Customer & Conduct¶
| Domain ID | D04 |
| Owner | Chief Compliance Officer / Head of Customer |
| Jurisdiction | NZ + AU |
| Applicability | Platform — SD08 delivers consent capture (MOD-049), disclosure enforcement (MOD-050), and case and complaint management (MOD-053). In Track 2 tenants use these modules to meet their own customer conduct obligations. |
Fair treatment of customers, product suitability, complaints management, and consumer protection obligations.
IDR timeframes¶
NZ (FSCL): Acknowledge within 1 business day, resolve within 40 working days. AU (AFCA/ASIC RG 271): Acknowledge within 5 business days, resolve within 45 calendar days. Both: unresolved complaints must be escalated to the external dispute resolution scheme.
Policies¶
| Code | Policy name | Status |
|---|---|---|
| CON-001 | Customer Fairness & Conduct Policy | Draft |
| CON-002 | Complaints & Internal Dispute Resolution Policy | Draft |
| CON-003 | Vulnerable Customer Policy | Draft |
| CON-004 | Product Disclosure & Sales Practice Policy | Draft |
| CON-005 | Fee & Pricing Transparency Policy | Draft |
| CON-006 | Marketing & Advertising Policy | Draft |
| CON-007 | Consumer Data Right (CDR) Policy | Draft |
| CON-008 | Financial Hardship Policy | Draft |
Systems satisfying this domain¶
- MOD-007: Account state machine — AUTO (hardship → Protected state)
- MOD-023: Transaction fraud scorer — AUTO (customer protection)
- MOD-025: FX rate lock — GATE (spread disclosed before transfer)
- MOD-049: Consent capture — GATE (CDR, marketing)
- MOD-050: Disclosure enforcement — GATE (product disclosure)
- MOD-053: Case & complaint management — ALERT/LOG (IDR SLA)
Policies in this domain¶
| Code | Title | Status | Owner |
|---|---|---|---|
| CON-001 | Customer Fairness & Conduct Policy | Draft | Chief Compliance Officer |
| CON-002 | Complaints & Internal Dispute Resolution Policy | Draft | Head of Customer Experience |
| CON-003 | Vulnerable Customer Policy | Draft | Head of Customer Experience |
| CON-004 | Product Disclosure & Sales Practice Policy | Draft | Head of Product |
| CON-005 | Fee & Pricing Transparency Policy | Draft | Head of Product |
| CON-006 | Product suitability and governance | Draft | Chief Risk Officer |
| CON-007 | Consumer Data Right (CDR) Policy | Draft | Head of Customer Experience |
| CON-008 | Financial Hardship Policy | Draft | Head of Customer Experience |
| CON-009 | NZ DTA Key Information Summary Disclosure Policy | Draft | Chief Compliance Officer |
Compiled 2026-05-22 from source/entities/risk-domains/D04.yaml