The Banking Code Compliance Committee (BCCC) has expressed concerns about banks’ organisational capability – particularly in relation to how they equip and enable staff to comply with the Banking Code – the adequacy of staff training and the robustness of their compliance frameworks to identify the genuine root cause of breaches and prevent a recurrence.

The BCCC’s report, Building Organisational Capability, makes 17 better practice recommendations under five key areas:

• Communication strategy – that is effective and ensures employees understand the intent and importance of processes related to the Code’s customer protections.
• Learning and development – that goes beyond Code awareness to ensure all staff understand the Code’s role in the consumer protection framework.
• Systems, processes, and technology – that is designed for compliance and has the customer and employee’s needs at its centre.
• Robust compliance frameworks – that can accurately identify a breach, drill down to find the true root cause, and fix it to prevent it from happening again.
• Culture – that promotes customer-centric decision-making and empowers staff to take ownership of achieving fair customer outcomes.

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