APRA code of conduct

1. Purpose

The Values and Code of Conduct Policy (Policy) is a policy that sets out the standard of behaviour that APRA employees and contractors providing goods or services to APRA are expected to meet. Specifically:

• APRA’s Values (Values)
• the APRA Code of Conduct (Code of Conduct).

2. Application

The Policy applies to all APRA employees (including permanent, fixed term and casual) and those who occupy a position (whether as a contractor, consultant or otherwise within APRA) (collectively referred to as Employees) whilst:

• in APRA’s workplace or working remotely
• conducting business on behalf of APRA from an external location
• participating in work-related functions, events or social media communications where you can reasonably expect to be identified as an APRA Employee
• outside of work where your conduct may impact in any way on APRA’s reputation, your colleagues, APRA employees or APRA business
• accessing APRA’s information and communication systems.

3. APRA Values

APRA's Values, as determined by the Chair under section 48AB of the Australian Prudential Regulatory Authority Act 1998 (APRA Act), are:

Integrity

Be honest, courageous and resolute.

Collaboration

One team with one purpose.

Accountability

Be clear and consistent. Own it and do it.

Respect

Be open, fair and inclusive.

Excellence

Show acumen. Be bold, confident and decisive.

4. APRA Code of Conduct

APRA's Code of Conduct, as determined by the Chair under section 48AC of the APRA Act, is as follows.

Principle 1: We treat each other with Respect

A core APRA value is respect for one another.

This means Employees are required to:

• not engage in any form of harassment, sexual harassment, bullying, unlawful discrimination, victimisation or other forms of unacceptable behaviour
• comply with the Preventing Discrimination, Harassment and Bullying and the Preventing Sexual Harassment Policy.
• comply with all relevant legislation and Codes of Practice as they relate to Respect@Work
• treat all people in the course of their work (including entities, external stakeholders, vendors and suppliers) with respect, fairness, courtesy and sensitivity
• not treat anyone less favourably for raising or proposing to raise a genuine allegation or complaint of breach of this Policy and/or other relevant APRA policies, as applicable.

Principle 2: We adhere to the highest Professional and Ethical standards of behaviour

APRA operates at the highest standard of propriety and integrity is a cornerstone of how APRA regulates and executes its mandate.

This means Employees are required to:

• act in a way that upholds the Values
• comply with the Code of Conduct
• carry out work diligently and responsibly
• not engage, either directly or indirectly, in any form of fraud, dishonest behaviour, bribery or corruption
• minimise and manage any conflict of interest (real or perceived) in connection with their employment, including disclosing internal or external personal relationships that may be perceived as a conflict of interest
• immediately disclose to their people leader, and seek approval prior to commencing, any outside employment or business activities (including paid or unpaid activities) in accordance with the APRA Conflicts of Interest Framework and Procedure
• take all reasonable steps to avoid accepting gifts, benefits, entertainment, compensation or consideration that might reasonably be expected to create a conflict of interest and report any gifts and benefits received or given in accordance with the APRA Conflicts of Interest Framework and Procedure
• disclose any equity holdings they have in APRA-regulated entities and abide by the APRA Financial Holdings Disclosure Policy regarding the acquisition of financial holdings
• ensure that they act within APRA’s delegated authority in making decisions and financial undertakings on behalf of APRA
• maintain appropriate confidentiality about all dealings, including with any Minister, Minister’s member of staff, regulated entities and with each other
• only use APRA resources in a proper manner and for a proper purpose
• not provide false or misleading information in response to a request for information that is made for official purposes in connection with their employment or engagement by APRA.

Principle 3: We comply with all applicable laws and regulations and safeguard APRA's reputation

Employees are required to comply with all applicable laws, regulations, policies and reasonable and lawful directions and to always behave in a way that protects APRA's reputation.

This means Employees are required to:

• act in a way that upholds the APRA Values and the integrity and good reputation of APRA
• comply with all applicable laws and regulations, APRA policies and other Commonwealth Government policies, including but not limited to section 56 of the APRA Act
• comply with any lawful and reasonable direction
• act in accordance with the IT Acceptable Use and Privacy Policy and APRA Security Policy
• APRA • People & Culture • November 2025 6
• and not disclose any information obtained in the course of performing their duties for APRA other than with approval and for authorised purposes
• obtain approval before making any public comment or address on behalf of APRA and comply with the Employee Social Media Policy
• refrain from behaviours which may negatively impact APRA’s reputation, including when representing APRA or being seen to represent APRA at external functions, events or training courses, including when overseas
• immediately inform their People Leader of any changes to personal circumstances that may impact on their ability to perform their role and/or which may have the potential to impact APRA’s reputation
• conform with all security requirements associated with people, physical sites, accessing APRA information, including meeting ongoing security clearance requirements.

Principle 4: We are empowered to speak up

Employees are required to speak up when they see behaviour or conduct that contravenes the Code of Conduct, the APRA Act, policies or applicable laws.

This means Employees are required to:

• immediately declare and report any errors, omissions, breaches of the law, breaches of regulatory obligations or breaches of APRA policies through appropriate channels and never attempt to conceal any wrongdoing or potential wrongdoing
• immediately report any incidents relating to fraud, corruption, data breaches, breaches of confidentiality requirements under the APRA Act, stakeholder complaints or breaches of security protocols in the APRA Issue and Incident Standards
• not victimise anyone who speaks up or is presumed to have spoken up.

Employees are also empowered to speak up if they see behaviour that is inconsistent with APRA values.

People leaders are also required to take appropriate actions to address any behaviours that are contrary to APRA's Values, APRA's Code of Conduct, or any other behaviours or conduct that is inappropriate.

Principle 5: We take steps to keep ourselves and each other safe

APRA is committed to the physical and psychological wellbeing of all persons impacted by its activities by providing a safe working environment.

This means Employees are required to comply with the obligations and requirements in the Work Health and Safety Policy. 

In summary, this includes the requirement for Employees to:

• take reasonable care for their own health and safety
• ensure their acts or omissions do not adversely affect the health and safety of anyone
• adhere to and cooperate with any reasonable direction, policy or procedure relating to workplace health and safety
• participate in eliminating or minimising workplace hazards or report any risk beyond their control to their people leader or other relevant WHS contact such as an APRA WHS Representative.

5. Accountabilities and Responsibilities

People Leaders 

All People leaders will:

• set clear expectations as to the standards of behaviour required of your direct reports and teams
• foster and enable APRA’s speak up culture, ensuring that their team feels safe to raise any issues or concerns
• identify any breaches of this Policy and address these as appropriate.

All Employees

All Employees have a responsibility to:

• understand and exhibit the behaviours articulated in this Policy; and
• review this Policy and sign an attestation to acknowledge their responsibilities under this Policy every 12 months.

People & Culture

People and Culture will:

• manage and monitor compliance of this Policy, including managing Employee attestations every 12 months
• provide guidance and support where potential breaches of this Policy are identified
• report as necessary breaches of this Policy
• update and review this Policy as required.

Enterprise Risk

Enterprise Risk will:

• have oversight of risk conduct actions
• manage APRA's risk appetite and operational risk.

6. Suspected breaches of the APRA Values and Code of Conduct

Please refer to APRA’s Grievance Handling and Investigations Policy.