Anti-Bribery and Corruption Policy and Principles

Westpac requires compliance with anti-bribery and corruption (“AB&C”) laws in all markets and jurisdictions in which it operates. These laws include, but are not limited to, the Australian Criminal Code Act 1995, the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977. Where a conflict arises between applicable country AB&C legislative requirements, Westpac’s position is that it will always adopt the more onerous requirement.

Westpac’s Anti-Bribery and Corruption Compliance Program includes a global Anti-Bribery & Corruption Policy, with Board endorsement and oversight and clear emphasis that Westpac does not tolerate the giving or receiving of bribes, including the making of facilitation payments. Westpac expects that books and records must be fair and accurate and reasonably detailed. We expect all employees, and other third parties with whom Westpac works, to comply with these principles in the performance of their services for or on behalf of Westpac.

Westpac’s AB&C Program includes the following global standards

• No Westpac entity or individual shall engage in bribery or corrupt practices in any form, whether direct or indirect;

• No Westpac entity or individual shall engage in bribery with a public official or private party. This includes any advantage provided to a close family member or other closely connected person of the public official or private party; and

• No Westpac entity or individual shall engage in the provision of a facilitation payment. Facilitation payments are typically small, unofficial sums made to secure or expedite a routine government action by a government official.  Exceptions may be permitted in extraordinary circumstances to protect against loss of life, limb or liberty.

As part of the prevention, detection and remediation of AB&C risks, mandatory employee training and risk assessments are conducted throughout Westpac.

Westpac also maintains clear whistleblowing policies and processes to ensure that individuals can confidentially report concerns and to ensure that such concerns are investigated and resolved appropriately.

The Westpac Group is committed to the process of continuous improvement to ensure its ABC framework remains robust across all areas of its operations.