Seven domains to
drive change

Debra Hazelton, Chair AMP and CEW member

December 2021

In the middle of 2020 AMP became Australia’s most high profile corporate #MeToo story. Understandably, as a result, the company faced criticism from all stakeholders – employees, investors, clients and the broader community.

Following the resignation of the Chairman, a non-executive director and the demotion of the senior executive concerned, the newly appointed Chair and board, together with the relevant senior executives, committed to use the situation to not only understand and address the challenges within AMP, but also to support reform across the Australian financial services industry through commissioning a thorough review, and sharing the resultant actions and learnings.

AMP undertook a detailed and holistic investigation into its culture and work practices. It needs to be stressed at the outset that the driver of this work was our recognition of the need to understand and deal with root causes, and not simply a reaction to the increased scrutiny.

We set ourselves a high benchmark (global best practice), and used the substantive framework introduced in the Australian Human Rights Commission (AHRC) Respect@Work 2020 Report together with other thought leadership. We approached the work with commitment and humility, recognising that transformative culture change requires a long-term, continuous- improvement mindset.

In the spirit of the transparency advocated by the Respect@Work report, we are making this detailed case study available to CEW to deliver on our commitment to contribute to the creation of safer, more inclusive and respectful workplaces free from all forms of discrimination, bullying, misconduct and harassment.

The case study maps out the actions we took against the seven domains set out in the Respect@Work 2020 Report framework. The domains are mutually overlapping and reinforcing – with many actions contributing across more than one domain.

1. Leadership

Meaningful action must begin with the Board, CEO and Executive leadership. The starting point needs to be the leaders “owning” the problem and understanding that it emanates from a complex interplay of subcultures and circumstances – it is not a matter to be ‘managed’ nor box-ticking. Strong leadership is critical to ensure that the message is clear and unequivocal throughout the organisation and at every level.

Our response required a hard look at the culture of the AMP group and was made possible by the alignment and commitment of senior leaders working in close collaboration with the Board Culture Working Group chaired by myself with Andrea Slattery and Rahoul Chowdry. The Board Culture Working Group set the tone from the top, commissioning a comprehensive Workplace Culture and Conduct Review (the Review) which was conducted by global inclusion experts.

This process began with extensive desk research including reviews of: AMP’s case management; whistleblower framework; data; policies, processes and training materials; and employee communications. It also involved over 30 internal and external interviews, 20+ employee focus groups (covering over 200 people) and an anonymous, confidential online survey of all employees (with a 59% participation rate).

The review identified several areas where work was required to bring AMP in line with global best practice to reflect rapidly changing expectations and standards. Among the major findings of the review were the need to: 

  • Adopt a more person-centred approach in our policies and processes on conduct matters, moving away from the traditional legalistic, and compliance driven approach.
  • Improve consistency and quality of approach to incident measurement, records and data across the group.
  • Lift levels of capability and co-ordination around managing conduct issues, and provide further channels to raise issues; and 
  • More actively communicate Board and senior leadership commitment to inclusion and diversity.

There was another review finding, one which highlighted the importance of our reaction to these events, not just for AMP but for the broader industry. The review found that based on Australian financial sector benchmarks the number of sexual harassment complaints in AMP, in fact represented a lower percentage of our workforce than the Australian finance sector overall. This tells us that such misconduct is systemic across the industry and emphasises the need for a dramatic shift in the way each company currently thinks about each incident.

Going forward we all must avoid the temptation to deal with each incident’s complex circumstantial context in an effort to “resolve” and “move on”. As a society we are at an inflection point – expectations have radically changed and strong leaders must unite to focus on the general elimination of this behaviour across the industry. 

The review served as both an audit and risk assessment of current status and was considered in depth by the Board Culture Working Group and the Executive team. With the purpose of establishing a proactive and systematic framework for prevention and response to misconduct in the workplace, the Executive team then developed a comprehensive Management Action Plan consisting of 69 initiatives. Plan deliverables are tracked monthly and progress is discussed at the Board.

To date 46 initiatives have been delivered in line with the People & Culture(P&C)Strategy, and a further 14 are in progress and on-track for completion by year end. The remaining nine initiatives will be delivered in 2022 H1. Of these initiatives, two critical leadership-related actions implemented were:

  • Reaffirmation of our commitment to 40:40:20 gender targets. Since doing so, we have achieved 50:50 at Board (currently 8 members) including both a female Chair and CEO. We have met the 40:40:20 target among broader senior leadership however still have work to do at the Executive Management level (currently 34% female). This remains a key focus; and
  • We have implemented Inclusive Leadership Training for all 60 senior leaders recognising the importance of considering intersectionality when addressing sexual harassment. Training included workshops on the inclusion imperative and a 360-degree assessment of inclusive leadership capability. It was designed as an interactive, blended learning program. Each leader received individual feedback and coaching on their own assessment and participated in a ‘catalyst conversation’ with a volunteer employee from a different gender, cultural background and/or sexual orientation to better understand the lived experience of our diverse employee base.

2. Risk Assessment and Transparency

While the review served as our base-line risk assessment & audit, rather than relying on a single point-in-time analysis we have incorporated specific consideration of conduct matters in our Work Health & Safety quarterly reports. 

The transparency of reporting conduct issues has improved markedly internally and externally. For example:

  • Internally, we have:
    • Introduced quarterly reporting on Conduct to the Board – highlighting any trends and discussing cases to monitor risk and drive improvement. 
    • Published key statistics and trends on conduct and consequence management on Workplace (AMP’s internal Facebook for employees) to encourage discussion and create opportunities for micro and social learning. Historical statistics and trends are also available to our employees.
    • Introduced a quarterly Culture Dashboard, the design of which was initially agreed with the Board to encourage discussion, debate, reflection and drive improvement. 
  • Externally, we have:
    • Significantly enhanced reporting on conduct cases and employee complaint statistics in the 2020 Sustainability Report and intend to drive improvement as we move into our 2021 reporting suite.
    • Shared the initiatives and progress against the Management Action Plan with around 50 clients and 50 shareholders globally.

3. Culture

Misconduct can be traced back to a culture that lacks respect. A respectful culture is inclusive and embraces diversity – and means safer workplaces. Respect underlies trust, and the benefits of a respectful, trusted corporate culture to businesses is overwhelmingly positive – for employees, customers and clients, and all stakeholders. 

A truly inclusive and diverse culture is critical to prevent harassment of any type, and we are taking significant action in this space:

  • Together with the Inclusive Leadership training, we have established the Inclusion Taskforce comprising 18 employee representatives from all areas and all levels of the business across the world. The taskforce worked collaboratively with P&C to strengthen the inclusion framework, update the global I&D policy and develop and implement a comprehensive annual Inclusion Program to build support for gender, ethnicity, ability and generational diversity to add to our existing strong programmes such as the Reconciliation Action Plan (RAP) and AmProud (LGBTQI+). 


The Respect@Work report also highlights the role of HR policies and processes in shaping culture. We have:

  • Updated all our policies and procedures (on a rolling replacement basis) to be more person-centred based on the review findings that they were quite traditional, legalistic and compliance driven 
  • Streamlined the number of policies and improved the accessibility of online content and support information available on the intranet
  • Acknowledged the critical role of performance and reward in shaping culture, by formally reflecting performance, behaviour, conduct, risk management and inclusion outcomes into our performance and reward framework. Consequences (both positive and negative) are now consistently applied.


In the second phase of continuous improvement, we’ve set out on a culture@AMP journey. This entails listening to our employees through a comprehensive series of workshops to understand current and desired culture to help reset the definition of Purpose and Values and to further build and embed a culture of trust, respect, inclusion and performance as we move towards demerger.

4. Knowledge

We are committed to improving the level of knowledge across the organisation to enhance understanding of the various forms that misconduct can take, and to clarify the type of behaviours expected in the workplace. Training initiatives implemented include:

  • Inclusion and diversity training: building on the inclusive leadership training for senior leaders we have sourced simple, interactive learning modules from SBS to provide foundational training for all employees. This training is rolling out through Q4 this year.
  • We have updated our code of conduct by strengthening the commitment to valuing differences and creating a safe workplace. The materials are now far more explicit about what constitutes harassment, what to do about it and how to report as a victim or bystander. We included a case study to help bring this to life.
  • Consistent with AHRC recommendations, we have implemented mandatory annual refresher code of conduct training courses for all employees (with a 100% completion rate in 2020 and are on track for similar participation in 2021). The intent is to ensure conduct remains top of mind, and that the learning is ongoing rather than one-off at induction.


We launched a new ‘whistle-blower’ learning module written in a simple, clear and people-centred style. Once updated, we undertook extensive internal communications recognising the importance of informing all employees about the variety of channels available for reporting concerns of misconduct of any type.

5. Support

To improve support within the AMP workplace, we have:

  • Established a centralised workplace relations specialist team, replacing a system where each business unit managed their own conduct issues. This team has assumed responsibility for consistent management and investigation of workplace conduct issues and for improving record keeping, data and regular reporting.
  • Invested in targeted training and up skilling for the workplace specialists to ensure management of cases is procedurally fair but, importantly, performed in a person-centred, trauma informed manner.
  • Provided professional mental health support to all parties involved in any investigation or who may be impacted by misconduct of any kind. In our work on support, a key finding was that it was important to adopt a ‘person’ rather than solely ‘victim centred’ approach recognising that everyone involved may need support.

More broadly, we have also uplifted our Employee Assistance Program support, introducing a more comprehensive program which now includes counselling, legal advice and general health and wellbeing services.

6. Reporting

Under “reporting” we focused on increasing the options available to workers to report workplace misconduct as well as the potential barriers to reporting.

Like many businesses, we had multiple channels for reporting incidents – through the leader, P&C business partners, WHS team, workplace specialists, internal and external anonymous whistleblowing lines, the CHAMP employee assistance program etc. 

We found through the review that launching a formal investigation was regarded by some employees (whether the person experiencing sexual harassment, leaders or bystanders) as a barrier to reporting. We have therefore:

  • Created an informal channel where employees can discuss concerns without necessarily proceeding to formal complaint or automatically triggering an investigation. To this end, we have extended the role of our accredited mental health first aid officers, a group of around 120 volunteer employees specifically trained to help colleagues facing mental health issues. We have also provided additional training for supporting and responding to concerns regarding workplace misconduct issues. 
  • We have subsequently improved communication and promotion of the range of channels available to raise concerns or seek advice, both through formal mechanisms such as code of conduct training, and more informal channels such as AMP’s internal facebook Workplace.

7. Measuring

The review indicated that we needed to improve the consistency and quality of approach to incident measurement, record-keeping and data across the group. The two issues at the core were:

  • The historical decentralised approach to case management, application of consequences, data collection, record keeping and reporting; and
  • Historical under-investment in HR IT systems with multiple systems used for data collection and record keeping. This resulted in data capture that wasn’t standardised and separately stored making it difficult to identify trends.

To strengthen this area, the initiatives implemented via the Management Action plan included:

  • Centralisation of case management, data and record-keeping and the establishment of a Group-wide reporting system for all conduct cases handled by P&C, including whistleblowing cases.
  • Establishment of a central Consequence Management Committee chaired by the CEO to review all serious conduct cases on a quarterly basis and consistently apply consequences and report.
  • Implementation of a new human capital management system to improve data capture and recording of complaints and actions, enabling better identification of trends and monitoring of the effectiveness of each initiative. This new system is due for implementation in Q1 2022.
  • Enhanced culture and conduct reporting to Management and the Board on a quarterly basis, including insights on volume by type of misconduct, consequences applied, and trends etc.
  • To assist in shaping future policy we also participated in the industry-wide review on use and disclosure of non-disclosure agreements conducted by the Australian Council of Superannuation Investors (ACSI) in partnership with the AHRC.
  • Introduction of a Leadership Inclusion Index. This index is measured against a set of global benchmarks and forms part of our broader approach to measuring organisational culture. It is measured bi-annually and communicated via the Culture Dashboard.

Key learnings

  • Those who speak up show courage. Leaders, both Board and Management, need to match this courage by owning and facing into the often heavy-lifting necessary to drive meaningful organisational culture change.
  • At the outset the introduction of a new proactive systematic framework, a radical overhaul of systems and processes and resetting an institutional legalistic mindset might seem overwhelming. We found that an incremental approach – taking manageable but meaningful actions – helped build momentum and drive transformative change. It also allowed the continual re-evaluation of our progress, helping us course- correct along the way. 
  • A constructive partnership between Board and Management was essential so that an agreed roadmap was actioned early to shift the focus from self-analysis to implementation and improvement. It was also important to establish a regular rhythm for joint Board/ Management discussion and debate. 

For AMP, it was important to broaden the scope to address all forms of misconduct, including sexual harassment. Essentially, all misconduct is rooted in lack of respect – the end goal is to create a safe and inclusive workplace free from all forms of harassment, discrimination, bullying or misconduct. This comprehensive approach also helped when having some of the more challenging conversations.

Moreover, given our company size and the many competing priorities, to address separate processes, policies, and training modules for different forms of misconduct would have been inefficient, and may have hindered progress.

We commend those companies that have adopted stand-alone sexual harassment policies but encourage tailoring the approach to best fit each organisation’s circumstances.


When asked to provide this case study, CEW requested that AMP set out what we consider to be our legacy in this regard.

At the outset the AMP Board and Management were committed to ensure that by addressing the significant challenges at the time with genuine diligence, we would not only redress AMP-specific matters, but we could contribute to reducing harassment within the broader Australian corporate environment. We are attempting to deliver on this commitment in a number of ways:

  • By sharing our experience in forums like this, role modelling the transparency advocated in the Respect@Work report; and
  • By supporting the AHRC team to produce a practical business implementation guide based on  Respect@Work principles.  This guide (due for publication in coming months) is designed to help others change their workplace, sharing different corporations’ learnings and collating the tools developed by other key bodies and organisations into a single, accessible document.


We fully recognise that this is a continuous journey and that there will always be more work to do in this space, but by sharing our actions, sincerely intend to substantially contribute to the creation of safer, more respectful and productive workplaces for everyone’s benefit.

CEW has developed a range of resources to help leaders bring about real change in their organisations, and to track and eliminate sexual harassment.

We need to set the tone and lead from the top. With this in mind, here are examples of some things we should never say or accept from others:

  • A bullying and harassment policy should be enough to deal with sexual harassment and related inappropriate conduct.
  • We have low report rates of sexual harassment and related inappropriate conduct, so it’s not a problem at this organisation.
  • We have a reporting hotline which is well publicised, but we don’t get many calls about sexual harassment or related inappropriate conduct, so it’s not an issue here.
  • I have been in this industry for decades and I have never seen it, so it mustn’t be happening.
  • That’s the remit of our HR team. If there were ever a big issue, they would escalate it to us.
  • Our staff engagement scores are terrific and there is no indication of there being a sexual harassment problem here. That means we’re doing enough.
Most cultural issues aren’t hiding in plain sight. Often, it’s the things that aren’t being talked about that we need to be concerned about. Research tells us that sexual harassment is common and that it’s significantly under reported. In fact, increased reporting can indicate greater psychological safety and a culture of trust that the organisation takes sexual harassment seriously. We have a positive duty to prevent sexual harassment and related inappropriate conduct, and to continuously assess and evaluate whether we are meeting the requirements of the duty. 

We need to ensure our people feel safe to come forward and report instances of sexual harassment or related inappropriate conduct in the workplace. The only way they’ll do this is if they can see that leadership takes this issue seriously.

We take the health and wellbeing of our people very seriously. We work hard to improve our safety outcomes and reduce injuries, and overall we do a good job of preventing physical harm to our people.

As we have seen in many other organisations, sexual harassment is more prevalent than a lot of people think. This represents a real risk to keeping people safe in the workplace, and to our people’s wellbeing and productivity.

It can also cause significant damage to our reputation, our brand as an employer of choice, lost business, and to our corporate standing. If we fail to take steps to address this conduct, we may be subject to enforcement action and/or civil penalties. Our organisation may also be held liable for inappropriate conduct committed by our employees unless we took all reasonable steps to prevent the conduct occurring. 

We need to make it crystal clear to everyone in the organisation that we have zero tolerance for any form of sexual harassment. We will always take appropriate action when sexual harassment or related inappropriate conduct occurs. We seek to prevent these unlawful behaviours and to have a zero-harm workplace. We welcome the new Australian positive duty placed on organisations by the Anti-Discrimination and Human Rights Legislation Amendment (Respect at Work) Act 2022 and commit to implementing its provisions in a timely fashion and demonstrating our leadership. 

We need to treat sexual harassment and related inappropriate conduct risks as we would any other physical or psychological risk in the workplace. We already have existing systems and processes in place for identifying and mitigating workplace health and safety risks and hazards, and for defining our desired safe and respectful culture. 

We need to embed these sexual harassment response frameworks into our existing risk reporting practices and organisational culture, so all forms of sexual harassment and related misconduct are eradicated.

We can’t afford to wait on this; we need to act urgently. 

Sexual harassment is any unwelcome sexual advance, request for sexual favours or other conduct of a sexual nature. It’s not only a human rights issue, which is unlawful under the Sex Discrimination Act, but also a workplace health and safety (WHS) risk which can cause significant psychological, physical, reputational and financial harm.

Existing systems and processes for managing WHS risks and hazards should be used to eliminate the risks and control the likelihood of sexual harassment occurring in the workplace.

Board members and senior executives have a duty to address this. Everyone deserves to work in a safe, respectful and inclusive environment. Respect is everyone’s business.

Sexual harassment is any unwelcome sexual advance, request for sexual favours or other conduct of a sexual nature. It’s not only a human rights issue, which is unlawful under the Sex Discrimination Act, but also a workplace health and safety (WHS) risk which can cause significant psychological, physical, reputational and financial harm.

Existing systems and processes for managing WHS risks and hazards should be used to eliminate the risks and control the likelihood of sexual harassment occurring in the workplace.

Board members and senior executives have a duty to address this. Everyone deserves to work in a safe, respectful and inclusive environment. Respect is everyone’s business.