NAB's Framework FOR CUSTOMERS EXPERIENCING VULNERABILITY - Support in moments that matter Inclusive banking services
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2019 – 2020 NAB’s Framework FOR CUSTOMERS EXPERIENCING VULNERABILITY Support in moments that matter Inclusive banking services
EXECUTIVE SPONSOR MESSAGE
As a major Australian bank, we take our responsibility to
society very seriously. We know we need to do, and be, better.
We want to support all our customers to thrive and to be all
that they can be. And we want to take significant steps to
support customers who are at greater risk of harm or loss due
to circumstances that may make them particularly vulnerable.
We understand that there are times when life can be
incredibly tough and that some of our customers face certain
challenges banking with us. We are working to put measures
in place to meet our customers’ needs, and support them in
the moments that matter.
NAB has a strong and proud history in supporting customers
and community during the hard times, such as our financial hardship assistance, domestic and
family violence support, and help in the aftermath of natural disasters. We know that when
you’re feeling exposed to risk or harm you don’t want to worry about your banking. That’s
why we seek to be more proactive, helpful and easier to work with to lighten the load.
The Customer Vulnerability Framework is a key step we’ve taken to better understand our
customers’ needs when they’re experiencing vulnerability. Importantly, it sets out a range of
initiatives that outline how we will create a more inclusive and simpler banking experience.
This marks the beginning of a journey for NAB as we continue to learn from our customers
and community on how we can better adapt to the needs of vulnerable customers. We look
forward to sharing more with you on the road to being a more inclusive bank.
Sharon Cook
Chief Legal and Commercial Counsel
NAB Customer Support team Discussing vulnerability can raise issues.
can provide assistance if you are If you need support the following is
experiencing vulnerability: available to you:
1300 308 175 Lifeline 1800 RESPECT
contact between the hours of - 13 11 14 or (family violence couselling)
8am to 5pm AEST Monday to Friday lifeline.org.au - 1800 737 732 or
respect.org.au
nab.com.au/customersupport
Beyond Blue
nab.com.au/wecare - 1300 22 4636 or National Debt Helpline
beyondblue.org.au - 1800 007 007 or
nab.com.au/endtoviolence
ndh.org.au
NAB’s Framework for Customers Experiencing Vulnerability 2
1. INTRODUCTION
At NAB we have begun to shine a light to better understand vulnerability, our customers’
needs and to better support our customers in the tough times, as well as the good.
Most people will experience vulnerability, in some form, during their lifetime. It is a personal
situation where people are exposed and susceptible to harm or loss. The devastating effects of
a drought, the challenge of living with a chronic illness, the difficulty of raising a family on a
low income – there are many situations that contribute to peoples’ experience of vulnerability.
NAB has an important role to play to
make banking more inclusive for all our
customers and to support customers
experiencing vulnerability in ways that
are proactive, helpful and makes it
easier for them.
This framework outlines our
understanding of customers
experiencing vulnerability and the
actions NAB will take to build on our
existing foundations to create greater
inclusion, more accessible services
and support customers in moments
that matter.
DEFINITION
NAB defines customer vulnerability as:
Vulnerability is a personal situation, where people are exposed and susceptible to harm or loss.
Everyone may experience being vulnerable in their life and its impacts can be experienced differently.
Customer vulnerability involves an inter-play of personal and environmental circumstances,
market practices and the actions of our organisation.
Customer vulnerability is a state and does not define a customer. Our research into customer case studies and complaints
has shown that customers experiencing vulnerability may have or be experiencing:
• Low financial literacy • Financial abuse • Elder abuse
• Age-related impairment • Natural disasters • Disability
• Mental illness • Serious illness • On low income
• Cognitive impairment • Lost a loved one • Low digital literacy
• Scams and fraud • Domestic and family violence • Live in a remote location
• Culturally and linguistically • An addiction or behavioural • Other circumstances causing
diverse backgrounds challenges significant detriment
NAB’s Framework for Customers Experiencing Vulnerability 3
2. BACKGROUND
Australian society is changing
Our population of about 25 The impacts of ageing, chronic Australians are overrepresented
million people is growing, illness and bereavement all among those targeted by financial
as well as ageing, and our contribute to potential vulnerability. scams and fraud.
There are also people in our
country is one of the most Our environment is also changing.
community with particular needs,
ethnically diverse in the Over the coming decades projected
including the one in five people
world, with more than 20% changes to our climate, anticipates
living with a disability (ABS, 2015);
of Australians speaking Australians will experience increased
one in six women and one in 16
a language other than frequency of severe weather
men who have been subjected
events, including prolonged
English (Australian Bureau to family and domestic violence
drought, extreme heatwaves,
of Statistics 2018). While (ABS 2017); and Australia’s first
floods and bushfires (Department
many Australians enjoy a people, Aboriginal and Torres Strait
of the Environment and Energy,
good standard of living and Islanders, who are overrepresented
2018). While all Australians will be
among these groups (ABS, 2014-15).
are living longer than ever impacted, vulnerable communities
before, half of us are living As a society we are becoming experiencing social exclusion and
with at least one chronic more aware of hidden problems disadvantage will experience the
condition1 which affects such as abuse of elderly people. It effects disproportionately to those
quality of life (Australian is estimated that one in six people with the financial, material and
over 60 years of age have been social resources to cope (National
Institute of Health and
subjected to financial abuse (World Climate Change Adaptation Research
Welfare, 2018).
Health Organisation 2015) and older Facility, 2017).
17 %
17 %
18.5 %
20 % 50%
of people over 60 of Australian women of Australians of Australian Adults of Australians are
have experienced have been subjected are living with have experienced living with at
financial abuse to family and a disability a mental health least one chronic
domestic violence condition within the condition affecting
last year quality of life
1 including cancer, cardiovascular disease, mental health conditions, arthritis, back pain, chronic pulmonary disease and diabetes. 23% of people
estimated to have two or more of these conditions.
NAB’s Framework for Customers Experiencing Vulnerability 42. BACKGROUND
Financial Resilience Anyone can experience vulnerability a vulnerability event, we seek to
and there may be a large portion understand longer term what is
Most Australians will experience
of our 9.4 million customers required to support customers’
some form of vulnerability in their
experiencing financial stress and recovery, assist prevention and
lifetime and its impact on financial
vulnerability. protection of customers and
health and wellbeing is evident.
preparedness for future events.
Recent research into Australians A proportion of Australian
We also seek to be more inclusive
levels of financial resilience tells consumers are excluded and
of customers experiencing ongoing
us that 66% of Australia’s adult underserved by the market. Often
vulnerability and find better ways to
population is experiencing through a lack of alternatives, they
meet their banking services needs.
some level of financial stress and turn to high cost short-term loans.
vulnerability. And of those, more
Building resilience and maintaining
than 2.1 million adults (11%) were
experiencing severe and high levels
financial health is a key feature 11%
of people experience
of sound social and economic
of financial vulnerability (Centre for severe and high levels
development. By not only supporting
Social Impact, Financial Resilience in
customers immediately following
Australia 2018).
31K
Financially
Excluded and
Underserved
Consumers
66%
of people experience financial
Australians supported
vulnerability and stress
with a no or low
interest loan in 2018 Source: Financial Resilience in Australia 2018
9.4M
18,315 66% NAB Customers
Customers in Customers
Financial Difficulty Potentionally Vulnerable
Customers assisted with may be experiencing some level of
financial hardship in 2018 financial stress and vulnerability at
any point in time.
Source: NAB Sustainability Report 2018 and Financial Resilience in Australia 2018
NAB’s Framework for Customers Experiencing Vulnerability 53. FRAMEWORK OBJECTIVE
Bank-wide Response
The objective of this framework
is to set out an appropriate
bank-wide response to be more
inclusive and better support
customers experiencing
vulnerability. By re-thinking the
customer experience across the
businesses value chain - how
we design products, sell and
communicate, service customers
and resolve issues – will enable us to
provide support to greater numbers
of vulnerable customers and to
better service their particular needs.
The purpose of this bank-wide
framework is to:
• build a deeper organisational
understanding of customer
vulnerability; NAB Customer Mrs Wilson with customer advisor Liam Woods
• take action to be more inclusive
and provide better support
experiencing vulnerability. This vulnerability. And also to New
for customers experiencing
framework aims to not only Zealand where like Australia,
vulnerability by understanding
uphold our Code obligations, change is currently underway.
their needs;
but exceed its requirements as We will continue to share our
• rebuild trust with customers by we seek to provide exceptional approach, learn from and be
delivering exceptional service; and service and support to customers guided by their endeavours.
• meet the requirements in the experiencing vulnerability.
As the initiatives in this framework
Banking Code of Practice 2019.
We have looked to the United are implemented, they will be
NAB is committed to the Banking Kingdom where during the last reviewed and refined based on
Code of Practice which sets a new four years the banking industry, our learnings. New initiatives will
standard for the banking industry driven by the Financial Conduct be developed, as required.
to be inclusive and accessible, and Authority, has lifted its support
take extra care with customers for customers experiencing
NAB takes extra care of customers experiencing vulnerability and has their interests at
heart. We want our customers to feel treated with sensitivity, respect and compassion for
their situation. Likewise, our employees are engaged, enabled and empowered to listen to,
support and guide customers experiencing vulnerability to assistance. Our employees feel
great pride in helping vulnerable customers, to support them to make a positive difference
to their lives.
NAB’s Framework for Customers Experiencing Vulnerability 64. UNDERSTANDING CUSTOMER VULNERABILITY
Deepening our organisational understanding of customers experiencing vulnerability
helps NAB to better address their needs, be more inclusive and provide support to our
customers, when they need it most.
It is common when thinking about resilience. We know that identifying • Just as our individual experiences
vulnerability to categorise people at risk customers and supporting are unique, so too is the
into groups and see vulnerability them early on, can help customers vulnerability experience. People
in terms of “us and them”. remain financially stable and get in different situations and with
However, vulnerability is more back on their feet sooner. different capacities, respond and
broad and complex and anyone cope in a range of ways.
We also recognise that people with
can experience vulnerability at any • Talking about personal
ongoing vulnerability require us to
time. Some circumstances result vulnerabilities takes courage
think differently and find ways to be
from unexpected life events, such and strength. Some peoples’
more inclusive. Features of customer
as serious illness or loss of income. vulnerability can make
vulnerability are that:
Others may experience vulnerability communication difficult, as well
in the longer-term, such as disability • Anyone can become vulnerable at
as people feeling shame and
or low income.2 any time, and it can be temporary,
embarrassment.
sporadic or permanent.
Vulnerable customers are going • The impact of vulnerability is
• It is complex as many people in
through tough times but may strong. People often can be trying
vulnerable situations don’t see
not see themselves as vulnerable. to cope with limited time, energy
themselves as vulnerable and
Different people experiencing and resources in a high stress
some people can have multiple
vulnerability have different capacities environment. Their thinking may
vulnerabilities.
and strategies to cope. Many people be impacted as their priorities
have great courage, strength and are elsewhere.
2 FCA, 2015, Occasional Paper No. 8, Consumer Vulnerability
NAB’s Framework for Customers Experiencing Vulnerability 75. KEY PRINCIPLES
Our Approach Showing Empathy and things happening. Hence, NAB
Understanding takes greater care to ensure we
NAB’s approach to supporting
are easy to deal with, we follow up
vulnerable customers is grounded Being authentic, having empathy
and follow through with promises
in four key principles for how we and understanding for vulnerable
made to vulnerable customers,
will think and act differently. These customers, demonstrates NAB’s
and we don’t make commitments
principles ensure the integrity of respect and care for people. Even
we can’t meet. By being open and
our strategy to achieve desired though it may not be possible to
honest, NAB will help vulnerable
objectives for both customers truly understand what another
customers reciprocate and disclose
experiencing vulnerability and NAB. person is going through, being
their situation. NAB’s relationship
heard makes people feel valued.
The Banking Code of Practice 2019 with vulnerable customers is two-
Empathy is different to sympathy,
provides ethical, customer-oriented way, as we respond appropriately to
which can come across as having
and sustainable standards of best their needs, find flexible solutions to
pity for someone else’s situation.
practice for Australia’s banks. help overcome barriers and deliver
Having empathy and compassion
We seek to exceed these standards exceptional customer service. We
means we feel for the person and
and aim to create exceptional also seek to find ways to be more
commit to taking action for them.
customer service and support inclusive and make it easier for
for our customers experiencing We acknowledge that many customers experiencing vulnerability
vulnerability. vulnerable customers have great to bank with us.
strength, courage and resilience.
Listen, Consider, Act for the Supporting customers experiencing
When we are sensitive and open
Customer vulnerability to help themselves
to understanding vulnerable
For NAB this means putting the customers, they are more likely to NAB cannot solve all vulnerable
customer at the heart of everything disclose their situation and trust us customers’ problems. However,
we do, especially keeping vulnerable to help. Ultimately, we aim to treat as a financial service provider we
customers front of mind. By listening vulnerable customers, as we would have an important role to play in
to our customers story and ‘walking want to be treated ourselves if we supporting customers experiencing
in their shoes’ we can better design were in their situation. We recognise vulnerability. NAB can help make
for vulnerable customers’ needs vulnerability doesn’t just affect our a positive difference to customers
right from the outset, and consider customers, it impacts our employees experiencing vulnerability by being
the real impacts to customers of as well. Support for employees sensitive and having compassion for
changes to products and services interacting with vulnerable their situation; by looking out for red
before they occur. When we fully customers or experiencing flags and noticing when something
consider customers, we look at what vulnerability themselves is doesn’t seem right; by being
is the right thing to do for them, important. understanding and taking action
not only what is required by law. to provide support; and guiding
Lasting banking relationship
Taking action to provide support vulnerable customers towards other
for our most vulnerable customers Building lasting banking sources of support.
will lift our performance to deliver relationships requires trust. NAB
exceptional service for all customers. wants to be there for customers
when life is challenging, as well as
Acting with Honesty,
when things are going well. When a Integrity and Fairness
person has experienced significant to all customers is
detriment or disadvantage, they central to NAB’s Code
are naturally fearful of further bad of Conduct.
NAB’s Framework for Customers Experiencing Vulnerability 86. VULNERABLE CUSTOMERS’ NEEDS
Recent research has found the highest community expectations of financial
service providers are: listens to the needs of the customer and responds (70%);
have ethical business practices (67%); and places customers ahead of profits (66%)
(Edelman, 2018 Australia Trust Barometer)
An analysis of NAB vulnerable Bank to respond flexibly to their Genuinely caring and acting in their
customer case studies looked at needs best interest
stories of exceptional customer
Vulnerable customers need: Vulnerable customers need:
service and where we could have
done better. It found that the bank • the bank to be responsive and • sensitivity when disclosing their
is mostly reactive when there are actively looking for ways to situation and being confident the
issues or problems for customers provide support. bank will support their interests.
experiencing vulnerability and • a response that is tailored to their • their information to be protected
there has been a lack of clarity needs. and held sensitively when
around what we can do. With • to be supported by the right area recorded.
changing customer and community of the bank, especially customers • the bank to be proactive in making
expectations of banks, we aim to with specific needs. contact if it suspects they are
become more proactive, helpful and • to discuss a range of options to having financial difficulty.
easy to deal with. enable them to help themselves • the bank to be proactive in
Customer vulnerability is complex. and feel in control. noticing red flags, such as of
However, the analysis of vulnerable • to have their situation considered financial abuse, problematic debt,
customer case studies showed there earlier in the design and scams and fraud and reaching out
were common needs across different development phase of products to the customer.
customers’ situations, these being: and services. • the bank to make it easier for
them when recently bereaved,
Clear, easy and empathetic
separating from a partner,
communication
diagnosed with serious illness or
Vulnerable customers need: having power of attorney.
• to be heard and feel they have
been genuinely listened to and
understood.
• simple, easy to understand
information without any hidden
surprises in the fine print.
• a range of ways to communicate,
which is most helpful to them,
especially customers with specific
needs.
NAB’s Framework for Customers Experiencing Vulnerability 9Current Support Available This extensive support assists
many customers experiencing
NAB has a wide range of support
vulnerability. We have identified
initiatives currently available to
four areas of focus to build on
customers (see section 9 for more
these foundations and provide
details), including:
greater support and inclusion
• Hardship assistance and to lift our understanding of
• Our Customer care team vulnerable customers’ needs.
• Customer feedback, complaint
resolution and remediation
• Support for those on low incomes
building financial inclusion and
resilience
• Domestic and family violence
support
• Natural disaster and crisis response
• Rural and Regional Australia
strategy
• Indigenous Australian prosperity
• Accessibility action plan
• A fee-free transaction account.
NAB’s Framework for Customers Experiencing Vulnerability 107. FOCUS AREAS FOR SUPPORT
Older Customers affordable credit. The way our scams and fraud can happen to
customers are banking is changing anyone. However, analysis of our
Inclusive and accessible banking
and increasingly they are using customers shows older customers
services and reducing susceptibility
digital options, such as transacting are at significantly greater risk of
to elder abuse, scams and fraud.
online and using the NAB Mobile scams and fraud that are increasingly
We are committed to being there App. We continue to invest in sophisticated. We seek to be
for our customers in all of life’s smartATMs, and face-to-face proactive in helping reduce older
moments. We understand that banking in branches and Australia customers susceptibility and support
older customers can have different Post outlets. We also seek to lift the them when they have been a victim
banking needs, whether it’s planning digital inclusion of older customers of crime.
for retirement, downsizing from and help improve their digital
the family home, setting up term skills and confidence in banking
deposits or seeking access to via the internet. Financial abuse,
Initiative Responsible Performance Indicator Timeline
1. Improve inclusive and accessible banking by reviewing EGM Banking Review conducted. October 2020
guidance on access and availability of credit to older Products
Customer communication
customers. If appropriate, provide information on safe Consumer
process in place.
alternative forms of credit available. Lending
2. Build inclusion of older customers through better EGM Deposits Product reviews conducted. March 2020
understanding their needs and the proactive & Transaction
Promotion of relevant products
promotion of NAB products and services of relevance Services
to meet older customer needs.
to older customers, such as NAB’s Retirement Account
and NAB’s fee-free everyday personal transaction
account.
3. S upport older customers to build digital literacy and EGM Retail Digital learning sessions March 2020
confidence to ensure safe access to banking services, conducted in relevant locations.
initially focussing in communities where NAB has
Evaluation survey conducted to
identified a need.
measure customer outcomes.
4. L ift security awareness and build confidence of older Chief Enterprise Deliver external awareness
Australians to help protect customers from Elder Security Officer campaign in partnership.
financial abuse, scams and fraud. Enable frontline
Enable and support frontline to
bankers to recognise potential financial abuse and
recognise red flags.
initiate confidential discussion with customer. Work in
partnership with community organisations to provide Capture prevention data. October 2019
external resources and support.
NAB’s Framework for Customers Experiencing Vulnerability 117. OUR FOCUS AREAS FOR SUPPORT
Making It Easy talk about vulnerability experiences of attorney, have an addiction or
and we understand that different problematic debt from gambling.
For customers experiencing
people need different support. We Customers can talk to us about their
vulnerability to be supported and
are working to make it easier for situation and while protecting their
to help us meet their needs.
customers such as those who are privacy, help us to better support
Anyone can become vulnerable bereaved, diagnosed with serious them.
and it can be sporadic, temporary illness, experiencing family and
or permanent. It can be difficult to domestic violence, holding power
Initiative Responsible Performance Indicator Timeline
5. E
nable and empower front-line bankers and create a EGM Business Customer support team June 2019
specialist vulnerability team to provide tailored support, and Consumer established.
as well as referrals to community support partners, as Operations
Community support partners
required.
in place and customer referrals
made.
6. Improve bereavement notification process for customer EGM Business Information available to
representatives by providing clear and accessible and Consumer customer representatives.
information, treating them with sensitivity, enabling Operations
Employee training completed.
one notification across all of NAB, and ensuring
deceased customers are not charged fees. Fees not charged. June 2019
One notification process October 2020
implemented.
7. S upport customers seeking help with problematic GM Customer Visa card block available and June 2019
gambling by restricting gambling on their Visa debit Assist customers aware.
and credit cards at their request and referring them to
Partnership with support October 2019
Gambler’s Help services.
services in place and customer
referrals made.
8. E
nsure customers holding a government concession EGM Deposits Process in place for customers
card are aware of our affordable everyday no fee basic & Transaction applying for new transaction
transaction account. We do not charge dishonour fees Services account.
on basic accounts. If you are a government concession
Process in place to identify
card holder, we will not allow informal overdrafts on
customers with government
your basic account.
concession cards and remove
informal overdrafts.
Front-line aware of new process. March 2020
9. M
ake it easier for customers to be supported by a GM Customer Banker guidance developed and
third party with clearer guidance for bankers assisting Assist rolled out.
customers with a Power of Attorney, Letter of Authority,
Customer experience feedback March 2020
Guardianship order or Administration Order. We will
gathered.
review and provide ways for customers with limited
English to access and undertake their banking.
10. To enable employees to provide appropriate support, GM Customer Specialist team process June 2019
with a customer’s explicit permission and with respect Assist developed.
for customer confidentiality, we will record a customer’s
vulnerability and their support need. In particular,
we will capture a need for third party support, if the
customer’s primary language spoken is other than
English and the needs of customers with a disability
NAB’s Framework for Customers Experiencing Vulnerability 127. OUR FOCUS AREAS FOR SUPPORT
Universal Design, Service of all people, as much as possible banking tools and features in mobile
And Change when designing products, reviewing apps, we are working to ensure that
how we service our customers and no one is discriminated against or
Keeping vulnerable customers at considering impacts on customers less able to access banking products
the heart of product design, service experiencing vulnerability as we and services.
and change processes. make changes. With advances
We recognise that vulnerability can in technology providing new
be experienced by any customer, at opportunities to offer customers
any time. We seek to create access, greater options to access, control
understand and consider the needs and manage their finances via online
Initiative Responsible Performance Indicator Timeline
11. Promote fair and inclusive banking by creating a EGM Deposits Document available in branch March 2020
visual easy read document for NAB’s fee-free everyday & Transaction and online
personal transaction account and information on how Services
to use it.
12. Provide guidance to product owners and change GM Business Develop guidelines on October 2020
makers to consider customer vulnerability and Enablement vulnerability and accessibility
accessibility needs and universal design principles. Customer needs and universal design
Raise vulnerable customer pain points and events for Experience principles.
consideration and action.
GM Customer Pain points considered by July 2019
Experience Customer Experience LT.
13. Review policies considering vulnerable customer EGM Banking Policy review conducted
needs for separation of joint loans, joint accounts and Products
Clear processes developed and October 2019
treatment of Guarantors. Develop clear processes for Consumer
in place
bankers to support customers. Lending
14. H
elp customers avoid or manage problematic credit EGM Banking Customers contacted and October 2019
card debt, by proactively contacting customers to Products process to send communications
prevent at risk customers from entering problematic Consumer established.
debt and sending targeted communications to help Lending
Product selector tool and March 2020
customers out of problematic debt. Proactively
information available to
communicate with customers who are transferring
customers.
a credit card balance to encourage them to reduce
balance and debt, and to create fairer outcomes.
Uplift tools to support customers in selecting the
right product and improve education to encourage
financial health and responsibility.
NAB’s Framework for Customers Experiencing Vulnerability 137. OUR FOCUS AREAS FOR SUPPORT
Building Our Capability As we build our organisational information, tools and resources
understanding of vulnerability and they need, as well as empower
Employee training and support to
further understand the needs of our staff to use their emotional
enable and empower support for
vulnerable customers, we must intelligence and be guided by
vulnerable customers.
also work to ensure our people NAB’s values to support vulnerable
have access to support too. We customers.
aim to enable employees with the
Initiative Responsible Performance Indicator Timeline
15. R
aise awareness of all employees to treat customers GM Social Impact Training provided to all July 2019
experiencing vulnerability with sensitivity, respect Australian employees and
and compassion. Provide training so employees can additional training to front line
identify different vulnerabilities and know how to staff.
support customers.
16. Create information hub for employees to access up-to- GM Social Impact Information developed and July 2019
date information on intranet on vulnerability and how accessible to all employees
to support vulnerable customers.
17. Provide continual learning to build capability of GM Customer Training provided to all specialist October 2019
specialist teams engaging with vulnerable customers Assist teams.
to respond sensitively and with empathy. Ensure teams
Information and work
are enabled to proactively assist and resolve issues as
instructions available to teams.
soon as possible.
18. Ensure support is available for employees who are EGM Support in place and employees October 2019
working with customers experiencing vulnerability. Performance and aware.
Reward
NAB’s Framework for Customers Experiencing Vulnerability 148. GOVERNANCE AND ACCOUNTABILITY
This Framework sets out initiatives to be implemented during financial years 2019 and
2020 and supports NAB’s compliance with the Banking Code of Practice 2019. Sharon Cook,
Member of the Executive Leadership Team and Chief Legal and Commercial Counsel is
accountable for its overall implementation, with clear lines of responsibility for each initiative
given to Executive General Managers (EGM) and General Managers (GM).
Ongoing guidance and oversight of streams. This group will provide
the framework will be maintained attestation for NAB’s compliance
by NAB’s Social Impact governance with the Banking Code of Practice
group who will guide NAB, raise and will monitor and report
horizon issues and maintain on progress to NAB’s Executive
accountability. Customer Committee and the Board
Customer Committee. The group
Implementation of the Framework
will seek external advice, conduct
will be driven by the already formed
vulnerable customer testing and
Customer Vulnerability Steering
audits to determine Banking Code
Group of senior leaders, together
compliance.
with the four focus area work
NAB’s Framework for Customers Experiencing Vulnerability 159. CURRENT SUPPORT AVAILABLE
Hardship assistance Care team straight away. We know Support for those on low incomes
it could be any number of factors building financial inclusion and
When life throws curveballs, it can
making repayments hard, so the resilience
be hard for customers to keep on
team has developed the Customer
top of their loan and credit card Our goal is to assist Australians
Care Kit, to help customers connect
repayments, leases or business in building financial resilience –
with organisations ready to help
loans. We encourage customers with making it easier to bounce back
out – free of charge (nab.com.au/
money worries to get in touch with from financial shocks. This includes
wecare).
NAB Assist right away. NAB Assist supporting those that don’t have
looks at every situation differently Customer feedback, complaint access to credit or banking, which
and helps to find the best way to resolution and remediation can put them at risk of long term
get customers back on their feet. It financial hardship. Since 2003, we’ve
We’re always trying to improve our
may mean temporarily changing the been working with Good Shepherd
customers’ banking experience,
size and frequency of repayments Microfinance and Federal and State
but we know things don’t always
or deferring the next repayment to governments to provide access to
go the way they should. Customers
provide some breathing space. NAB the No Interest Loan Scheme (NILS),
can raise an issue with us, find out
at Work is a new initiative to address StepUP, Good Money stores, and
how it will be resolved and what
unemployment a major cause Speckle a fast online cash loan.
to do if they’re still not satisfied.
of financial distress. Depending Together we have provided over
Feedback can be provided online, in
upon the level of job readiness, 200,000 no and low interest loans
branch or by calling 13 22 65. NAB
participants receive guidance and to Australians living on low incomes
Resolve seeks to create a greater
tools, such as an employment coach, since 2005.
customer experience through the
access to financial counsellors and
Easy Resolution model. By engaging,
other support networks. Customers
empathising, understanding and
who need help with their finances
fixing or escalating, NAB Resolve is
can visit a branch or call NAB Assist
making a difference through their
on 1800 701 599 (8am-8pm Mon-
honest, helpful and transparent
Fri, or 9am-1pm on Saturdays AEST/
manner. With the issues revealed
AEDT). For help with business
and explored by the Royal
lending contact 1300 961 577.
Commission, NAB established the
Our Customer Care team Customer Remediation Centre to
ensure impacted customers are
NAB Assist’s Customer Care team
compensated more quickly. This
has helped many customers through
team is working to resolve known
financial hardship. If a customer’s
issues, including the customer
situation requires extra assistance,
response initiative from our
this is available from our Customer
Wealth business.
NAB’s Framework for Customers Experiencing Vulnerability 169. CURRENT SUPPORT AVAILABLE
Domestic and family violence Natural disaster and crisis response Rural and Regional Australia
support strategy
NAB supports our customers and
NAB provides a range of support to communities both in the immediate NAB committed to keeping branches
customers experiencing domestic aftermath of a natural disaster and in regional and rural Australia open
and family violence. NAB Assist can on the road to recovery. Customers until at least January 2021. Four
provide a referral for customers impacted by extreme weather customer contact centres are to open
needing wholistic support to events, flood and drought and other in Toowoomba, Tamworth, Bendigo
CareRing. NAB joined Kildonan’s natural disasters such as earthquakes and Bunbury to service regional,
CareRing program to provide and bushfires are supported by agribusiness and small business
customers access and referrals relieving financial stress with customers. NAB’s Drought Assistance
to support services, including our financial relief package and Package is available to support
counselling, support from social supporting communities with customer during prolonged drought
workers, financial counselling, grants, fundraising appeals and conditions and we are no longer
referral to emergency housing, volunteering. charging higher default interest rates
working with families and men’s to Agribusiness customers affected
In March 2019, NAB made significant
behavioural change programs. NAB by drought who are in hardship
additional commitments to provide
was the first Australian bank to make and behind on their repayments.
further support for flood-stricken
the Domestic and Family Violence NAB is also supporting Agribusiness
farmers in Queensland, including
Assistance Grant available to customers in rural and regional
the deferral of interest and
customers who don’t have access or Australia, to receive the financial
repayments, for up to three years.
limited access to alternative funding benefit of being able to offset their
In addition, NAB offers up to $500m
options that will enable them to Farm Management Deposit (FMD)
in concessional loans at a reduced
leave the situation. The grant is for against their agricultural lending
rate, to support our flood-affected
current NAB customers who have in the form of a discount to their
customers in North Queensland
held an account for a reasonable lending interest rate.
to assist with repairs, restocking
period of time. It has an upper limit
and re-opening for business. The
of $2,500 and is at NAB’s discretion.
concessional loans are available to
NAB customers in flood impacted
areas across North Queensland on
a case by case basis.
NAB’s Framework for Customers Experiencing Vulnerability 179. CURRENT SUPPORT AVAILABLE
Indigenous Australian prosperity
NAB is proud to support the success
of Aboriginal and Torres Strait
Islander people, businesses and
communities. In 2008, we launched
our first Reconciliation Action Plan
(RAP) and since then we’ve been
working with Indigenous Australians
to help improve financial resilience,
increase business and employment
opportunities, and develop NAB’s
cultural capabilities. We supported
more than 16,000 Indigenous
Australians access more than
$15 million in fair and affordable
microfinance between 2015-2017.
To better support our Aboriginal
and Torres Strait Islander customers, environment for our people. Our Account, all of our customers have
we accept alternative forms of first Accessibility Action Plan was easy access to their money, with no
identification for customers from launched in 1997 and our 2019-2010 monthly account fee, no minimum
remote Indigenous communities, plan continues this commitment. monthly deposits, no overdrawn
in the form of selected community At its heart are actions to listen fees, and no ATM withdrawal fees at
identification cards, or letters from and respond to customers, and over 7,000 ATMs across Australia.
referees. We are also supporting support our people by providing
Industry involvement and
Indigenous customers to access a great place to work. To achieve
publications
fee-free ATMs in a range of remote this we’ve focused on inclusive and
communities. NAB has created a universal design when developing NAB is an active participant in
dedicated customer service line, to products and services; embedding forums to discuss and identify
better support access for Indigenous an inclusive culture through the support for vulnerable customers,
Australians, particularly those who stories we tell and recognising our including a number of Australian
live in remote parts of Australia. diverse workforce and community; Banking Association roundtables
To access this support line, listening to our customers and and the Thriving Communities
customers may call the Indigenous acting on feedback; and increasing Partnership.
Customer Service Line directly the disability confidence of our
NAB engages with the For Purpose
on 1800 966 100. people to create an environment
sector and community organisations
that anticipates, and seamlessly
Accessibility Action and has a Financial Inclusion
accommodates, diversity.
Action Plan, Accessibility Action
There are more than 4 million
A fee-free transaction account Plan, Reconciliation Action Plan
Australians living with disability, and
and Financial Resilience Report
so it is important that we design Access to a transaction account
which provide further details of our
our products and services with enables people to store money
support and are available at
accessibility in mind. A culture of and send and receive payments
nab.com.au/socialimpact
accessible products and services electronically. It is the most basic
is central to great customer requirement for financial inclusion.
experiences and a positive working With the NAB Classic Banking
NAB’s Framework for Customers Experiencing Vulnerability 1810. REFERENCES
Australian Banking Association (ABA), August 2018, Banking Code of Practice Contact us
Australian Banking Association (ABA), June 2013, Industry guideline - Protecting We value feedback from our
vulnerable customers from potential financial abuse customers, people and community.
BBA, February 2016, Improving outcomes for customers in vulnerable circumstances You can get in touch or find out
more:
Centre for Social Impact, 2018, Financial Resilience in Australia 2018
Email: social.impact@nab.com.au
Financial Conduct Authority UK (FCA), February 2015, Occasional Paper No. 8
Consumer Vulnerability Call: 13 22 65 Mon-Fri
Financial Ombudsman Service Australia (FOS), November 2017, The FOS Approach 8am - 7pm (AEST/ADST)
to financial elder abuse
Web: nab.com.au/socialimpact
Alternative formats of this document
are available upon request.
© 2019 National Australia Bank Limited ABN 12 004 044 937 AFSL and Australian Credit Licence 230686. A150294-0619
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