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 2024 Sustainability Data Pack.

Case study: Human rights in the agricultural sector

The Australian economy relies heavily on seasonal and migrant labour, especially in the agricultural sector. A range of unions, academics, and human rights focused non-government organisations and the NSW Anti-Slavery Commissioner have raised concerns about potential for modern slavery in the Australian agricultural sector. 

In 2018 the Fair Work Ombudsman’s inquiry in workplace practices in the agricultural sector found evidence of illegal labour hire arrangements and misused of piece rates. Concerns have also been raised in Senate hearings about occurrences of unsafe conditions and indentured labour relating to use of Pacific seasonal workers. 

These issues present human rights risks NAB considers, where appropriate, when undertaking its credit risk assessment and due diligence processes. ESG risk assessment of customers forms part of these processes and involves consideration of customers’ ESG-related performance and how they are managing ESG risk, including human rights, in accordance with exposure-related trigger thresholds and ESG-related policy requirements. 

Our ESG risk assessment has identified some instances of poor labour practices related to use of labour hire companies. Where risks like these have been identified, ongoing customer relationship management includes engagement with customers to discuss their ESG-related performance, issues and initiatives. If there is evidence of systemic non-compliance or material ESG performance issues, including those relating to human rights, this may result in termination of the customer relationship if these issues are not addressed.

Managing concerns and grievances

The Group recognises 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 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, 920KB)
• Discrimination and Harassment guidelines (PDF, 277KB)
• NAB AML CTF Statement  (PDF, 792KB)
• Anti bribery and corruption policy (PDF, 116KB)