Human rights

History

In 2008, the United Nations Human Rights Council recognised that while the primary duty to protect and promote human rights lies with national governments, businesses also have a responsibility. The UN Guiding Principles on Business and Human Rights (UNGPs) operate on the UN’s ‘Protect, Respect and Remedy’ Framework and they acknowledge that businesses can cause, contribute or be directly linked to human rights abuses.

Definition

We define human rights broadly and view them as people-first principles that set out minimum standards of human behaviour and actions, which provide a framework on how we can contribute towards dignity, equality and mutual respect for all.

Commitment

At Bendigo and Adelaide Bank,ⁱ we acknowledge that businesses can both advance and hinder human rights. We believe in protecting and respecting human rights principles and remedying violations where they occur. We do this by working to hold ourselves to the same standards we expect from others, across all financial and products services we offer, in our operations and across our value chain, as well as how we engage with and support our stakeholders.

Developing our commitment

International guidance

While we recognise all human rights principles, we focus on those that our operations can substantially impact. To help us determine which principles are most relevant to the Bank, we assessed our operations in line with globally recognised standards and recommendations to identify areas with greater risk – where actions or behaviour would have a significant or severe negative impact and jeopardise human rights. The UN Guiding Principles on Business and Human Rights (UNGPs), the ILO's Declaration on Fundamental Principles and Rights at Work, the UN Sustainable Development Goals and the UN Global Compact’s Ten Principles form the basis of our approach. These are supplemented by state-based Australian human rights legislation.

Due diligence

When undertaking human rights due diligence, we look to consider how our business operations can have actual and potential impacts on human rights. This means taking steps to meaningfully consult stakeholders and consider how different human rights principles intersect and impact one another. We periodically review our due diligence processes to consider how our operations may cause or contribute to harm. Review enables us to improve our approach and minimise future and potential risk.

Delivering our commitment

Engaging with our value chain

As one of Australia’s largest banks, we wear many hats – we are not just a financial services provider, we are also an employer, a buyer of goods and services and an active member of our communities. At our core, we are guided by our purpose to “feed into prosperity, not off it”. With our range of responsibilities and wide reach, we are in a position to impact the lives of many individuals and communities, and we are committed to ensuring our impact is positive. We believe our vision and values set us apart – these are the behaviours and actions we strive for everyday and they are articulated in our Code of Conduct.

We expect the same of our suppliers and partners – our specific expectations are set out and communicated to suppliers and partners through our Supplier Code of Conduct, Modern Slavery Policy and Modern Slavery Plan. To help deliver these, we prioritise engagement mechanisms that allow for meaningful consultation with stakeholders who sit within our sphere of influence. We communicate progress annually through our Modern Slavery Statement and sustainability reporting.

Creating shared and sustainable prosperity

Community is a key part of our identity – we operate on the belief that profits generated within a community should be invested back into it. To help ensure we are acting sustainably and engaging in economic activities that create shared prosperity, we prioritise place-based investment, advocacy, and philanthropy. Our approach to social change is guided by our strategic Social Purpose Framework, our on-the-ground Community Bank network and our Community Enterprise Foundation which mobilises the distribution of sponsorships, donations and appeals. Our Financial Inclusion Action Plan also supports this work.

A clean, healthy and sustainable environment helps a community thrive. Climate change, pollution, and biodiversity / nature loss threaten the livelihood and wellbeing of current and future generations. Through our Climate & Nature Action Plan, BENZero and Climate Credit Risk Policy we are taking steps to respond to climate change and prevent further harm. We continue to explore tangible ways we can work with stakeholders who share our ambition to drive action towards a resilient and sustainable future. As part of this, we work to ensure we are doing appropriate customer and sector due diligence prior to and during engagement.

Being inclusive and supporting development

Education and engagement help us ensure human rights are considered and embedded into our everyday activities and relationships. Change starts at home, so we are focused on providing our people with access to employment, development and participation that is free from exploitation. This is encouraged through our learning and development strategy and platform, financial and non-financial support for personal and professional development opportunities, our Remuneration Policy and reward framework.

We strive for a workplace that is inclusive, does not discriminate and provides equitable opportunity for our people, regardless of how they identify. Our policies, standards and procedures regarding people will align with human rights standards, adjusted to fit local laws and practices, including industrial agreements. We work to promote a culture of respect for human rights, diversity, and inclusion within our workforce, ensuring equal opportunities for all. We are committed to preventing work health safety hazards and managing our work health safety requirements.

We value diversity by fostering an inclusive environment, advocating for the rights of people with disability and promoting accessibility. Belonging at BEN is our central strategy to developing a culture that embraces our diverse workforce, with an Executive Sponsor for each of the priority dimensions. This is supported by our Reconciliation Action Plan and Accessibility and Inclusion Plan.

Protecting data privacy and security

Privacy considerations are built into products, services, internal systems and processes. Our approach is primarily guided by internal policies. These policies set out how we protect data security and privacy across our brands and platforms and these are informed by the Australian Privacy Principles and Office of the Australian Information Commissioner.

Combating corruption and bribery

We believe engagement with government, regulators and industry is important and, when we engage, we seek to represent the voices of our customers and the Bank in addition to our business priorities. Our Anti-bribery and Corruption Policy and its associated policies guide our approach to external engagement.

Providing access to remedy

Wherever possible we take a preventative approach through education and awareness. In addition to this, and to take account of those instances when we do not take appropriate action, we provide grievance mechanisms and offer remedial action where appropriate.

Our Customer Advocate Office works with our customers to achieve appropriate resolution to customer complaints and where appropriate facilitates external remediation through the Australian Financial Complaints Authority (AFCA). We periodically review our processes to ensure they are communicated clearly, in plain language and in a manner accessible to all customers. Mechanisms are in place for our people to raise concerns related to human rights impacts in the workplace.

Reporting fully and transparently

We believe in disclosing our progress and actions fully and transparently. We continue to keep our stakeholders informed through regular communication with industry bodies, regulators, brokers, analysts and investors and reporting externally in accordance with established reporting standards and obligations.

Complying with our commitment

Risk frameworks

Environmental, Social and Governance (ESG) Risk is defined as the risk of failure to appropriately identify and manage material environmental, social, and governance risks and opportunities – appropriate management of human rights is an ESG Risk. We classify ESG Risk as a Strategic Risk, so we need to make sure we are regularly identifying, reviewing and strategically managing the Bank’s human rights risks.

We also take a risk-led approach to compliance by remaining aware of and compliant with all applicable regulatory and legislative requirements. Our Process Architecture Framework and Standard allows us to map risk, while our responsibility and accountability frameworks for directors’ and executives’ statements clearly set out responsibilities to help us manage risk. These are enabled by our Group Risk Management Framework and our Three Lines of Defence Model.

Monitoring and tracking

We take a risk-based approach to identifying, managing and mitigating risks related to the Bank’s products and services. Monitoring and tracking processes and systems and internal and external audits ensures that we are remaining compliant with our legislative obligations, our voluntary commitments, and policies, strategies and plans. For example, our Financial Crime Risk function is responsible for performing transaction monitoring and analysis to identify money laundering and terrorism financing activities. This is performed through account monitoring techniques designed to identify red flags. When monitoring the modern slavery risk environment, we stay informed through a combination of third-party risk assessments, employee insights, reports published by industry and relevant civil society organisations, and our participation in industry networks and working groups.

Training and communication

Our people are critical to ensuring regulatory and legislative compliance and managing risk. We expect them to abide by our Code of Conduct, any applicable policies and procedures and all laws and regulations. To make sure our people are aware of our conduct standards, we have annual mandatory training and regular reminders through a range of internal channels. Training and regular communication helps us deliver safe and compliant products and services. We want to work in an environment where our people feel empowered to speak up when they have concerns and our Whistleblower Policy and Speaking Up Program help support this.

Accountability and responsibility

We have controls in place to help ensure we are delivering our human rights commitments. Our Board, Board committees, Executives and Management are delegated responsibilities for their area of expertise. In addition to this, our policies, frameworks and strategies have clear accountabilities, are informed by internal and external expertise and have transparent review and approval processes. To ensure they are embedded in operational procedures, we communicate them internally and externally and several are made publicly available.

The following are relevant to our human rights commitment: