All Compliance Documents

Vulnerability and Treating Customers Fairly Policy

GT Industries (AUST) Pty Ltd T/A MoneyBuddy (ACN 682877701) Australian Credit Licence 567039
Effective Date: 15/08/2025

1. Purpose

This policy sets out how we identify, support and treat vulnerable customers fairly. It reflects our obligations under:

  • National Consumer Credit Protection Act 2009 (NCCP Act)
  • National Credit Code (NCC)
  • ASIC Act 2001 (unfair practices and unconscionable conduct)
  • ASIC Regulatory Guide 209 (Responsible Lending Conduct)
  • ASIC Regulatory Guide 271 (Internal Dispute Resolution)
  • AFCA complaint handling expectations

The purpose of this policy is to ensure all customers, including those experiencing vulnerability, receive fair, transparent and respectful treatment in all dealings with us.

2. Scope

This policy applies to all staff, contractors and representatives involved in:

  • Credit assessment and loan approvals
  • Customer service and collections
  • Hardship and complaints handling
  • Marketing and product distribution

3. Definition of Vulnerability

A customer may be considered vulnerable where their circumstances reduce their ability to:

  • Understand information provided about credit products
  • Communicate their needs or make informed decisions
  • Manage credit obligations without hardship

Examples include (but are not limited to):

  • Low financial literacy
  • Disability or mental health conditions
  • Age-related vulnerability (elderly or very young borrowers)
  • Language or literacy barriers
  • Dependence on Centrelink or government benefits
  • Financial hardship (unemployment, sudden income loss)
  • Family or domestic violence
  • Indigenous or remote community disadvantage

4. Principles of Fair Treatment

We are committed to:

  1. Respect and dignity – treating all customers fairly, honestly, and without discrimination.
  2. Accessibility – ensuring information is provided in plain language and alternative formats where required.
  3. Extra care – providing additional assistance to vulnerable customers to ensure they understand their rights and obligations.
  4. No exploitation – avoiding practices that could take advantage of a customer’s vulnerability.
  5. Fair outcomes – balancing compliance with commercial decisions to avoid causing undue hardship.

5. Staff Responsibilities

  • Identification: Staff must be alert to indicators of vulnerability (financial distress, communication difficulties, requests for hardship).
  • Adaptation: Adjust communication methods (slower pace, plain English, interpreters).
  • Escalation: Refer complex or sensitive cases to senior management or the hardship/complaints team.
  • Confidentiality: Handle sensitive information respectfully and in compliance with the Privacy Act 1988.

6. Lending and Assessment

  • We must not rely solely on customer declarations of affordability.
  • We will obtain and verify financial information (bank statements, payslips) in line with responsible lending obligations (s 117–123 NCCP Act).
  • Where indicators of vulnerability are present, additional inquiries will be made to ensure the loan is not unsuitable.

7. Collections and Hardship

  • Vulnerable customers must not be subject to aggressive or unfair collection practices.
  • Customers may request a hardship variation under s 72 NCC.
  • Staff must proactively explain hardship options if vulnerability is identified.
  • Collection strategies will be adapted (e.g. more flexible repayment plans).

8. Complaints Handling

  • Vulnerable customers must be given priority in the complaints process.
  • Complaints will be managed in accordance with ASIC RG 271.
  • Customers must be informed of their right to escalate complaints to AFCA.

9. Training and Awareness

  • All staff will receive training on identifying and supporting vulnerable customers.
  • Refresher training will be provided annually.
  • Case studies and AFCA determinations will be reviewed to improve practice.

10. Monitoring and Reporting

  • We will track cases involving vulnerable customers and review outcomes regularly.
  • Internal audits will test compliance with this policy.
  • Breaches of this policy may lead to disciplinary action.

11. Governance

  • This policy is approved by the Board/Executive Management.
  • The Compliance Manager is responsible for implementation and oversight.
  • The policy will be reviewed annually, or sooner if required by changes in law or ASIC/AFCA guidance.

GT Industries (AUST) Pty Ltd T/A MoneyBuddy | ACN 682 877 701 | ACL 567039

Vulnerability and Treating Customers Fairly Policy | MoneyBuddy