Contents

Treating Customers Fairly

Accessibility

47. We will take reasonable steps to ensure that any website, app, or methods we use to communicate with you meet the kinds of accessibility standards (for example, the Web Content Accessibility Guidelines) that are relevant to our business and the methods by which we communicate with you.

48. If we become aware or you tell us that you need extra help to access our products because of accessibility factors (for example – because you are a person with disability or communication, hearing or visual impairment or language barriers) we will treat you with sensitivity, respect, understanding and empathy. We will take reasonable measures to support your interactions with us, having regard to the type of product and the channel the product is normally distributed through. This might include referring you to free external support services (such as interpreters or the National Relay Service).

Use of technologies

49. If we use customer-facing artificial intelligence (AI) as part of our business operations to provide products covered by this Code to you, we will have risk management processes to identify and mitigate risks in its use and we will monitor its operation to ensure it is compliant with relevant laws and standards that apply to us.

50. Customer-facing AI can include the autonomous or semi-autonomous analysis of data and content using sophisticated techniques and tools. It can also create content or output that is not programmed or copied from existing data, but is generated based on patterns, structures and examples learned from large datasets.

Privacy and confidentiality

51. We will handle your information, and information about your use of the product, in accordance with our Privacy Policy and the law.

52. We will comply with the privacy legislation including the Privacy Act 1988 and the associated standards in the Australian Privacy Principles, and the Privacy (Credit Reporting) Code 2025 (if applicable to us) which sets standards about participation in credit reporting and management of information and data (such as the collection, processing, storage, maintenance, use, transfer and disclosure of your personal information or data to other parties).

53. We will publish our Privacy Policy on our website, in our app or on our platform.

54. We will treat information that you give us or information that we collect about you (including through data collection techniques, such as screen scraping) in accordance with our Privacy Policy and the law.

Information and data protection

55. We will take reasonable steps to protect your personal information and data from misuse or loss and from unauthorised access, modification or disclosure. This may include asking you to re-verify your identity from time to time.

56. We will regularly review the security and reliability of our information systems.

57. We will aim to implement and maintain information security controls that are commensurate with the size and extent of the information risks and cybersecurity threats we may face.

58. We will apply security measures or access controls that are reasonably appropriate or necessary for the product you have with us (for example – account registration, password protection and/or multi factor authentication).

Security measures and controls

59. If we use additional security measures or controls (such as multi-factor authentication) to verify your identity, open an account or access our products, we will have regard to relevant standards and authentication protocols (including standards published by the Australian Government from time to time) when designing or updating our systems.

Scams and fraudulent activity

60. To help protect you from scams and fraudulent activity, we will not:

  • ask you for information like passwords, PINs or secure access codes in an unsolicited email, text, phone call or message;
  • ask for remote access to your computer or devices to “fix a problem” or send you software to download; or
  • ask you to make payments through unusual mechanisms (such as stored value cards or gift cards), or urgently transfer your assets or funds to another place to keep them “safe”.

61. If you receive an unsolicited contact asking for this type of information that appears to be from us or you are not sure whether a communication is legitimate, you should contact us via the contact details on our website, app or platform or another trusted source (such as the contact number on the back of your debit or credit card) to check.

62. If you believe you may have been the victim of a financial scam or some other fraudulent activity that involves our products or you notice suspicious or unusual activity in relation to your product, you should contact us as soon as possible. You can also contact Scamwatch or the police if you think a crime has been committed. IDCARE may also be able to help you in relation to identity theft.

Customers experiencing financial difficulties and other hardship

63. Financial difficulties or other hardship can occur for a range of reasons that are out of your control, including but not limited to:

a. change in income or employment status;

b. relationship breakdown;

c. illness or injury;

d. natural disasters.

64. If we become aware or if you tell us that you are experiencing financial difficulties or other hardship, we will work with you to identify ways we may be able to provide support in accordance with our policies. We encourage you to tell us about your circumstances as this is the best way to help us help you.

65. We will tell you how to contact us about financial difficulty and other hardship assistance arrangements on our website, our app or other digital platforms we may use.

Consumers

66. If your contract with us is regulated under the NCCP Act, you should tell us as soon as possible if you are experiencing financial difficulties or other hardship. You can do this yourself or through someone else you appoint to act on your behalf (for example - a lawyer, accountant, financial counsellor, or legal aid officer). We may ask you or the person acting on your behalf to complete a form to confirm you have provided your consent for the person to act for you.

67. We will provide information on our website, app or digital platform about how to contact us if you are experiencing financial difficulties or other hardship. We may also contact you to discuss your situation if it becomes apparent to us that you may be experiencing financial difficulties or other hardship.

68. We may ask you to give us information to help us understand your financial difficulties or other hardship and consider how we could help. Any help we can provide will depend on your circumstances and the information you give us.

69. We may provide you with a temporary or simple arrangement to help you or we may agree with you on a new repayment arrangement (called a “contract variation”). If we agree on a contract variation, this will be in writing (including in electronic form where permitted by law and our agreement with you).

70. We are not required to offer a temporary or simple arrangement or a contract variation, but we will provide assistance if we think it will help you recover your financial situation. We will tell you about the support we can provide after we have considered your circumstances and the information you have given us.

71. There are circumstances where we may not offer you a temporary or simple arrangement or contract variation, including (but not limited to) where we reasonably believe:

a. your financial position cannot be restored; or

b. it will, or is likely to, make your circumstances worse; or

c. you will not have an ability to repay the amounts you owe us after the period of financial difficulty or other hardship ends; or

d. we do not have sufficient information to substantiate your financial hardship.

Small Business Customers

72. If you are a Small Business customer and you tell us you are experiencing financial difficulties, we may consider reasonable modifications to your repayment arrangements or other terms and conditions of your contract, insofar as possible within our credit policies. We are not required to do so, but we will do our best to explore options that may help your business through a temporary period of difficulty.

People experiencing vulnerability

73. We are committed to helping customers who are experiencing vulnerability. If we become aware or if you tell us that you may be experiencing vulnerability, we will treat you with sensitivity, respect, understanding and empathy. We recognise that vulnerability may be temporary in some cases and/or can happen to anyone.

74. Characteristics of vulnerability may include (but are not limited to):

  • cognitive or other impairment;
  • family or domestic violence (including financial abuse);
  • age-related financial abuse;
  • mental health issues;
  • addiction-related issues;
  • serious illness or injury;
  • insecure housing or homelessness;
  • language or literacy barriers;
  • issues related to cultural norms and expectations; or
  • other personal or financial circumstances – for example, incarceration or institutionalisation, the serious illness or death of a partner or close family member, a relationship breakdown or some form of natural disaster.

75. We may not be aware of your vulnerability unless you tell us about it. If you tell us about your circumstances, we will consider how we can help to address the financial implications for the product we provide to you.

76. If you want to appoint someone to act on your behalf in your dealings with us, we will provide you with clear information about how you can do this.

77. The misuse of our products by another person (whether they are related or known to you, or not) to inflict economic, financial or emotional abuse on you is unacceptable. If we become aware this is occurring, we will do what we reasonably can to help minimise or stop the misuse.

Deceased estates

78. If you are the executor of a deceased estate or are otherwise entitled at law to deal with a deceased estate, we will do what we reasonably can (and as permitted under relevant laws, such as succession and privacy laws) to help you resolve or deal with the customer's financial affairs with us as quickly as practicable.

Transparent debt recovery practices

79. If a debt recovery process becomes necessary, we will act in accordance with our legal obligations. This includes (where relevant depending on whether your loan is regulated under the NCCP Act) our obligations to tell you about late or missed payments, to issue you with a written notice of a default prior to commencing legal proceedings or taking other enforcement action, and to generally give you a reasonable opportunity to remedy the default. However, if we reasonably think that the default cannot be remedied, we may have rights under your contract and at law to take action without telling you first.

80. We will only use as agents, and sell our debts to debt collectors, that to the best of our knowledge comply with the ACCC and ASIC Debt Collection Guideline.

81. The steps we may take to recover or on-sell your debt may be different depending on what type of Customer you are, the product you have, and the terms of your contract with us.

82. Schedule 1 sets out more information for Consumers about our debt recovery practices.

83. Schedule 3 sets out more information for Small Business customers covered by this Code about our debt recovery practices.