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Conduct Advisory

Are you delivering behaviours and practices that embed positive customer and community outcomes in your business?

Society’s expectations of organisations have fundamentally shifted – we saw this play out over the past few years through the events leading into and examined at the Financial Services Royal Commission, and beyond. When it comes to conduct, all organisations are now under the spotlight – judged by the 1% of what goes wrong, not the 99% of what goes right.

Taking action to identify and address conduct issues is now imperative for senior leaders and Boards; it’s no longer good enough to wait for issues to present themselves.

Implementing a robust Conduct framework provides a systematic approach to help identify and address conduct vulnerabilities, and helps organisations to demonstrate a commitment to proactively identifying the ‘1%’.

Good quality, insightful reporting on customer outcomes, trends and the root causes of any incidents or breaches support senior management and board oversight and decision making, help identify new and emerging risks to fair and suitable customer outcomes, as well as opportunities for improvements to business processes and the products and services provided to customers.

We work with clients to design and assess frameworks to treat customers fairly, including the development of conduct, product governance, sales practices and complaints handling frameworks. We also help clients identify where they may be the most vulnerable to conduct issues, and help them to design and implement solutions to address these.

Our Solutions

We design and assess enterprise-wide conduct frameworks to support the proactive management of Conduct across the organisation.

We design and assess product governance frameworks to embed Conduct into the product lifecycle (including the Design and Distribution Obligations).

We design and assess sales practices frameworks including the design and assessment of balanced scorecards and consequence management frameworks to enable the delivery of fair and suitable outcomes for customers.

We design complaints handling policies and processes, assess the implementation and operational effectiveness of complaints handling in organisations, including operating models, and support with readiness reviews for the new ASIC Regulatory Guide 271 on internal dispute resolution. 

We design and assess vulnerable customer frameworks, and review readiness and compliance with the ever-increasing industry codes and compliance obligations that specifically relate to vulnerable customers. We also bring capabilities in voice analysis and data analytics to help support the identification and support of vulnerable customers.

We are the leading firm in Australia on the design and implementation of Customer Advocate roles in organisations. Members of our team helped define the ABA Customer Advocate Principles, and we performed the 2019 post-implementation of customer advocate roles in banks across Australia. 

Our Frameworks and Methodologies

An organisation’s Conduct definition will be unique to it. There is no one-size-fits-all framework that can be used to manage and monitor Conduct. Conduct definitions must also be aligned with the organisation’s strategic goals, and core values.

Deloitte’s Conduct Framework is made up of components of across five pillars. These are the parts or aspects of the business that need to be effectively managed and monitored to deliver on the Conduct definition. We use this framework as a basis when supporting clients to design Conduct Frameworks or identify conduct vulnerabilities.