect these assets and you must not use them inappropriately.
Inappropriate use includes:
- excessive personal use of the Banks phones, email, or computing systems;
- using the Banks letterhead for personal correspondence;
- sending personal emails using the Banks email system in your professional capacity as a representative of the Bank (and not in your personal capacity); or
- using the Banks resources for activities prohibited under this Code or any other Bank policy.
To help maintain a safe and secure environment for people and prevent unauthorised access to, or loss of, its assets, you must:
- follow the Banks safety and security practices and procedures;
- inform your People Leader if you become aware of any intrusion, security threats or inappropriate use of assets; and
- maintain the confidentiality, integrity, and availability of the assets.
Make sure youre familiar with the policies detailed in Section 7.1 when using Bank assets.
4.2. The Banks information and communications technology systems (ICT Assets)
On a limited basis, you can use the Banks ICT Assets for personal internet browsing or emails. However, any such use must comply with the Banks Information Systems Security and Acceptable Use Policy.
Your use of the ICT Assets will be monitored in accordance with the Banks Information Systems Security and Acceptable Use Policy and the Bank may use the results of this monitoring to raise any concerns with you related to your use of the ICT Assets.
4.3. Safeguarded information
During your work with the Bank, youll have access to a range of information, including:
- confidential information not generally available outside of the Bank;
- third party confidential information;
- price sensitive information, which if it were generally available could have a material effect on the price or value of shares or other financial instruments (see Section 2.8(a);
- privileged information where the Bank is protected by legal privilege;
- personal information about individuals;
- information 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 this information is solely to enable you to perform your role. You have a legal obligation, whether this information is the Banks or a third partys:
- 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, relevant Governor, or the Chief Operating Officer any instances where:
- 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/or
- you have contact 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 you have access to in the course of your employment, and the steps to take in the event of an unlawful disclosure, see Section 7.1.
4.4. Intellectual property
During your work with the Bank, you may be directly or indirectly involved in creating or developing materials where intellectual property rights arise. The Bank will own all right, title and interest in these materials.
5. Breaches of this Code
5.1. Context and protections
Its important that the Bank is made aware of and investigates any potential breaches of this Code. Its also important that you feel safe reporting any potential breaches. This section outlines the range of options and protections available to you.
5.2. How to raise a concern
If you have questions about this Code, how it applies to you, any expected behaviours, or are unsure about whether certain conduct is consistent with this Code, seek guidance from your People Leader or Head of Department. You are required to comply with this Code and take reasonable steps to ensure that those who report to you or who you work with, do the same. If you are aware of any conduct that breaches this Code, or you have a reasonable basis to believe that a breach has occurred, you are required to report it as soon as practicable. In line with our Open & Dynamic culture and commitment to transparency, we have several formal avenues for you to raise concerns, including:
- your People Leader;
- your Head of Department;
- your relevant Governor or the Chief Operating Officer;
- a People Partner;
- the Head of Employee Relations;
- the Chief People Officer;
- through the FairCall Service at <https://rba.kpmgfaircall.kpmg.com.au/.>
FairCall is an independent service provided by KPMG that allows you to raise concerns anonymously. Any concerns raised through FairCall are reported to the Deputy Governor. Reports to FairCall can be made without disclosing personal details, however, you can also choose to identify yourself and give permission for KPMG to share your details with the Deputy Governor.
If you become aware of any conduct that is in breach of this 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 People Leader; or
- any of the following, each of whom is an Authorised Officer for the purposes of the PID
Act:
- 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 Chief People Officer should be referred directly to the Deputy Governor or another Authorised Officer. A serious allegation about the Governor should be referred to the Governance 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).
If you have reported a corruption issue to an Authorised Officer (either directly or through your People Leader) and the Authorised Officer believes or suspects that the issue could involve corrupt conduct by someone at the Bank, or providing services to the Bank, that is serious or systemic, the Authorised Officer must refer the issue to the NACC. You may also refer a corruption issue directly to the NACC.
The Reporting Wrongdoing Policy also contains details of how to report a concern in the course of your work at the Bank. The Bank expects you to be honest when making a complaint and to do so as soon as you become aware of the issue. If youre part of an investigation, its important that you keep everything discussed confidential.
5.3. Consequences of breach
It is mandatory to comply with this Code, and the RBA treats any breaches seriously (including breaches of any Bank policies, procedures or guidelines which underpin this Code). This includes where someone has assisted in the breach of the Code or, as a leader, has not taken appropriate action in relation to a breach or alleged breach. Where a breach of this Code has occurred, appropriate action including disciplinary action up to and including termination of employment (or engagement) may be taken and, in appropriate cases, the matter may be referred to the police.
Breaches that the Bank considers serious misconduct, or repeated breaches are likely to result in termination of employment (or engagement).
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 the People Department, another suitable person from within the Bank, or by an external investigator. The Bank will determine the form, timing, and person to conduct the investigation, considering:
- the importance of keeping investigations into employee matters confidential;
- the need to ensure that the investigation is conducted fairly;
- the circumstances of each party;
- conducting the process quickly and efficiently;
- ensuring the outcome is accurate and reliable; and
- if the PID Act applies, the requirements of that Act.
If an issue that could involve corrupt conduct has been referred to the NACC (directly or by an Authorised Officer), then the NACC may investigate the issue itself, may investigate jointly with the Bank or may, if the NACC refers the matter to the Bank for investigation, oversee that investigation, give the Bank directions about the planning and conduct of the investigation and/or request the Bank to provide progress and completion reports.
The person raising the concern and the person(s) to whom the concern relates may be required to not report for work during the investigation. This will be with no loss of pay or other conditions if the Bank considers this to be appropriate to undertake an effective investigation and to protect everyone involved. Alternatively, the Bank may assign those involved alternative duties during the investigation with no loss of pay or other conditions.
6. Code Management
6.1. Administration
This Code is administered by the People Department.
6.2. Implementation
Everyone at the RBA is responsible for complying with this Code of Conduct. All staff with executive and people leader responsibilities are accountable for managing workplace behaviour consistent with this Code, and for creating a culture that aligns with our Values and our Open & Dynamic ambition.
6.3. Monitoring and review
The Code is reviewed annually by the RBAs People Department.
Changes to the Code must be approved by the RBA Executive Committee.
Material changes to the Code must be approved by the Governance Board.
7. Resources
There are RBA policies, procedures and guidance which underpin this Code. All related documents can be found on the Banks intranet.
7.1. Reserve Bank
Policies
- Fraud and Corruption 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 Procedures
Guidelines
- Gifts, Hospitality and Other Benefits – Guidelines
- Privacy Guidelines
- Protected Information, Protected Documents and Maintaining Confidentiality – Instructions
Frameworks
- Protective Security Framework
8. Who do I speak to for more information?
If you have any questions or concerns relating to this Code or how it should be applied, you can speak with your People Leader, Head of Department, relevant Governor, or the Chief Operating Officer.
For more general enquiries or clarification about this Code or associated documents, contact the People Support Team.
You can connect with the below people and teams for specific issues.
Appropriate use of position
Head of Department, relevant Governor, or Chief Operating Officer
Avoiding conflicts of interest
Head of Department, relevant Governor, or Chief Operating Officer
The Chief People Officer for issues relating to personal relationships.
Appropriate workplace conduct and behaviour
People Leader, Head of Department, the Head of Employee Relations, or FairCall Service
Bank property, information and resources
Information Department, Information Technology Department, Workplace Department
Breaches of the Code
People Leader, Head of Department, relevant Governor or Chief Operating Officer, People Partner, Head of
Employee Relations, Chief People Officer, or the FairCall Service
Confidential, sensitive, privileged, personal or protected information
Head of Department, relevant Governor, or Chief Operating Officer
External Presentation and Publication Policy
Head of Department, relevant Governor or Chief Operating Officer
Fair dealings with third parties
Head of Department, relevant Governor, or Chief Operating Officer
Gifts, hospitality, and other benefits
Head of Department, relevant Governor, Chief Operating Officer, or Secretarys Department
Involvement in other employment
Head of Department, relevant Governor, or Chief Operating Officer
Media comment and use of social media
Communications Department
No fraud or corruption
Any Authorised Officer or FairCall Service
Safe work environment
Head of Safety and Wellbeing
The Banks information and communications technology systems (ICT Assets)
Information Technology Department
Transacting in financial instruments
Head of Department, relevant Governor or Chief Operating Officer
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 Head of Department, relevant Governor or Chief Operating Officers approval, the gift may be donated to the Benevolent Fund or returned to the recipient. [1]
Insider trading is transacting while in possession of information that you know, or ought reasonably to know, is price sensitive that is, information of or about an entity that is not generally available, but which, if it were generally available, a reasonable person would expect to have a material effect on the price or value of shares or other financial instruments issued by the entity. Insider trading is prohibited by the Corporations Act 2001. [2]
Funding Investment when used anywhere in paragraph (a) means any equity, equity-like, hybrid or debt capital markets investment including, without limitation, shares, preference shares, share futures, warrants, options, bonds, bills, promissory notes and certificates of deposit. [3]
Other than a private health insurer. [4]