Governance Policies

Governance Policies

Fit for purpose policies have been developed to ensure that NAIF operates in the public interest by balancing its public sector accountabilities with its mandate. This includes a core suite of governance charters and policies, which have been independently reviewed to ensure they meet Australian best practice.

Board Charter sets out the structure, function, duties and responsibilities of the NAIF Board and the duties and responsibilities of management.

Board Audit & Risk Committee (BARC) Charter – describes the duties and responsibilities of the BARC in exercising its primary functions including financial reporting, performance reporting, risk management and oversight and the internal control environment.

AML/CTF Program – NAIF is required to identify, mitigate and manage the Money Laundering and Terrorism Financing risk that it potentially faces. This Program describes the structures in place to do this including transaction risk assessment, customer due diligence procedures and reporting of suspicious matters to Australian Transaction Reports and Analysis Centre (AUSTRAC).

Anti-Corruption Policy – describes the application of appropriate management control systems to deter and prevent bribery and corruption and provides guidance to staff regarding how to raise a concern in that regard.

Code of Conduct – The Code of Conduct outlines the obligations and responsibilities of all staff employed by NAIF in relation to general duties, use of information and personal behaviour. NAIF staff are required to comply with the Code of Conduct with sanctions in place in the event of a breach.

Confidentiality Policy – provides NAIF staff with an overview of what is defined as confidential information and obligations in relation to how such information is to be protected.

Conflict of Interest Policy – sets out NAIF’s approach to the effective identification and management of Conflicts of Interest that affect it, its staff, Directors and its Service Providers. The policy covers actual, apparent or potential Conflicts of Interest.

Environment and Social Review of Transactions Policy – provides a framework to guide the NAIF Executive in assisting the Board in making Investment Decisions and the Board in discharging its functions in relation to assessment of a proposed project’s environmental and social and related project governance risks.

Freedom of Information Policy – sets out the approach to, and management of, access to information including how NAIF will comply with its obligations under the Freedom of Information Act 1982 (Cth).

Incident Reporting Policy – outlines NAIF’s commitment to the prompt and effective reporting of an incident (defined as an event, error or breach that has led to or may lead to financial loss or reputational damage to NAIF or its stakeholders) and to support and encourage staff to report incidents. Provides guidance on how an incident should be reported, investigated and remediated and provides some protection for staff who make reports.

Privacy Policy – describes how NAIF collects, uses and discloses personal information and implements the requirements of the Privacy Act 1988 Cth (Act) and any rules, regulations or principles made under that Act.

Public Interest Disclosure Policy – The Public Interest Disclosure Act (PID Act) promotes integrity within the Commonwealth public sector by providing a framework for Commonwealth officials to disclose suspected wrongdoing and for agencies to investigate and respond to such disclosures. This Policy applies to all public officials under the PID Act and includes all current and former employees of the NAIF as well as NAIF Directors.

Risk Management Framework – details NAIF’s approach to risk management including risk identification, analysis, measurement and monitoring. The Risk Management Framework consists of several key components through which NAIF manages risk, namely Governance, Risk Appetite, Risk Process, Risk Measurement, Risk Culture, Controls and Assurance.

Staff Securities Trading Policy – sets out NAIF’s approach to managing staff securities trading, including insider trading and trading in the securities of project proponents and other entities about which staff may gain inside information through their position at NAIF.