Westpac Group 2019 Corporate Governance Statement

2019
Corporate
Governance
Statement
Westpac Banking Corporation
ABN 33 007 457 141
Help when
it matters.

12019 Westpac Group Corporate Governance Statement
Corporate governance
As an overseas listed issuer in New Zealand, we are
deemed to satisfy and comply with the NZX Listing
Rules, provided that we remain listed on the ASX and
comply with the ASX Listing Rules.
The ASX, through the ASXCGC Recommendations and
the NZX, through the NZX Corporate Governance Code,
have adopted similar ‘comply or explain’ approaches to
corporate governance. The ASXCGC Recommendations
may, however, materially differ from the corporate
governance rules and the principles of NZX’s Corporate
Governance Code.
United States
Westpac has American Depositary Shares (ADS)
representing its ordinary shares quoted on the
New York Stock Exchange (NYSE), trading under
the symbol WBK. Under the NYSE Listing Rules,
foreign private issuers (like Westpac) are permitted to
follow home country practice in respect of corporate
governance in lieu of the NYSE Listing Rules. However,
we are still required to comply with certain audit
committee and additional notification requirements.
We comply in all material respects with all NYSE Listing
Rules applicable to us.
Under the NYSE Listing Rules, foreign private issuers
are required to disclose any significant ways in which
their corporate governance practices differ from
those followed by domestic US companies. We have
compared our corporate governance practices to the
corporate governance requirements of the NYSE Listing
Rules and note the significant differences below.
The NYSE Listing Rules require that, subject to limited
exceptions, shareholders be given the opportunity
to vote on equity compensation plans and material
revisions to those plans. In Australia, there are no laws
or ASX Listing Rules that require shareholder approval
of equity based incentive plans or individual grants
under those plans (other than for Directors, including
the Chief Executive Officer (CEO)).
Westpac’s employee equity plans have been disclosed
in the Remuneration Report in Section 10 of the
Directors’ report (located in our 2019 Annual Report),
which is subject to a non-binding shareholder vote
at the Annual General Meeting (AGM) and grants to
our CEO are approved by shareholders. The details of
grants under our equity-based incentive plans have
been disclosed in Note 33 of our financial statements
for the year ended 30 September 2019.
The NYSE Listing Rules set out specific requirements
for determining whether a director will be regarded
as independent. While these requirements are broadly
consistent with Westpac’s criteria for independence
(described below under ‘Board, Committees and
oversight of management’), under Australian
independence requirements, the Board is able to
apply discretion in its determination of a director’s
independence that differs from the NYSE Listing Rules.
The NYSE Listing Rules also provide that the Board
Nominations Committee’s responsibilities should include
selecting, or recommending that the Board select,
the Director nominees for the next annual meeting
for shareholders, and overseeing the evaluation of the
Board. The Board, rather than the Board Nominations
Committee, reviews and recommends the Director
nominees for election at the AGM and undertakes an
annual review of its performance.
Introduction
This Corporate Governance Statement, which has
been approved by the Board, describes our corporate
governance framework, policies and practices as at
4 November 2019.
Framework and our approach to governance
Corporate governance is the framework of systems,
policies and processes by which we operate, make
decisions and hold people to account. The framework
establishes the roles and responsibilities of Westpac’s
Board and management. It also establishes the systems,
policies and processes for monitoring and evaluating
Board and management performance and the practices
for corporate reporting, disclosure, remuneration, risk
management and engagement of security holders.
Our approach to corporate governance is based on a
set of values and behaviours that underpin our day-
to-day activities, provide transparency and fair dealing
and seek to protect stakeholder interests. It includes
a commitment to maintaining the highest standards
of corporate governance, which Westpac sees as
fundamental to the sustainability of our business and
our performance.
We regularly review local and global developments in
corporate governance to assess their implications and
to respond to changes in the operating environment.
We also improve our systems, processes and policies
and look to strengthen our frameworks to reflect
changing expectations where appropriate.
We have equity securities quoted on securities
exchanges in Australia, New Zealand and the United
States.
Australia
The principal listing of Westpac ordinary shares is on
the ASX, trading under the code WBC. Westpac also
has hybrid securities, capital notes, senior notes and
subordinated notes listed on the ASX.
We comply with the ASX Corporate Governance
Principles and Recommendations (third edition)
(ASXCGC Recommendations) published by the ASX
Limited’s Corporate Governance Council (ASXCGC).
In addition, we already comply with a number of the
recommendations contained in the fourth edition
of the ASX Corporate Governance Principles and
Recommendations.
We must also comply with the Corporations Act,
the Banking Act, including Part IIAA – The Banking
Executive Accountability Regime amongst other laws,
and, as an Authorised Deposit-taking Institution, with
governance requirements prescribed by APRA under
Prudential Standard CPS 510 Governance.
This Corporate Governance Statement addresses each
of the ASXCGC Recommendations with an explanation
of our corporate governance practices, demonstrating
our compliance with each Recommendation.
Further details about the ASXCGC Recommendations
can be found on the ASX website www.asx.com.au.
New Zealand
Westpac’s ordinary shares are also quoted on
the NZX, which is the main board equity security
market operated by NZX Limited. Westpac also has
subordinated notes quoted on the NZX Debt Market.
Corporate governance

22019 Westpac Group Corporate Governance Statement
Corporate governance
Board and Board Committee Structure
Board
Committees
Delegation
Assurance,
Oversight through
Reporting
Chief Executive
Ocer
Board
External auditors
Group Audit
Independent
Assurance
External professional
advice

Accountability
Delegation
Provide assurance on
risk components of
financial statements
Nominations
Risk
& Compliance
AuditRemuneration
Technology
Provide assurance on remuneration components of
financial statements
Group Executives
DelegationAccountability
The diagram above shows Westpac’s Board and current Board Committee structure. The structure comprises a
Board with five Board Committees that oversee Westpac’s business. The Board’s responsibilities include approving
and overseeing the implementation of Westpac’s strategy, approving the Group’s risk management framework, risk
management strategy and risk appetite statement, and overseeing the three lines of defence model.
From time to time, the Board may form other Committees or request Directors to undertake specific extra duties.
In addition, from time to time, the Board participates (either directly or through representatives) in due diligence
committees in relation to strategic decisions and capital and funding activities.
The Board has delegated to the CEO, and through the CEO to the Executive Team, responsibility for the day-to-day
management of Westpac’s business.
The key functions of the Board and each of the Board Committees are outlined in this Corporate Governance
Statement. All Board Committee Charters are available on our website at www.westpac.com.au/corpgov.

32019 Westpac Group Corporate Governance Statement
Corporate governance
How the Board and Committees work including
oversight of management
Board of Directors
Roles and responsibilities
The role of the Board is to provide leadership and
strategic guidance for Westpac and its related bodies
corporate.
The Board Charter outlines the roles and responsibilities
of the Board. Key responsibilities are:
• approving, and overseeing management’s
implementation of, the strategic direction of
Westpac Group, its business plan and significant
corporate strategic initiatives;
• evaluating Board performance and determining
Board size and composition;
• approving the Westpac Board Renewal Policy and
the Westpac Group Remuneration Policy;
• selecting, appointing and determining the duration,
remuneration and other terms of appointment of the
CEO and Chief Financial Officer (CFO);
• approving individual remuneration levels for Group
Executives, other executives who report directly to
the CEO, any other accountable persons under the
Banking Executive Accountability Regime, and any
other person the Board determines;
• evaluating the performance of the CEO;
• succession planning for the CEO and Group
Executives;
• approving the appointment of Group Executives and
the General Manager Group Audit and monitoring
the performance of Group Executives;
• approving the annual targets and financial
statements and monitoring performance against
forecast and prior periods;
• determining our dividend policy;
• considering and approving our overall risk
management framework, approving our Group Risk
Management Strategy and Group Risk Appetite
Statement and monitoring the effectiveness of risk
management by the Group;
• forming a view of our risk culture and identifying any
desirable changes;
• considering the social, ethical and environmental
impact of our activities and monitoring compliance
with our sustainability policies and practices;
• overseeing and monitoring Workplace Health and
Safety (WHS) issues in the Group and considering
appropriate WHS reports and information;
• maintaining an ongoing dialogue with Westpac’s
external auditor and, where appropriate, principal
regulators;
• overseeing internal governance, including delegated
authorities and approving policies for appointments
to our controlled entity boards; and
• overseeing and monitoring customer complaints.
Governance and conduct focus areas
In addition to the roles and responsibilities outlined in
the Board Charter, this year the Board has also focused
on addressing the recommendations, observations
and findings of Westpac’s Culture, Governance
and Accountability (CGA) self-assessment and the
Royal Commission into Misconduct in the Banking,
Superannuation and Financial Services Industry (Royal
Commission). These areas of focus include Board and
executive governance, risk and compliance, customer
experience, remuneration and accountability and
culture.
The Board has continuing oversight over the
implementation of both Westpac’s Royal Commission
and CGA response plans.
The Board also met with representatives from the
Australian Securities and Investments Commission,
Australian Prudential Regulation Authority, Australian
Transaction Reports and Analysis Centre and the
Australian Financial Complaints Authority during the
course of the year.
Delegated authority
The Constitution and the Board Charter enable the
Board to delegate to Committees and management.
The roles and responsibilities delegated to the Board
Committees are captured in the Charters of each of the
five established Committees, namely:
• Audit;
• Risk & Compliance;
• Nominations;
• Remuneration; and
• Technology.
The Board Charter, Board Committee Charters and
the Constitution are available on our website at
www.westpac.com.au/corpgov.
The Delegated Authority Policy Framework outlines
principles to govern decision-making within the
Westpac Group, including appropriate escalation and
reporting to the Board. The scope of, and limitations
to, authority delegated by the Board to the CEO and
through the CEO to other Group Executives, is clearly
documented and covers areas such as operating and
capital expenditure, funding and securitisation, and
lending. These delegations balance effective oversight
with appropriate empowerment and accountability
of management. Any matters or transactions outside
the delegations of authority given to management are
required to be referred to the appropriate Board or
relevant Board Committee for approval.
The Executive team, Disclosure Committee and
Executive Risk Committee are not Board Committees
(that is, they have no delegation of authority from
the Board) but sit beneath the CEO and the Board
Committees to implement Board-approved strategies,
policies and manage risk across the Group.

42019 Westpac Group Corporate Governance Statement
Corporate governance
1. Composition requirements for each Committee are set out in the relevant Committee Charter.
2. Steven Harker was appointed as a Member of the Board Audit Committee effective from 1 October 2019.
3. Margaret Seale was appointed as a Member of the Board Remuneration Committee effective from 1 October 2019.
Independence
Together, the Board members have a broad range of relevant financial and other skills and knowledge, combined
with the extensive experience necessary to guide our business. Details are set out in Section 1 of the Directors’
report, in our 2019 Annual Report. A skills matrix for the Board appears on page 6 of this statement.
All of our Non-executive Directors satisfy our criteria for independence, which align with the guidance provided
in the ASXCGC Recommendations and the criteria applied by the NYSE and the US Securities and Exchange
Commission (SEC).
The Board assesses the independence of our Directors on appointment and annually. Each Director provides an
annual attestation of his or her interests and independence.
Directors are considered independent if they are independent of management and free from any business or other
relationship that could materially interfere with, or reasonably be perceived to materially interfere with, the exercise
of their unfettered and independent judgement. Materiality is assessed on a case by case basis by reference to
each Director’s individual circumstances rather than by applying general materiality thresholds.
Each Director is expected to disclose any business or other relationship that he or she has directly, or as a partner,
shareholder or officer of a company or other entity that has an interest in Westpac or a related entity. The Board
considers information about any such interests or relationships, including any related financial or other details,
when it assesses the Director’s independence.
Size and membership of Board Committees as at 30 September 2019
Committee Composition
1
Name of Committee
Board Audit
Committee
Board Risk &
Compliance
Committee
Board Nominations
Committee
Board Remuneration
Committee
Board Technology
Committee
Number of Members
Minimum three
members
Minimum three
members
Composed of all
Board Committee
Chairs, Board
Chairman and such
other members as
determined by the
Board
Minimum three
members
Minimum three
members
Composition
All members are
Independent Non-
executive Directors
All members are
Non-executive
Directors
Majority of members
are Independent
Non-executive
Directors
All members are
Independent Non-
executive Directors
All members are
Independent Non-
executive Directors
Maximum one
Executive Director
All other members
are Independent
Non-executive
Directors
Committee Chair
Chair is Independent
Non-executive
Director, who is not
the Board Chairman
Chair is Independent
Director, who is not
the Board Chairman
Chair determined by
the Board
Chair determined by
the Board
Chair determined by
the Board
Lindsay Maxsted
Chairman,
Non-executive,
Independent
Chair

Brian Hartzer
CEO,
Executive
Nerida Caesar
Non-executive,
Independent
Ewen Crouch
Non-executive,
Independent
Chair

Alison Deans
Non-executive,
Independent
Chair

Craig Dunn
Non-executive,
Independent
Chair

Anita Fung
Non-executive,
Independent
Steven Harker
2
Non-executive,
Independent
Peter Marriott
Non-executive,
Independent
Chair

Peter Nash
Non-executive,
Independent
Margaret Seale
3
Non-executive,
Independent

52019 Westpac Group Corporate Governance Statement
Corporate governance
Chairman
The Board elects one of the independent Non-executive
Directors as Chairman. Our Chairman is Lindsay
Maxsted, who became Chairman on 14 December 2011.
The Chairman’s role includes:
• providing effective leadership to the Board in
relation to all Board matters;
• guiding the agenda and conducting all Board
meetings to facilitate discussions, challenge and
decision-making;
• in conjunction with the Company Secretaries,
arranging regular Board meetings throughout the
year, confirming that minutes of meetings accurately
record decisions taken and, where appropriate, the
views of individual Directors;
• overseeing the process for appraising Directors and
the Board as a whole;
• overseeing Board succession;
• acting as a conduit between management
and the Board, and being the primary point of
communication between the Board and CEO;
• representing the views of the Board to the public;
and
• taking a leading role in creating and maintaining an
effective corporate governance system.
CEO
Our CEO is Brian Hartzer. The CEO’s role includes:
• leadership of the management team;
• developing strategic objectives for the business and
achievement of planned results; and
• the day-to-day management of the Westpac Group’s
operations, subject to the specified delegations of
authority approved by the Board.
Board meetings
The Board had 11 scheduled meetings for the financial
year ended 30 September 2019, with additional
meetings held as required. In addition to the Board
considering strategic matters at each Board meeting,
the Board also discusses our strategic plan and
approves our overall strategic direction on an annual
basis. The Board also conducts a half year review
of our strategy. The Board conducts workshops on
specific subjects relevant to our business and the Board
throughout the year. Board meetings are characterised
by robust exchanges of views between Board and
management, with Directors bringing their experience
and independent judgement to bear on the issues and
decisions.
Non-executive Directors regularly meet without
management present, so that they can discuss issues
appropriate to such a forum. In all other respects, senior
executives are invited, where considered appropriate, to
participate in Board meetings. They are also available to
be contacted by Directors between meetings.
Meetings attended by Directors for the financial year
ended 30 September 2019 are reported in Section 9 of
the Directors’ report, in our 2019 Annual Report.
Nomination and appointment
As set out in its Charter, key responsibilities of the
Board Nominations Committee are:
• assessing the skills required to discharge
competently the Board’s duties having regard to
Westpac’s performance, financial position and
strategic direction;
• developing, reviewing, assessing and recommending
to the Board policies on Director tenure, Board
composition and size;
• reviewing and making recommendations to the
Board annually on diversity generally within the
Group, measurable objectives for achieving diversity
and progress in achieving those objectives;
• developing and implementing succession planning
for Non-executive Directors;
• reviewing the process for the orientation and
education of new Directors and any continuing
education for existing Directors;
• reviewing eligibility criteria for appointing Directors;
• considering and recommending candidates
for appointment as Directors to the Board and
determining the terms and conditions (excluding
remuneration) on which Non-executive Directors are
appointed and hold office;
• considering and recommending candidates for
appointment to the Boards of significant subsidiaries
(including Westpac New Zealand Limited and our
insurance and superannuation businesses); and
• reviewing and where necessary, developing the
Group’s corporate governance policies to provide
reasonable assurance that they meet international
corporate governance standards.
Board skills, experience and attributes
Westpac seeks to maintain a Board of Directors with
a broad range of financial and other skills, experience
and knowledge necessary to guide the business of the
Group. In addition, Westpac seeks to maintain a diverse
Board, which at a minimum, collectively has the skills
and experience detailed in Figure 1 overleaf. Figure 1
also illustrates Board tenure and gender diversity.

62019 Westpac Group Corporate Governance Statement
Corporate governance
Figure 1 – Board skills, experience and attributes as at 30 September 2019
STRATEGIC AND COMMERCIAL ACUMEN
An ability to define strategic objectives, constructively question business plans and
implement strategy using commercial judgement
FINANCIAL SERVICES EXPERIENCE
Experience working in, or advising the banking and financial services industry (including
wealth management), with strong knowledge of its economic drivers and global business
perspectives
FINANCIAL ACUMEN
Highly proficient in accounting or related financial management and reporting for
businesses of significant size
RISK
Experience in anticipating, recognising and managing risks, including regulatory,
financial and non-financial risks, and monitoring risk management frameworks and
controls
TECHNOLOGY
Experience in developing or overseeing the application of technology in large complex
businesses, with particular reference to innovation and the Group’s digital transformation
strategic priority
GOVERNANCE
Commitment to, and knowledge of, governance, environmental and social issues, with
particular reference to the legal, compliance, regulatory and voluntary frameworks
applicable to listed entities and highly regulated industries
PEOPLE, CULTURE AND CONDUCT
Experience in people matters including workplace cultures, morale, management
development, succession and remuneration, with particular reference to the Group’s talent
retention and development initiatives and the ability to consider and respond to matters
relating to inclusion and diversity
EXECUTIVE LEADERSHIP
Being appointed as CEO or a similar senior leadership role in a large complex
organisation, and having experience in that position in managing the business through
periods of significant change
LISTED COMPANY EXPERIENCE
Held two or more Non-executive Directorships on Australian or international listed
companies
INTERNATIONAL
Senior leadership experience involving responsibility for operations across borders, and
exposure to a range of political, cultural, regulatory and business environments in that
position
CUSTOMER FOCUS
Experience in developing and overseeing the embedding of a strong customer-focused
culture in large complex organisations, and a demonstrable commitment to achieving
customer outcomes
11 out of 11
Number of Directors
11 out of 11
10 out of 11
10 out of 11
8 out of 11
9 out of 11
9 out of 11
9 out of 11
7 out of 11
7 out of 11
7 out of 11
27
%
27
%
45
%
36
%
64
%
BOARD TENURE DIVERSITY
BOARD TENURE
0-3 Years3-6 Years6-9+ Years
DIVERSITY
Male Female
1

1. Chart does not add to 100% due to rounding.

72019 Westpac Group Corporate Governance Statement
Corporate governance
The Board Nominations Committee considers and
makes recommendations to the Board on candidates
for appointment as Directors. Such recommendations
pay particular attention to the mix of skills, experience,
expertise, diversity, independence and other qualities of
existing Directors, and how the candidate’s attributes
will balance and complement those qualities and
address any potential skills gaps in relation to the
current composition of the Board. External consultants
are used to access a wide base of potential Directors.
Board appointments are also made with regard to the
Group’s Service Revolution vision and three strategic
priorities of:
• building our customer franchise;
• digital transformation; and
• strengthening performance disciplines.
1
Prior to a Director’s appointment or consideration
for election or re-election by shareholders, Westpac
conducts due diligence and provides shareholders
with all material information relevant to a decision on
whether or not to elect or re-elect a Director.
New Directors receive an induction pack which includes
a letter of appointment setting out the expectations
of the role, conditions of appointment including the
expected term of appointment, and remuneration. This
letter conforms to the ASXCGC Recommendations.
Term of office
The Board may appoint a new Director, either to fill
a casual vacancy or as an addition to the existing
Directors, provided the total number of Directors does
not exceed fifteen Non-executive Directors and three
Executive Directors. Except for the CEO, a Director
appointed by the Board holds office only until the
close of the next AGM but is eligible for election by
shareholders at that meeting.
Our Constitution states that at each AGM, one-third of
eligible Directors, and any other Director who has held
office for three or more years since their last election,
must retire. In determining the number of Directors to
retire by rotation, no account is to be taken of Directors
holding casual vacancy positions or of the CEO. The
Directors to retire by rotation are those who have been
the longest in office. A retiring Director holds office
until the conclusion of the meeting at which he or she
retires but is eligible for re-election by shareholders
at that meeting. The Board makes recommendations
concerning the election or re-election of any Director
by shareholders. In considering whether to support a
candidate, the Board takes into account the results of
the Board performance evaluation conducted during
the year.
The Westpac Board Renewal Policy limits the maximum
tenure of office that any Non-executive Director other
than the Chairman may serve to nine years, from the
date of first election by shareholders. The maximum
tenure for the Chairman is twelve years (inclusive of any
term as a Director prior to being elected as Chairman),
from the date of first election by shareholders. The
Board, on its initiative and on an exceptional basis,
may exercise discretion to extend the maximum
terms specified above where it considers that such an
extension would benefit the Group. Such discretion
will be exercised on an annual basis and the Director
concerned will be required to stand for re-election
annually.
Director induction and continuing education
All new Directors participate in an induction program to
familiarise themselves with our business and strategy,
culture and values and any current issues before the
Board. The induction program includes meetings with
the Chairman, the CEO, the Board Committee Chairs
and each Group Executive.
The Board encourages Directors to undertake
continuing education and training to develop and
maintain the skills and knowledge needed to perform
their role as Directors effectively, including by
participating in workshops held throughout the year,
attending relevant site visits and undertaking relevant
external education.
Access to information and advice
All Directors have unrestricted access to company
records and information, and receive regular detailed
financial and operational reports from senior
management. Each Director also enters into an access
and indemnity agreement, which among other things,
provides for access to documents for up to seven years
after his or her retirement as a Director.
The Chairman and other Non-executive Directors
regularly consult with the CEO, CFO and other
senior executives, and may consult with, and request
additional information from, any of our employees.
All Directors have access to advice from senior internal
legal advisors including the Group Executive, Legal &
Secretariat.
In addition, the Board collectively, and all Directors
individually, have the right to seek independent
professional advice, at our expense, to help them
carry out their responsibilities. While the Chairman’s
prior approval is needed, it may not be unreasonably
withheld.
Company Secretaries
Westpac has two Company Secretaries:
• The Senior Company Secretary is our Group
Executive, Legal & Secretariat. The Senior Company
Secretary attends Board and Board Committee
meetings and is responsible for providing Directors
with advice on legal and corporate governance
issues.
• The Group Company Secretary also attends Board
and Board Committee meetings and is responsible
for the operation of the secretariat function,
including advising the Board on governance and,
in conjunction with management, giving practical
effect to the Board’s decisions. The Group Company
Secretary is accountable to the Board, through
the Chairman, on all matters to do with the proper
functioning of the Board.
Profiles of our Company Secretaries for the financial
year ended 30 September 2019 are set out in Section 1
of the Directors’ report, in our 2019 Annual Report.
1. Further information about the Service Revolution and our strategic priorities is available in our 2019 Annual Report.

82019 Westpac Group Corporate Governance Statement
Corporate governance
Board Committees
Composition and independence
Board Committee members are chosen for the skills
and experience they can contribute to the respective
Board Committees and their qualifications are set out
in Section 1 of the Directors’ report, in our 2019 Annual
Report. The membership of each Board Committee is
set out in the table entitled ‘Size and membership of
Board Committees as at 30 September 2019’ in this
Corporate Governance Statement. All of the Board
Committees are comprised of independent Non-
executive Directors, except for the Board Technology
Committee, of which the CEO is a member.
Operation and reporting
Scheduled meetings of the Board Committees occur
at least quarterly. Each member’s attendance at Board
Committee meetings held during the financial year
ended 30 September 2019 is reported in Section 9 of
the Directors’ report, in our 2019 Annual Report. All
Board Committees are able to meet more frequently
as necessary. Each Board Committee is entitled to the
resources and information it requires and has direct
access to our employees and advisers. The CEO attends
all Board Committee meetings, except where he has a
material personal interest in a matter being considered.
Senior executives and other selected employees
are invited to attend Board Committee meetings as
required. All Directors can receive all Board Committee
papers and can attend any Board Committee meeting,
provided there is no conflict of interest.
Performance
Board, Board Committees and Directors
The Board undertakes ongoing self-assessment as well
as commissioning an annual performance review by an
independent consultant.
The review process conducted in 2019 included an
assessment of the performance of the Board, the Board
Committees and each Director, with outputs collected,
analysed and presented to the Board. The Board
discussed the results and agreed follow up actions
on matters relating to Board composition, process,
priorities and continuing education.
The Chairman also discusses the results with individual
Directors and Board Committee Chairs. The full Board
(excluding the Chairman) reviews the results of the
performance review of the Chairman and results are
then privately discussed by the Chairman of the Board
Risk & Compliance Committee with the Chairman.
Management
The Board, in conjunction with its Board Remuneration
Committee, is responsible for:
• determining the goals and objectives relevant to the
remuneration of the CEO, and the performance of
the CEO in light of these goals and objectives; and
• approving individual remuneration for Group
Executives, other executives who report directly to
the CEO, any other accountable persons under the
Banking Executive Accountability Regime, and any
other person the Board determines.
The Board Risk & Compliance Committee and the Board
Audit Committee also refer to the Board Remuneration
Committee any matters that come to their attention
that are relevant, including with respect to risk adjusted
remuneration.
Management performance evaluations for the financial
year ended 30 September 2019 were conducted
following the end of the financial year.
There is a further discussion on performance objectives
and performance achieved in the Remuneration Report
in Section 10 of the Directors’ report (which is located in
our 2019 Annual Report).
All new senior executives receive a letter of
appointment setting out the conditions and
expectations of the role, together with an extensive
briefing on our strategies and operations and the
respective roles and responsibilities of the Board and
senior management.
Advisory Boards
Westpac has established Advisory Boards for its
operations in Asia, the Pacific, Victoria and for BankSA,
to advise management on the strategies and initiatives
of those businesses within the overall Group strategy.
Responsibilities of the Advisory Boards include:
• providing advice to management on management’s
strategies and initiatives to continue to strengthen
the position and identity of the business;
• providing advice to management of the relevant
business so as to promote and preserve its distinct
position and identity and align business values with
those of the relevant communities served;
• considering and assessing reports provided by
management on the health of the relevant business;
• acting as ambassadors for the business, including
by supporting community and major corporate
promotional events to assist in building relationships
with the bank’s customers, local communities and
the business and government sector, and advising
senior management on community matters
relevant to the provision of financial services in the
community it serves; and
• alerting management to local market opportunities
and issues of which Advisory Board members are
aware that would enhance the provision of services
to customers and potential customers and the
position of the bank in its local communities.
Ethical and responsible decision-making
At Westpac, our vision is to become one of the world’s
great service companies, helping our customers,
communities and people to prosper and grow. One of
the ways we seek to achieve this vision is through our
core values.
Westpac is also focused on the impact of its
organisational culture on the Group’s operations,
including its management of risk. We take an
integrated approach to sustainably embedding a
strong risk culture, including through leadership
and communication, risk appetite and governance,
risk awareness and transparency, accountability and
reinforcement, and behaviours and relationships.

92019 Westpac Group Corporate Governance Statement
Corporate governance
Our Values
Our Values support our customer-focused strategy and
are embedded in our culture. These are:
• integrity – we earn trust by demonstrating the
highest standards of honesty and ethical behaviour;
• service – we are here to help and delight our
customers;
• one team – we collaborate to deliver the best
outcomes for our customers and the company
overall;
• courage – we challenge the status quo and find a
way to make things better; and
• achievement – we strive for excellence and deliver
results.
Our values guide our behaviour and reflect our
commitment to our customers, communities and each
other.
Our Compass
Our Compass helps us navigate the world of banking,
capturing Our Vision, Values, Behaviours and the non-
negotiables of our Code of Conduct, to consistently
guide us in everything we do.
Together the four points of the Compass provide
direction and support by guiding our behaviour and
outlining where to turn if we need help:
• Our Vision – why we are here
• Our Values – how we behave
• Our Service Promise – how we serve
• Our Code of Conduct – how we deliver
Code of Conduct and Principles for Doing Business
Our Code of Conduct (Code) describes the standards of
conduct expected of our people, both employees and
contractors. The seven principles making up the Code
are:
• we act with honesty, integrity, and due skill, care and
diligence;
• we comply with laws and with our policies;
• we do the right thing by our customers;
• we respect confidentiality and do not misuse
information;
• we value and maintain our professionalism;
• we work as a team; and
• we manage conflicts of interest responsibly.
The Code’s guiding principles help us make the right
decisions, ensuring we uphold the reputation of the
Group. As employees of the banking and finance
industry, we are also committed to creating greater
accountability, transparency and trust with our
customers and the broader community. With that in
mind, the principles within our Code also reflect the
community’s expectations of us, such as those outlined
in the Banking and Finance Oath. The Code has the full
support of the Board and the Executive Team and we
take compliance with the Code very seriously.
Our commitment to sustainable business practice and
behaviours against which we expect to be judged in
pursuit of our vision to be one of the world’s great
service companies, helping our customers, communities
and people to prosper and grow, is set out in our
Principles for Doing Business (Principles).
The Principles apply to all Directors, employees and
contractors.
We also have the frameworks in place which apply to
support both our Code and Principles, internally and
externally across our value chain, including:
• a range of internal guidelines, policies, frameworks,
communications and training processes and tools,
including an online learning module entitled ‘Doing
the Right Thing’; and
• a range of externally-facing codes, frameworks,
operating principles, policies, and position
statements, addressing issues such as human rights,
climate change and the environment.
The Principles are available on our website.
Key policies
We have a number of key policies to manage
our regulatory compliance and human resource
requirements. We also subscribe to a range of external
industry codes, such as the Banking Code of Practice
and the ePayments Code.
Code of Ethics for Senior Finance Officers
The Code of Accounting Practice and Financial
Reporting complements our own Code. The Code
of Accounting Practice and Financial Reporting is
designed to assist our CEO, CFO and other principal
financial officers in applying the highest ethical
standards to the performance of their duties and
responsibilities with respect to accounting practice and
financial reporting by requiring those officers to:
• act honestly and ethically, particularly with respect
to conflicts of interest;
• provide full, fair, accurate and timely disclosure in
reporting and other communications;
• comply with applicable laws, rules and regulations;
• promptly report violations of the Code of
Accounting Practice and Financial Reporting; and
• be accountable for adherence to the Code of
Accounting Practice and Financial Reporting.
The Code of Accounting Practice and Financial
Reporting is available on our website at
www.westpac.com.au/corpgov.
Conflicts of interest
The Group has a detailed conflicts of interest
framework, which includes a Group policy supported
by specific divisional policies and guidelines aimed at
identifying and managing actual, potential or apparent
conflicts of interest.
The conflicts of interest framework includes a separate
Westpac Group Gifts and Hospitality Policy. This Policy
provides employees with guidance to manage their
obligations relating to the giving and receiving of gifts
or hospitality.
The Board
All Directors are required to disclose any actual,
potential or apparent conflicts of interest upon
appointment and are required to keep these disclosures
to the Board up to date.
Any Director with a material personal interest in a
matter being considered by the Board must declare
their interest and, unless the Board resolves otherwise,
may not be present during the boardroom discussions
or vote on the relevant matter.

102019 Westpac Group Corporate Governance Statement
Corporate governance
Our employees and contractors
We expect our employees and contractors to:
• have in place adequate arrangements for the
management of actual, potential or apparent
conflicts of interest;
• obtain consent from senior management before
accepting a directorship on the board of a non-
Westpac Group company;
• disclose any material interests they have with our
customers or suppliers to their manager and not
be involved with customer relationships where they
have such an interest;
• not participate in business activities outside their
employment with us (whether as a principal, partner,
director, agent, guarantor, investor or employee)
without approval or when it could adversely
affect their ability to carry out their duties and
responsibilities; and
• not solicit, provide facilitation payments, accept or
offer money, gifts, favours or entertainment that
might influence, or might appear to influence, their
business judgement.
Fit and Proper Person assessments
We have a Board-approved Westpac Group Fit and
Proper Policy that meets the requirements of the
related APRA Prudential Standards and covers the
requirements of Part IIAA of the Banking Act 1959 – The
Banking Executive Accountability Regime, which applies
to ADIs and their subsidiaries. In accordance with
that Policy, we assess the fitness and propriety of our
Directors and also of individuals who perform specified
statutory roles required by APRA Prudential Standards
or ASIC licensing requirements. The Chairman of the
Board (and in the case of the Chairman, the Board)
is responsible for assessing the Directors and Non-
executive Directors of the Westpac and subsidiary
Boards, Group Executives, external auditors and
actuaries. A Fit and Proper Committee is responsible
under delegated authority of the Westpac Board for
undertaking fit and proper assessments of all other
employees who hold statutory roles. In all cases, the
individual is asked to provide a detailed declaration and
background checks are completed.
Concern reporting and whistleblower protection
Under the Westpac Group Speaking Up Policy, we
encourage our employees, contractors, secondees,
former employees, brokers, service providers (such
as auditors, accountants and consultants) and our
suppliers to raise any concerns about our activities
or behaviours that may be unlawful or unethical.
Our attitude is ‘when in doubt report’ and our senior
management are committed to protecting the
dignity, well-being, career and good name of anyone
reporting wrongdoing, as well as providing them with
the necessary support. Westpac does not tolerate
retaliation or adverse action related to a whistleblowing
disclosure.
The Speaking Up Policy sets out how someone can raise
a concern using the whistleblowing channels, including
our concern reporting system ‘Concern Online’ and our
Whistleblower Hotline. Both channels enable reporting
on an anonymous basis. Concerns may include
suspected breaches of our Code, Westpac policies or
regulatory requirements.
When a whistleblower raises a concern they may
choose to involve the Whistleblower Protection Officer,
who is responsible for protecting the whistleblower
against personal disadvantage as a result of making a
report.
We investigate reported concerns in a manner that
is confidential, fair and objective. If the investigation
shows that wrongdoing has occurred, we are
committed to changing our processes and taking
action in relation to those parties who have behaved
incorrectly. Outcomes may also involve reporting the
matter to relevant authorities and regulators.
Relevant Board Committees are charged with
overseeing Westpac’s whistleblower program and the
Westpac Group Executive Risk Committee is provided
with quarterly reporting on whistleblowing. These
reports include a number of metrics, including statistics
about concerns raised.
Westpac’s Speaking Up Policy is available on our
website at https://www.westpac.com.au/about-
westpac/westpac-group/corporate-governance/
principles-policies/.
Securities trading
Under the Westpac Group Securities Trading Policy,
Directors, employees, secondees and contractors are
prohibited from dealing in any securities and other
financial products if they possess inside information.
They are also prohibited from passing on inside
information to others who may use that information
to trade in securities. In addition, Directors and any
employees, secondees or contractors (and their
‘associates’) who, because of their seniority or the
nature of their position, may have access to material
non-public information about Westpac (known
as Prescribed Employees) are subject to further
restrictions, including prohibitions on trading prior to
and immediately following annual and half year results
announcements.
We manage and monitor these obligations through:
• the insider trading provisions of our Policy, which
prohibit any dealing in any securities where
a Director or employee has access to inside
information that may affect the price of those
securities;
• restrictions limiting the periods in which the
Directors and Prescribed Employees can trade in
Westpac securities and other Westpac financial
products (Blackout Periods);
• a prohibition on short-selling Westpac securities by
Directors and Prescribed Employees;
• requiring Directors and Prescribed Employees to
either obtain approval or notify their intention to
trade outside Blackout Periods and confirm that
they have no inside information;
• monitoring the trading of Westpac securities by
Directors and Prescribed Employees;
• maintaining a register of Prescribed Employees,
which is regularly updated;
• notifying ASX of trades of Westpac securities by
Directors of Westpac as required under the ASX
Listing Rules; and
• forbidding employees from entering into hedging
arrangements in relation to their unvested employee
shares or securities, whether directly or indirectly.
The Westpac Group Securities Trading Policy is available
in the Corporate Governance section of our website.

112019 Westpac Group Corporate Governance Statement
Corporate governance
Customer Advocate
Westpac’s Customer Advocate provides an avenue of
escalated review for complaints outcomes in relation
to personal and small business customers, which is
separate to our standard internal dispute resolution
processes. The Customer Advocate has the power to
review and make independent and binding decisions
about these complaints, where customers are not
satisfied with the outcome of the internal dispute
resolution process.
Further details on our Customer Advocate are available
on our website.
Anti-Bribery and Corruption
The Westpac Group has an Anti-Bribery and Corruption
(ABC) Policy, an ABC Standard, and bribery prevention
procedures and systems. They comprise the Westpac
ABC Framework.
Westpac has zero tolerance for any form of bribery and
corruption. This includes a ban on facilitation payments.
Westpac is committed to preventing, detecting
and deterring bribery and corruption by managing
its bribery and corruption risk and complying with
relevant ABC legislation in all jurisdictions in which it
operates, not simply because it is required to, but it is
the right thing to do. This includes compliance with the
Australian Criminal Code Act 1995, the UK Bribery Act
2010 and the US Foreign Corrupt Practices Act 1977.
Under the ABC Policy, Westpac expects that its officers,
employees, agents, contractors, subsidiaries and third
parties acting for or on behalf of Westpac will comply
with all applicable ABC laws and will not offer, provide,
authorise, request or receive a bribe or anything which
may be viewed as a bribe.
Westpac is also required to design and maintain a
system of internal controls, keep accurate books and
records and put in place adequate procedures to
prevent bribery, which are set out in the Westpac ABC
Framework.
Slavery and Human Trafficking
Westpac publishes its Slavery and Human Trafficking
Statement in accordance with the Transparency in
Supply Chains provision (section 54) of the UK’s
Modern Slavery Act 2015 on an annual basis. The
statement outlines the Group’s commitment to
sustainable business practices and advancing human
rights, and the steps we have taken to prevent modern
slavery in our business and supply chains globally
during the financial year.
The statement is available on our website.
Diversity
Westpac has an Inclusion & Diversity Policy that sets
out the inclusion and diversity initiatives for the Group.
This is coupled with a comprehensive Inclusion &
Diversity strategy to help deliver on our key priorities
and actions. In this context, diversity covers both
the visible and invisible differences that make our
employees unique, whether that be gender, gender
identity, age, ethnicity, accessibility requirements,
cultural background, sexual orientation or religious
beliefs, or the differences we have based on our
experiences, insights and perspectives.
The objectives of the policy and the 2018-20 Inclusion &
Diversity strategy are to ensure that the Group:
• has a workforce profile that delivers competitive
advantage through the ability to garner a deep
understanding of customer needs;
• has a truly inclusive workplace where every
individual can shine regardless of gender, cultural
identity, age, work style or approach; and
• leverages the value of diversity for all our
stakeholders to deliver the best customer
experience, improved financial performance and a
stronger corporate reputation.
To achieve these objectives, the Group:
• has set Board-determined, measurable objectives
for achieving gender diversity. The Board assesses
annually both the objectives and progress in
achieving them;
• assesses pay equity on an annual basis;
• encourages and supports the application of
flexibility policies across the business;
• is committed to proactively assisting Aboriginal and
Torres Strait Islander Australians wishing to access
employment across our brands;
• implements our Accessibility Action Plan for
employees and customers with accessibility
requirements, including ensuring employment
opportunities are accessible for people with a
disability; and
• actively promotes an environment of inclusion for
lesbian, gay, bisexual, transgender, intersex and
queer (LGBTIQ+) employees.
The implementation of these objectives is overseen by
the Westpac Group Inclusion & Diversity Council, which
is chaired by the CEO and meets bi-annually.
The Board, or an appropriate Board Committee,
receives regular updates from the Inclusion & Diversity
Council on inclusion and diversity initiatives.
The creation of the Inclusion & Diversity Governance
Framework has resulted in the establishment of:
• Inclusion & Diversity Business Unit Councils, chaired
by the relevant Group Executive of that business
unit; and
• the Inclusion & Diversity Working Group, consisting
of appointed general manager representatives
across each business unit and chaired by the Head
of Inclusion & Diversity.
We continue to listen to the needs of our employees
through our employee action groups and our periodic
employee survey (which includes questions that
constitute an ‘Inclusion Index’).
Our Inclusive Leadership program ensures we are
investing in the right capabilities for an inclusive culture.
The majority of senior leaders and Group Executives
have already completed the program and our focus is
now on completion by our broader people leader group.
In October 2010, the Board set an objective to increase
the proportion of women in leadership roles (over
5,000 leaders from our Executive Team through to
our bank managers) from 33% to 40% by 2014, which
was achieved in September 2012, two years ahead
of schedule. Since November 2017, Westpac has
maintained 50% women in leadership roles. We continue
focussing our efforts on maintaining this equality.

122019 Westpac Group Corporate Governance Statement
Corporate governance
At 30 September 2019, the proportion of women
employed by the Group was as follows:
• Board of Directors: 36%;
• leadership
1
roles: 50%; and
• total Westpac workforce: 58%.
In addition to the Group’s commitment to achieving
its targets, in 2015 our CEO signed up as a Pay Equity
Ambassador through the Workplace Gender Equality
Agency.
Westpac offers a range of flexible working options for
our people based on their needs, work preferences and
the needs of the business. These include:
• flexible work hours;
• mobile working;
• working part-time; and
• job sharing.
In addition, Westpac offers a variety of leave options
that support flexibility, including parental leave,
wellbeing and lifestyle leave and domestic violence
support leave. In 2018 Westpac introduced new policies
on Gender Transition leave, ‘Sorry Business’ Indigenous
bereavement leave and extended Domestic and Family
Violence leave.
Further information on our inclusion and diversity
programs and performance can be found on our
website at https://www.westpac.com.au/about-
westpac/inclusion-and-diversity/.
Sustainability
We view sustainable and responsible business practices
as important for our business and shareholder value.
Sustainability is about managing risks and opportunities
in a way that best balances the long term needs of all
our stakeholders – our customers, employees, suppliers,
investors and community partners – as well as the wider
community and the environment at large.
Our management of sustainability aims to address
the matters that we believe are the most material for
our business and stakeholders, now and in the future.
We also understand that this is an evolving agenda
and seek to progressively embed the management of
sustainability matters into business practice, while also
anticipating and shaping emerging social issues where
we have the skills and experience to make a meaningful
difference and drive business value.
Reporting
We report on the most material sustainability matters
to Westpac, details of how we manage the associated
risks and opportunities and our performance against
our sustainability strategy in the Annual Review
and Sustainability Report, the Annual Report, the
Sustainability Performance Report and the full year and
half year ASX results, all of which are available on our
website.
Our sustainability reporting is subject to independent
limited assurance, performed in accordance with the
Australian Standard on Assurance Engagements 3000
Assurance Engagements Other Than Audits or Reviews
of Historical Financial Information (Revised) (‘ASAE
3000’). The assurance provider also assesses whether
our sustainability reporting is prepared in accordance
with AA1000 AccountAbility Principles Standard
(2008) and the GRI Standards.
Financial reporting
Approach to financial reporting
Our approach to financial reporting reflects three core
principles:
• that our financial reports present a true and fair
view;
• that our accounting methods comply with applicable
accounting standards and policies; and
• that our external auditor is independent and serves
security holders’ interests.
The Board, through the Board Audit Committee,
monitors Australian and international developments
relevant to these principles, and reviews our practices
accordingly.
The Board delegates oversight responsibility for the
integrity of financial statements and financial reporting
systems to the Board Audit Committee. The Board Risk
& Compliance Committee provide periodic assurances
and reports (as appropriate) to the Board Audit
Committee. Similarly, the Board delegates oversight
responsibility for the preparation of remuneration
reports and disclosures to the Board Remuneration
Committee, who recommend and provide relevant
assurances through the Board Audit Committee to the
Board for approval.
Board Audit Committee
As set out in its charter, key responsibilities of the Board
Audit Committee are:
• overseeing the integrity of the financial statements
and financial reporting systems of Westpac and its
related bodies corporate;
• overseeing the external audit engagement, including
the external auditor’s qualifications, performance,
independence and fees;
• overseeing the performance of the internal audit
function;
• overseeing the integrity of the Group’s corporate
reporting, including the Group’s financial reporting
and compliance with prudential regulatory reporting
and professional accounting requirements; and
• reviewing and approving policies and procedures for
the receipt, retention and treatment of information
submitted confidentially by employees and
third parties about accounting, internal control,
compliance, audit or other matters about which an
employee has concerns, and monitoring employee
awareness of these policies and procedures.
1. Women in Leadership refers to the proportion of women (permanent and maximum term) in leadership roles across the Group. It
includes the CEO, Group Executives, General Managers, senior leaders with significant influence on business outcomes (direct reports to
General Managers and their direct reports), large (3+) team people leaders three levels below General Manager, and Bank and Assistant
Bank Managers.

132019 Westpac Group Corporate Governance Statement
Corporate governance
The Board Audit Committee reviews, discusses with
management and the external auditor, and assesses:
• any significant financial reporting issues and
judgements made in connection with the
preparation of the financial reports;
• the processes used to monitor and comply with laws
and regulations over financial information, reporting
and disclosure; and
• the process surrounding the disclosures made by
the CEO and CFO in connection with their personal
certifications of the Group’s half year and full year
financial statements.
In addition, the Board Audit Committee maintains
an ongoing dialogue with management, the external
auditor and Group Audit, including regarding those
matters that are likely to be designated as Key Audit
Matters in the external auditor’s report. Key Audit
Matters are those matters which, in the opinion of the
external auditor, are of the most significance in their
audit of the financial report.
As part of its oversight responsibilities, the Board Audit
Committee also conducts discussions with a wide range
of internal and external stakeholders including:
• the external auditor, about our major financial
reporting risk exposures and the steps management
has taken to monitor and control such exposures;
• Group Audit and the external auditor concerning
their audits and any significant findings, and the
adequacy of management’s responses;
• management and the external auditor concerning
the half year and full year financial statements;
• management and the external auditor regarding
any correspondence with regulators or government
agencies, and any published reports which raise
material issues or could impact on matters regarding
the Westpac Group’s financial statements or
accounting policies; and
• the Group Executive, Legal & Secretariat regarding
any legal matters that may have a material impact
on, or require disclosure in, the financial statements.
Periodically, the Board Audit Committee consults
with the external auditor without the presence of
management about internal controls over financial
information, reporting and disclosure and the fullness
and accuracy of the Group’s financial statements. The
Board Audit Committee also meets with the General
Manager Group Audit without other members of
management being present.
The Board Audit Committee also refers to the Board
or any other Board Committees any matters that come
to the attention of the Board Audit Committee that
are relevant for the Board or the respective Board
Committees.
Financial knowledge
The Board Audit Committee comprises five
independent, Non-executive Directors and is chaired by
Peter Marriott.
All Board Audit Committee members have appropriate
financial experience, an understanding of the financial
services industry and satisfy the independence
requirements under the ASXCGC Recommendations,
the United States Securities Exchange Act of 1934 (as
amended) and its related rules, and the NYSE Listing
Rules.
The Board has determined that Mr Marriott is an
‘audit committee financial expert’ and independent in
accordance with US securities law.
The designation of Mr Marriott as an audit committee
financial expert does not impose duties, obligations or
liability on him that are greater than those imposed on
him as a Board Audit Committee member, and does
not affect the duties, obligations or liability of any other
Board Audit Committee member or Board member.
Audit committee financial experts are not deemed as an
‘expert’ for any other purpose.
CEO and CFO assurance
The Board receives regular reports from management
about our financial condition and operational results, as
well as that of our controlled entities. Before the Board
approves the financial statements for a financial period,
the CEO and the CFO provide formal statements to
the Board, and have done so for the financial year
ended 30 September 2019, that state that in all material
respects:
• Westpac’s financial records have been properly
maintained in that they:
–correctly record and explain its transactions, and
financial position and performance;
–enable true and fair financial statements to be
prepared and audited; and
–are retained for seven years after the transactions
covered by the records are completed;
• the financial statements and notes comply with the
appropriate accounting standards;
• the financial statements and notes give a true and
fair view of Westpac’s and its consolidated entities’
financial position and of their performance;
• any other matters that are prescribed by the
Corporations Act and regulations as they relate to
the financial statements and notes are satisfied; and
• the declarations provided in accordance with section
295A of the Corporations Act are founded on a
sound system of risk management and internal
control, and that the system is operating effectively
in all material respects in relation to financial
reporting risks.
External auditor
The role of the external auditor is to provide an
independent opinion that our financial reports are true
and fair, and comply with applicable regulations.
Our external auditor is PricewaterhouseCoopers
(PwC), appointed by shareholders at the 2002 Annual
General Meeting (AGM). Prior to 2002, individuals who
were partners of PwC or its antecedent Firms were
our external auditors from 1968. Our PwC lead audit
partner is Lona Mathis and the quality review partner is
Wayne Andrews. Ms Mathis and Mr Andrews assumed
responsibility for these roles in June 2017 and January
2015, respectively.
The external auditor receives all Board Audit
Committee, Board Risk & Compliance Committee
and Board Technology Committee papers, attends
all meetings of these committees and is available
to Committee members at any time. The external
auditor also attends the AGM to answer questions
from shareholders regarding the conduct of its audit,
the audit report and financial statements and its
independence.

142019 Westpac Group Corporate Governance Statement
Corporate governance
Our Disclosure Committee is responsible for
determining what information should be disclosed
publicly under the policy, and for assisting employees in
understanding what information may require disclosure
to the market on the basis that it is price sensitive. The
Disclosure Committee is comprised of the CEO and the
Executive Team.
The Group Executive, Legal & Secretariat is the
Disclosure Officer. The Disclosure Officer is ultimately
responsible for all communication with relevant stock
exchanges and notifying regulators in any jurisdiction as
a result of market disclosure.
Once relevant information is disclosed to the market
and available to investors, it is also published on our
website. This includes investor discussion packs,
presentations on and explanations about our financial
results. Our website information also includes Annual
Review and Sustainability Reports, Annual Reports,
results announcements, CEO and executive briefings
(including webcasts, recordings or transcripts of all
major events), notices of meetings and key media
releases.
Shareholder communication and participation
We seek to keep shareholders fully informed about
our strategy, business operations, performance and
governance. As part of our investor relations program,
we continually review our communications approach,
seeking to maintain best practice and effective two-way
communication with shareholders. This includes:
• Designing and maintaining the Investor Centre on
the Group’s website to make all relevant company
information available and to structure that
information in a way that makes it easy to find and
access;
• Responding to shareholder queries directly via
phone, email and mail;
• Preparing company presentations that seek
to respond to the questions frequently asked
by shareholders along with major industry and
company topics of interest; and
• Ensuring appropriate access to all major market
briefings and shareholder meetings, including via
webcasts and maintaining that information on our
website.
Shareholders can access our financial calendar which
lists all major market briefings and shareholder
meetings. Announcements on these events may also be
made through ASX announcements.
Shareholders are given the option to receive information
in print or electronic format from both Westpac and its
share registry.
Our Annual General Meeting (AGM) is an important
opportunity for engaging and communicating with
shareholders, and we typically rotate the location
of our AGM throughout capital cities to ensure we
reach a broad range of shareholders over time. While
shareholders are encouraged to attend and actively
participate, the AGM is webcast and can also be viewed
at a later time from our website. Shareholders who are
unable to attend the AGM are able to lodge a direct
vote or appoint their proxies through a number of
channels, including online. At the time of receiving the
Notice of Meeting, shareholders are also invited to put
forward questions they would like addressed at the
AGM.
As our external auditor, PwC is required to confirm
its independence and compliance with specified
independence standards on a semi-annual basis (at
half and full year), however in practice it confirms its
independence on a quarterly basis.
We strictly govern our relationship with the external
auditor, including restrictions on employment, business
relationships, financial interests and use of our financial
products by the external auditor.
Engagement of the external auditor
To avoid possible independence or conflict issues, the
external auditor is not permitted to carry out certain
types of non-audit services for Westpac and may be
limited as to the extent to which it can perform other
non-audit services as specified in our ‘Pre-approval of
engagement of PwC for audit and non-audit services’
(Guidelines). Use of the external audit firm for any
non-audit services must be assessed and approved in
accordance with the pre-approval process determined
by the Board Audit Committee and set out in the
Guidelines.
The breakdown of the aggregate fees billed by the
external auditor in respect of each of the two most
recent financial years for audit, audit-related, tax and
other services is provided in Note 35 to our financial
statements for the year ended 30 September 2019. A
declaration regarding the Board’s satisfaction that the
provision of non-audit services by PwC is compatible
with the general standards of auditor independence
is provided in Section 11 of the Directors’ report, in our
2019 Annual Report.
Group Audit (internal audit)
Group Audit is Westpac’s internal third line assurance
function that provides the Board and Senior Executives
with independent and objective evaluation of the
adequacy and effectiveness of the Group’s governance,
risk management and internal controls for the Westpac
consolidated group.
Group Audit is governed by a charter approved by the
Board Audit Committee that sets out the purpose, role,
scope and high level standards for the function. The
General Manager Group Audit has a direct reporting line
to the Chairman of the Board Audit Committee and an
administrative line to the Chief Financial Officer. Group
Audit also has unrestricted and private access to the
Chief Executive Officer.
Group Audit’s responsibilities include regularly reporting
to the Board.
Market disclosure
We maintain a level of disclosure that seeks to provide
all investors with equal, timely, balanced and meaningful
information. Consistent with these standards, the
Group maintains a Board-approved Market Disclosure
Policy, which governs how we communicate with our
shareholders and the investment community.
The policy reflects the requirements of the ASX, NZX
and other offshore stock exchanges where we have
disclosure obligations, as well as relevant securities and
corporations legislation. Under our policy, information
that a reasonable person would expect to have a
material effect on the price or value of our securities
must first be disclosed via the ASX unless an exception
applies under regulatory requirements.

152019 Westpac Group Corporate Governance Statement
Corporate governance
Risk management
Roles and responsibilities
The Board is responsible for approving the Group’s
overall risk management framework, the Westpac
annual Group Risk Management Strategy and the
Westpac Group Risk Appetite Statement and for
monitoring the effectiveness of risk management by
the Westpac Group. The Board has delegated to the
Board Risk & Compliance Committee responsibility to:
establish a view of the Group’s current and future risk
position relative to its risk appetite and capital strength;
review and approve frameworks, policies and processes
for managing risk; and review and, where appropriate,
approve risks beyond the approval discretion provided
to management.
The Westpac Group Risk Management Framework,
Risk Management Strategy, Risk Taxonomy and Risk
Appetite Statement were reviewed by the Board Risk
& Compliance Committee and were approved by the
Board during the financial year ended 30 September
2019.
The Board Risk & Compliance Committee reviews and
monitors the risk profile and controls of the Group for
consistency with the Group Risk Appetite Statement
and reviews and monitors capital levels for consistency
with the Group’s risk appetite. The Board Risk &
Compliance Committee receives regular reports from
management on the effectiveness of our management
of Westpac’s material risks. More detail about the role
of the Board Risk & Compliance Committee is set out
later in this section under ‘Board Risk & Compliance
Committee’.
The CEO and Executive Team are responsible for
implementing our risk management framework and risk
management strategy, and for developing frameworks,
policies, controls, processes and procedures for
identifying and managing risk in all of Westpac’s
activities.
We have adopted a Three Lines of Defence model to aid
in holistic end-to-end management of risk, within which
all employees play an active role. This necessitates
co-operation between businesses and functions, such
that there are no gaps in risk coverage. Effective risk
management enables us to:
• accurately measure our risk profile and to balance
risk and reward within our risk appetite, optimising
financial growth opportunities and mitigating
potential loss or damage;
• protect Westpac Group’s depositors, policyholders,
investors and counterparts by maintaining a balance
sheet with sound credit quality and buffers over
regulatory minimums;
• deliver suitable, fair and clear or transparent
outcomes for our customers that support market
integrity;
• embed adequate controls to guard against excessive
risk or undue risk concentration; and
• meet our regulatory and compliance obligations.
The 1st Line of Defence – Business and Support:
manages the risk they originate
The 1st Line proactively identifies, evaluates, owns and
manages the risks in their business/domain. It also
ensures that business activities are within approved
risk appetite and policies. The 1st Line of defence is
accountable for ‘self-certification’.
In managing its risk, the 1st Line is required to establish
and maintain appropriate governance structures,
controls, resources and self-assessment processes,
including issue identification recording and escalation
procedures.
The 2nd Line of Defence – Risk: provides oversight,
insight and control of First Line activities
The 2nd Line sets frameworks, policies, limits and
standards for use across the Group.
Risk reviews and challenges 1st Line activities and
decisions that may materiality affect Westpac’s risk
position, and independently evaluates the effectiveness
of the 1st Line’s controls, monitoring, compliance, and
monitors progress towards mitigating risks. In addition,
the 2nd Line provides insight to the 1st Line, assisting
in developing, maintaining and enhancing the business’
approach to risk management.
The 2nd Line analyses and reports on the aggregated
risk profile of the Group to ensure end-to-end oversight
of risk, and can accept risks outside of the business’ risk
appetite.
The 3rd Line of Defence – Provides Independent audit
Group Audit is an independent assurance function
that evaluates and opines on the adequacy and
effectiveness of both 1st and 2nd Line risk management
approaches and tracks remediation progress, with the
aim of providing the Board, and Senior Executives, with
comfort that the Group’s governance, risk management
and internal controls are operating effectively.
Our overall risk management governance structure is
set out in more detail in the table ‘Risk Management
Governance Structure’ included in this Corporate
Governance Statement.
Westpac distinguishes between different types of risk:
• governance risk – the risk that the right information
does not get to the right people or governance
fora in the right format and timeframe to empower
decision making. It is driven by organisational
structures and relationships including between the
Board, management, its shareholders and other
stakeholders, which leads to deficient decision
making, poor accountability and ineffective
structures and processes;
• risk culture – is the risk that our culture doesn’t
promote and reinforce behavioural expectations or
structures to identify, understand, discuss and act on
risks. This leads to ineffective risk management, poor
risk awareness, risk-taking outside of risk appetite
that is tolerated and a culture where key learnings
are not integrated into Group-wide and customer
outcomes, impeding continuous improvement;
• strategic risk – the risks arising from key elements of
the strategic objectives and business plans;
• capital adequacy risk – the risk that the firm has
an insufficient level or composition of capital to
support its normal business activities and to meet
its regulatory capital requirements under normal
operating environments or stressed conditions
(both actual and as defined for internal planning or
regulatory testing purposes). This includes the risk
from the Group’s pension plans;
• credit risk – the risk of financial loss where a
customer or counterparty fails to meet their financial
obligations to Westpac;

162019 Westpac Group Corporate Governance Statement
Corporate governance
As set out in its charter, the Board Risk & Compliance
Committee:
• assists the Board to consider and approve the
Group’s overall risk framework for managing risk;
• reviews and recommends the Risk Management
Strategy and Westpac Group Risk Appetite
Statement to the Board for approval;
• reviews and monitors the risk profile and controls of
the Group consistent with the Westpac Group Risk
Appetite Statement;
• reviews and approves the frameworks, policies and
processes for managing risk;
• reviews and approves the limits and conditions that
apply to credit risk approval authority delegated to
the CEO, CFO and CRO and any other officers of the
Westpac Group to whom the Board has delegated
credit approval authority;
• monitors changes anticipated for the economic and
business environment including consideration of
emerging risks and other factors considered relevant
to our risk profile and risk appetite;
• assists the Board to make its annual declaration to
APRA on risk management under APRA prudential
standard CPS 220 Risk Management;
• reviews and where appropriate approves risks
beyond the approval discretion provided to
management; and
• assists the Board to oversee compliance
management within the Group.
From the perspective of specific types of risk, the Board
Risk & Compliance Committee’s role as set out in the
current Committee charter has included:
• credit risk – approving key policies and limits
supporting the Credit Risk Management Framework,
and monitoring the risk profile, performance and
management of our credit portfolio;
• liquidity risk – approving key policies and limits
supporting the Liquidity Risk Management
Framework, including our annual funding strategy,
recovery and resolutions plans and monitoring the
liquidity position and requirements;
• market risk – approving key policies and limits
supporting the Market Risk Management
Framework, and monitoring the market risk profile;
• conduct risk – reviewing and approving the
Westpac Group Conduct Framework and reviewing
and monitoring the performance of conduct risk
management and controls;
• operational risk – approving key policies supporting
the Operational Risk Management Framework and
monitoring the performance of operational risk
management and controls;
• compliance risk – reviewing and approving
the Westpac Group Compliance Management
Framework and Financial Crime Risk Management
Framework, supporting policies and standards and
monitoring the performance of compliance and
financial crime risk management and controls;
• reputation risk – reviewing and approving the
Reputation Risk Management Framework and
reviewing and monitoring the performance of
reputation risk management and controls; and
• sustainability risk – reviewing and approving the
Sustainability Risk Management Framework.
• funding and liquidity risk – the risk that the Group
cannot meet its payment obligations or that it
does not have the appropriate amount, tenor or
composition of funding and liquidity to support its
assets;
• market risk – the risk of an adverse impact on
earnings resulting from changes in market factors,
such as foreign exchange rates, interest rates,
commodity prices or equity prices. This includes
interest rate risk in the banking book - the risk to
interest income from a mismatch between the
duration of assets and liabilities that arises in the
normal course of business activities;
• conduct and compliance risk – the risk of failing to
abide by compliance obligations required of us or
otherwise failing to have behaviours and practices
that deliver suitable, fair and clear outcomes for our
customers and that support market integrity;
• operational risk – the risk of loss resulting from
inadequate or failed internal processes, people and
systems or from external events. This definition
includes legal and regulatory risk but excludes
strategic risk;
• cyber risk – The potential for loss or harm to the
business and stakeholders related to the use of
technology;
• reputational risk – the risk that an action, inaction,
transaction, investment or event will reduce trust
in the Group’s integrity and competence by clients,
counterparties, investors, regulators, employees or
the public; and
• sustainability risk – the risk of reputation or
financial loss due to failure to recognise or address
material existing or emerging sustainability related
environmental, social or governance issues. This
includes climate change related risks.
Westpac has received advanced accreditation from
APRA and the RBNZ under the Basel II capital
framework, and uses the Advanced Internal Ratings
Based (Advanced IRB) approach for credit risk and
the Advanced Measurement Approach (AMA) for
operational risk when calculating regulatory capital.
Material exposure to economic, environmental and
social sustainability risks
Westpac’s material exposures to economic,
environmental and social sustainability risks are
managed in accordance with our risk management
strategy and frameworks.
Further details about these risks and how Westpac
manages them are referred to in our 2019 Sustainability
Performance Report available on our website.
Board Risk & Compliance Committee
The Board Risk & Compliance Committee comprises all
of Westpac’s independent, Non-executive Directors and
is chaired by Ewen Crouch.

172019 Westpac Group Corporate Governance Statement
Corporate governance
The Board Risk & Compliance Committee also:
• oversees and approves the Internal Capital
Adequacy Assessment Process and in doing so
reviews the outcomes of Westpac Group stress
testing, sets the target capital ranges for regulatory
capital and reviews and monitors capital levels for
consistency with the Westpac Group’s risk appetite;
• provides relevant periodic assurances and reports
(as appropriate) to the Board Audit Committee;
• reviews and approves other risk management
frameworks and/or the monitoring of performance
under those frameworks (as appropriate);
• forms a view of Westpac’s risk culture and oversees
the identification of, and steps taken to address, any
desirable changes to risk culture and periodically
reports to the Board;
• refers to the Board or any other Board Committees
any relevant matters that come to the attention of
the Board Risk & Compliance Committee; and
• in its capacity as the Westpac Group’s US Risk
Committee, oversees the key risks, risk management
framework and policies of the Group’s US
operations.
Compliance Management Framework
The Compliance Management Framework sets out our
approach to managing compliance with our obligations
and mitigating compliance risk. It is an integral part of
the broader risk management strategy and is regularly
assessed and enhanced as appropriate to ensure it
responds to the internal and external environment and
supports our strategic compliance direction.
To proactively manage our compliance risks, our
compliance objective is to:
• comply with our legal obligations, regulatory
requirements, voluntary codes of practice to which
we subscribe, and Group policies, including the
Westpac Code of Conduct;
• establish frameworks, policies and processes
designed to manage, monitor and report compliance
and to minimise the potential for breaches, fines or
penalties, or loss of regulatory accreditations; and
• ensure that appropriate remedial action is taken to
address instances of non-compliance.
Remuneration
The Board Remuneration Committee assists the Board
by ensuring that Westpac has coherent remuneration
policies and practices that fairly and responsibly reward
individuals having regard to performance and that
reflect Westpac’s risk management framework, the law
and the highest standards of governance.
The Board Remuneration Committee has been in place
for the whole of the financial year and is comprised
of four independent Non-executive Directors and is
chaired by Craig Dunn. All members of the Board
Remuneration Committee are also members of the
Board Risk & Compliance Committee, which assists in
the integration of effective risk management into the
remuneration framework.
As set out in its charter, the Board Remuneration
Committee:
• reviews and makes recommendations to the Board
in relation to the Westpac Group Remuneration
Policy (Group Remuneration Policy) and assesses
the Group Remuneration Policy’s effectiveness and
its compliance with laws, regulations and prudential
standards;
• reviews and makes recommendations to the
Board in relation to the individual remuneration
levels of the CEO, Non-executive Directors, Group
Executives, other Executives who report directly to
the CEO, any other Accountable Persons under the
Banking Executive Accountability Regime, other
persons whose activities in the Board Remuneration
Committee’s opinion affect the financial soundness
of Westpac, any person specified by APRA, and any
other person the Board determines;
• reviews and makes recommendations to the Board
in relation to the remuneration structures for
each category of persons covered by the Group
Remuneration Policy;
• reviews and makes recommendations to the Board
on corporate goals and objectives relevant to the
remuneration of the CEO, and the performance of
the CEO in light of these objectives;
• reviews and makes recommendations to the Board
on the short and long-term variable reward plans for
Group Executives and any other Accountable Person
under the Banking Executive Accountability Regime;
• reviews and makes recommendations to the Board
in relation to approving equity based remuneration
plans; and
• oversees general remuneration practices across the
Group.

182019 Westpac Group Corporate Governance Statement
Corporate governance
The Board Remuneration Committee reviews and
recommends to the Board the size of variable
reward pools each year based on consideration of
pre-determined business performance indicators
and the financial soundness of Westpac. The Board
Remuneration Committee also approves remuneration
arrangements outside of the Group Remuneration
Policy relating to individuals or groups of individuals
which are significant because of their sensitivity,
precedent or disclosure implications. In addition,
the Board Remuneration Committee considers and
evaluates the performance of senior executives when
making remuneration determinations and otherwise as
required.
The Board Remuneration Committee also reviews and
makes recommendations to the Board for the reduction
of variable reward (including to zero) where:
• subsequent information or circumstances indicate
that all or part of the grant was not justified; or
• the Board Remuneration Committee determines
that an adjustment should be made as a result
of risk or compliance failures, poor customer
outcomes, where an Accountable Person under the
Banking Executive Accountability Regime has failed
to comply with their accountability obligations or
any other matter it considers relevant.
Independent remuneration consultants are engaged
by the Board Remuneration Committee to provide
information across a range of issues, including
remuneration benchmarking, market practices and
emerging trends and regulatory reforms.
The Board Remuneration Committee seeks feedback
from and considers matters raised by the Board Risk &
Compliance Committee and Board Audit Committee,
including with respect to remuneration outcomes,
adjustments to remuneration and alignment of
remuneration with the risk management framework.
The Board Remuneration Committee refers to the
Board and any other Board Committee any matters
that come to its attention that are relevant for the
Board or the respective Board Committee
Further details of our remuneration framework are
included in the Remuneration Report in Section 10
of the Directors’ report (which is located in our 2019
Annual Report). The Board Remuneration Committee
reviews and recommends the Remuneration Report
through the Board Audit Committee to the Board for
approval.

192019 Westpac Group Corporate Governance Statement
Corporate governance
Risk Management Governance Structure
Westpac’s risk management governance structure is set out in the table below:
Board
• approves our overall risk management framework, the Westpac Group Risk Management Strategy and the Westpac
Group Risk Appetite Statement; and
• makes an annual declaration to APRA on risk management.
Board Risk & Compliance Committee (BRCC)
• assists the Board to consider and approve the Group’s overall risk framework for managing risk;
• reviews and recommends the Westpac Group Risk Management Strategy and Westpac Group Risk Appetite
Statement to the Board for approval;
• reviews and monitors the risk profile and controls of the Group consistent with the Westpac Group Risk Appetite
Statement;
• reviews and approves material frameworks, policies and processes for managing risk;
• reviews and approves the limits and conditions that apply to credit risk approval authority delegated to the CEO,
CFO, CRO and any other officers of the Westpac Group to whom the Board has delegated credit approval authority;
• monitors changes anticipated for the economic and business environment including consideration of emerging risks
and other factors considered relevant to our risk profile and risk appetite;
• assists the Board to make its annual declaration to APRA on risk management under APRA prudential standard
CPS220 Risk Management;
• reviews and where appropriate approves risks beyond the approval discretion provided to management; and
• assists the Board to oversee compliance management within the Group.
Other Board Committees with a risk focus
Board Audit Committee
• oversees the integrity of financial statements and financial reporting systems, and matters relating to taxation risks.
Board Remuneration Committee
• oversees remuneration policies and practices of the Westpac Group in the context that these policies and practices
reflect Westpac’s risk management framework, including making recommendations to the Board for the reduction or
lapsing of incentive-based equity grants to employees as a result of risk or compliance failures.
Board Technology Committee
• oversees the implementation of the Westpac Group’s technology strategy, including risks associated with major
technology programs.
Executive Team
• executes the Board-approved strategy;
• delivers the Westpac Group’s various strategic and performance goals within the approved risk appetite;
• approves the position statements that guide the Westpac Group’s response to sustainability issues; and
• monitors key risks within each business unit, capital adequacy and the Westpac Group’s reputation.

202019 Westpac Group Corporate Governance Statement
Corporate governance
Executive risk committees
Westpac Group Executive Risk Committee
• leads the management and oversight of material risks across the Westpac Group within the context of the risk
appetite approved by the Board;
• oversees the effectiveness of the Risk Management Framework and the execution of the Risk Management Strategy;
• monitors and reviews the Group’s risk profile for all identified material risks;
• shapes and promotes a strong risk culture; and
• oversees emerging risks and allocates responsibility for assessing impacts and implementing appropriate actions to
address these.
Westpac Group Asset & Liability Committee
• leads the optimisation of funding and liquidity risk-reward across the Group;
• reviews the level and quality of capital to ensure that it is commensurate with the Group’s risk profile, business
strategy and risk appetite;
• oversees the Liquidity Risk Management Framework and key policies;
• oversees the funding and liquidity risk profile and balance sheet risk profile; and
• identifies emerging funding and liquidity risks and appropriate actions to address these.
Westpac Group Credit Risk Committee
• reviews and oversees the Credit Risk Management Framework and key supporting policies;
• oversees Westpac’s credit risk profile; and
• identifies emerging credit risks, allocates responsibility for assessing impacts, and responds as appropriate.
Westpac Group Market Risk Committee
• reviews and oversees the Market Risk, Equity Risk and Insurance Risk Management Frameworks and key market risk
management policies;
• reviews policies and limits for managing traded and non-traded market risk; and
• reviews and overseas the market risk, equity risk and insurance risk profile.
Westpac Group Operational Risk Committee
• reviews and oversees the Operational Risk Management Frameworks and key supporting policies;
• oversees Westpac’s operational risk profile; and
• identifies emerging operational risks, and appropriate actions to address these.
Westpac Group Remuneration Oversight Committee
Some of the key responsibilities of the Westpac Group Remuneration Oversight Committee include:
• supporting the CEO, Board Remuneration Committee and the Board by reviewing and approving remuneration
frameworks, guidelines and short term variable reward plans underpinning the Board-approved Westpac Group
Remuneration Policy from a Human Resources, Risk (including Compliance), Finance and Legal perspective and in
line with external requirements;
• assisting the Board Remuneration Committee and the Board in fulfilling its responsibility to oversee remuneration
policies and practices of the Group in the context that these policies and practices fairly and responsibly reward
individuals having regard to customer and shareholder interests, long term financial soundness and prudent risk
management;
• recommending to the CEO for recommendation to the Board Remuneration Committee remuneration arrangements
for Responsible Persons, risk and financial control employees, Material Risk Takers and other individuals whose
activities may impact the financial soundness of Westpac below the Group Executive level; and
• recommending to the CEO for recommendation to the Board Remuneration Committee the criteria and rationale for
determining the total quantum of the Group variable reward pool.
Prudential Reporting and Compliance Committee
• oversees from a Group-wide perspective, the Group’s compliance with prudential requirements and regulatory
reporting;
• oversees the effective management of prudential compliance breaches, incidents and issues including remediation
actions; and
• monitors and reviews ongoing prudential governance activities, including changes to prudential standards
Reputational Risk Committee
• reviews issues with material reputation risk that arise in the operations of Westpac’ business to mitigate reputation
risk and detrimental customer impacts.
Westpac Group Financial Crime Risk Committee
• oversees Anti-Money Laundering and Counter-Terrorism Financing, Anti-Bribery and Corruption, Sanctions and Tax
Transparency within the context of the risk appetite approved by the Board;
• reviews and oversees the Financial Crime Management Framework, key supporting policies, programs and standards;
• monitors and oversees Westpac’s financial crime risk profile; and
• identifies emerging financial crime risks, and appropriate actions to address these.

212019 Westpac Group Corporate Governance Statement
Corporate governance
Risk function
Risk Function
• promotes a strong risk culture;
• owns the design and content of the Risk Management Framework;
• defines the structure and coverage of risk appetite;
• defines the annual risk strategy to execute the Risk Management Framework ensuring the management of risks in
alignment with risk appetite and business strategy;
• establishes risk policies, procedures and limits;
• measures and reports on risk levels; and
• provides oversight of and direction on the management of risks.
Independent internal review
Group Audit
• reviews the adequacy and effectiveness of management controls over risk.
Divisional business units and functions
Business Units and Functions
• responsible for identifying, evaluating and managing the risks that they originate within approved risk appetite and
policies; and
• establish and maintain appropriate risk management and compliance controls, resources and self-assessment
processes.