Corporate social responsibility

Our corporate responsibility and sustainability approach

As a provider of critical market infrastructure, ASX fulfils a meaningful social purpose. Through the raising of capital and management of risk, ASX helps business to grow, create jobs and contribute to the community. By facilitating the exchange of capital and providing data for informed decision making, we provide investors opportunities to invest their capital which will in turn help them to create wealth that contributes to their positive future.

We assess and manage our social, governance and environmental sustainability risks and know the importance of this in executing our strategy and creating long-term value. Below we explain how we conduct our business in a sustainable way.

For us, sustainability is about taking steps in the near-term to help ensure that our strong financial and operational performance continues into the long-term and that we are prepared for the opportunities and challenges ahead. This means:

  • Investing in our infrastructure and enhancing our customers’ experience
  • Building an engaged and skilled workforce
  • Establishing appropriate governance arrangements and playing a leadership role in governance
  • Making a positive impact on the community
  • Managing our impact on the environment.

Information about our investments in infrastructure and enhancing our customers’ experience is set out in our Annual Report on page 5. Details of our material business risks and how we are responding to them are set out in the operating and financial review in our Annual Report on pages 12 to 21.

Our people

Our people are central to achieving ASX’s vision of being the ‘world’s most respected financial marketplace’. ASX is committed to building an engaged, skilled and responsible workforce guided by values and behaviours that support our strategy. To do this, we:

  • make clear the behaviours we expect of employees
  • commit to protecting the confidentiality and position of employees who wish to raise matters concerning the integrity of ASX
  • strive to create a diverse and inclusive workplace
  • have a strategy to attract and retain talent through our remuneration policies and practices, our training and development programs, by providing a safe workplace and programs to support employee wellbeing.

Corporate culture

We work to instill and reinforce a culture of acting lawfully, ethically and responsibly and know this is key to creating long-term value. We are committed to maintaining a high standard of integrity and investor confidence. We’ve implemented the following programs, policies and codes which articulate the behaviours we expect of our people.

Our values

The launch of ASX’s values program was a highlight of FY18. Our values program was developed by our employees, for our employees. The ASX values are behaviours that guide our actions and decision making and reflect our brand and culture. Our values are to:

Be Open, Be Trustworthy, Be Original, Be The Example.

Code of Conduct

ASX has a code of conduct which is underpinned by our values. The Code of Conduct applies to directors and employees. It sets the standards for how we work at ASX and states our values to anyone dealing with ASX. The Code requires employees and directors to act in a way that is guided by ASX’s values – including acting in the best interests of ASX and with honesty, integrity and fairness.

Management and the Board monitor ASX’s culture and behaviour, through the use of online surveys to measure engagement. Results are reviewed by the Remuneration Committee. ASX’s Internal Audit function and Regulatory Assurance function provide periodic feed- back on cultural matters.

Anti-bribery and corruption and whistleblower protection

In addition to our Code of Conduct, ASX has a range of policies in place that guide employee behaviour including our:

  • Anti-bribery and corruption policy which states our requirements regarding the management of gifts and benefits. The policy requires employees to report all gifts above a specified threshold. The Audit and Risk Committee receives periodic reports on these disclosures
  • Whistleblower protection policy which supports employees who report non-compliant or suspicious or unethical conduct. It formalises ASX’s commitment to protecting the confidentiality and position of employees who wish to raise matters concerning the integrity of ASX.

ASX periodically requires staff to attest to their understanding of, and compliance with, ASX’s Code of Conduct and anti-bribery and corruption policy. These policies and our whistleblower protection policy are available on ASX’s website.

Diversity and inclusion

ASX knows that a diverse and inclusive work environment brings performance benefits.

We support a workplace where employees have equal access to career opportunities, training and benefits. We treat employees fairly and respectfully and ensure they are not judged by their gender, age, ethnicity, race, cultural background, religion, sexual orientation, disability or caring responsibilities.

Our focus on gender equality

We promote gender equality as a priority. We have a target of 40% female representation for all management levels. In FY18 we exceeded this target at 41%. Our progress in FY18 against our measurable objectives is set out below.

To encourage greater representation of women at all levels in the organisation we:

  • Set gender diversity targets. Achievement against the targets is monitored by the Remuneration Committee
  • Require gender-balanced shortlists when recruiting all roles
  • Embed gender equality targets as part of an executive’s balanced score card and review the executive’s achievement against these targets when determining their short-term incentive
  • Undertake annual pay equity reviews and make adjustments where a gap is identified
  • Participate in the Chief Executive Women Leaders Development program which provides individual coaching for participants
  • Support Male Champions of Change, with our CEO a member.





Diversity % of women

On the Board




Executive committee roles




Management executive roles




Management/team leader roles




Total % of women in management position roles




Professional/technical roles




Administrative roles




Across the entire organisation




ASX also implements gender-neutral policies to help build an inclusive workplace. An example of this is our parental leave policy which makes available paid and unpaid leave to all new parents (including superannuation payments) regardless of gender.

Attracting and retaining talent

The market for talented people is competitive and so we continue to evolve our offerings to employees to ensure we attract and retain high performing professionals. In addition to remuneration, we offer learning and development opportunities, leadership training and support employee wellbeing programs.


ASX employees receive a market competitive total fixed remuneration package. Subject to performance, employees also participate in a short-term incentive plan that rewards individual behaviours and performance with ASX shares and/or cash (depending on the role). Details about our remuneration practices and policies are included in our Annual Report on pages 39 to 51.

ASX also supports employees who want to be shareholders and during the year, offered to all ASX employees the opportunity to acquire ASX shares under a $1,000 General Employee Share Plan. In FY18, this offer was accepted by 57% of staff.

Learning and development

We believe that our sustainability is strongly supported by high performing individuals who seek to improve their skills and performance. ASX offers learning and development programs at all levels of the organisation to help staff grow their skills and their careers.

Building leadership capability

During FY18, ASX launched a new leadership development program which is aligned with ASX’s values and designed to positively influence our culture. All leaders at ASX have participated in this program which will be rolled out to additional staff in FY19.

ASX also participates in the Chief Executive Women Leaders Development Program which provides individual coaching for participants.

Employee wellbeing


ASX is committed to the health and safety of all employees, visitors and contractors. Employees are encouraged to identify and address potential causes of workplace risk, injury and illness.

The Audit and Risk Committee receives quarterly updates on ASX’s compliance with workplace health and safety (WHS) laws. WHS performance is audited periodically by an independent third party. ASX’s FY18 lost-time injury frequency rate (the number of lost time injuries per 1 million hours worked) was very low at less than 0.1. This is in line with FY17.

Prevention of harassment and discrimination

ASX works to prevent discrimination and harassment in the work- place. ASX has processes in place to monitor and address discrimination and employees must complete online training periodically.


ASX has a wellbeing program to support employees to balance their work, personal and family life. We offer subsidised activities such as yoga, pilates, meditation, lunchtime sport and a walking club. ASX’s Social Committee co-ordinates company funded events throughout the year.

Supporting working families

ASX offers flexible working conditions to help employees balance their work and personal lives. We enable employees to change their work hours and place of work, set up a job share arrangement, take career breaks and parental leave or purchase additional leave.

In FY18, approximately 63% of staff identified as working in a flexible capacity.

ASX’s parental leave policy provides 16 weeks’ paid leave for primary carers and four weeks’ paid leave for secondary carers. Superannuation contributions foregone during unpaid parental leave are paid as a one-time contribution on return to work up to a maximum of 36 weeks. Graduated return to work options are available to support employees transition back to the workplace.


ASX is committed to maintaining and promoting high standards of corporate governance and believes this is a driver of shareholder value. This section of the report is divided into two segments. Firstly, it explores elements of ASX’s own governance arrangements and secondly, how ASX promotes high standards of corporate governance in Australia.

ASX’s governance arrangements

Our corporate governance statement in our Annual Report on pages 28 to 38 describes our principal governance arrangements and practices for effective decision making and accountability.

Additional details on how we manage conflicts of interest and perform our compliance and enforcement functions are set out below.

Managing conflicts of interests

ASX has well established arrangements to address the potential for actual and perceived conflicts. These include:

  • Governance arrangements, including for ASX’s self-listing
  • Customers, competitor and supplier arrangements
    • licence obligations (including the ‘review party’ framework)
    • information handling standards.

Arrangements are also in place for handling conflict sensitive information relating to other market operators that use services provided by ASX’s clearing and settlement (CS) facilities.

ASIC is ASX’s listing authority and monitors ASX’s own compliance with the listing rules.

ASX has a Regulatory Assurance function whose responsibilities include reviewing ASX’s compliance with our conflict and information handling standards and reports on these matters to the Audit and Risk Committee.

Compliance and enforcement arrangements

ASX Group licensed entities have arrangements for monitoring and enforcing compliance by listed entities and participants with ASX’s operating rules, and for handling conflicts between the licensed entities’ commercial interests and their licence responsibilities.

ASX has a dedicated Compliance function which monitors and enforces compliance with the operating rules of each licensed entity. ASX’s conflict handling arrangements are set out in our conflict handling policy which is available on our website.

ASX’s Audit and Risk Committee and ASX licensed entities have oversight of the performance of these functions. Previously, this oversight role was performed with the assistance of a related body corporate, ASX Compliance Pty Limited.

Playing a leadership role in corporate governance

ASX Corporate Governance Council

Promoting high standards of corporate governance helps to develop a market of quality and integrity which is key to maintaining the strength of ASX’s listing franchise and also helps improve the strength of the Australian economy and investment environment.

The ASX Corporate Governance Council, a body independent of ASX, brings together business, investment, and shareholder groups. As the convener, ASX nominates the Chair (currently Ms Elizabeth Johnstone), contributes one member of the Council and provides executive support.

The ASX Corporate Governance Council publishes a principles-based framework for corporate governance practices – the Corporate Governance Principles and Recommendations ('the Principles') – that serves as a relevant and practical guide for listed entities, investors and the wider Australian community.

ASX’s listing rules require that listed entities disclose the extent to which they have followed the recommendations set by the Council during the relevant reporting period. Where companies have not followed a recommendation, they must provide an explanation (‘if not, why not’ reporting). These reporting requirements bring transparency to the corporate governance practices of listed companies, which enables investors to make informed investment decisions.

In May 2018, the Council commenced public consultation on proposals to update and issue a fourth edition of 'the Principles' to address a number of matters including corporate values and culture, whistleblower and anti-bribery and corruption policies, and cyber risks. The Council’s proposed changes anticipated and respond to some of the governance issues identified in recent enquiries such as the Hayne Royal Commission. On behalf of the Council, ASX conducted national roadshows in June 2018 to inform and seek feedback from listed entities and other interested stakeholders about the proposed changes.

ESG guidance to issuers

The Council has contributed to an improvement in public reporting and awareness of environment, social and governance (ESG) matters by listed entities. 'The Principles' require listed entities to include details in their Annual Report of how they manage their material economic, environmental, social sustainability and governance risks.

Sustainable Stock Exchanges Initiative

ASX is a partner exchange in the United Nations’ Sustainable Stock Exchange (SSE) Initiative.

The SSE is a peer-to-peer learning platform for exploring how exchanges, in collaboration with investors, regulators and companies, can enhance corporate transparency on ESG issues and encourage sustainable investment.

Responsible and ethical business practices

Fraud and cyber security

As the operator of critical financial markets infrastructure ASX has a range of fraud and cyber-risk mitigation strategies and systems in place.

We are proactive in managing resilience across our systems and processes. In addition to the use of risk management strategies, processes and tools, ASX employees undertake regular security awareness training.
As a markets operator and provider of clearing and settlement facilities, ASX is subject to the risk of fraud – either internally by staff or externally by third parties targeting customers using ASX’s name or infrastructure. To mitigate these risks we have appropriate fraud prevention and detection procedures in place.
Our fraud control framework enables executive management and business units to prevent, detect and respond to potential fraud. The framework is a combination of embedded fraud controls and general staff awareness, supported by regular business unit and independent fraud risk assessment.

Socially responsible practices

ASX is committed to acting in a socially responsible way. In addition to the practices and policies outlined above, this is reflected in our approach to taxation and how we work with our key suppliers to ensure they also meet our ESG requirements.


Taxation is an important component of our corporate responsibility framework and enterprise risk management framework.

We adopt a low risk tax strategy with our activities and tax compliance obligations and apply the following principles:

  • Meet all taxation obligations in accordance with applicable legislation and requirements
  • Adopt a conservative approach in the interpretation of applicable taxation legislation
  • Seek professional tax advice or a tax ruling from the ATO in circumstances where the potential taxation outcome is uncertain
  • Do not enter into transactions or structures with the primary objective of reducing tax liabilities.

ASX’s Tax Transparency Report is released to the market at the time of its Annual Report and published on ASX’s website. The report provides further detail on our approach to tax and discloses the amount of income tax paid. ASX’s total tax contribution in FY18 was $313.4 million.

Our suppliers and how we manage our suppliers

ASX aims to partner with suppliers that share our ESG standards. ASX promotes ESG practices in our supply chain by incorporating ESG clauses in our standard supplier agreement. ASX's suppliers are expected to comply with all relevant laws and regulations, ASX's ESG standards and to measure and improve their ESG practices.

Material suppliers must comply with ASX's Supplier Code of Conduct, which includes minimum expectations across key ESG areas. ASX reserves the right to carry out assessments of the practices of our suppliers to ensure alignment with this Code.

ESG considerations are included in all material procurement tenders.

Community engagement

ASX aims to contribute positively to the Australian community. We contribute through providing free, accessible education about the markets, supporting volunteer work by ASX employees and working with select charity foundations and not-for profit organisations.


We are committed to promoting informed investing and also acknowledge its importance in supporting ASX’s business.

We provide access to free tools and resources to explain the potential rewards and risks of investing including online courses, YouTube presentations, face-to-face events around Australia and a monthly e-newsletter that has approximately 300,000 subscribers.

ASX also conducts the share market game for school students and also the general public. This helps to familiarise participants with mechanics of share trading. The game is linked to the live market – connecting players to real-world events. In FY18, there were more than 69,000 student entries and more than 46,000 entries from members of the public.


We believe volunteering is an important way that our employees can contribute to the community. We assist our employees to support worthwhile causes and participate in community programs outside the workplace. This includes providing paid volunteering leave. ASX’s community programs allow employees to support causes and charities of their choice. ASX matches employee donations to these charity partners and made donations to 47 charities in FY18.

Charity and donations

ASX works with a number of charity foundations and not-for-profit organisations that support a range of causes. Details of our contributions and relationships are set out below.

ASX Thomson Reuters Charity Foundation

The Foundation supports Australian children’s and medical research charities by organising fundraising events for financial markets participants. In FY18, over $1.2 million was raised and distributed to 38 charities.

The Foundation has two ASX representatives on its eight person board. ASX volunteers the company secretariat and finance functions for the Foundation and ASX employees volunteer to assist with the fundraising activities.

ANZAC Centenary Public Fund

ASX is contributing a total of $1 million over 5 years to the Anzac Centenary Public Fund. The Fund, established by the Australian Government, receives donations to commemorate the centenary of Australia’s involvement in the First World War and a Century of Service. Projects honour and improve understanding of the service and sacrifice of Australia’s servicemen and women, past and present, in defending Australia’s values and freedom.

ShareGift Australia

ASX supports ShareGift Australia, a non-profit that aggregates under-utilised share capital to generate funding for other charities. To date ShareGift has donated more than $1.6 million to over 470 charities.

ASX's support includes the reimbursement of all ASX exchange fees on ShareGift transactions and promoting ShareGift via the CHESS statements sent to investors.

Any individual shareholder may donate a parcel of shares – large or small – free of brokerage and the proceeds support the community.


We are a service-based organisation that does not extract physical or natural resources and are not involved in the manufacture or transport of products. Our environmental footprint is small. It arises from the energy used in our three offices, two data centres and from consumables (primarily paper). ASX’s environmental risks are not significant.

Nevertheless, we are mindful of our impact on the environment and we are committed to acting responsibly. We measure the impact of our activities. We minimise consumption of materials. We recycle and use carbon-neutral consumables. We support awareness of environmental issues.

FY18 environmental outcomes

ASX’s electricity and paper usage outcomes are set out below:


FY18 electricity and paper usage





Actual reduction from prior year

Electricity GHG1 emission (excluding ASX’s data centre hosting) per $1,000 of revenue generated (in t CO2-e2)




Paper usage (excluding CHESS statements and notifications) by headcount (tonnes)




1 Greenhouse gas (GHG) emissions

2 Tonnes of carbon dioxide equivalent


Electricity usage

ASX’s total electricity consumption remained flat in FY18 and decreased 3% relative to revenue.

More than half of ASX’s energy usage is in the Australian Liquidity Centre (ALC), ASX’s primary data centre.

The ALC supports the equipment and systems of customers who co-locate with ASX and provides efficiencies to customers generally. Customers would otherwise be required to operate such systems from their own or other facilities.

Growth in this business (and its energy consumption) reflects the ALC’s position as the premier financial markets ecosystem in Australia. The number of IT cabinets hosted in the ALC has grown from 117 to 301 in the last five years.

ASX has implemented measures to ensure that a disruption to the supply of electricity to our sites (including to its data centres) will not result in a service disruption to our customers. The infrastructure that supports ASX’s data centres incorporates uninterruptible power supply systems, which provide ongoing electricity in the event of a loss of power from the grid. ASX’s business continuity management plans outline how we will maintain operations in such circumstances. These plans are reviewed periodically.

Paper usage

ASX’s paper usage is carbon neutral and by headcount (excluding CHESS statements and notifications) decreased by 1% over FY18.

Management continues to reduce paper usage in ASX’s business. ASX encourages its shareholders to receive electronic communications instead of hard copy communications via post.

Environmental impact

Greenhouse gas (GHG) emissions






Scope 1 – diesel and gas

t CO2-e1





Scope 2 – electricity

t CO2-e











GHG emissions by activity






Scope 1 – diesel and gas combustion

t CO2-e





Scope 2 – electricity (data centre hosting)

– electricity (remainder ASX’s business)

t CO2-e









Scope 3 – travel (business travel and commuting)

  • paper usage (office)2
  • paper usage (CHESS statements and notifications)2

t CO2-e t CO2-e t CO2-e



















Paper usage






Office use






CHESS statements and notifications






1 Tonnes of carbon dioxide equivalent

2 GHG emissions reported inclusive of carbon offset. ASX commenced using 100% carbon neutral paper in 2015.