Corporate Governance - Bendigo and Adelaide Bank
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Corporate Governance

Customer Feedback Management Policy


Overview

We love to hear from our customers whether it's a compliment, suggestion or a complaint.  It is important for us to know what we do well and we are just as keen to hear when we have not met our customer's expectations no matter the circumstance.

This policy provides an outline of how our staff will handle customer feedback which includes compliments, suggestions and complaints.

Purpose

Our vision is to be Australia's most customer connected Bank.  Our strategy is to focus on the success of our customers, people, partners and communities.  We do this by listening and responding and respecting every customer's choice, needs and objectives.

This policy provides the foundation for implementing a consistent approach throughout the Group that will facilitate the Group's compliance with its regulatory obligations and the current Australian Standard AS ISO.

We consider Internal Dispute Resolution (IDR) to be an important and necessary first step in the complaint handling process. It gives the Group the opportunity to hear when we do not meet our customers' expectations and address them genuinely, efficiently and effectively.  Addressing IDR complaints in this way can also assist in improving business systems and products or services, which is integral to growing a successful business.

This policy sets out the minimum procedures for safeguarding our customers' confidence by dealing with their feedback and the key principles to be followed to enable the Group, each business unit and individual staff members to implement and understand their obligations in the handling of customer complaints.

This policy forms part of the Group's broader regulatory compliance obligations.

Definitions
Complaint Expression of dissatisfaction made to or about an organisation, related to products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.
Customer A customer can be defined as an account holder, a shareholder or anyone interacting or seeking to interact with us.
Feedback Includes compliments, suggestions and complaints.
Group

Means:

Bendigo and Adelaide Bank Limited including all its subsidiaries;
Bendigo Bank agencies;
Bendigo Bank franchises (including Community Bank® branches); and
Bendigo and Adelaide Bank Related Entities
Policy Statement
Scope of Policy This policy applies to the whole of the Group.
Policy Ownership

The Office of the Customer Advocate has developed this policy with the assistance of senior management and staff.

Each area of the Group is responsible for overseeing compliance with this policy.
Feedback

The Group is always keen to find out ways to improve its customer service.

If customers have any compliments, suggestions or complaints related to the products or services provided by the Group, any of our staff can assist with the feedback.

They will be objective and proactive in responding to our customers in order to achieve fair, reasonable and timely outcomes.

We will ensure that all complaints are fully documented, investigated and resolved as prescribed in the Australian Securities and Investments Commissions (ASIC) regulatory guide (RG165).

There are many ways the customer can provide their feedback to us:

External Dispute Resolution Scheme

Each Group entity that holds an Australian Financial Services Licence (AFSL) or Australian Credit Licence or is otherwise required to maintain a membership with an ASIC approved EDR Scheme, will remain members of the external dispute resolution scheme that cover complaints made about us.

The Group's EDR Schemes are the Financial Ombudsman Service Australia and the Superannuation Complaints Tribunal.

Financial Ombudsman Service Australia
GPO Box 3
Melbourne Vic 3001
Phone: 1800 FOS AUS (1800 367 287)
Fax: 03 9613 6399 
Email: info@fos.org.au 
www.fos.org.au

Superannuation Complaints Tribunal
Locked Bag 3060 GPO
Melbourne Vic 3001
Phone: 1300 780 808
Fax: 03 8635 5588
Email: info@sct.gov.au
www.sct.gov.au

Office of the Australian Information Commissioner
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au

Centralised Complaint Register

Details of all feedback from across the Group will be recorded in LINX which will form the Group's centralised register.

The centralised register helps us to identify systemic or ongoing issues from across the Group that may impact our customers. 
Procedures The Group has internal procedures which provide the key principles for us to follow when handling customer feedback. They outline the importance of listening to and working with the customer to achieve a satisfactory outcome for both parties (see related documents below).
Key Responsibilities
Board of Directors In limited circumstances the Group Boards, via their subcommittees may be authorised to access customers' complaints, but only in circumstances where the information is required to complete a customer request or for monitoring the Group's compliance with this policy.
Executive/Senior Leadership Team

Each Executive/Senior Leader has the day to day responsibility and accountability for maintaining compliance with this policy in their business units.

Each Executive/Senior Leader is responsible for ensuring details of all feedback in their business units is recorded in LINX.
Customer Avocate

The Customer Advocate's role is to review complaints escalated from our customers when they are not satisfied with the outcome of the Group's Internal Dispute Resolution (IDR) process.  The Customer Advocate will impartially assess the complaint, keep the customer informed of the progress and provide the customer with an outcome of the review of their complaint in a timely manner.

The Customer Advocate will have strategic influence with regards to helping broader cohorts or groups of customers as well as identifying systemic issues or problems within the Group. This could include shaping or overseeing remediation programs, influencing product development and distribution processes, or engaging in preventive risk management initiatives.  They will engage with customer representatives, including consumer advocates, legal aid officers, community legal centres and financial counsellors.

Our Customer Advocate operates separately from our business and reports regularly to the Managing Director and Chief Customer Officer, as well as engaging with Executives and Senior Management to provide insights into customer perspectives and recommendations for improvement.

Customer Feedback Team The Team captures customer feedback received across the Group and also supports the business in resolving customer complaints by advising the appropriate course of action. If the business is not confident or trained appropriately in resolving a complaint, the matter can be escalated to the Customer Feedback Team.
Customer Liaison Oversight Officer The Customer Liaison Oversight Officer will conduct periodic reviews of the performance of the Customer Advocate Office and report outcomes together with recommendations through to the Chief Customer Officer and the Managing Director.
Business Unit Manager / Branch Managers

Officers with supervisory or line management duties are responsible for ensuring the business unit is operating in a manner that deals with customer feedback as per the requirements of this policy. This includes ensuring all staff receive the appropriate training and supervision and understand the requirements of this policy.

Any potential compliance breakdowns must be reported to the next level of management and actioned to minimise the risk of breakdowns in the future.
Group Operational Risk

Group Operational Risk (through Group Regulatory Compliance) is responsible for:

  • Assisting the business Units (including subsidiaries) with regulatory compliance by providing guidance, support and advice with respect to compliance with this policy.
  • Working with business Units (including subsidiaries) to develop solutions for breaches with this policy.
Assessing and reporting breaches of RG165 as set out in the Group Regulatory Compliance policy.
Group Legal Group Legal is the key legal adviser for the Group and is responsible for providing support, guidance and advice to business units/subsidiaries as to the adequacy of their policies and procedures and the changes required to meet regulatory obligations.
Corporate Secretariat Corporate Secretariat is the first point of contact for all liaisons with Regulators and is responsible for reporting any regulatory compliance breaches to relevant regulators (when required).
Learning and Development Are responsible for ensuring training and education on this policy is provided to staff.
All other officers/staff All officers of the Group are responsible for complying with this policy and its related procedures including completing training as designated by their role.
Related Documents

Related documents which should be read in conjunction with this policy include:

Review

This Policy will be reviewed every two years by Customer Advocate Office in conjunction with Group Operational Risk or sooner if required.