Introduction

Our Fair Conduct Programme (FCP) is designed to establish and maintain policies, processes, systems, and controls that to support fair treatment of our retail Customers. The FCP ensures that we comply with the fair conduct principle at all times.

This summary is intended to help our customers understand how we ensure fair treatment. It is provided in accordance with section 446H of the Financial Markets (Conduct of Institutions）Amendment Act 2022 (CoFI).

The BOCNZ Fair Conduct Programme will be reviewed at least once a year but will be updated when there is any material changes identified and required. The FCP was approved on the 22nd of November 2024 by BOCNZ’s Board of Directors.

Key elements of the programme

1.Governance of our Fair Conduct Programme

• The Bank of China (New Zealand) Limited (BOCNZ) Fair Conduct Programme is approved by and overseen by our BOCNZ Board.
• Various BOCNZ governance groups support the fair treatment for Customers, including the Board, Associated Committees, senior management and risk and compliance management oversight through monitoring and reporting activities.
• BOCNZ employs a Three Lines of Defence Model and maintains a regular cycle of internal assurance reviews across frontline processes based on different risk. Those reviews are endorsed by senior management, and the Board, who receive reporting on the reviews and actions arising out of those reviews.

2.How we meet our compliance obligations to Customers

• We have legal and compliance functions, which are supported by internal and external specialists where required.
• We administer compliance training, and compliance assurance for various legislative regimes and licenses for BOCNZ businesses.
• We monitor regulatory updates for the introduction of any new laws, regulations, and guidance from regulators.
• Oversight and governance of compliance is provided through reporting to senior management, and the Board.
• We maintain BOCNZ policies and processes, and third-party contracts that BOCNZ enters into with its partners. This supports awareness of, and compliance with, our compliance obligations that arise outside legislation and regulations.

3.How we review our products, services, and distribution methods

• BOCNZ products are distributed solely through BOCNZ employees including mobile mortgage managers. BOCNZ does engage BOCNZ accredited mortgage brokers to refer Customers to BOCNZ. However, BOCNZ does not presently engage brokers, agents, or other intermediaries to provide advice or sell financial products to Customers.
• BOCNZ conducts a quality assurance programme.
• Product and pricing decisions are subject to a governance framework that applies to the whole product lifecycle. This supports BOCNZ to:
  • Clearly identify its target market
  • Understand Customer needs (when considered as a group) when products are being designed
  • Provide staff training on products
  • Consider whether reasonable value is provided to Customers
  • Periodically review products to ensure they continue to meet Customers’ needs.

4.How we identify, monitor, and manage conduct risks

• Conduct risks are captured in BOCNZ’s risk management processes, including in its Risk Management Framework, and risk reports to senior management and the Board. Senior Management provides reporting to the Board on risk appetite metrics and periodically reviews conduct risk metrics.
• Frontline staff are supported in their identification, monitoring and management of conduct risks, via training and internal reporting.
• We maintain an incident management policy and process to support the identification, recording, escalation and reporting of incidents at BOCNZ. That process is supported with the use of a centralised incident management system and support from BOCNZ’s Operational Risk function.

5.How we oversee the conduct of our employees and agents

• BOCNZ hires people with relevant skills and experience for their roles. Staff are supported in their roles with:
  • relevant induction processes
  • training
  • supervision from their managers
  • performance management where conduct falls short of BOCNZ expectations.
• In addition, all BOCNZ staff are expected to conduct themselves in accordance with BOCNZ’s code of conduct. BOCNZ also has a Whistleblower Policy and Process to support staff to call out conduct that they feel falling short of expected standards.

6.How we train our staff

• We provide topical and technical training and coaching to staff where that training is relevant for the competent and capable performance of their roles.
• Training and training content may be delivered both internally and via external training providers.
• From 2025 we will provide training to all staff on the BOCNZ Fair Conduct Programme.

7.How we manage sales incentives for staff who sell BOCNZ products

• BOCNZ does not provide sales incentives to staff based on value or volume of sales. BOCNZ has a Renumeration Framework, which applies across the organisation, including staff involved in providing products to Customers. The Framework is regularly reviewed to ensure staff are renumerated and incentivised in a manner that aligns with BOCNZ’s obligations under all financial services licences BOCNZ holds.

8.How we communicate with Customers

• BOCNZ may communicate with Customers through various methods including phone, letter, email, video conference and face-to-face.
• Interactions with Customers may be recorded in BOCNZ systems and may include call recordings, email exchanges, and file notes from discussions between our staff and Customers.

9.How we conduct customer care and handle conflict with Customers

• BOCNZ has a complaints process to support Customers to make a complaint to BOCNZ about its products and services.
• That process includes, if required, escalation to the Chief Compliance Officer and to BOCNZ’s independent external dispute resolution scheme via the Banking Ombudsman which is a free dispute resolution service if necessary.
• Complaints provide useful feedback and insights to BOCNZ management and are reported accordingly.
• BOCNZ acknowledges that at various times certain Customers may be vulnerable and our staff will have due regard to Customers’ interests in these circumstances. In addition, for Customers who might be experiencing financial hardship, we have a hardship policy and process for Customers who may need assistance.
• If you are a retail Customer and have a complaint about BOCNZ or our products and services, you can access BOCNZ’s complaints process by clicking here: Make a Complaint.

Relevant services and associated products

Our Fair Conduct Programme (FCP) applies to all retail financial products and services we offer, ensuring that customers receive clear and transparent information and are treated fairly. According to Section 446E of the CoFI, our bank is classified as a "Financial Institution." As a registered bank, we provide a range of retail financial products and services, including Online Saver Accounts, Term Deposits, and Home Loans. To learn more about our products, please visit the links below:

• Online Saver Account
• Term Deposit
• Home Loan