Report - COP Prototype

2022 Communication on Progress

ANZ Group Holdings Limited

Published date

June 28, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

ANZ's 2021 Annual Report https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf ANZ's 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf ANZ's Board EESG Committee Charter https://www.anz.com/content/dam/anzcom/shareholder/Ethics-Environment-Social-and-Governance-Committee-Charter-Oct-2020.pdf

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

ANZ's Human Rights Statement: https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf ANZ's Climate Change Commitment: https://www.anz.com/content/dam/anzcom/shareholder/ANZ-2021-climate-change-commitment.pdf ANZ's Modern Slavery Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/esg/human-rights/modern-slavery-statement-2021.pdf ANZ's Equal Opportunity, Bullying and Harassment Policy https://www.anz.com/content/dam/anzcom/shareholder/Equal-Opportunity-Bullying-and-Harassment-Policy-Summary.pdf ANZ's Wellbeing Safety Policy https://www.anz.com.au/content/dam/anzcomau/documents/pdf/wellbeing-safety-policy.pdf?MOD=AJPERES&adobe_mc=MCMID%3D49061309673430232591953298274404107473%7CMCAID%3D2DE87DB4052C7108-600000C0A0002455%7CMCORGID%3D67A216D751E567B20A490D4C%2540AdobeOrg%7CTS%3D165224285622 ANZ's Anti Bribery Anti Corruption Policy https://www.anz.com/content/dam/anzcom/shareholder/anti-bribery-and-anti-corruption-policy-june-2021.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

ANZ's Board EESG Committee Charter https://www.anz.com/content/dam/anzcom/shareholder/Ethics-Environment-Social-and-Governance-Committee-Charter-Oct-2020.pdf ANZ's Human Resources Committee Charter: https://www.anz.com/content/dam/anzcom/shareholder/anz-human-resources-committee-charter.pdf ANZ's Board Risk Committee Charter: https://www.anz.com/content/dam/anzcom/shareholder/Risk-Committee-Charter-Oct-2020.pdf

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

ANZ's ESG Governance: https://www.anz.com.au/about-us/esg/our-approach/governance-risk-management/ ANZ's Board EESG Committee Charter https://www.anz.com/content/dam/anzcom/shareholder/Ethics-Environment-Social-and-Governance-Committee-Charter-Oct-2020.pdf ANZ's Human Resources Committee: https://www.anz.com/content/dam/anzcom/shareholder/anz-human-resources-committee-charter.pdf ANZ's Board Risk Committee: https://www.anz.com/content/dam/anzcom/shareholder/Risk-Committee-Charter-Oct-2020.pdf ANZ's Corporate Governance Structure: https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-corporate-governance-statement.pdf

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

ANZ's 2021 Annual Report: https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf See Risk management (p.51-55), Governance (p. 40-50), What matters most (p.9) ANZ's 2021 ESG Supplement, https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf See: What matters most (p.6-8); ESG Governance and risk management (p.5), Financial Crime page (p.46)

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

ANZ's Supplier Code of Practice https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/wcmmigration/supplier-code-of-practice-english.pdf?MOD=AJPERES

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Suppliers, including subcontracted suppliers, are screened as part of Group Procurement’s ongoing supplier due diligence using a third-party tool that assesses performance against 28 ESG issues, including human rights. ANZ's 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf See: (P. 47) Responsible Business Lending; and (P. 50) Managing ESG risk and opportunities in our supply chain

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

ANZ's Responsible Business Lending page re: Social and Environmental Risk Screening tool: https://www.anz.com.au/about-us/esg/policies-practices/responsible-business-lending/

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

ANZ staff globally can raise concerns about the company’s conduct related to human rights, labour rights, environment or anti-corruption under ANZ’s Whistleblower Policy. The internal version of the Whistleblower Policy is available to staff on the intranet site ‘Max’ and the external version is publicly available on anz.com See ANZ's Whistleblower Policy, https://www.anz.com/content/dam/anzcom/shareholder/whistleblower-policy.pdf and ANZ's ESG Supplement: https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf See: Improving conduct and culture (Page 35-36), Wellbeing / EAP service (p. 57) ANZ's website for Respecting Human Rights / ANZ's Human Rights Grievance Mechanism https://www.anz.com.au/about-us/esg-priorities/fair-responsible-banking/human-rights/

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

The ANZ Whistleblower Policy is published and communicated to all staff in English. Contractors, vendors and suppliers are all able to make reports under ANZ’s Whistleblower Policy. When making a report staff, contractors, vendors and suppliers can choose to be identified or remain anonymous. Reports under the Whistleblower Policy are managed confidentially, in accordance with the policy and relevant laws. The Whistleblower Policy has processes in place to seek to prevent retaliation. The policy makes clear that ANZ does not tolerate retaliation and any allegations of retaliation are taken very seriously and are appropriately looked into. Under the policy concerns in relation to the matters listed in Q8 can can be raised about ANZ (including its related bodies corporate and controlled entities) or anyone connected to ANZ. See ANZ's Whistleblower Policy: https://www.anz.com/content/dam/anzcom/shareholder/whistleblower-policy.pdf

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

ANZ's Human Rights Statement: https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf ANZ's Supplier Code of Practice: https://www.anz.com.au/about-us/esg/policies-practices/sustainable-procurement/ ANZ's Responsible Lending https://www.anz.com.au/about-us/esg/policies-practices/responsible-business-lending/ ANZ's Human Rights and Modern Slavery: https://www.anz.com.au/about-us/esg-priorities/fair-responsible-banking/human-rights/

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

ANZ's approach to materiality: https://www.anz.com.au/about-us/esg/our-approach/materiality/ ANZ's ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf What matters most (page 6); ESG targets (p. 11-14)

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

ANZ's 2021 Annual Report https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf See Overview of ANZ's Remuneration Framework (P. 78), ANZ's Group Performance Framework (P.87-91)

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	8
Male (%)	62.5
Female (%)	37.5
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)	0
Executive (%)	1
Independent (%)	7

Optional comment

ANZ's 2021 Annual Report https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf See pages 40-41

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Limited assurance provided on the ESG content in our: Annual Report, page 252 https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf ESG Supplement, page 82 https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Reasonable assurance for minority of metrics

Reasonable assurance on ANZ's GHG Emissions and Carbon Offset Data Statement: See https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/esg/2021-03/ghg-assurance-statement-2021.pdf

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

https://www.anz.com.au/about-us/esg/reporting/

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2022
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

ANZ's Human Rights Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf ANZ's Consumer Data Right Policy https://www.anz.com.au/content/dam/anzcomau/documents/pdf/consumer-data-right-policy.pdf ANZ's Privacy Policy https://www.anz.com.au/content/dam/anzcomau/documents/pdf/privacy-policy.pdf ANZ's Land Acquisition Position Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/anz-land-acquisition-statement-nov2021.pdf

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

ANZ's 2022 Human Rights Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

All ANZ employees and contractors complete Code of Conduct training. See page 4 ANZ's 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf https://www.anz.com/content/dam/anzcom/shareholder/code-of-conduct.pdf

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

This year we significantly upgraded our Human Rights Statement (Statement) and developed a new Grievance Mechanism (Mechanism) for people whose human rights may have been impacted by our large business lending customers. Under the UNGP framework we respect the human rights of our employees, carry out risk-based due diligence regarding human rights in our business relationships, and commit to improving our transparency and reporting. Business customers are also expected to meet their obligations under the UNGPs and consent to participate in our grievance mechanism should we accept a complaint about them.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
2022
Forced labour
2022
Child labour
2022
Non-discrimination in respect of employment and occupation
2020
Occupational safety and health
2020
Working conditions (wages, working hours)
2021

Optional comment

ANZ's Human Rights Statement: https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf ANZ's Modern Slavery Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/esg/human-rights/modern-slavery-statement-2021.pdf ANZ Equal Opportunity, Bullying and Harassment Policy https://www.anz.com/content/dam/anzcom/shareholder/Equal-Opportunity-Bullying-and-Harassment-Policy-Summary.pdf ANZ Wellbeing Safety Policy https://www.anz.com.au/content/dam/anzcomau/documents/pdf/wellbeing-safety-policy.pdf?MOD=AJPERES&adobe_mc=MCMID%3D49061309673430232591953298274404107473%7CMCAID%3D2DE87DB4052C7108-600000C0A0002455%7CMCORGID%3D67A216D751E567B20A490D4C%2540AdobeOrg%7CTS%3D165224285622 Working conditions are set out in a suite of internal ANZ policies, such as Allowances and Reimbursement, Hours of Work, Overtime and Loading.

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

ANZ's Human Rights Statement: https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/anz-human-rights-statement-nov2021.pdf Modern Slavery Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/esg/human-rights/modern-slavery-statement-2021.pdf Australian EBA (https://www.fwc.gov.au/document-search/view/aHR0cHM6Ly9zYXNyY2RhdGFwcmRhdWVhYS5ibG9iLmNvcmUud2luZG93cy5uZXQvZW50ZXJwcmlzZWFncmVlbWVudHMvMjAxNy8xMC9hZTQxNzIxNy5wZGY1/3/26ac0e44-8a26-4165-8081-5232e1cb30e6/ANZ%24%24FSU ANZ Equal Opportunity, Bullying and Harassment Policy https://www.anz.com/content/dam/anzcom/shareholder/Equal-Opportunity-Bullying-and-Harassment-Policy-Summary.pdf ANZ Wellbeing Safety Policy https://www.anz.com.au/content/dam/anzcomau/documents/pdf/wellbeing-safety-policy.pdf?MOD=AJPERES&adobe_mc=MCMID%3D49061309673430232591953298274404107473%7CMCAID%3D2DE87DB4052C7108-600000C0A0002455%7CMCORGID%3D67A216D751E567B20A490D4C%2540AdobeOrg%7CTS%3D1652242856

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf
Forced labour
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf
Child labour
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf
Non-discrimination in respect of employment and occupation
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf
Occupational safety and health
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf
Working conditions (wages, working hours)
Stakeholder engagement is outlined on pages 9-10 of our 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Optional comment

Stakeholder engagement is embedded in our policies, processes and operations. Outlined on pages 9-10 of our 2021 ESG Supplement are the key issues raised by our stakeholders throughout the year and how we responded. https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

All employees complete a suite of OH&S training including: Being Safe in your Workspace, Emergency Preparedness, and Mental Health Awareness. All ANZ employees and contractors complete Code of Conduct training. See page 4 ANZ's 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf https://www.anz.com/content/dam/anzcom/shareholder/code-of-conduct.pdf

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

ANZ's Modern Slavery Statement: https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/esg/human-rights/modern-slavery-statement-2021.pdf ANZ's Human Rights Statement https://www.anz.com.au/content/dam/anzcomau/documents/pdf/aboutus/ANZ-human-rights-statement-may-2022.pdf In relation to working conditions, ANZ negotiates enterprise agreements with relevant representative bodies in a number of countries.

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	91

Optional comment

See ANZ's 2021 ESG Data pack: https://www.anz.com.au/content/dam/anzcom/shareholder/2021-anz-esg-data-pack.xlsx

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)

Optional comment

We do not publicly disclose this information.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	35.3
Non-executive board	42.8

Optional comment

See ANZ's 2021 ESG Data pack https://www.anz.com.au/content/dam/anzcom/shareholder/2021-anz-esg-data-pack.xlsx See ANZ's 2021 Annual Report https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-annual-report.pdf

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	100

Optional comment

ANZ's female to male salary ratios (%) for non management like for like roles is 102% (we were unable to type 102% in the above field). See ANZ's 2021 ESG Data Pack 'Social' tab https://www.anz.com.au/content/dam/anzcom/shareholder/2021-anz-esg-data-pack.xlsx

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.9

Optional comment

0.9% Australia See ANZ's 2021 ESG Data Pack https://www.anz.com.au/content/dam/anzcom/shareholder/2021-anz-esg-data-pack.xlsx

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate
We don't disclose this publicly.

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
We don't disclose this publicly
Forced labour
We don't disclose this publicly
Child labour
We don't disclose this publicly
Non-discrimination in respect of employment and occupation
We don't disclose this publicly
Occupational safety and health
We don't disclose this publicly
Working conditions (wages, working hours)
We don't disclose this publicly

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

See Case study titled 'Paying the Living Wage in New Zealand' on page 52 of ANZ's 2021 ESG Supplement: https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf See Case study on 'Modern Slavery material risks and key exposures & impacts of COVID-19' on page 55 of ANZ's 2021 ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
2021
Oceans
Forests / Biodiversity / Land Use
2021
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

Optional comment

ANZ's Responsible business page https://www.anz.com.au/about-us/esg-priorities/fair-responsible-banking/responsible-business-lending/

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

See ANZ's Responsible Business page https://www.anz.com.au/about-us/esg-priorities/fair-responsible-banking/responsible-business-lending/ ANZ's Supplier Code of Practice https://www.anz.com.au/about-us/esg-priorities/fair-responsible-banking/sustainable-procurement/ ANZ's Environmental Footprint page https://www.anz.com.au/about-us/esg-priorities/environmental-sustainability/environmental-footprint/

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

See ANZ's TCFD page 10 for information on climate risk training provided to frontline bankers: https://www.anz.com.au/content/dam/anzcom/shareholder/ANZ-2021-Climate-related-Financial-Disclosures.pdf

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	Climate action target: Reduce scope 1 and 2 emissions 24% by 2025 and 35% by 2030 (against a 2015 base year); Fund and facilitate at least AU$50 billion by 2025 towards sustainable solutions for our customers; Encourage and support 100 of our largest emitting business customers to establish, and where appropriate, strengthen existing low carbon transition plans, by 2024. Develop an enhanced climate risk management framework that strengthens our governance and is responsive to climate change, by end 2022.
Energy & Resource Use	Energy & resource use target: increase renewable electricity use to 100% by 2025
Water	Water target: reduce potable water consumption by 25% by 2025 (against a 2017 baseline)
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Waste target: reduce waste to landfill by 30% by 2025 (against a 2017 baseline)
Oceans

Optional comment

Please note: Water, Energy, Waste and Scope 1 & 2 targets are Absolute, externally verified and on track A summary of ANZ's progress against the targets are summarized on pages 3 and 4 of ANZ's 2021 TCFD report, https://www.anz.com.au/content/dam/anzcom/shareholder/ANZ-2021-Climate-related-Financial-Disclosures.pdf

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
We do not disclose this publicly
Water
We do not disclose this publicly
Oceans
Forests / Biodiversity / Land Use
We do not disclose this publicly
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
We do not disclose this publicly
Energy & Resource Use
We do not disclose this publicly

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

6424

Scope 2 Emissions

Full

None

Emissions (tCO2e)

104984

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

When applying the ’market-based’ method to calculate GHG Emissions, total Global GHG Emissions are 98,082 tCO2-e. In accordance with The Climate Active Carbon Neutral Standard, ANZ purchased, retired and allocated 98,082 tCO2-e this reporting year in line with the 'market-based' method. Environmental reporting year runs 1 July - 30 June to align to environmental regulatory reporting requirements. We do not currently disclose absolute Scope 3 emissions from our lending (‘financed emissions’). We do disclose two separate emissions intensity metrics that cover our power generation loan book a nd our Australian large commercial building portfolio – refer to our Climate-related Financial Disclosures available at https://www.anz.com.au/content/dam/anzcom/shareholder/ANZ-2021-Climate-related-Financial-Disclosures.pdf . We will continue to monitor the emergence of methodologies that may be suitable for disclosure of absolute emissions from our lending activities in future. *Note: Our Scope 3 Emissions, partial, is 42,289 tCO2e

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

We do not publicly disclose this information.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

ANZ has a target to fund and facilitate at least AU$50 billion by 2025 towards sustainable solutions for our customers, including initiatives that help improve environmental sustainability, support disaster resilience, increase access to affordable housing and promote financial wellbeing. See page 13 https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

See page 30 of ANZ's ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

We don't publicly disclose this information. However, our Sustainable Finance fee income is up 63% from FY 20 to FY 21. This business also participated in 81 Sustainable Finance deals with a total deal size of $119b during FY21. See page 9 of ANZ's 2021 FY results investor discussion pack: https://www.anz.com/content/dam/anzcom/shareholder/2021-FY-results-investor-discussion-pack.pdf

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

See ANZ"s Climate-Related Financial Disclosures for information about our support for customers and industries to transition to net zero emissions. We also seek to align our lending decisions to the Paris Agreement goals, reduce our impact by managing and reducing emissions from our operations, and engage constructively and transparently with stakeholders. Link: https://www.anz.com.au/content/dam/anzcom/shareholder/ANZ-2021-Climate-related-Financial-Disclosures.pdf

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

See page 46, ESG Supplement https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf

Optional comment

Question AC1.1: 2021 was the last year this program was reviewed.

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

ANZ's Anti Bribery Anti Corruption policy includes conflicts provisions which is supported by more detailed requirements. See: https://www.anz.com/content/dam/anzcom/shareholder/anti-bribery-and-anti-corruption-policy-june-2021.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

All employees and contractors must comply with ANZ's Code of Conduct, which sets the expected standards of professional behaviour and guides us in applying our values. https://www.anz.com/content/dam/anzcom/shareholder/code-of-conduct.pdf

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Optional comment

See ANZ's Anti Bribery and Anti Corruption Policy https://www.anz.com/content/dam/anzcom/shareholder/anti-bribery-and-anti-corruption-policy-june-2021.pdf

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
We don't disclose this information publicly.
Confirmed during the current year, and related to this year
We don't disclose this information publicly.

Optional comment

Please see Code of Conduct breaches in Governance tab of ANZ's 2021 ESG Data pack https://www.anz.com/content/dam/anzcom/shareholder/2021-anz-esg-data-pack.xlsx?adobe_mc=MCMID%3D49061309673430232591953298274404107473%7CMCAID%3D2DE87DB4052C7108-600000C0A0002455%7CMCORGID%3D67A216D751E567B20A490D4C%2540AdobeOrg%7CTS%3D1655877363

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

ANZ is a founding member of the Bribery Prevention Network Australia which is an initiative of the United Nations Global Compact, Australia. ANZ is a corporate member of Transparency International Australia.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Our Anti-Bribery and Anti-Corruption (ABAC) Policy and Framework sets out the principles and conduct provisions which apply to ABAC business integrity matters applicable to ANZ, its employees and third parties. Our commitment to business integrity is described by way of key ABAC principles and the practical behavioural outcomes required to demonstrate adherence to the ABAC policy. Capacity in our ABAC team has increased in response to growing regulatory and social expectations to combat bribery and corruption. We also developed specific due diligence requirements to support our third-party risk program, to ensure we maintain procedures to know our third parties and hold them to our standards of business integrity. See Financial Crime in ANZ's ESG Supplement (p.46) https://www.anz.com.au/content/dam/anzcom/shareholder/2021-esg-supplement.pdf See ANZ's ABAC Policy https://www.anz.com/content/dam/anzcom/shareholder/anti-bribery-and-anti-corruption-policy-june-2021.pdf