Vulnerable Customer Policy¶


Code	`CON-003`
Domain	Customer & Conduct
Owner	Head of Customer Experience
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD01
Review date	2027-03-25

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

Purpose¶

Govern the platform's obligations for handling customer complaints, including acknowledgement timeframes, investigation standards, escalation pathways, and external dispute resolution.

Scope¶

All complaints received from customers or prospective customers in NZ and AU through any channel.

Policy statements¶

The platform SHALL maintain a complaints management process that is accessible, fair, and free of charge to customers. The process SHALL be clearly communicated in product terms and the platform's website.

All complaints SHALL be acknowledged within one business day of receipt. The acknowledgement SHALL confirm receipt, provide a reference number, and set out the expected resolution timeframe.

The platform SHALL aim to resolve standard complaints within 10 business days of receipt and complex complaints within 20 business days. Where a complaint cannot be resolved within these timeframes, the customer SHALL be informed of the reason and the revised expected timeframe.

Complaints involving financial hardship, vulnerable customers, or potential regulatory breaches SHALL be escalated to a senior complaints handler and treated as high priority.

Where a complaint cannot be resolved to the customer's satisfaction, the customer SHALL be informed of their right to escalate to the external dispute resolution scheme: Financial Services Complaints Limited (FSCL) in NZ and the Australian Financial Complaints Authority (AFCA) in AU.

The platform SHALL maintain records of all complaints, their classification, resolution outcomes, and timeframes for a minimum of seven years.

Complaint trends SHALL be reviewed monthly by the Head of Customer and reported to the Board Risk Committee quarterly. Systemic issues identified from complaint patterns SHALL be escalated for root cause remediation.

Satisfying modules¶

Module	Name	Mode	Description
MOD-040	Churn & health score engine	`ALERT`	Financial stress signals in health score can trigger vulnerable customer flag — automated identification
MOD-053	Case & complaint management module	`AUTO`	Vulnerable customer flags visible in every agent view — special handling applied automatically
MOD-065	Credit servicing & collections	`AUTO`	Routes customers who meet hardship criteria into the hardship assessment workflow with appropriate communications triggered.
MOD-126	Power of attorney and third-party authority	`AUTO`	Third-party authorities are monitored for abuse patterns — a sudden increase in transaction frequency or value by an attorney triggers an alert to the back-office team for review as a potential vulnerable customer concern.
MOD-138	Deceased customer and estate management	`AUTO`	The account holder's deceased status triggers enhanced care obligations — all estate communications are managed with empathy protocols and automated payment outflows are suspended on notification.
MOD-139	Financial hardship formal variation workflow	`AUTO`	Hardship customers are flagged as vulnerable in MOD-007 and all communications are managed with empathy protocols during the variation period.

Part of Customer & Conduct · Governance overview Compiled 2026-05-22 from source/entities/policies/CON-003.yaml