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Ethical and responsible behaviour

Code of Conduct

NHFIC’s Codes of Conduct for Board members and staff were approved by the Board on 31 August 2018 and apply to Board members, senior executives and employees. The codes provide information about the behaviours that NHFIC expects and seeks to foster a culture where ethical conduct is valued and demonstrated in its day-to-day business.

All employees, consultants and contractors are required to demonstrate key behaviours consistent with the following standards:

  • act with care, diligence, being impartial and objective
  • perform to the best of their ability, maintaining high standards of honesty and integrity
  • treat everyone with courtesy and respect, without coercion or harassment of any kind
  • consider matters on their merits
  • comply with applicable Australian laws and NHFIC’s policies, procedures and guidelines.

The Codes of Conduct are supported by a number of internal policies and procedures, providing further guidance for Board members and staff on acceptable actions and behaviour.

Public interest disclosure (whistleblower) protection

NHFIC is committed to maintaining the highest standards of ethical and accountable conduct and ensuring that individuals who make public interest disclosures are provided with the protections available under the Public Interest Disclosures Act 1994 (PID Act).

NHIFC has developed detailed processes to be followed by NHFIC’s supervisors, authorised officers, principal officer and investigation delegates for reporting, investigating and responding to disclosures made under the PID Act.

NHFIC’s Public interest Disclosure (Whistleblower) Policy provides a framework for the escalation of disclosable conduct. This includes conduct that is illegal, corrupt, unethical or is an abuse of public trust. The Whistleblower Policy applies to all current and former employees of NHFIC, including contractors providing goods or services to NHFIC.

Anti-Money Laundering/Counter Terrorism Financing (AML/CTF)

As a designated service provider, NHFIC is required to have an AML/CTF program in place which, among other things, identifies, manages and reduces the money laundering and terrorism financing risk it potentially faces.

NHFIC has enrolled with the Australian Transaction Reports and Analysis Centre (AUSTRAC) and developed a comprehensive AML/CTF program. The program includes a framework for reporting suspicious matters to AUSTRAC together with comprehensive ‘know your customer’ procedures and ongoing customer due diligence and transaction monitoring procedures.