Code of Conduct

The Code has been endorsed by the Executive Committee and the Managing Director and adopted by the Board of Bendigo and Adelaide Bank.

The Board and management are committed to the Group complying with the law and promoting a culture of fair and ethical behaviour.

We believe that by creating success for our customers and communities, we build the success of the Group.

We aim to do each of the following.

• Provide an exceptional customer experience.
• Offer relevant solutions to meet customer needs.
• Help our customers prosper.

Help to improve the prospects of communities in which we operate.

Our corporate values reflect the culture in the Group and include:

• Teamwork
• Engagement
• Performance
• Leadership
• Passion
• Integrity

Our corporate values provide a framework that guides the way we interact with each other, our customers, our partners, our shareholders, our suppliers and the community.

Teamwork – We are one team with one vision. We work together, encourage diversity and respect the unique contribution of each individual.

Engagement – We listen, understand, then deliver. We build our success through the success of others.

Performance – We strive for sustainable success. We seek and provide feedback and find a better way.

Leadership – We all lead by example. We show initiative, are accountable and empower others.

Passion – We believe in what we do and are proud of our bank.

Integrity – We build a culture of trust. Wr are open, honest and fair.

Our engagement with communities is central to our strategy and stands our bank apart.

The success of our business will grow in line with the increasing prosperity of the communities we serve. Committing to help improve the economic and social fabric of our communities is therefore good business.

We are willing and able to extend our support beyond the provision of banking services. We seek engagement with community leaders, to understand their aspirations and goals and to ally our commercial skills with local community spirit to promote better outcomes for all parties.

We are willing to challenge orthodoxy and to create collaborative solutions that give both partners the best chance of sustainable success.

Communities and their businesses must adopt sound environmental practices if they are to sustain themselves.

We aim to lead by example and to provide customers and communities tools to help their own efforts.

We will continue to refine our own business practices to minimise waste and energy use, recycle consumables and compensate the environment for other activities. We will promote and develop solutions for sustainable environmental practices by our customers, partners and communities.

A conflict of interest occurs when we have an interest outside the Group (whether private or otherwise) that could prejudice or improperly influence our judgment or the performance of our professional duties and obligations. We recognise that our primary business responsibility is to the Group.

If a conflict of interest arises or may arise, this is to be disclosed by an employee to the line manager, so that it can be dealt with appropriately. Depending on the nature and extent of the conflict, the measures taken to protect against a conflict of interest may include that the employee does not participate in the relevant decision or activity, or disclosing the conflict to third parties affected by it and making sure that the employee is not the sole decision-maker on the matter.

Example: You or a family member has an interest in a company with whom you are to negotiate a contract on behalf of Bendigo and Adelaide Bank for the provision of services. Your interest needs to be disclosed to your line manager in advance, to enable your line manager to make other arrangements for the negotiation.

We do not use our position, nor information acquired by virtue of our position, to obtain an advantage for ourselves or someone else or to cause detriment to Bendigo and Adelaide Bank or any company in the Group.

We do not misuse company assets. We use all company goods, services and facilities provided by the Group (for example, buildings, property, computers, computer systems and data, telephones, office equipment, corporate credit cards and motor vehicles) in accordance with the terms on which they are provided.

We may only accept and give token gifts and modest hospitality and professional courtesies. We must not accept or give a gift or courtesy that could either lead to, or be seen to lead to, a conflict of interest such that our judgment is prejudiced or improperly influenced.

Example: You are managing a tender process and a gift accompanies the tender from one of the parties. You should return the gift, as to accept it may be seen as improperly influencing your decision on the tender.

We all want to work in a safe, healthy and productive workplace. Therefore, we do not misuse prescription drugs, or use or possess illicit drugs. We do not consume alcohol where it affects work performance, public relations, safety or where it breaches the law.

A confidential counselling support service is available (see 16 above).

As a director or employee, we each owe an obligation of confidentiality to the company. This obligation covers information about any company in the Group and its customers, coming to our knowledge in the performance of our duties as an employee or director. This information may not be used or disclosed except in performing our duties or as required by law.

In particular, we are committed to safeguarding our customers’ and employees’ privacy by making sure that personal information is protected.

Each employee and director is required to comply with laws and with the policies of the Group, including this Code of Conduct.

Any member of staff who breaches this obligation may face disciplinary action, including termination of employment. In the case of a breach of the law, there may be legal consequences for the employee or director.

Each director and officer is to promote compliance with laws and with the policies of the Group.