Agenda

1. Identifying Systemic Issues and Improving Customer Service Annette Donselaar ASM BA BCom MComLaw LLM DFP Grad Dip Compliance AACIHead of Australian Region Compliance

2. Agenda • Why complaints and compliance teams need to work together • Systemic analysis in practice - why doesn’t it always work? • Strategy into action • NAB – a case study • Benefits and ongoing maintenance

3. Does this sound familiar? • We have a wide range of breaches but why don’t know why they occur. • We capture information about our customer complaints but we have difficulty truly understanding what irritates customers. • We have a ‘gut feel’ about what is going wrong but we can’t quite put our finger on it. • We need funding to address some issues but we don’t have the statistics to back it up. • Customers tell us that we have certain problems but it is not reflected in our data.

4. The link between complaints & compliance • If you could identify with any of the statements, you are searching for a better way to understand your compliance environment - environmental data (especially complaints!) is critical. • By creating open lines of communication between complaints & compliance teams you can: • Identify and prioritise the critical impact issues on customers and the organisation • Enhance data quality and integrity by focussing on classifications, relationships and significance • Providing meaningful data to prove (or disprove!) folklore • Enable differentiation between symptoms and cause

5. Systemic analysis • Systemic analysis is seen as the ‘cure all’ to support this process. However … • Focus tends to be on immediate resolution by customer facing staff - rather than broader analysis. • Data collection tends to support individual resolution. • Data input is not always seen as valuable by staff - the problem is fixed so why record it? • Due to the nature of information collected, analysis tends to focus on broader issues rather than product or service. • Lack of integration of complaints data with broader risk events.

6. Strategy into action • Complaints and Compliance teams developed a joint project to address deficiencies in systemic analysis. • Purpose was to ensure that: • staff understood why data is important • ensuring better analysis of data captured • closer working relationship on testing, analysis and response to data collected • Post implementation reviews

7. Strategy into action • Complaints training to become mandatory compliance training for all customer facing staff. • Complaints and compliance teams review monthly extract of complaints data -lag indicators for trend analysis. • Appointment of systemic analysis manager for complaints data who works closely with compliance staff. • Information integration: • trending and indexing data from BFSO database • risk profiling information across products • continuous improvement on capture tools and lead indicators.

8. NAB – Our approach • Potential systemic issue identified - either through BFSO, CCMC or by own analysis. • Business unit analysis of issue with compliance team to determine breadth and significance. • Once systemic issue confirmed: • Regulator/complaints body engagement program and information determined • Dedicated workstreams created to address fundamental issues • Regular reporting and briefings to stakeholders (including ACA where appropriate) • Post implementation review to identify lessons learned.

9. Workstreams • Stop and Remedy • short term fix (‘stop’ the problem) and long term remedies • Quantify andAnalyse • Identify extent of the problem • Communication • strategy for internal and external information (letters, adverts, internet) • Compensation • principles and business rules

10. Benefits • ‘Future proofing’ systems through knowledge of actual and potential breakdowns. • Better intelligence to identify trends of potential and actual failures. • Early warning of systemic issues through business understanding, ownership and commitment. • Focus on the symptoms rather than the causes, and understanding addressing systemic issues is not a quick fix.

11. Ongoing Maintenance • Critical element is sustainability – ensuring that: • Ongoing measurement program is embedded in the compliance function and supported by the business. • Monitoring of issues with reporting of systemic trends to senior management. • Data integrity reviewed and interrogated on a regular basis. • Feedback loops to prevent reoccurrence developed, monitored and reviewed.