Our Key Commitments to You

We will be fair and honest in our dealings with you

21. We will act honestly and with integrity. We will be fair and responsible in our dealings with you. We will be clear in our communications with you.

We will focus on customers

22. We aim to deliver a positive customer experience over the life cycle of your product.

23. We will provide you with different ways to contact us – for example, by phone, or through our website or app, or through other communication channels. For some products, we may have more specific or limited ways to communicate due to the manner in which your product is offered, including for example, where a product is entirely online or managed by a third party.

24. We will use plain language and avoid using unnecessarily complex legal and technical words as much as possible when communicating with you. However, there may be times where this is unavoidable (such as when the law requires us to use particular words or to communicate with you in a particular way).

We will comply with our industry and legal obligations

25. We will comply with our obligations under the law and this Code. If we don't, and you are impacted, we will correct this in accordance with our legal obligations and our agreement with you.

26. If you are a Consumer and your contract with us is regulated under the National Consumer Credit Protection Act 2009 (NCCP Act), we will make an assessment about whether the credit contract is 'not unsuitable' for you. Schedule 1 of this Code provides additional information about how we will do this.

27. Loans that are for predominantly business or commercial purposes are not regulated under the NCCP Act. We will only provide our products to you where we believe you meet our product and lending requirements. Schedule 3 of this Code provides additional information about how we will do this.

We will deliver high standards of service

28. We will take reasonable steps to ensure our products are reasonably fit for their intended purpose and are as described in our terms and conditions, disclosures, marketing materials, and agreements with you.

29. We will respond to questions about the features of our products and how they work. We may do this in different ways (such as by publishing FAQs on our website or app).

30. We will not engage in pressure sales tactics.

31. We may require you to obtain independent advice before entering into a contract with us. We will tell you if this applies to you. You may need to get your own financial, legal or taxation advice if you have queries or questions about how our products may impact your financial or personal circumstances.

We will provide clear information about our products

32. We will give you clear and useful information about our products to help you make an informed decision about whether to use them.

33. Before you enter into a contract with us for a product, we will give you information about:

a. our product terms and conditions;

b. fees and charges;

c. interest (if this is applicable), or the total amount payable and the repayment amount (although this does not apply to revolving facilities, for example, where the total amount to be repaid depends on your use of the facility);

d. any other pre-contractual disclosures required by law; and

e. how we will notify you about any changes.

34. We will continue to provide you with clear and useful information over the life cycle of your product, including about any changes to the product, and any changes to your or our obligations.

35. We may give this information to you in different ways where the law allows us to (for example – in electronic and digital formats). Our terms and conditions will describe how we will communicate with you.

36. We will ensure disclosures about our fees and charges are up to date and accurate.

37. We will review our policies (such as credit assessment procedures, and the design and distribution framework for our products) in accordance with our review procedures or whenever events indicate that a review is required to ensure that our policies are current, comply with the law and align with our commitments in this Code.

We will ensure our staff and representatives are trained and competent

38. We will ensure that people who are authorised to act on our behalf (for example, our employees, agents, and authorised credit representatives (ACRs) where applicable) are adequately trained and are competent to engage with you in relation to our products.

We will tell you about commissions and other benefits we pay to Intermediaries

39. We (or our Intermediaries if we require it under our arrangements with them) will make information available about commissions and other benefits that might be paid to the Intermediary in connection with the distribution or referral of our products. For the avoidance of doubt, this does not include remuneration paid in relation to marketing and advertising of our products.

40. If you are a Consumer, we will disclose the amount of remuneration or other benefit if it is ascertainable at the time we make the disclosure.

41. If you are a Small Business customer or your product is not regulated under the NCCP Act, our terms and conditions, term sheet or other document related to your contract will refer to commissions or other benefits that we may pay to an Intermediary in connection with the distribution or referral of our products.

We will deal fairly with complaints

42. We will handle complaints promptly and fairly. We will make information about how you can make a complaint and how we manage complaints available on our website, app or other platforms we use, including information about timeframes for considering and responding to complaints.

43. We will provide you with clear information on what to do if we do not resolve your complaint in a way that is acceptable to you. This information may be different depending on the product we provide to you. See Part D of this Code for more information.

We will support and promote this Code

44. We will make this Code publicly available including, for example, via links to the AFIA website on our website or in our app or digital platform.

45. We will support the monitoring, supervision and ongoing effectiveness of this Code and ensure our staff are trained to put it into practice.

46. We will implement systems and processes to support our compliance with this Code, including taking steps to address any issues if necessary.