Customer Fairness & Conduct Policy¶


Code	`CON-001`
Domain	Customer & Conduct
Owner	Chief Compliance Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD01
Review date	2027-03-25

Regulations: CoFI Act 2022 · NZ FMC Act · ABA Banking Code · NZ Banking Code ¶

Purpose¶

Govern the platform's obligations to treat customers fairly, act in their best interests, and provide products and services that are appropriate to their needs.

Scope¶

All products, services, customer interactions, and communications of the platform in NZ and AU.

Policy statements¶

The platform SHALL design, distribute, and administer products with the fair treatment of customers as a primary objective. Product governance processes SHALL assess customer outcomes before launch and at each annual review.

The platform SHALL ensure that all customer communications are clear, fair, and not misleading. Marketing materials, terms and conditions, and fee schedules SHALL be reviewed for consumer clarity before publication.

The platform SHALL provide customers with timely and accurate information to enable informed decisions. Key product features, fees, risks, and rights SHALL be disclosed at or before the point of sale.

Where a product or service is not appropriate for a particular customer, the platform SHALL not proceed with the sale. Staff and digital channels SHALL be capable of identifying and declining inappropriate sales.

The platform SHALL monitor customer outcomes on an ongoing basis. Outcome monitoring metrics SHALL include complaint volumes, product usage patterns, fee incidence, and early arrears rates. Adverse outcomes SHALL trigger a root cause review.

The platform SHALL maintain an accessible and effective complaints process. All complaints SHALL be acknowledged within the timeframes set in CON-003.

The platform SHALL comply with the NZ Consumer Guarantees Act, Fair Trading Act, and AU Australian Consumer Law obligations in all customer interactions.

Satisfying modules¶

Module	Name	Mode	Description
MOD-008	Dormancy & escheatment engine	`AUTO`	Dormant customer contacted before funds transferred — fair conduct obligation met automatically
MOD-009	eIDV & document verification	`AUTO`	Same verification checks applied consistently to all customers — no discriminatory variation
MOD-011	KYC periodic review scheduler	`AUTO`	Review cadence consistent across all customers of same tier — no discretionary skipping
MOD-023	Transaction fraud scorer	`AUTO`	Customers protected from fraud automatically — not reliant on reporting it after the fact
MOD-040	Churn & health score engine	`AUTO`	At-risk customers proactively identified and contacted — fair conduct met before customer disengages
MOD-051	Financial automation rules engine	`AUTO`	Automated actions executed exactly as customer configured — no discretionary deviation
MOD-063	Notification orchestration	`AUTO`	Ensures all required regulatory disclosures and event-driven communications are sent to the customer at the correct time.
MOD-072	Customer profile & settings	`AUTO`	All profile changes are confirmed and acknowledged by the customer before being applied — no silent updates to contact or identity details.
MOD-078	Card & account controls	`AUTO`	Spending limits and card controls are set and visible to the customer in the app — changes take effect in real time with immediate confirmation.
MOD-105	Product eligibility engine	`GATE`	Eligibility evaluation considers existing exposure, customer segment, and product complexity tier — ensuring products are not offered to customers for whom they are unsuitable.

MOD-107	Next best product engine	`CALC`	Ranking model is periodically tested for demographic fairness — no protected characteristic may systematically suppress product recommendations for a customer group.

MOD-108	Product offer engine	`AUTO`	Offer generation rate and acceptance outcomes are monitored by MOD-107 fairness reporting — systematic disparities trigger a compliance alert.

MOD-109	Product deal engine	`LOG`	Deal audit trail enables periodic review for consistent treatment — agents cannot offer materially different deals to similarly situated customers without an auditable reason.

MOD-118	Member equity and share registry	`AUTO`	Dividend distributions are calculated consistently across all members using the declared rate and recorded shareholding — no discretionary variation.
MOD-124	Physical card issuance and bureau integration	`AUTO`	Card replacement is initiated automatically when a card is reported lost or stolen, with no manual intervention required to trigger the bureau order.
MOD-125	Joint account management	`AUTO`	All joint account holders receive statements, notices, and communications simultaneously — no holder receives less information than any other.
MOD-129	Teller operations and branch cash management	`AUTO`	Cash receipts are posted and the customer's available balance is updated immediately upon teller confirmation — the customer's balance is never temporarily reduced or withheld pending a manual reconciliation step.
MOD-130	Notice account management	`AUTO`	Withdrawal is released automatically on the notice expiry date without requiring manual intervention — no customer is held beyond their contracted notice period.
MOD-131	Mutual governance and AGM administration	`AUTO`	All eligible members receive AGM notice, proxy forms, and annual report simultaneously via their preferred channel — no member receives less notice than any other.
MOD-134	Community account management	`AUTO`	All authorised signatories receive account communications and statements simultaneously.
MOD-137	Agency banking adapter	`AUTO`	Agency transactions are reflected in the customer's account balance and transaction history with the same speed as digital channel transactions — no delayed posting for the agency channel.
MOD-142	Deposit guarantee scheme disclosure	`AUTO`	The coverage indicator on the account detail screen updates automatically whenever the account balance changes, so the customer always sees their current coverage position without needing to check separately.
MOD-155	Target Market Determination (AU DDO)	`LOG`	Out-of-target-market distribution events and TMD trigger breaches are logged as conduct events and escalated for review.

Part of Customer & Conduct · Governance overview Compiled 2026-05-22 from source/entities/policies/CON-001.yaml