Given name
I have read the Submission Guidelines.
Name of organisation
Do you have any general comments on the revised AusNCP complaint procedures?
ANZ Group Holdings Limited ('ANZ') welcomes the opportunity to respond to this consultation.
ANZ generally supports the additional detail in this revision of the AusNCP procedures. In ANZ’s view, the proposed revisions are helpful in further clarifying and formalising the existing procedures.
ANZ welcomes the amendments to the procedure that support the protection of at-risk persons and groups, including those who raise concerns regarding business conduct (e.g. paragraphs 3 and 31.2).
Additionally, ANZ believes the requirements for parties to engage in good faith will enhance the value gained through the NCP process for both the notifier and the enterprise (e.g. paragraphs 40 and 44).
Do you have any comments on specific paragraphs or sections of the revised updated AusNCP complaint procedures?
Initial Assessment
Paragraph 30.2 –ANZ queries if the paragraph should refer to the ‘proposed outcome’ (vs ‘outcome’) as the examiner can amend the statement based on the parties’ comments at their discretion.
Paragraph 17 & 32 –ANZ queries if there will be any allowances against disclosure of sector in situations where a complaint is made against an enterprise in a highly concentrated sector or jurisdiction, where naming the sector would reveal the identity of the enterprise.
Final Statement
Paragraph 54 – ANZ appreciates that these constructive comments will be included in a final statement and supports the formalisation of this step in the procedure.