Responsible selling and marketing

The Bank has instituted specific processes to ensure that the Treating Customers Fairly principles are closely considered when undertaking sales of investment products to potentially vulnerable customers. The Bank has defined vulnerable customers as those with no prior investment experience and who are elderly or have limited formal education. A suitability assessment is conducted for all customers, taking into account their investment experience, age, risk appetite, concentration risk and other relevant factors. Where a customer is considered suitable, the product is sold with clear and transparent risk disclosure, including guidance that investors should be prepared to hold the investment to full term, and the potential risk of loss of investment capital in certain circumstances.

As part of continuous improvement to meet customers’ needs, the Bank frequently engages external parties to conduct customer focus group surveys before launching a new product to better understand the needs of the target market.

In India and Pakistan there have been a number of problems experienced with the local postal system. After analysis of the root cause, the end of 2008 was dedicated to confirming up-to-date contact details with customers who contacted the Bank, to ensure the most efficient and convenient communication option was open to the customer to work round difficulties relating to the local postal system.

In addition, Consumer Banking has made it easier for customers to update contact details via a simple telephone call, rather than requiring written instructions. It has also accelerated the deployment of customer-friendly technology such as email and SMS alerts to assist customers in managing their transactions and accounts.