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1 Credit and Investments Ombudsman Reflect Reconciliation Action Plan September August

2 Cover page band artwork by Dreamtime Creative

3 Our business The Credit and Investments Ombudsman (CIO) is an independent and impartial service that helps consumers resolve complaints about financial services providers (FSPs) who are CIO members. Over 24,000 FSPs are CIO members, including finance brokers, non-bank lenders, credit reporting bodies, mutual banks, credit unions, building societies, motor vehicle finance providers, financial planners, timeshare providers, consumer retail finance providers, debt purchasers, and small amount lenders. We investigate complaints made to us and assist the affected parties to reach a fair outcome. Our service is free to consumers and small businesses. CIO staff joined a Heritage Walk in the Botanical Gardens Sydney during National Reconciliation Week. We are approved as an external dispute resolution (EDR) scheme by the Australian Securities and Investments Commission (ASIC) to operate in the financial services industry. In addition, we are recognised by the Office of the Australian Information Commissioner (OAIC) as an EDR scheme to handle privacy and credit reporting complaints under the Privacy Act As at 12 October, CIO employs 62 staff. Currently, CIO has no staff members from an Aboriginal or Torres Strait Islander background. We work closely with selected recruiting companies to attract new staff from an Aboriginal or Torres Strait Islander background. CIO operates nationally from its head office in Sydney. Yabun Festival CREDIT AND INVESTMENTS OMBUDSMAN 1

4 Our RAP The RAP will serve as a comprehensive strategy to enhance access to justice for First Australians. National Reconciliation Week We provide services for all consumers. We are concerned about barriers to access for consumers who are at risk of being at disadvantage including First Australians. Our Consumer Engagement Strategy addresses gaps in CIO s current outreach program, while promoting an awareness of CIO s services among a diverse range of consumers. The strategy targets barriers that may prevent consumers from accessing the scheme. The Reconciliation Action Plan (RAP) will support our strategy by removing barriers between Aboriginal and Torres Strait Islander communities and our services. Currently about 3% of our complainants identify themselves as Aboriginal or Torres Strait Islander peoples. While this figure is proportionate to the wider Australian population, we are concerned about consumers falling through the gaps of our outreach program. Social, cultural and economic factors relevant to Aboriginal and Torres Strait Islander consumers mean they are at a higher risk of falling victim to predatory mis-selling. Furthermore, they may be disadvantaged by impaired literacy and numeracy skills, and can find it a challenge to obtain documentary evidence in support of their complaints. Our RAP will promote reconciliation on a number of levels: Our RAP will formalise our efforts to foster cultural competence internally among our staff. We will support businesses owned by Aboriginal or Torres Strait Islander people by sourcing selected services from them. E.g. consumer resources aimed at First Australians as these suppliers have expertise in communicating with them effectively. We hope that our RAP will create employment opportunities for First Australians through a number of HR initiatives. As part of our RAP we will promote awareness and appreciation of Aboriginal and Torres Strait Islander peoples within our organisation. Many staff members were raised overseas so they have had very little exposure to Aboriginal and Torres Strait Islander peoples and the political, economic and social context of reconciliation in Australia. Our staff members will have the opportunity to participate in events for National Reconciliation Week and NAIDOC Week. Since 2016 we have provided opportunities for staff to engage with National Reconciliation Week and NAIDOC Week. In addition, cultural appreciation and training workshops have been held annually since Staff will also have the opportunity to receive training so they have a better understanding of issues which may affect complaints from consumers from an Aboriginal or Torres Strait Islander background. This would enable staff to provide a better service to First Australians. We want to ensure that Aboriginal and Torres Strait Islander peoples are represented within the staff demographics. For this reason, we have engaged Spearhead Careers which is owned by Aboriginal Employment Strategy Limited (AES). 2 CREDIT AND INVESTMENTS OMBUDSMAN

5 Our reconciliation journey to date Fortunately, Legal Aid NSW had great expertise in Aboriginal outreach and their field officers referred complaints from Aboriginal communities to us. We were also invited to visit community legal centres in rural NSW to interview Aboriginal consumers in relation to complaints they had made about consumer leases for household goods. Our case managers interviewed consumers to afford them more effective access to our services. The interviews allowed us to gain a deeper appreciation of the perspectives of consumers from Aboriginal or Torres Strait Islander backgrounds. Senior Lisa visiting communities in rural NSW. Our reconciliation journey began in 2014, when we first devised our Consumer Engagement Strategy (CES). Our strategy should ensure that every consumer in Australia knows about our services and remove any barriers to access. Our strategy has focused on groups that are at risk of disadvantage such as the elderly, people from culturally and linguistically diverse (CALD) backgrounds, and consumers identifying as First Australians. As a result, we participate in about 20 events annually, including events targeting First Australians (see p. 4), to reach out to the wider community. We also made our website more accessible by adding translations for CALD consumers. Recently, we added a video in Auslan for hearing-impaired users. In 2015, one of our s spent a week in the Northern Territory, raising awareness about our scheme within the local Aboriginal communities. We met with financial counsellors at the Money Workers Association NT (MWANT) Conference and numerous community service providers including the North Australian Aboriginal Justice Agency, Darwin Legal Aid Centre, Legal Aid NT and others. In conjunction with the 2016 MWANT Conference, we visited a remote community located in the Tiwi Islands, north of Darwin. The visit provided us with a deeper insight into the circumstances of Aboriginal consumers living in remote areas, and the effect that has in the way we deal with their complaints. When we sought feedback from financial counsellors and community legal centres, it became apparent that First Australians were among our more vulnerable stakeholder groups. We needed to become more proactive and expand our collaboration initiatives with community services providers to reach them more effectively. Financial counsellors told us that internet and telephone access is not always available in remote communities and that we have to factor in these issues when dealing with complaints lodged by First Australians. Furthermore, there were language, cultural, geographical, and technological barriers to consider. Senior James meeting residents on the Tiwi Islands, NT, during a visit organised by the Money Workers Association of the Northern Territory (MWANT). CREDIT AND INVESTMENTS OMBUDSMAN 3

6 All of our staff members have received training provided by the NSW Ombudsman's Office on Aboriginal cultural appreciation in 2014 and While the NSW Ombudsman is not an Aboriginal and Torres Strait Islander organisation, the two presenters were both from an Aboriginal background and shared their stories and knowledge with us. The workshop was instructive in providing culturally responsive, flexible and consistent services to First Australians. Our officers learned how to identify Aboriginal or Torres Strait Islander peoples over the phone so they can take their circumstances into consideration. Staff members are also able to retrieve information relating to Welcome to Country and Acknowledgement of Country and other resources from the staff intranet page. We formed our Consumer Liaison Committee (CLC) in The Committee encouraged an open exchange of ideas and feedback in relation to our outreach program and general complaint management process. The Committee enabled advocacy groups to collaborate more effectively with us and to discuss issues of mutual interest. One of the committee members also represents the Indigenous Consumer Assistance Network. At the first meeting, a CLC member suggested that CIO should develop a RAP in order to make our scheme more welcoming and accessible to First Australians. We have hosted stalls at a number of significant Aboriginal and Torres Strait Islander community events. In, we hosted a stall at the Yabun Festival in Sydney, which is one of the largest annual events celebrating Aboriginal and Torres Strait Islanders cultures. We also exhibited at the Musgrave Park Family Fun Day in Brisbane which is one of the largest annual NAIDOC Week events. In 2016 and, we hosted a stall at a Sorry Day community event in Adelaide to inform consumers about our services. In 2016, we celebrated National Reconciliation Week (NRW) which coincided with the Vivid Sydney festival where artworks by Aboriginal artists were projected on the sails of the Sydney Opera House. To mark the occasion, we invited our staff to a harbour cruise which was also operated by an Aboriginal-owned business. The following year, all staff were invited to join a guided tour of the Botanical Gardens to discover its Aboriginal heritage. The event took place on 2 June in conjunction with NRW. Over the past three years, we have participated in additional initiatives which supported our reconciliation journey. In 2015, we hosted a stall at the NAIDOC Family Fun Day in Dubbo, NSW. The following year, members of our would-be RAP working group attended a flag raising ceremony at the Sydney Downing Centre. NAIDOC Week 2016 was also promoted in our staff and consumer advocate newsletters. In, existing RAP Working Group members attended the NAIDOC in the City opening ceremony and encouraged staff to come along. We joined the Good Service Mob in 2016 to expand our outreach program. The Good Service Mob (NSW) is a group of agencies that provide free services to consumers. The group organises Consumer Forums for Aboriginal and Torres Strait Islander peoples living in remote communities in NSW. With our RAP we hope to improve engagement with consumers from an Aboriginal or Torres Strait Islander background, promote equality and make a meaningful contribution towards a reconciled Australia. The RAP is championed by CIO s and developed with the HR. 4 CREDIT AND INVESTMENTS OMBUDSMAN

7 Our partnerships/current activities Money Workers Association of the Northern Territory (MWANT) MWANT is the professional peak body for Financial Counsellors and Financial Literacy Educators in the Northern Territory. Their financial counsellors support numerous Aboriginal or Torres Strait Islander communities. We are actively involved in their annual conference and travel to the NT each year to train their staff and promote our services to Aboriginal communities. Senior James in NT meeting with representatives from MWANT and the Telecommunications Industry Ombudsman for the MWANT Conference. Indigenous Consumers Assistance Network (ICAN) A representative from ICAN is part of our Consumer Liaison Committee to make recommendations on our Consumer Engagement Strategy and general complaint management process. We currently work together with the following organisations to improve access for Aboriginal and Torres Strait Islander peoples to our scheme: Legal Aid NSW Legal Aid NSW refers complaints from Aboriginal and Torres Strait Islander consumers to us. We travelled to remote towns in New South Wales and interviewed Aboriginal and Torres Strait Islander consumers about complaints about a particular financial services provider specialising in the leasing of household goods. A representative from Legal Aid NSW is also a member on our Consumer Liaison Committee. Financial Counselling Australia (FCA) We present at numerous State and National Financial Counsellors Conferences throughout the year. These events are attended by many financial counsellors who provide services to Aboriginal and Torres Strait Islander consumers. Since 2014 we have participated in the FCA s annual Yarning Circle. These forums are organised by financial counsellors servicing consumers from an Aboriginal or Torres Strait Islander background. We have gained great insights into issues affecting consumers which allowed us to optimise our services. Ombudsman NSW The Ombudsman NSW has provided Aboriginal Cultural Appreciation Training to our staff since As many staff members were born overseas, the previous workshops were a great platform to facilitate basic knowledge about Aboriginal and Torres Strait Islander history and cultures. Australian and New Zealand Ombudsman Association (ANZOA) We are part of an interest group about Indigenous complaint handling. The group focuses on complaint entry point procedures, sharing information and resources, improving complaint handling practices, and procedures for Indigenous people of Australia and New Zealand. Good Service Mob The Good Service Mob (NSW) is a group of agencies that provide free services to consumers. The group has been organising Community Information Days for remote communities in NSW. CREDIT AND INVESTMENTS OMBUDSMAN 5

8 Relationships Action Deliverable Timeline Responsibility 1 Establish a RAP Working Group Form a RAP Working Group (WG) comprising of the CEO,, HR, and a participant outside the company who is from an Aboriginal or Torres Strait Islander background, possibly a financial counsellor. December Recruit WG member to represent First Australians. December and HR Develop Terms of Reference for our RAP WG. and HR s Host RAP WG meeting twice annually. December, July and HR 2 Build internal and external relationships Update and review a list of organisations focusing on consumer affairs and/or financial literacy among Aboriginal and Torres Strait Islander peoples. Update and review a list of other RAP organisations and other like-minded institutions we could approach to exchange ideas for RAP initiatives, particularly relating to outreach. January January Develop ideas for collaboration with RAP organisations within RAP WG. Working Group Track and report on relationship building progress. June 6 CREDIT AND INVESTMENTS OMBUDSMAN

9 Relationships Action Deliverable Timeline Responsibility Scan for NRW events that would be of April interest to staff. Promote these events on 3 the Staff News intranet page. Participate in and celebrate National Reconciliation Week (NRW) (27 May - 3 June ) Circulate Reconciliation Australia s NRW resources and reconciliation materials among our staff. Encourage staff to attend a NRW event via internal communication channels. Investigate opportunity to host a companywide social event. May May Ensure our RAP WG participates in an external NRW event. May 4 Develop Internal Awareness Plan to engage and inform key internal stakeholders of RAP responsibilities. October Raise internal awareness of our RAP Build and promote RAP intranet page. Inform new staff members about our RAP on induction day. September September HR CEO will update the Board and management on RAP progress. CEO RAP activities will be reported quarterly to internal stakeholders at Management Committee meetings., December, March, June Brief HR on all their RAP obligations. August CREDIT AND INVESTMENTS OMBUDSMAN 7

10 Respect Action Deliverable Timeline Responsibility Capture data and measure our December HR employees current level of knowledge 5 and understanding of Aboriginal and Torres Strait Islander cultures, histories and achievements. Investigate Aboriginal and Torres Strait Islander cultural learning and development Run Aboriginal Cultural Appreciation Training conducted by external education provider (e.g. NSW Ombudsman) annually to ensure newer staff * have the opportunity to learn more about Aboriginal and Torres Strait Islander cultures, histories and achievements. *staff that joined after the last training in August 2016 HR Consider inviting a traditional Land Owner to do a Welcome to Country through our Local Aboriginal Land Council. HR Develop quizzes within the Aboriginal Cultural Appreciation Training workshop to track knowledge among staff. December HR HR manager to review cultural awareness training needs within our organisation together with the RAP working group. September HR 6 Participate in and celebrate NAIDOC Week Promote NAIDOC Week internally to staff in the company newsletter. Cover NAIDOC Week in Consumer and Members Newsletters. Investigate Aboriginal site tours by the Metropolitan Local Aboriginal Land Council or local events for NAIDOC Week. July June Ensure RAP WG members participate in an external NAIDOC Week event. June 8 CREDIT AND INVESTMENTS OMBUDSMAN

11 Respect Action Deliverable Timeline Responsibility 7 Raise internal understanding of Aboriginal and Torres Strait Islander cultural protocols Approach Metropolitan Local Aboriginal Land Council by or phone for information regarding cultural protocols document for Welcome to Country and Acknowledgement of Country. Develop an Aboriginal and Torres Strait Islander cultural protocols document for Welcome to Country and Acknowledgement of Country. December February Post resources and protocols on our intranet page to provide staff with guidance around Welcome to Country and Acknowledgment of Country protocols. Add information about local Traditional Owners of the lands and waters to intranet page. January Develop list of local Traditional Owners of the lands and waters within our organisation s sphere of influence. December Prepare Acknowledgement of Country for CEO for the annual CIO Dispute Resolution Conference in Sydney. Refer to local Land Council website (Metropolitan Local Aboriginal Land Council) for events held in Sydney CBD. 8 Use existing resources to promote respect and/or RAP initiative Share dates of National Reconciliation Week and NAIDOC Week and promote other events celebrating Aboriginal and Torres Strait Islander cultures and information on staff intranet. Subscribe to external newsletters covering events to stay up-to-date. Post resources relating to Reconciliation Australia s Share Our Pride online tool on staff intranet and encourage staff to use them. Promote the RAP program in our members newsletter to encourage them to adopt their own RAP. January Cover RAP in the Annual Report on Operations Stakeholder Engagement section to promote the initiative externally. August CREDIT AND INVESTMENTS OMBUDSMAN 9

12 Opportunities Action Deliverable Timeline Responsibility Ensure all recruitment campaigns are January HR manager forwarded to Spearhead Careers to alert 9 job seekers from an Aboriginal or Torres Strait Islander background. Investigate Aboriginal and Torres Strait Islander employment Review HR Policies to encourage employment of Aboriginal and Torres Strait Islander peoples. Develop and implement an Aboriginal and Torres Strait Islander employment and retention strategy. HR manager HR manager 10 Investigate Aboriginal and Torres Strait Islander supplier diversity Investigate how we can incorporate supplier diversity principles into our procurement strategy. Develop an understanding of the mutual benefits of procurement from Aboriginal and Torres Strait Islander owned businesses. Develop a business case for procuring goods and services from Aboriginal and Torres Strait Islander businesses: consider outsourcing media products (brochure or video) to creative agency. Use Supply Nation to source creative agency. October December January January and Admin 10 CREDIT AND INVESTMENTS OMBUDSMAN

13 Opportunities Action Deliverable Timeline Responsibility 11 Make CIO more accessible to consumers identifying as Aboriginal or Torres Strait Islander people Commission a consumer brochure aimed at First Australians. Release brochure: upload to website, send to selected RAP organisations, and consumer advocates including those representing First Australians. Conduct annual audit of closed complaints from Aboriginal or Torres Strait Islander consumers to identify areas that need to be improved. We will consider aspects such as: Method of communication Timelines Outcomes Survey responses/feedback Complaints issues Service/product complained about January January Risk and Compliance Team Audit results to be shared at RAP WG meetings. Host a stall at three or more outreach events aimed at Aboriginal or Torres Strait Islander consumers annually before the end of the financial year. June Events 12 Explore collaboration opportunities with community services providers Investigate opportunity to conduct workshops and train frontline community workers at organisations, e.g. workshops held in the NT for local financial counsellors with an Aboriginal or Torres Strait Islander focus. Mail consumer brochure for First Australians and other consumer resources to other RAP or like-minded organisations. June February Financial Hardship Senior CREDIT AND INVESTMENTS OMBUDSMAN 11

14 Tracking and Progress Action Targets Timeline Responsibility 13 Build support for the RAP Develop and update a Development and Implementation Plan and timeline. Plan budget for future RAP initiatives. Develop and update an Internal Awareness Plan to track, monitor and report on the progress of all internal RAP activities. Complete the RAP Impact Measurement Questionnaire and submit to Reconciliation Australia. 30 September 14 Review and Refresh RAP Liaise with Reconciliation Australia to develop a new RAP based on learnings, challenges and achievements. Submit draft RAP to Reconciliation Australia for formal review and endorsement. July September 12 CREDIT AND INVESTMENTS OMBUDSMAN

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16 RAP contact Christian Haag and Events Case Management E info@cio.org.au T F PO Box A252 Sydney South NSW 1235 Credit and Investments Ombudsman Limited ABN