Westpac Group Complaint Management Policy - WBC.107.002.0937 - Royal Commission
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WBC.107.002.0937 Westpac Group Complaint Management Policy Version 6.0 Approved 30 June 2016 Owner Group Head of Customer Experience Contact Group Customer Experience
WBC.107.002.0938 Contents PART 1 - Introduction 1. Overview ......................................................................................................................................... 3 2. Scope .............................................................................................................................................. 5 3. Internal Dispute Resolution ............................................................................................................. 7 4. External Dispute Resolution ............................................................................................................ 8 PART 2 - Complaint Management 5. Receiving a Complaint .................................................................................................................... 8 6. Initial Complaint handling steps ...................................................................................................... 9 7. Risk assessment and assigning priority ........................................................................................ 12 8. Acknowledging a Complaint .......................................................................................................... 12 9. Investigating a Complaint .............................................................................................................. 13 10. Complaint resolution ..................................................................................................................... 13 11. Complaint resolution timeframes .................................................................................................. 14 12. Closing a Complaint ...................................................................................................................... 16 13. Summary of Westpac Group’s Complaint management model .................................................... 17 PART 3 - Complaint Recording and Monitoring 14. Complaint recording ...................................................................................................................... 17 15. Complaint monitoring .................................................................................................................... 18 PART 4 - Other Information 16. Confidentiality ................................................................................................................................ 20 17. Resources and support ................................................................................................................. 20 18. Record keeping ............................................................................................................................. 21 19. Roles and responsibilities ............................................................................................................. 21 20. Policy governance ......................................................................................................................... 24 21. Consequences of non-compliance with this Policy ....................................................................... 24 22. Policy implementation ................................................................................................................... 24 23. More information ........................................................................................................................... 25 24. Definitions...................................................................................................................................... 25 25. Document version control ............................................................................................................. 26 Appendix A – Maximum complaint resolution timeframes (Australia)................................................... 27 2
WBC.107.002.0939
Part 1 - Introduction
Our Vision is to be one of the world's great service companies, helping our customers,
communities and people to prosper and grow.
Service leadership is central to our Group strategy and realising our Vision. Providing a
superior customer experience for each customer, every time, requires us to listen, learn and
act promptly when things go wrong or customers express dissatisfaction.
We have an established and comprehensive complaint management framework of which this
Complaint Management Policy (Policy) is the cornerstone. It sets out the minimum standards
for handling customer complaints and is supported by Business Unit procedures.
Collectively, our complaints management framework helps to ensure that the complaints we
receive are dealt with genuinely, promptly, fairly and consistently.
1. Overview
Recognising our vision and Our Service Promise, we encourage our customers to tell us if
they are dissatisfied with any aspect of their experience.
We encourage our people to respond to complaints genuinely and authentically and
empower them to act in ways that foster deep and enduring customer relationships.
We also recognise that, properly handled and analysed, complaints help Westpac Group
innovate and improve in ways that make things simpler, easier and better for our customers.
1.1 Guiding principles
This Policy is based on the international and Australian standards for customer satisfaction
and complaints handling (ISO 10002:2014 and AS/ISO 10002:2006) and reflects the
commitments in Our Service Promise.
The basic complaint management principles that Westpac Group employees are expected to
meet ensure our customers’ concerns are handled confidentially, respectfully and with
careful consideration and professionalism. Our principles, in summary, are:
3WBC.107.002.0940
Fairness
Responsiveness Accountability
Complaint
Continual
Accessibility Management Improvement
Principles
Confidentiality Visibility
Objectivity
1.2 Policy objectives
The Policy objectives are as follows:
• Establish clear rules for consistent complaint management across the Group in
accordance with Our Service Promise and Australian and international standards.
• Provide customers with a free, accessible and simple means of raising and dealing
with their complaints.
• Create a customer-focused complaints approach and encourage our people to
continuously improve the customer experience and deliver service leadership.
• Promote a positive complaints culture.
• Encourage senior management commitment through the provision of adequate
resources and employee training.
• Identify and address systemic risks.
• Identify trends and eliminate root causes of complaints.
• Ideally provide customers with agreed solutions, however where an external body
imposes a solution, ensure this is implemented in accordance with the
requirement/obligation.
• Promote continual improvement of Westpac Group’s complaint handling processes.
• Comply with all relevant laws, regulations and industry codes of practice.
4WBC.107.002.0941
2. Scope
2.1 Who does this policy apply to?
The Policy applies to all Westpac Group employees, including but not limited to directors,
managers, contractors, authorised representatives, product distributors and consultants in
all Westpac Group businesses and subsidiaries globally. It also applies to employees of
suppliers providing outsourced complaint handling services to Westpac Group.
Divisional and Business Unit requirements
Divisions and Business Units may supplement this policy with their own requirements
without reducing Employees’ obligations under this Policy.
Employees located in Australia should confirm any additional divisional or Business Unit
requirements that apply in addition to this Policy.
Locations outside Australia
Locations outside Australia may document their own complaints management requirements,
incorporating local regulatory obligations and with reference to relevant divisional and
Business Unit requirements, where appropriate. Locational policies cannot reduce
Employees’ obligations under this policy.
Employees located outside Australia should refer to their Location-specific policy in addition
to this Policy.
2.2 What is a Complaint?
Westpac Group adopts its definition of Complaint from the Australian and international
standards.
A complaint is an expression of dissatisfaction made to Westpac Group
related to its products or services, or the complaints handling process itself,
where a response or resolution is explicitly or implicitly expected.
While it is usually easy to recognise a complaint, note that:
• The customer does not have to say “I want to make a complaint” – we look and listen
for relevant cues.
• Even if a complaint is resolved on the spot, it still falls within the above definition.
• If a customer merely expresses an opinion or makes a general comment about a
product or service, and it is plain that they do not seek a response or resolution from
Westpac Group, that opinion or comment is not a complaint.
• A customer query or request for assistance without an expression of dissatisfaction is
not a complaint covered by this Policy, but is still addressed with due care and
5WBC.107.002.0942
concern.
2.3 What Complaints does this Policy apply to?
The Policy applies to all complaints received by Westpac Group, including any outsourced
supplier of complaint handling services to Westpac Group, except for the categories of
complaints listed below.
Complaints may be received from customers, investors, and others who interact with
Westpac Group (e.g. consumer interest groups and community organisations).
For simplicity, in this Policy we refer to any complainant as a Customer.
The Policy does not apply to the following complaints:
• Complaints commenced via litigation. Employees receiving Letters of Demand,
Statements of Claim or similar legal documents must immediately contact Legal
and/or Specialised Compliance.
• Complaints referred to Westpac Group via any regulator (e.g. the Australian
Securities and Investments Commission or Australian Prudential Regulation
Authority) or quasi-regulatory bodies (e.g. Code Compliance Monitoring Committee),
who will typically have specific requirements for responding to complaints. However,
Business Units may adopt relevant principles from this Policy where they do not
conflict with the regulator’s requirements.
• Complaints about criminal conduct. These should be immediately forwarded to
your Manager and Specialised Compliance, who will advise if Group Protective
Services should be engaged.
• Employee complaints and/or employment disputes about work, working
conditions or conditions of service (i.e. employee grievances). These should be
forwarded to the Human Resources manager that supports your Business Unit.
• Whistleblower complaints including complaints submitted via Concern Online (refer
to the Whistleblower Protection Policy).
2.4 Business Unit procedures
Business Unit procedures must align with this Policy and must provide all employees within
that Business Unit with sufficient information to enable them to understand and perform
their complaint management obligations.
In documenting their own procedures to support this Policy, Business Units should ensure
these contain clearly defined roles and responsibilities, and should consider:
6WBC.107.002.0943
• the size and complexity of their business, including the range of products and services
and the nature of the customer base;
• how customers are made aware of and assisted to use the complaints handling
process;
• how senior management and relevant stakeholders or support teams are promptly
notified of any significant complaints or associated risks;
• how complaint process changes are managed, including employee communication and
training; and
• how processes are monitored to ensure they are operating effectively and efficiently
and continue to meet the requirements of this Policy.
2.5 Policy exceptions
Exceptions to this Policy may be required where there are unique characteristics or legal
requirements facing individual Westpac Group subsidiaries, Business Units or Locations.
The Group Head of Customer Experience must be consulted and any exceptions approved
prior to implementation. There is no prescribed format for requesting exceptions however
they need to be in writing (including risk assessment and Specialised Compliance review,
and approved and signed off by the relevant General Manager).
The Group Customer Experience Team will maintain a register of approved and declined
exceptions.
Westpac New Zealand
Westpac New Zealand Limited (WNZL) is required to implement the Policy having regard to
the conditions of registration imposed on it by the Reserve Bank of New Zealand and New
Zealand legislative requirements. Wherever possible, WNZL processes should otherwise
align with the Policy.
3. Internal Dispute Resolution
Having effective Internal Dispute Resolution (IDR) procedures increases the likelihood that
we successfully resolve complaints promptly, and to the satisfaction of our customers,
without the intervention of an External Dispute Resolution (EDR) scheme.
All employees who deal with customers, not just our complaints handling employees, need
to have an understanding of our IDR procedures as set out in this Policy and in their separate
Business Unit process documents.
We need to ensure that customers know about the existence of our IDR procedures and how
to make a complaint. Common examples of how we inform customers include but are not
limited to, marketing and product disclosures, account statements, policy documents,
customer letters and electronic based information via Westpac Group websites.
7WBC.107.002.0944
The appropriate method for Business Units to adopt to inform customers of their IDR
procedures and how to make a complaint should be based on the nature, scale and
complexity of their business.
This Policy is primarily concerned with Westpac Group’s IDR procedures, but it also
discusses the linkage between IDR and EDR.
4. External Dispute Resolution
4.1 Membership of EDR scheme
Depending on the Business Unit’s licence arrangements and business activities it may need
to be a member of a regulator-approved EDR scheme. For example, Westpac and a number of
its subsidiaries are members of the Financial Ombudsman Service in Australia.
4.2 Advising customers of relevant EDR scheme
Westpac Group businesses that are a member of an EDR scheme must provide details about
how its customers can access the EDR scheme. There are also requirements to include EDR
information in certain documents such as Financial Services Guides and Credit Guides.
Business Units must maintain effective processes and controls to ensure customers are
advised of the relevant EDR scheme where applicable.
Part 2 – Complaint Management
This section outlines the requirements at each stage of the complaint process.
Complaint Initial Assess & Acknow-
Investigate Resolve Close
received handling Assign ledge
5. Receiving a Complaint
It is important that our customers feel comfortable about making complaints and can do so
easily. Business Units must offer flexible, convenient and accessible methods for our
customers to lodge complaints. Complaint methods may include, but are not limited to, a
combination of:
• Verbal complaints. These can be made in person or via the phone.
8WBC.107.002.0945
• Written complaints. These can be sent to a branch, Business Unit or other area of
Westpac Group by post, fax or email. Complaints may also be forwarded from the
Financial Ombudsman Service or equivalent body.
• Website complaints. These can be entered on various Westpac Group internet sites.
• Social media complaints. Complaints can be received through social media, such as
Facebook or Twitter.
All complaints must be managed in line with this Policy regardless of the channel received;
no channel is more important than any other.
6. Initial Complaint handling steps
The first point of contact is often the most critical. We have an opportunity to demonstrate
that we are ready, willing and able to help our customers at the very start – doing this well
can set the scene for a better customer experience and outcome. There are three
components that will help, and can be used in the order most appropriate to the situation:
Examples
Appreciation
‘I’m grateful/pleased…’
The customer has chosen to tell us about
their issue so we can fix the situation and ‘I appreciate…’
learn from it instead of having the customer
‘It’s good that you’ve raised this’
leave Westpac or tell their friends and family;
so acknowledge this upfront.
Action
‘I will fix/change/update/correct this’
The customer is lodging their complaint
because they want action from us. Articulate If you need to investigate or influence the
exactly what you are going to do to resolve outcome then, for example, say: ‘Let me
the matter. If this is within your control state check’, ‘Let me look into’, ‘I’ll investigate…’
this.
‘I will call back at 4pm’, ‘you will receive a
It is important to explain what will happen letter confirming’, ‘your account will be
next. updated by’, etc.
Empathy
‘I regret…’
Apologising for a matter is encouraged when
we are responsible for the error (see section ‘I’m disappointed…’
10.1).
‘I’m concerned…’
Other ways of demonstrating empathy are
by acknowledging what you can see, hear or
appreciate in relation to the customer’s
situation.
During the initial point of contact, and at all other times, employees are expected
demonstrate the Service Behaviours that form part of Our Service Promise.
9WBC.107.002.0946
6.1 Take ownership
We approach a complaint with curiosity and perseverance to truly understand and resolve
the customer’s concern. Complaints are always handled with integrity, a commitment to
doing the right thing and delivering on our promises.
We expect employees to exercise ownership of complaints. Employees should not blame
other employees or Business Units or use them as an excuse.
Taking ownership means employees are responsible for finding the correct person to handle
the complaint, even if the complaint did not originate in their Business Unit or within their
area of expertise. All employees and Business Units receiving complaints must take
ownership until they have either resolved the complaint or handed it over to someone who
can manage or resolve it better than them. Employees must ensure customers are kept
informed of the status of complaint resolution.
6.2 Get the facts
Employees must ensure they understand the customer’s issue(s). We should aim to
anticipate and respond to customers’ needs, including unexpressed needs, but be careful not
to guess or attempt to fill in gaps. Items to consider include:
What is the issue? Paraphrase the customer’s issue to confirm mutual
understanding.
What resolution are they Clarify this with the customer as often this is the key to
seeking? understanding their concern.
Write it down if necessary Asking the customer to write down the issue(s) can be
useful, particularly where multiple dates and various
people are involved.
6.3 Dealing with unreasonable behaviour
It is important to remember that, even where a customer’s conduct may appear
unreasonable, they may have a valid complaint and that complaint must always be handled
appropriately and be investigated as fully as possible.
In very rare circumstances, a customer may exhibit behaviour that makes it unreasonable for
our people to continue providing IDR services. It is important that we identify any such
behaviour so that we can appropriately support our people and continue to manage dealings
with these customers according to our values. Suspending IDR services is a serious step to
take and Business Units must determine the appropriate managerial level required to
approve IDR services being suspended. We categorise unreasonable behaviour into two
10WBC.107.002.0947
broad categories:
Aggressive complaints • Aggressive behaviour is any behaviour which attempts to
dominate or threaten another. It may include shouting,
verbal abuse, threats or other forms of harassment
through to physical violence.
• Note: The safety and wellbeing of our people is
paramount. Business Unit procedures should be followed
for dealing with aggressive customers.
Habitual complaints These are complaints which:
• have been made by a complainant who frequently or
obsessively lodges complaints with Westpac that (after
proper investigation and consideration) have on all prior
occasions been shown to be entirely unfounded, and
where it is clear that the new complaint is equally
unfounded; or
• relate to an issue that has already been fully addressed,
and finally and definitively resolved, in accordance with
all applicable internal and/or external dispute resolution
processes.
Before suspending IDR services to a customer, the following must be satisfied:
• The Business Unit’s complaint procedure must have been correctly implemented
and no material element of the complaint overlooked or inadequately addressed.
This includes the final outcome of the complaint (and details of our EDR scheme,
where appropriate) being communicated to the customer as outlined in section 11.3.
• For IDR services to be suspended before a final outcome is reached, the behaviour of
the complainant must have become so habitual, obsessive, vexatious, aggressive or
intimidating that it is unreasonable to continue. IDR services are to be reinstated as
soon as it is reasonable and safe to do so.
6.4 Dealing with emotional complaints (threats of suicide, despair
etc.)
Customers expressing threats of suicide or similar drastic action must be given priority and
immediately referred to your Manager and/or Group Protective Services who will determine
the appropriate action. This could include contacting the police. Customer-facing Business
Units must ensure employees are trained in dealing with this type of complaint.
6.5 Translators and other assistance for customers
Westpac Group is flexible and alert to the needs of customers with special needs.
11WBC.107.002.0948
Intellectual disability, mental health disorders or cultural or linguistic differences can make
it difficult for certain customers to advocate for themselves when making a complaint.
These conditions can also make it difficult for people to maintain an interest in their
complaint or to provide further information when asked.
Business Units must establish processes for dealing with customers requiring special
assistance. Such assistance may include interpreter services and brochures in various
languages explaining the complaints process. Employees must show a readiness to deal with
a guardian, friend, advocate or other person who acts, with appropriate authority, on behalf
of a customer.
7. Risk assessment and assigning priority
While all complaints need to be treated consistently and in accordance with this Policy, some
may need to be addressed more urgently than others. For example, some complaints may be
able to be resolved quickly and simply whilst others may require detailed investigation or
even legal advice.
Each complaint must be initially assessed in terms of urgency, severity,
safety implications, complexity, impact and the possibility of immediate
action
The following are examples of complaints that should be prioritised:
Complex • Sometimes a complaint may have numerous products and
complaints service issues. These should be clearly identified and priority
assigned because they may take longer to determine.
Reputation risk • Employees must immediately contact Westpac Group’s Media
Relations team if a complaint may attract media interest.
Urgent complaints • Any complaint of financial hardship (e.g. where a customer is
requesting a change to their loan repayment terms).
• Complaints about health or safety issues should be urgently
dealt with ahead of other complaints.
8. Acknowledging a Complaint
Receipt of each complaint should be acknowledged to the customer immediately or as soon
as possible, and in line with Business Unit procedures. The maximum acceptable timeframe
for acknowledging complaints is within two business days of receipt.
12WBC.107.002.0949
In general, a complaint should be acknowledged in the same manner it was received.
Verbal acknowledgements will differ from written acknowledgements but they should
convey essentially the same information as written acknowledgements. Written
acknowledgements must contain, at a minimum, the following information:
• the complaint date;
• the timeframe for resolving the complaint;
• a contact name and contact details; and
• a unique identifier.
It is at the discretion of the Business Unit whether complaint acknowledgement is necessary
when a satisfactory outcome is agreed with the customer on the spot.
9. Investigating a Complaint
Employees and Business Units must ensure that all the relevant circumstances and
information surrounding the complaint are investigated. It is important that the
investigation is fair and impartial and that no conflict of interest, or other form of bias,
interferes with the investigation. The level of investigation should be consistent with the
seriousness and impact of the complaint.
A proper investigation by Westpac Group should involve:
• Addressing all complaint issues. Failure to do so may generate further complaints.
• Taking into account the views of the individuals affected, including allowing them
adequate opportunity to provide relevant information.
• Taking into account previous decisions about similar complaints.
10. Complaint resolution
Responding to complaints gives us the opportunity to demonstrate our passion for helping
people and our commitment to providing superior service with every customer interaction.
10.1 Apologies
The impact of a sincere apology, offered early in the process, can have a powerful impact.
Where we have clearly made an error it is appropriate to accept responsibility and offer an
apology.
10.2 Complaint resolution principles
The complaint resolution outcomes offered should be fair and aim to foster strong and
enduring relationships. When considering an appropriate complaint resolution, we are
13WBC.107.002.0950
guided by the following principles:
We are open and • We do the right thing. If we make an error, we acknowledge it and
accountable commit to promptly fixing it.
The first option is to • The first option we consider (where possible) is to give the
consider the remedy customer what they want, if it is reasonable. This needs to be
requested by the balanced against the merits of their complaint and considerations
customer of cost and fairness.
Informal resolution • Our focus is agreeing a resolution.
and compromise are
to be attempted • Business Units should make every reasonable effort to resolve
wherever possible disputes quickly.
Our approach is • We consider all of the factors that may have triggered the
holistic complaint and we genuinely attempt to understand the issue from
the customer’s perspective (including the practical effect of
Westpac’s decisions on the customer).
• In resolving a complaint, we take into account legal advice on the
parties' rights and obligations, and we are guided by our model
litigant principles (as advised by DRG) and broader
considerations of reasonableness and fairness.
We are consistent • Like cases should, as a matter of principle, be treated equally.
• Differences in redress between similar cases should be clearly
attributable to material differences in the circumstances.
11. Complaint resolution timeframes
11.1 Early resolution of complaints is key
This Policy’s objective is to promote resolution of complaints as soon as possible and to
resolve most complaints at first instance.
In many cases (particularly where a complaint is made verbally), employees and Business
Units will be able to resolve a complaint on the spot by means of a simple apology,
explanation, or by immediately correcting the mistake.
If a complaint is not able to be resolved on the spot, Business Units must provide progress
reports to the complainant at regular intervals. The Business Unit must determine the
appropriate regular interval based on the type of complaint and, if applicable, the customer’s
reasonable request to be kept advised at more frequent intervals.
14WBC.107.002.0951
11.2 Maximum IDR timeframes
Business Unit procedures must state the maximum timeframes for different types of
complaints that are common to their business. Employees in Locations outside Australia
should adhere to their Location-specific Policy for IDR timeframes.
We aim to resolve complaints as quickly as possible. The general rule is that Westpac Group
must provide a “final response” to the complainant within 45 days (calendar days). In the
pursuit of best practice, Business Units should aim for timeframes shorter than 45 days. As a
guide, Westpac Group aims to resolve the majority of complaints relating to banking services
within five business days.
Note: different regulatory timeframes may apply to complaints relating to certain products
and services, for example:
• General insurance products
• Superannuation products
• Banking Services and guarantees
• Electronic Transactions
• Credit reporting
• Customer hardship, defaults and enforcement proceedings
In addition, some Business Units and Locations may have Industry Codes of Practice
mandating different timeframes. For example, both the Code of Banking Practice and the
ePayments Code state that IDR must complete their investigation within 21 days or inform
the customer of the need for more time to complete the investigation. Business Units must
always comply with applicable Industry Codes of Practice as part of their Policy obligations.
Business Units must ensure that their complaints management procedures address these
specific requirements. Refer to Appendix A for further details on Australian requirements.
Westpac Group must provide a response (see section 11.4) even if the complaint remains
unresolved at the end of the maximum IDR timeframe.
11.3 Communicating the final response before the end of the
maximum IDR timeframe
The final response must be in writing and must inform the customer of 1:
• The final outcome of their complaint, including:
reasons for reaching a decision on the complaint;
adequately addressing the issues that were raised in the complaint; and
where appropriate, referring to applicable provisions in legislation, codes,
standards or procedures.
1This requirement does not apply to complaints resolved within 5 business days unless your Business Unit or
Location-specific policy or procedures say otherwise.
15WBC.107.002.0952
• Where appropriate, their right to take the complaint to an EDR scheme 2 and if so, the
name and contact details of the relevant EDR scheme.
11.4 What if a final response can’t be provided in time?
If a Business Unit can’t resolve the dispute within 45 days (or the relevant IDR timeframe)
the Business Unit must provide clear and accurate information about the next stage of the
complaint process.
Before the end of that period, the Business Unit must write to the customer to inform them
of:
• the reason for the delay in responding to their complaint; and
• their right to complain to an EDR scheme, if appropriate, including the name and
contact details of the relevant EDR scheme.
12. Closing a Complaint
A complaint must not be closed until at least one of the following occurs:
• Westpac Group and the customer have agreed to an outcome and appropriate
redress (if applicable) has been provided.
• The customer has not responded to Westpac Group for an extended period of time
(as determined by the relevant Business Unit or Location) and all efforts have been
exhausted in contacting them.
• A court, tribunal or EDR Scheme has made a decision and Westpac Group has fully
complied with the decision.
Business Units must have in place a process for closing a complaint.
2 Not applicable to complaints from wholesale clients in Australia.
16WBC.107.002.0953
13. Summary of Westpac Group’s Complaint
management model
First point of contact Internal dispute External dispute
complaints handling resolution (IDR) resolution (EDR)
• Employees VALUE •More senior •If complaint is
customer officer or unresolved,
complaints. designated Westpac advises
• Employees complaints review complainant of
empowered with officer. external options.
clear delegations • Reviews • E.g. an alternative
and training to unresolved dispute resolution
resolve less complaints or complaints agency
serious complaints serious complaints such as the FOS or
wherever possible referred from the other avenues of
at FIRST initial employee appeal or review.
CONTACT. who received the
•Serious complaints complaint.
referred directly •Focus on
to the next stage. RESOLUTION.
Part 3 – Complaint recording and
monitoring
14. Complaint recording
14.1 When to record Complaints
We gain powerful insights from the complaints we receive, including the ability to detect
systemic issues and embed continuous improvement. For that reason, wherever it is
practical to do so, employees should record complaints, even those that are resolved on the
spot.
The following complaints must be recorded:
• Any complaint not resolved to the complete satisfaction of the customer within 5
business days.
• A hardship complaint.
• Declined insurance claim.
• A complaint about the value of an insurance claim.
17WBC.107.002.0954
• Other complaints as directed in Business Unit or Location policies and procedures.
14.2 How to record complaints
Employees must be aware of where and when they are required to enter complaints into
their Business Unit or Location’s complaint management system. Employees must be
educated and trained on the specific complaint management system applicable to their
Business Unit or Location. Appropriate system design and features are determined based on
the nature, scale and complexity of the relevant Business Unit or Location.
A complaints management system is only as good as the information in it. The minimum
requirements for any Westpac Group complaint management system include but are not
limited to:
• Appropriate safeguards to protect customers’ personal information and ensure their
confidentiality (see section 16).
• The ability to identify complaints by the products and services they relate to so that
meaningful data can be extracted and analysed.
• The capture of basic data such as date, name of customer and type of complaint.
• The capture of the outcome of the complaint, and (ideally) a record of all
correspondence with the customer relating to the matter.
• The ability to determine how long a complaint has been open and whether or not the
complaint was resolved within the designated timeframe.
• The ability to identify complaints as they near their maximum IDR timeframes and
(ideally) automatically prompt the Business Unit to respond before the end of the
maximum IDR timeframe.
• Being user-friendly and not pose unreasonable hurdles, either in time or complexity,
for all users.
• Including accompanying procedures that specify the steps for identifying, gathering,
maintaining, storing and disposing of records.
15. Complaint monitoring
Complaint analysis should be conducted by First Line of Defence (1LOD) Business Units
involved across the end-to-end customer experience. We take pride in always seeking new
ways to innovate and improve in ways that make things simpler and easier for our
customers.
Data analysis helps to identify and implement improved practices and should include:
• Identifying trends, emerging risks and systemic issues.
• Monitoring the time taken to resolve complaints.
• Identifying what information will be reported, to whom, by whom and how often.
• Making recommendations on process improvements as part of Westpac Group’s
continual improvement obligation.
18WBC.107.002.0955
Information gleaned from complaint monitoring should be factored into product and service
design and may provide insights into whether Westpac Group’s products and services are
performing as promised and remain suitable and fair for customers (refer to the Product and
Service Lifecycle Policy).
Issues identified must be recorded in the Group’s Risk & Compliance system (currently
ACCORD) in line with the Operational Risk Management Policy.
15.1 Identifying systemic issues
A customer’s complaint might point to a systemic problem. For example, a complaint could
expose a need for better training or support for employees who have given inaccurate or
unhelpful advice. Responsibility for seeing that such improvements are made may lie
elsewhere in Westpac Group, rather than with the complaint handling unit.
15.2 Identifying emerging risks
Trends in complaints data (for example, a rapid increase in overall complaints about a
particular issue) can help reveal common failings. Changes in Westpac Group business
models, products and services can cause complaints about the same (or a similar) issue.
Prompt action may head off a problem before it becomes a significant cause of complaints
and consumer detriment.
15.3 Identifying the potential for mass claims
Fair and prompt complaint handling and focussing on effective identification and mitigation
of emerging risks can help prevent ‘mass claims’ or class actions (a large number of
complaints about the same issue).
15.4 Senior Management oversight
Business Units should ensure that someone is appointed as responsible for providing regular
reporting of complaints metrics and insights to senior management in each division, and of
material metrics and insights from each division to Group level (e.g., Group RISKCO or
Executive Team meetings). Group level performance reporting is the responsibility of the
Group Customer Experience team.
15.5 Continuous improvement
Business units, as appropriate to their activity, should conduct regular reviews of end-to-end
IDR processes to identify areas for improvement.
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Part 4 – Other information
16. Confidentiality
We are committed to protecting the privacy and security of our customers’, colleagues’ and
the Group’s confidential information. This includes respecting customer confidentiality in
relation to complaints and adhering to the Westpac Group Privacy Policy.
Complaint information must only be accessible to employees where it is necessary as part of:
• the complaint handling process;
• managing the customer relationship;
• conducting complaint monitoring and analysis activities (see section 15); or
• identifying root cause and customer pain points to develop a program of continuous
improvements and key learning.
It is permissible to share information between Westpac Group Business Units for these
purposes or where it is legally or operationally necessary to do so.
All information relating to complaints must be stored appropriately, as required by Westpac
Group’s Records Management Policy and Divisional and/or Business Unit specific records
management processes.
Personal details that need to be disclosed for one purpose might need protection in other
situations. For example, it will often be necessary to identify a complainant to the
investigator, but the same details may not need to be disclosed in a management report on
complaint incidents and trends. Where possible, personal customer details should be
omitted in complaint data.
17. Resources and support
Our People are fundamental to delivering world class service. Business Units must have
enough employees to enable them to comply with their own timeliness and standards for
complaint handling. Managers must ensure their employees give appropriate priority to
helping complaint handling employees investigate and resolve complaints.
Complaint Handling Officers involved in more serious complaints should have access to:
• Facilities which ensure the customer’s confidentiality is maintained.
• Appropriate complaint management systems and tools.
• Employees at all levels of the organisation so that complaints can be resolved
quickly.
20WBC.107.002.0957
17.1 Training
All customer-facing employees must complete complaint handling training that is
appropriate to the activities of their Business Unit.
Employees who are responsible for responding to and/or resolving complaints should be
given additional guidance or training in customer contact and communication skills.
Management should determine the particular skills and aptitudes necessary for complaint
handling and use selection and training procedures that are appropriate to recruit and retain
the most suitable employees in complaint handling roles.
Complaint Handling Officers involved in more serious complaints, at a minimum, should
meet the following requirements:
• Have the skills to be able to act with sensitivity as well as be objective and impartial.
• Have clearly defined authority to act and provide redress to complainants.
Business Unit specific procedures must ensure that training requirements cover any
authorised or credit representatives, product distributors and any outsourced providers of
complaint handling services to the Business Unit.
18. Record keeping
It is important that records related to complaints handling accurately reflect the activity that
has taken place and are stored appropriately. Failing to maintain records for the
appropriate length of time puts Westpac Group and the relevant employee(s) at risk of being
unable to account for what has happened or what has been decided.
With dealing with records management, employees and Business Units must also comply
with Westpac Group’s Record Management Policy and Business Unit or Location-specific
records management processes.
19. Roles and responsibilities
Business Unit and Employee responsibilities are listed below.
Westpac Group Risk & Compliance Committee (RISKCO)
• Policy review and approval as per the RISKCO Terms of Reference.
Group Executives
• Lead by example to create an organisational culture where complaints are valued
and managed appropriately.
21WBC.107.002.0958
Group Head of Customer Experience
• Approve all non-material variations to the Policy.
• In conjunction with responsible business unit GM, approve Policy exemptions.
Group Customer Experience Team
• The contact point for all Policy enquires across Westpac Group.
• Maintain and update the Westpac Group intranet and other information resources
with Policy information.
• Develop a suitable communication plan to publicise the Policy, and its key features,
to all employees.
• Undertake regular Policy reviews.
• Maintain a register of Policy exceptions.
• Ensure business units provide training as required. Review any Group-wide
mandatory training relating to complaints handling as required.
• Group level complaints performance reporting
Business Units (First Line of Defence)
• Ensure processes are in place, documented and regularly reviewed to give more
specific detail on managing complaints within their Business Unit or Location. These
processes and associated documents must align with the Group Policy.
• Identify and allocate the resources required for an effective and an efficient
complaints handling process. These include resources such as employees, specialist
support and training.
• Promote awareness of the complaints handling process and the need to be customer
focussed.
• Ensure the information about complaints handling is easily accessible to all
customers, including vulnerable customers.
• Regularly review and analyse complaint data to identify emerging risks, systemic
issues and continuous improvement opportunities. Reporting must be provided to
senior management at regular intervals.
• Monitor timeline taken to resolve complaints and ensure timely resolution of each
complaint.
• Maintain and enhance business compliance plans by including appropriate
obligations and controls to ensure compliance with this Policy and any Business Unit
or Location specific policies and procedures.
• Ensure that employees, in particular customer facing employees, are appropriately
trained as necessary.
• Establish authorisation limits for employees to resolve complaints.
• Maintain appropriate records of complaints.
• Undertake regular reviews of IDR procedures to identify areas for improvement.
Managers/People Leaders
• Provide and/or ensure employees are appropriately trained and that training
material is updated as necessary.
• Ensure their people and business units adhere to this policy
22WBC.107.002.0959
Employees
• Undertake all required complaints management training, whether Group-wide
mandatory learning or Business Unit specific training.
• Comply with this Policy, together with their Business Unit or Locational documents
(i.e. policies and processes) developed to support and align with this Policy.
• Report any instances of Policy non-compliance (breaches and incidents) to
Specialised Compliance and in the Group Risk and Compliance Management System
(currently ACCORD).
• Comply with Westpac Group’s Code of Conduct and other relevant Group policies
• Treat customers in a courteous manner and promptly respond to their complaints.
Specialised Compliance (Second Line of Defence)
• Provide compliance advice to first line Business Units on their complaint
management policies, procedures, etc. as part of routine reviews.
• Notify the business and policy owner of changes that may impact on this policy and
our obligations. Provide prompt advice on changes and partner together to
introduce any change required.
• Provide advice on complaints referred from first line Business Units and support the
remediation of issues.
• Advise first line management and the relevant divisional risk and compliance
committee(s) of significant issues that arise through the complaints channel and the
overall effectiveness of complaint management processes and controls.
• Provide support on external breach reporting and external investigations (as
required).
• Review proposed changes to customer collateral to ensure appropriate disclosures
in relation to complaints handling practices.
• Support the first line to conduct ongoing reviews and update of compliance plans.
• Provide training and support to first line via updates on regulatory changes and
refreshers on obligations, etc.
Legal
• Dispute Resolution Group provides advice and assistance to manage complaints
when customers are legally represented, raise legal issues, or threaten or commence
legal proceedings.
• Provide advice on management of systemic issues.
Group Audit (Third Line of Defence)
• Provide independent assurance as to the adequacy and operating effectiveness of
the 1st and 2nd line risk management approach (identification, management and
controls) and track remediation progress.
23WBC.107.002.0960
20. Policy governance
• The legal and regulatory obligations underpinning this Policy are embedded in
compliance plans owned by Business Units across the Group.
• The Policy will be reviewed and refreshed by the Group Customer Experience Team
as required (that is, whenever there are significant regulatory changes as advised by
second line of defence or changed business needs).
• The Customer Experience Team will review the Policy annually to ensure it is up-to-
date and aligned to Westpac Group’s risk appetite.
• Material changes to the Policy must be approved by RISKCO as per the RISKCO
Terms of Reference.
• Non-material changes to the Policy must be approved by the Group Head of
Customer Experience, and retrospectively reported to RISKCO for noting.
21. Consequences of non-compliance with this Policy
Non-compliance with this Policy could have serious consequences for Westpac Group,
including penalties, adverse court orders, customer loss and reputational damage. All
employees are responsible for understanding how this Policy applies to their role.
No part of this Policy or its supporting processes should be interpreted as contravening or
superseding any other legal and regulatory requirements imposed upon the Westpac Group
in any jurisdiction in which it operates. Any conflict between this Policy and Westpac
Group’s legal obligations should be submitted immediately to the Group Head of Customer
Experience and the Chief Compliance Officer for further evaluation.
All Policy incidents and breaches must be reported in Westpac Group’s risk and compliance
management system, currently ACCORD. Westpac Group will take appropriate action after
consideration of all the relevant details. Refer to the Group Incident Management
Procedures and Guidance (available in the Risk Document Library) for further information
on what is an incident or breach and when to report it. A breach of this Policy may, in some
circumstances, result in disciplinary action up to and including dismissal.
22. Policy implementation
The Group Customer Experience Team is responsible for developing a suitable
communication plan to publicise the Policy, and its key features, to all employees.
The Policy establishes the minimum objectives for Westpac Group’s complaint management
obligations. It consists of high level statements that define the expectations across the
Group. The Policy defines the business goals but does not mandate how these goals are
implemented.
24WBC.107.002.0961
23. More information
If you are uncertain about whether or how this Policy applies to you and your Business Unit,
please speak to your immediate Manager. Alternatively, contact the Group Head of
Customer Experience.
24. Definitions
Term Definition
Banking Service Banking service means any financial service or product provided by us
in Australia:
including any financial service or product provided by us whether
supplied directly or through an intermediary; and
in the case of a financial service or product provided by another
party and distributed by us, extends only to our distribution or supply
of the service or product and not to the service or product itself.
Business Unit A segment of Westpac Banking Corporation representing a specific
business function- this may be a Division or part of a Division.
Complaint See section 2.2 of this Policy
Electronic Payment, funds transfer and cash withdrawal transactions that are:
Transaction initiated using electronic equipment, and
not intended to be authenticated by comparing a manual signature
with a specimen signature.
This includes:
a. electronic card transactions, including ATM, EFTPOS, credit card
and debit card transactions that are not intended to be
authenticated by comparing a manual signature with a specimen
signature;
b. telephone banking and bill payment transactions;
c. internet banking transactions, including ‘Pay Anyone’;
d. online transactions performed using a card number and expiry
date;
e. online bill payments (including BPAY);
f. transactions using facilities with contactless features and prepaid
cards, not intended to be authenticated by comparing a manual
signature with a specimen signature;
g. direct debits;
h. transactions using electronic toll devices;
i. transactions using mobile devices;
j. transactions using electronic public transport ticketing facilities,
k. mail order transactions not intended to be authenticated by
comparing a manual signature with a specimen signature; and
l. any other transaction specified by ASIC under clause 43 as a
transaction to which this Code applies.
25WBC.107.002.0962
Location Branches and/or offices operating in a geographical location and/or
(international) jurisdiction(s) outside of Australia. Locations may include one or more
Westpac Group Business Units co-located.
‘Westpac Group’, Westpac Banking Corporation ABN 33 007 457 141 and its subsidiaries.
‘Westpac’, Westpac Group also includes the divisions (see Business Unit definition
‘Group’, ‘we’, ‘us’ – above) operated by Westpac Banking Corporation, including all brands
and ‘our’ it operates under.
For the purposes of this Policy, and any processes developed by a
Business Unit to comply with this Policy, Westpac Group includes
overseas branches and subsidiaries.
25. Document version control
# Prepared by Approved Key changes
1.0 Steven Bardy OPCO Initial policy
Group Compliance 6 Jul 2006
2.0 Scott Jamieson OPCO Process changes, including addition of BT
Group Compliance 2 Feb 2009 information
3.0 Dan Hogan OPCO Revised / updated Group Wide policy
Group Compliance 5 Jul 2010 (formerly Complaints Resolution Policy)
4.0 Dan Hogan CCO Annual review
Group Compliance Jul 2011
5.0 Jilly Hanna OPCO Revisions to align with new ASIC RG 165
Enterprise Compliance Oct 2013 (June 2013) and various industry codes
6.0 James Boughton CCO Annual review. Change of Policy ownership
Enterprise Compliance 30 Jun 2016 to the Group Head of Customer Experience
and associated responsibilities to the Group
Customer Experience Team. Aligned with
‘Our Service Promise’.
26WBC.107.002.0963
Appendix A – Maximum complaint resolution timeframes
(Australia)
Maximum
Resolution
Timeframe
Type of (calendar
Complaint days) Exceptions / Conditions Source
All financial 45 Days If Westpac Group can’t resolve the ASIC
services dispute within 45 days (or the relevant Regulatory
complaints IDR timeframe) we need to provide the Guide 165
customer with reasons for the delay and
advise of their right to complain to (the
relevant) EDR scheme. Refer to ASIC
Regulatory Guide 165 for more detail.
Complaints 15 days In cases where further information, General
relating to assessment or investigation is required Insurance Code
General we can agree reasonable alternative time of Practice
Insurance frames with the customer. If the customer
does not agree to additional time, the
customer may escalate the complaint to
‘Stage 2’ (treated as a Dispute). Disputes
should be resolved within 15 business
days, unless otherwise agreed with the
customer. If more time is required, refer
to the General Insurance Code of
Practice for further detail.
Complaints 21 days The customer must be informed if Code of Banking
relating to Westpac Group requires more time. Practice
Banking Maximum response time is 45 Days
Services or unless there are exceptional
Guarantees circumstances. Refer to the Code of
Banking Practice for responses over 45
days.
Complaints 21 days • The customer must be informed if E Payments
relating to Westpac Group requires more Code or
Electronic time. Maximum response time is 45 Relevant
Transactions Days unless there are exceptional Scheme Rules
circumstances. Refer to the E
Payments Code for responses over
45 days.
• Complaints relating to scheme
cards may follow the scheme
timeframes instead. Refer to the
relevant scheme rules.
Complaints 30 days Unless the customer agrees to a longer S23B Privacy
relating to period. Westpac Group must Act 1988 (from
credit reporting acknowledge the complaint and outline 12 March 2014)
how it will deal with the complaint, in
writing, within 7 days.
Complaints 21 Days While the complaint is being handled, ASIC
relating to and for a reasonable time thereafter, Regulatory
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