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, Hong Kong, 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 2023 Sustainability Data Pack.

Case study: Assessing the human rights impact of AI

Automation is increasingly becoming a key area for banks, and while technological change can lead to advancements, there are also risks that arise from implementation that need to be well considered and balanced. AI systems have the capability to improve efficiency and increase customer satisfaction when engaging with banking services, and due to the special relationship that banks have with their customers, it is critical to ensure that any decision-making that uses AI systems is made ethically and with consideration to human rights. 

The Australian Human Rights Commission ('the Commission') sought to develop a Human Rights Impact Assessment (HRIA) Tool following its publication of recommendations in its Final Report: Human Rights and Technology including that private sector bodies should be encouraged to undertake HRIAs before using AI systems and that tools should be developed to assist them in doing so. 

The aim of the HRIA Tool is to assist banks in considering and measuring the risk to human rights posed by AI systems, implement strategies to address those risks and support the availability of remedies for any human rights violations. 

The Commission's partnership with NAB provided an opportunity to consult with our data ethics and analysis experts for feedback on the practicality and useability of the questions incorporated into the HRIA Tool. NAB considered it a valuable opportunity to help develop the HRIA Tool as it recognised that it is in both banks' and customers' interests, to ensure that it measures the risk to human rights posed by AI activities and to implement strategies to address those risks. 

In order to support development of the HRIA Tool, NAB coordinated input from a cross-functional group of colleagues working in areas including data science, human rights, finance, legal and customer service. 

The HRIA Tool builds upon the Commission’s work to develop practical guidance for the ethical use of AI systems for various sectors and businesses. 

Traditionally, banks employ a range of risk assessment tools. This tool can be tailored by banks and integrated into their data ethics assessment processes. To date, NAB has included various human rights specific questions into our own data ethics assessment process for review of more general data use cases. Now we will also consider human rights as a part of the risk assessment when considering use of AI tools. 

Copies of the Commission's Final Report: Human Rights and Technology and the HRIA Tool are available on the Commission's website, opens in new window.

More details of how we are addressing human rights are included in our annual reporting suite, modern slavery statements and BNZ’s sustainability reports, opens in new window. 

In Australia, these actions include the publication of an interim 2022-2023 Reconciliation Action Plan (RAP) while the application for our next three-year RAP (2024-26) is finalised; refreshing our Enterprise Agreement; continuing to progress our Inclusion and Diversity Strategy Framework and Group Accessibility Action Plan; and reporting on progress against our gender representation and gender pay gap targets.

Our Modern Slavery and Human Trafficking Statement outlines how we address this risk of modern slavery within our business operations and relationships. We have targets in place covering gender equality and supplier sustainability. 

We have a Human Rights Due Diligence process (PDF, 580KB), opens in new window which includes risk management processes designed to identify, assess, mitigate and monitor potential risk areas.

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), opens in new window. 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, 395KB), opens in new window 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.

In addition, the Group has a Whistleblower Protection Policy and associated Group Whistleblower Program. NAB actively promotes a Speak Up culture aimed at allowing everyone to feel welcome, included and empowered to express views, opinions, and concerns. Our Group Whistleblower Program provides a safe and confidential channel that allows employees and contractors to the Group to raise concerns about potential wrongdoings. Concerns can be reported by contacting KPMG’s FairCall Service, which is an independently monitored external hotline and reporting service.

KPMG’s FairCall Service is available for reporting modern slavery concerns. 

Our Group Whistleblower Protection Policy outlines how to make a report, how we support and protect whistleblowers, and how reports are investigated. The Group Whistleblower Program is available to all employees (including directors, officers, employees, former employees, contractors, suppliers, subcontractors and agents of the Group) and subsidiaries across our operations.

Grievances may also be received via social media, direct correspondence, or 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.

Should cases involve litigation, we will conduct ourselves in accordance with our Model Litigant Policy. 

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.

• UN Global Compact Communication on Progress, opens in new window
• 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.  

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, our Reconciliation Action Plan 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:

• National Australia Bank Ltd Code of Conduct
• Environmental, social and governance risk management and ESG Risk Principles (PDF, 313KB), opens in new window
• Managing financial crime
• Group Whistleblower Protection Policy (PDF, 395KB), opens in new window
• First Nation Australians support and Reconciliation Action Plan
• Supply chain management and Supplier Sustainability Principles (PDF, 8MB), opens in new window
• Accessibility and inclusion
• Group Inclusion and Diversity Policy (PDF, 920KB), opens in new window
• Discrimination and Harassment guidelines (PDF, 277KB), opens in new window