Separately, the Australian Prudential Regulation Authority (APRA) in August hit the bank with a $250 million capital add-on charge after ANZ admitted its markets unit inflated its bond trading figures to the federal government – portraying itself as more experienced than it actual was – and a workplace complaints investigation found traders in the Sydney dealing room were inebriated during working hours.

APRA criticised ANZ for not fixing its non-financial risks and having no clear plans for managing them more than five years after it ordered the bank to hold $500 million in capital over similar issues.

“I think it’s a fair observation from [APRA],” Whelan said.

“We started this four or five years ago, and we were leaning into it, I think, OK. We put a lot more resources behind it in the last 18 months, and we’re making more progress.

“There are six risk themes we’re doing one by one, we’ll have those in place. But then the game turns to, ‘How do you embed it and improve it on an ongoing basis?’ It’ll never stop, to be frank, but we’ll get to a point where I think we’re in a reasonable shape, I would hope, in the next five months.”

Whelan said he believed non-financial risks, such as reputational and cybersecurity issues, posed the biggest problems for banks because they damaged the brand and ultimately ended up costing the institution greater than financial issues.

He said the bank was reviewing its code of conduct following the string of problems to place a greater emphasis on a “speak-up culture”.

ANZ has also expanded the terms of reference of a separate review into workplace culture following APRA’s criticisms and will be required to reveal its “remediation plan” to the regulator.

“We had a handful of people who behaved incorrectly, which is really disappointing … but what did happen is that it got reported internally, and we dealt with it,” Whelan said.

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Elliott last month told a parliamentary committee he was expecting to have his bonuses cut because of the “reputational harm” the allegations have had on ANZ.

“I’m not for a minute suggesting here that we are perfect or that there aren’t other improvements we can make culturally, procedure-wise, policy-wise, all of it,” Elliott told this masthead.

“We’ll learn from this just like we’ve learned from other things. Whether or not it does result in an allegation or a case or anything, there’s clearly something to learn.

“We’ve had some … reputational damage and obviously that’s caused us to reflect, and we’ve already put in place some changes in those areas as well.”