Vulnerability and Treating Customers Fairly Policy

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.

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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
  

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• 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.
  

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• 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).
  

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• 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.
  

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• 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.
  

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