Westpac Group Complaint Management Policy - WBC.107.002.0937 - Royal Commission

 
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

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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:

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                                            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.

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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
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            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:

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         • 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.

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      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.

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         •    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.

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     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

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       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.

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     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.

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       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
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       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.

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     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.
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                •    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.
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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.
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            •   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.

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       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.

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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.

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     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
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     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.

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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.

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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.

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     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’.

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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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