Human rights approach

Managing human rights risk

The majority of the Group's financial services businesses operate in Australia and New Zealand, with branches and subsidiaries located in Asia (China, Singapore, India, Vietnam and Japan), the UK, France and the USA.

As a financial services organisation, we’re exposed to human rights risk in five key areas. For each of these five areas, we consider salient human rights issues and vulnerable groups in developing mitigation actions to reduce our inherent risk. For details of our salient issues and actions we are taking – refer to our 2025 Sustainability Data Pack.

Case study: Enhancing capability to protect customer privacy

The right to privacy is recognised as a fundamental entitlement and is also one of the Group’s salient ethical issues.

Privacy measures and controls safeguard individuals from unwarranted interference with personal information, communications, and private life.

This year, NAB released new privacy learning modules focused on privacy as a legal and ethical right. These modules provide colleagues with a basic understanding of privacy obligations and highlight the finance sector’s high volume of privacy complaints, reflecting sector-wide customer dissatisfaction.

The modules explain customer privacy rights are and outline procedures for responding to privacy requests and complaints.

Case study: Protecting vulnerable customers from financial abuse

NAB is committed to safeguarding vulnerable Australians from financial harm. Preventative and detective controls are implemented to identify customers who may be at risk of exploitation by individuals with account access through Power of Attorney or third-party signatory relationships. In addition, NAB actively identifies customers who may be victims of domestic violence or sextortion by analysing transactions for abusive and persistent patterns.

Cases involving vulnerable customers are investigated by NAB's Customer Service Hub and financial crime teams who work closely with relevant government authorities to ensure protection and accountability. Controls on products and services are continuously reviewed to enhance the ability to protect customers as part of its ambition of becoming Australia and New Zealand’s most customer-centric company.

Managing concerns and grievances

The Group recognises that it is important to listen and respond to concerns raised by customers and other stakeholders on a wide range of issues, including human rights issues. The Group is committed to doing business in a responsible manner which includes how the Group manages its operations (including supply chain) and financing activities. Information on the Group’s processes for receiving, investigating and addressing human rights grievances or concerns (including grievances related to modern slavery and human trafficking) is provided in its Human Rights Grievance Process (PDF, 565KB).

Customers or other externally impacted third parties can raise concerns or feedback by sending an email to the Group’s dedicated email address (grievances@nab.com.au), NAB Resolve (our complaints team), our independent customer advocate and our FairCall whistleblower service (PDF, 574KB) with details of the issue. Guidance on how to raise a concern can be found in various languages, under the ‘Guidance in other language’ tab below. The languages chosen for translation were based on:

• High risk countries defined in the Global Slavery Index;
• Countries associated with NAB’s financing activities; or 
• Non-English speaking languages in the countries in which NAB operates.

Grievances may also be received via social media, direct correspondence, or external bodies such as the Australian Human Rights Commission. 

Where grievances or concerns are raised, each claim is investigated and addressed as appropriate. This may include engagement with customers and other stakeholders. As part of the investigation process, steps are taken to understand the issue(s) and take appropriate action. Appropriate action may involve referring the matter to the relevant authorities (in the case of suspicions or allegations of modern slavery) and/or engaging with the customer about areas of the organisation that the Group finances. If modern slavery is found to be occurring, remediation processes will need to be considered.

Reporting on our performance

You can find more resources and reports on the actions we’re taking and how we manage human rights on Performance and reporting and Policies and resources, which are also addressed through some of the related documents listed below:

• UN Global Compact Communication on Progress
• Modern Slavery and Human Trafficking Statement

Related policies, frameworks and action plans

We recognise human rights concerns can arise in our own operations, as well as via interactions with external parties – in particular, business relationships, customer interactions, financing and investments, supply chain management and the communities served.

We aim to proactively identify, assess and address human rights risks and impacts which may arise in business relationships with customers and suppliers, as outlined in the Group’s Human Rights Due Diligence process (PDF, 580KB). Human rights risks and impacts can arise from factors such as poor labour practices, modern slavery, lack of Free, Prior and Informed Consent (FPIC), and improper land acquisition.

In Australia, actions to address some of these concerns are included within the publication of NAB’s 2024-2027 Reconciliation Action Plan (PDF, 9MB); through continuing to progress our Inclusion and Diversity Strategy Framework and Accessibility Action Plan; and by reporting on progress against our gender representation and gender pay gap targets. In New Zealand, this includes a focus on pay equality; a woman in senior leader cohort target; and a target for staff that identify as Māori. More details of how we are addressing human rights are included in our annual reporting suite, modern slavery statements and BNZ’s sustainability reports.

NAB’s Group Human Rights Policy is implemented through a range of internal policies, processes, frameworks and practices covering areas such as discrimination, accessibility, harassment, workplace bullying, occupational health and safety, modern slavery, whistleblower protection, privacy, financial resilience and provision of responsible products and services, as well as within our credit, investment and supply chain related policies and requirements.

Refer to Performance and reporting and our Resources library for more information on some of these areas, which are also addressed through some of the related documents listed below:

• National Australia Bank Ltd Code of Conduct
• Environmental, social and governance risk management and ESG Risk Principles (PDF, 313KB)
• Managing financial crime
• Group Whistleblower Protection Policy (PDF, 574KB)
• NAB’s 2024-2027 Reconciliation Action Plan (PDF, 9MB)
• Supply chain management and Supplier Sustainability Principles (PDF, 8MB)
• Accessibility and inclusion
• Group Inclusion and Diversity Policy (PDF, 208KB)
• Discrimination and Harassment guidelines (PDF, 277KB)
• NAB AML CTF Statement (PDF, 792KB)
• Anti bribery and corruption policy (PDF, 116KB)
• Domestic and family violence
• Customer Care Kit
• Vulnerable customers
• NAB’s 2025-2026 Framework for Customers Experiencing Vulnerability (PDF, 1MB)
• NAB framework for customers who need extra support 2024 to 2026 (PDF, 2MB)
• Practical support to improve your financial wellbeing
• Extra care support services