Trading in ANZ Securities Policy

Australia and New Zealand Banking Group Limited ABN 11 005 357 522
ANZ Centre Melbourne, Level 9A, 833 Collins Street, Docklands VIC 3008

28 October 2022

Market Announcements Office
ASX Limited
Level 4
20 Bridge Street
SYDNEY NSW 2000





Trading in ANZ Securities Policy

ANZ has made some amendments to its Trading in ANZ Securities Policy (principally the
re-introduction of a Pre-Trade Approval exemption in section 10(l) of the Policy) following
its scheduled review and encloses the amended Policy.
It ha s been approved for distribution by ANZ’s Company Secretary.

Yours faithfully




Simon Pordage
Company Secretary
Australia and New Zealand Banking Group Limited

Classification: External



Trading in ANZ Securities Policy
Policy Owner: Deputy Head OR&C, Institutional Risk Version 10
Policy Level: Level 2 Global October 2022

The Trading in ANZ Securities Policy (this policy) provides a globally consistent approach to Trading in
ANZ Securities by the directors of Australia and New Zealand Banking Group Limited (ANZBGL) and the
Employees and Contingent Workers of ANZBGL and its Controlled Entities (together, ANZ). This policy
requires that ANZ requirements are complied with, and all appropriate legal obligations are met, and
individuals act with honesty and integrity. The purpose of this policy is to put in place systems and
processes aimed at preventing insider trading or trading that could be perceived as insider trading,
reinforcing our culture to avoid the significant potential reputational damage to ANZ that any such trading
may cause, and to uphold the ANZ Code of Conduct.
Capitalised terms used throughout this policy have the meanings given in the Glossary.
APPLICATION
This policy applies to all ANZ Directors and all Employees and Contingent Workers of ANZ. To understand
how this policy applies you will need to check whether you are a Restricted Person.
POLICY DETAIL
OBLIGATIONS UNDER THIS POLICY
Background
This section sets out:
• the obligations applicable to all individuals to whom this policy applies;
• the additional obligations applicable to Restricted Persons other than ANZ Directors;
• the additional obligations applicable to all Restricted Persons; and
• the additional obligations applicable to ANZ Directors, ExCo members, direct reports to the ANZ CEO
and the ANZ Company Secretary.
Obligations applicable to all individuals
1. Insider trading is illegal: Individuals will not Trade, or advise, procure or encourage another
person to Trade in ANZ Securities at any time when in possession of Inside Information. For
avoidance of doubt, this applies even if:
a. the Trade would occur outside a Blackout Period;
b. the Trade is covered by an exception under section 10 of this policy where Trading is
permitted without Pre-Trade Approval;
c. a Pre-Trade Approval or Special Circumstances Trading Application has been granted; or
d. this policy otherwise provides a clearance or approval to Trade.
Inside Information must not be disclosed or passed on to any other person by any individual other
than in connection with the proper carrying out of the individual’s role and duties at ANZ.
2. Hedging interests is prohibited: Individuals will not and must ensure that others do not on
their behalf, hedge any interests that have been granted to the individual under any ANZ
employee equity plan that are either unvested or subject to a holding lock.

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Obligations applicable to Restricted Persons other than ANZ Directors
3. Actions required to use StarCompliance: Each Restricted Person other than ANZ Directors
must take the actions as described in the following table:
Circumstances where action
is required:
What the Restricted
Person must do:
By when:
• Restricted Person has an
active Brokerage Account.
• Restricted Person’s Associated
Person has an active
Brokerage Account.
Disclose and register each
Brokerage Account of the
Restricted Person and their
Associated Persons in
StarCompliance.
Before submitting first Pre-
Trade Approval request.
• Restricted Person’s
Brokerage Account is not
integrated with
StarCompliance.
• Restricted Person’s
Associated Person has a
Brokerage Account which is
not integrated with
StarCompliance.
Manually submit Broker
Statements for each
registered Brokerage Account
into StarCompliance.
Brokerage Statements for
integrated Brokerage
Accounts are not required to
be uploaded.
You may be asked by the
Compliance Control Room to
submit monthly where required
in your location, but otherwise
promptly when requested by the
Compliance Control Room.
Obligations applicable to all Restricted Persons
4. Inform Associated Persons of obligations: Restricted Persons should inform their Associated
Persons that the Restricted Person is prohibited from insider trading and, so that ANZ can monitor
compliance with this requirement and this policy:
a. the Restricted Person must maintain and disclose to ANZ, Trading records relating to ANZ
Securities, including those of the Associated Person; and
b. ANZ requires Pre-Trade Approval of Trading in ANZ Securities by both the Restricted Person
and their Associated Persons.
5. Maintain records: Restricted Persons will maintain and will seek to ensure that their Associated
Persons maintain, records of all Trading in ANZ Securities (including where applicable any related
Pre-Trade Approvals or approved Special Circumstances Trading Applications) for 12 months.
6. Inspection of records: On request by Compliance, the Compliance Control Room or Internal
Audit, Restricted Persons will provide for inspection, their ANZ Securities Trading records and the
ANZ Securities Trading records of their Associated Persons to confirm adherence to this policy.
7. No Trading during Blackout Period: Restricted Persons will not and must seek to ensure their
Associated Persons do not, Trade in ANZ Securities during a Blackout Period, unless one of the
exceptions permitting trading during a Blackout Period in section 10 applies, or a Special
Circumstances Trading Application has been approved and is expressed to permit Trading during
the Blackout Period.
8. No speculative trading: Restricted Persons will not and must seek to ensure their Associated
Persons do not, engage in speculative Trading of ANZ Securities. Without limiting the forgoing,
this means:
a. Restricted Persons will not, and must seek to ensure that their Associated Persons do not,
short-sell ANZ Securities; or
b. Restricted Persons will comply and must seek to ensure that their Associated Persons comply,
with the requirement that they hold ANZ Securities purchased or do not buy-back ANZ
Securities sold until a minimum period of 30 calendar days has passed since such purchase or

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sale. This requirement does not apply to a cashless exercise of ANZ deferred share rights or
performance rights, or where a Special Circumstances Trading Application has been granted.
9. No margin lending: Restricted Persons will not use ANZ Securities in connection with a margin
loan or similar financing arrangements that may be subject to a margin call or loan-to-value ratio
breach.
10. Requirement to obtain Pre-Trade Approval: Restricted Persons will obtain Pre-Trade Approval
using the process described in section 14
before they or their Associated Persons Trade in ANZ
Securities, except in the following circumstances:
Rights offers/share buy-backs
a. a disposal of ANZ Securities arising from the acceptance of an equal access share buy-back,
takeover offer or scheme of arrangement;
b. a disposal of rights acquired under a pro rata issue;
c. an acquisition of ANZ Securities pursuant to a pro rata issue;
d. to undertake or elect to take up entitlements in a rights issue or other offer that has been
announced on a securities exchange provided the Restricted Person is not in possession of
Inside Information, or to allow such entitlements to lapse;
e. to comply with a compulsory acquisition under the Corporations Act in Australia or under
equivalent laws in other jurisdictions;
Acquisition of shares without payment
f. the receipt of ANZ Securities under ANZ’s yearly Performance Review Process annual incentive
scheme;
g. the receipt of ANZ Securities given as a gift without a requirement for any payment (e.g. ANZ
Securities left to you in another person’s will);
Dividend Reinvestment Plan (DRP)
h. an election to commence, cease or vary participation in ANZ’s dividend reinvestment plan or
bonus option plan where such election is made outside a Blackout Period, provided that such
election is not made at a time when the Restricted Person is in possession of Inside
Information;
Off Market Transfers/Exercising Options
i. a transfer of ANZ Securities to another holding in the Restricted Person’s or Associated
Person’s sole name or to an account in the Restricted Person’s or Associated Person’s sole
name within a superannuation fund;
j. completed outside a Blackout Period:
(i) a transfer of ANZ Securities to a trading account in the name of a Close Family Member
or a company, trust or other entity wholly owned by the Restricted Person, the
Associated Person and/or their Close Family Member;

(ii) an exercise of ANZ deferred share rights or performance rights by the Restricted
Person (i.e. to “acquire and hold” the ANZ Securities that are the subject of the
deferred share right). For the avoidance of doubt, Pre-Trade Approval is required:

I. before disposing of the ANZ Securities acquired following such exercise; and

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II. via a Special Circumstances Trading Application, to exercise ANZ deferred share
rights or performance rights during a Blackout Period;
k. any mandatory conversion of ANZ Securities (e.g., convertible notes) into ordinary shares,
provided that the conversion is triggered automatically under the terms and conditions
applicable to the ANZ Security without the Restricted Person or their Associated Person’s
active participation or instruction;
Leave taken by Restricted Persons other than ANZ Directors
l. Restricted Persons other than ANZ Directors are exempt from the Pre-Trade Approval
requirement while they continue to meet the following conditions:
(i) the Restricted Person has been on leave for a period of greater than 30 calendar days;
and

(ii) the Restricted Person was not in possession of any Inside Information at the
commencement of their leave period;
Other exemptions
m. with respect to Associated Persons, if they are Trading within the scope of their own
employment with a third party (e.g. an Associated Person who is a stockbroker Trading in their
professional capacity for a non-related party is covered by this exemption; a day trader would
not be covered);
n. any indirect and incidental trading of ANZ Securities that occurs as a consequence of a dealing
in securities issued by a managed investment scheme, listed investment company, exchange
traded fund or similar investment vehicle, that is managed by a third party and that happens
to hold ANZ Securities as part of its portfolio; or
o. any additional exceptions determined by the Policy Owner, where applicable.
Obligation applicable to ANZ Directors
11. ANZ Directors will provide details of all their dealings in ANZ Securities to ANZ’s Corporate
Governance team including any related information required under applicable listing rules to
enable ANZBGL to comply with its disclosure obligations regarding Trading by ANZ Directors.
Obligations applicable to ExCo members, ANZ Company Secretary and certain others notified
12. DRP Pricing: ExCo members, the ANZ Company Secretary and any other individuals determined
to be (and notified as being) subject to this requirement by the ANZ CEO, Chief Risk Officer and
Group General Counsel from time to time will not and must seek to ensure their Associated
Persons do not, trade in ANZ Securities during a DRP Pricing Period.
13. Shareholding Guidelines: ExCo members must ensure that any requests for Pre-Trade Approval
meet the requirements of the Shareholding Guidelines (i.e., Requests for Pre-Trade Approval
should not take the ExCo member’s eligible holdings below the minimum holding requirement).
How to o btain a Pre-Trade Approval and related provisions
14. A request for Pre-Trade Approval will be made by a Restricted Person and the decision to approve
the request will be made as described in the following table:
Restricted Person: How to apply: Decision made by:
ANZ Directors and the
ANZ CEO
In writing to the Chairman of the ANZ Board or,
if the Chairman of the ANZ Board is not
The Chairman of the ANZ
Board or Chairman of the

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available, the Chairman of the ANZ Audit
Committee (or in the case of the Chairman of
the ANZ Board, from the Chairman of the ANZ
Audit Committee).
ANZ Audit Committee, as
applicable
All other Restricted
Persons
Apply using StarCompliance unless the
Compliance Control Room directs that an
alternative platform or process be used.
Compliance Control
Room

15. A request for any Pre-Trade Approval can be approved or declined by ANZ at its sole discretion,
without giving any reasons, and can be withdrawn at any time if new information becomes known
or there is a change in circumstances. ANZ’s decision to decline a Pre-Trade Approval request is
final and binding. Where a request is declined, the outcome is considered confidential information
and must not be disclosed.
16. Any Pre-Trade Approval granted is not an endorsement of the proposed Trade. The person doing
the Trading is individually responsible for their investment decisions and compliance with insider
trading laws. Before Trading, individuals should consider carefully whether they are in possession
of any Inside Information, and if in any doubt, they should not Trade. If an individual comes into
possession of Inside Information after receiving Pre-Trade Approval, the individual must not Trade
despite having received the Pre-Trade Approval.
17. A Pre-Trade Approval is valid only during the Effective Period. If the order is not executed within
the Effective Period, the Restricted Person must submit a new Pre -Trade Approval request to
ensure a valid Pre-Trade Approval has been obtained when the order is executed. This also
applies to limit orders.
SPECIAL CIRCUMSTANCES TRADING APPLICATIONS
Background
This section sets out the special circumstances in which disposal of ANZ Securities by Restricted Persons
(or their Associated Persons) that was previously declined or is otherwise prohibited by this policy may be
permitted with prior written approval.
Policy Statements
18. A Special Circumstances Trading Application may be sought where a need arises to dispose ANZ
Securities:
a. during a Blackout Period;
b. during the 30-day minimum holding period described in section 8b; or
c. where a Pre-Trade Approval request has been declined,
as a result of severe financial hardship, a pressing financial commitment that cannot be satisfied
otherwise than by disposing of ANZ Securities, or in other exceptional circumstances.
19. A Special Circumstances Trading Application should be made by a Restricted Person and the
decision to approve the request will be made as described in the following table:
Restricted Person: How to apply: Decision made by:
ANZ Directors and the
ANZ CEO
In writing to the Chairman of the ANZ Board or,
if the Chairman of the ANZ Board is not
available, the Chairman of the ANZ Audit
Committee (or in the case of the Chairman, of
The Chairman of the ANZ
Board or Chairman of the
ANZ Audit Committee, as
applicable

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the ANZ Board from the Chairman of the ANZ
Audit Committee).
All other Restricted
Persons
Apply using StarCompliance unless the
Compliance Control Room directs that an
alternative platform or process be used.
Line Manager and
Compliance Control
Room

20. In considering a Special Circumstances Trading Application, ANZ will have regard to:
a. whether the disposal would be likely to affect ANZ’s interest or reputation;
b. whether there is any actual or perceived Conflict of Interest;
c. whether the Restricted Person is in possession of Inside Information; and
d. all other relevant factors, including the nature of the exceptional circumstances outlined in the
applicant’s request.
21. In the case of a Special Circumstances Trading Application by an Employee or Contingent Worker
other than the ANZ CEO, the line manager of the applicant will be asked through StarCompliance
to endorse the application and confirm that they are not aware of any actual or perceived Conflict
of Interest in connection with the application.
22. A decision with respect to a Special Circumstances Trading Application will generally be provided
in writing within 4 Business Days of receipt of the request. Approvals will not be granted
retrospectively, and if an application is declined, that decision is final and binding on the person
submitting the application. ANZ reserves the right not to give a reason for declining the
application.
23. Where a Special Circumstances Trading Application is approved, the approval will be valid only for
Trading during the Effective Period.

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ROLES AND RESPONSIBILITIES
ROLES AND RESPONSIBILITIES OF ANZ DIRECTORS
All ANZ Directors should be aware of their obligations arising from this policy and abide by these
obligations in conjunction with their obligations under the ANZ Non-Executive Directors Code of Conduct.
ROLES AND RESPONSIBILITIES OF ALL EMPLOYEES AND CONTINGENT WORKERS
All Employees and Contingent Workers should be aware of their obligations arising from this policy and
abide by those obligations in conjunction with their obligations under the ANZ Code of Conduct. In
addition, all Employees and Contingent Workers must comply with their obligations under the ANZ Code
of Conduct to declare upon commencement of employment and acknowledge annually that they
understand the principles of the ANZ Code of Conduct (including in relation to this policy), have complied
with them in the previous 12 months, and agree to comply with them going forward.
All Employees and Contingent Workers who are Restricted Persons must:
• obtain and review a copy of the Privacy Statement; and
• provide a copy of the Privacy Statement to their Associated Persons for their review.
Employees and Contingent Workers who are Restricted Persons are required to provide certain
certifications to this effect and agree to the matters set out in the Privacy Statement on their own behalf
and on behalf of their Associated Persons when they first use StarCompliance and prior to making a Pre-
Trade Approval request through StarCompliance.
ROLES AND RESPONSIBILITIES OF LINE MANAGERS
Line managers of Employees and Contingent Workers will be required to review any Special
Circumstances Trading Applications from their direct reports to trade in ANZ Securities. Line managers
should review and assess whether there is an actual or perceived Conflict of Interest should the Restricted
Person transact in ANZ Securities, considering all relevant facts and circumstances. Line managers should
not endorse a Special Circumstances Trading Application which would lead to a Conflict of Interest with
the requesting Employee’s or Contingent Worker’s role at ANZ. A line manager may consider endorsing
the Special Circumstances Trading Application request if no Conflict of Interest exists. In the case that the
Line Manager is absent (or otherwise unable to fulfil their duties), the above listed responsibilities are
transferred to the Individuals Skip Line Manager in accordance with the ANZ Peoplesoft hierarchy.
ROLES AND RESPONSIBILITIES OF THE CORPORATE GOVERNANCE TEAM
The Corporate Governance team is responsible for record keeping in relation to Pre-Trade Approval
applications and decisions in respect of ANZ Directors.
ROLES AND RESPONSIBILITIES OF COMPLIANCE CONTROL ROOM
The Compliance Control Room is responsible for:
• Identification and allocation of Employees and Continent Workers known as “Restricted Persons”;
• Record keeping of all Pre-Trade Approval applications and outcomes decisions other than with respect
to ANZ Directors;
• Pre-Trade Approval enforcement and monitoring, including:
o actively monitoring Trading in ANZ Securities by ExCo members to meet GN27 obligations;
and
o actively monitoring Restricted Persons for compliance with this policy, any specific business
unit requirements and any specific country requirements;

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• Ensuring that the current version of this policy is available on the ANZ intranet;
• Circulating reminders in relation to Blackout Periods (including by email and on the ANZ intranet); and
• making reasonable enquiries (both internally and externally) for information to assist in deciding
whether to approve or reject Pre-Trade Approval requests.
POLICY BREACHES
All policy breaches must be immediately escalated to the Policy Owner and will be dealt with in
accordance with the ANZ Global Performance Improvement and Unacceptable Behaviour Policy.
Breaches of this policy will be investigated and will result in an appropriate consequence being applied.
For Employees and Contingent Workers, this may include re-assessment of bonus qualification,
prohibition from Trading and/or termination of employment or engagement.
A breach of this policy may also be a contravention of relevant insider trading or other laws, which may
result in financial penalties and/or imprisonment for individuals.
POLICY EXEMPTIONS
All policy exemptions, including country level exemptions to a global policy, must be submitted for
approval to the Policy Owner using the Policy Exemption Form with a copy to Policy Governance.
Country level policies should only be developed where there are specific legal or regulatory requirements
to do so.
LEGAL OBLIGATIONS
ANZ will comply with the minimum standards set out in this policy. In the event a legal obligation imposes
a higher standard or requirement on ANZ, the legal obligation will prevail over the applicable minimum
standard.
Where local law in any jurisdiction places obligations or procedural requirements on Employees or
Contingent Workers, which are in addition to the requirements in this policy, Employees and Contingent
Workers must also comply with those obligations or requirements.
If, in performing duties under this policy, an Employee or Contingent Worker complies with a legal
obligation that is inconsistent with this policy, the Employee or Contingent Worker must report this
inconsistency to their local compliance manager and to the Policy Owner.
WHERE TO G ET HELP
Contact your line manager, the Compliance Control Room or the Policy Owner. If you are an ANZ
Director, contact the Chairman of the ANZ Board or ANZ’s Corporate Governance team.

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GLOSSARY
Please refer to the Policy Glossary for definitions of standard terms used in this policy which are not
specifically defined below or elsewhere in this policy. Otherwise, the terms used in this policy are defined
elsewhere in this policy and as follows:

ANZ Director A person appointed to the Board of Directors of ANZGBL or a Controlled Entity of
ANZBGL who is not an employee of ANZBGL or a Controlled Entity

ANZ CEO means the Chief Executive Officer of ANZ.
ANZ Security means:
• a share or bond issued by ANZBGL or a Controlled Entity or a debenture of
ANZBGL or a Controlled Entity;
• any other security or financial product issued by ANZBGL or a Controlled Entity
that can be Traded on a financial market; or
• an option, derivative, future or warrant relating to any security or financial
product referred to above.
Associated Person means:
• a Close Family Member of the person; or
• a company, trust, or other entity the person or the person’s Close Family
Member controls or significantly influences.
Blackout Period means each period:
• (quarter trading updates) from the date which is 14 calendar days before the
scheduled date for an ANZBGL first quarter trading update or ANZBGL third
quarter trading update as the case may be, through to midday (AEST) on the
Business Day following the announcement of such trading update;
• (half year/interim results) from the later of the end of the 6
th
Business Day after
the ANZBGL first quarter trading update or the end of the last day in February,
through to midday (AEST) on the Business Day following the announcement of
ANZBGL’s half year/interim results;
• (full year/annual results) from the later of the end of the 6th Business Day after
the ANZBGL third quarter trading update or the end of the last day of August,
through to midday (AEST) on the Business Day following the announcement of
ANZBGL’s full year/annual results; and
• (other) any additional periods determined by ANZ from time to time.
Broker Statement A statement or record issued by a broker showing securities holdings and
transaction information with respect to a Brokerage Account.
Brokerage Account An account maintained by a Restricted Person (other than an ANZ Director) or their
Associated Persons with a broker for holding and transacting in securities.
Business Day A day that is not a Saturday, a Sunday or a public holiday or bank holiday in the
place concerned.

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Close Family
Member
of a person means:
• a spouse/partner (including de facto or same sex partner) of the person; or
• a child (who is under 18 years of age) or dependent of the person or of the
person’s spouse/partner (including de facto or same sex partner); or
• anyone else who is one of the person’s family and may be expected to influence
the person, or be influenced by the person, in the person’s dealings with ANZ or
ANZ Securities.
Conflict of Interest An actual, potential or perceived conflict of interest arises where the specific duties
or interests of a person or entity in respect of an outcome, are not aligned with that
person or entity’s obligations or duties to others to achieve a different outcome.
DRP Pricing Period means in relation to any eligible dividend, the period of 10 trading days (or such
other number of trading days as the Board may determine from time to time)
commencing on the third trading day immediately following the record date in
relation to that eligible dividend (or such other day as the Board may determine).
Effective Period means:
• in the case of ANZ Directors, such period of time as is determined by the
Chairman of the ANZ Board or the Chairman of the ANZ Audit Committee, as
applicable; and
• in all other cases, the period of time starting when a Pre-Trade Approval is
received by the Restricted Person and ending at the earlier of the close of
trading on the second trading day following the day of receipt of the Pre-Trade
Approval, or the start of the first day of the next Blackout Period.
For this purpose, trading day means a day for which the security is eligible to be
transacted.
ExCo means the Executive Committee of ANZBGL.
Inside Information Information that could be reasonably expected to have a material or significant
effect on the price or value of an ANZ Security and which is not generally available.
Pre-Trade Approval
The submission of a Trade Request for Personal Account Dealing purposes and
receipt of approval from the Compliance Control Room prior to any trading or
placement of an order or execution of any order.
Privacy Statement The ANZ Personal Account Dealing and Personal Conflicts Privacy Statement which
is available on the ANZ intranet.
Restricted Person Each of the following are Restricted Persons:
• ANZ Directors; and
• any other individuals determined by Compliance & Business Unit management
collectively as a Restricted Person (as stipulated in the Schedule maintained by
Compliance) who, because of their seniority or the nature of their position, are
likely to come into contact with key financial, operational, strategic or other
information about ANZ which, should it become generally available, could be

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reasonably expected to have a material or significant effect on the price or
value of an ANZ Security.
Refer to the Restricted Person Look-up Tool.
Special
Circumstances
Trading Application
An application by a Restricted Person to Trade in circumstances that would
otherwise be prohibited under this policy.
StarCompliance The online platform provided to ANZ by StarCompliance, Inc., used by ANZ to
assist in conducting automated Pre-Trade Approvals. StarCompliance can be
accessed by Employees and Contingent Workers on their mobile device through an
App provided by StarCompliance, Inc. or on their desktop through the ANZ
intranet.
Trade/Trading of ANZ Securities means:
• buying, selling or applying for ANZ Securities or providing an instruction to a
third party to do so;
• entering into a contract to buy, sell or apply for ANZ Securities, or procuring a
third party to do so;
• entering into a contract for difference relating to ANZ Securities;
• entering into a contract to buy, sell or exercise a deferred share right or
performance right relating to ANZ Securities;
• the conversion of convertible ANZ Securities;
• exercising ANZ employee deferred share rights or performance rights;
• to elect to commence, cease or vary participation in ANZ’s dividend
reinvestment plan or bonus option plan; or
• spread betting in relation to an ANZ Security.