Fair Treatment of WRB clients

Collections & Recoveries

The Group has a set of comprehensive policies that govern collections and recoveries for all WRB segments, in line with the Group’s Enterprise Risk Management Framework and under the oversight of the Chief Risk Officer (CRO), WRB as Risk Framework Owner. Oversight and governance of WRB retail collections are also the responsibility of the WRB Risk function, with regular reviews of performance metrics and complaints handling data.

The Group’s credit policies outline the high-level requirements with respect to all WRB collections and recoveries, which include the following:

• Ensuring that all collections staff receive appropriate training and demonstrate sufficient familiarly with the relevant Code of Conduct and internal policies prior to undertaking any collection activities
• Providing fair and reasonable treatment to clients, regarding any allowed concession or waiver
• Adhering to all applicable legal and regulatory requirements, as well as aligning calling and visitation hours to local regulations and practices
• Monitoring and regularly reviewing all client interactions with the Collections teams, including complaints and feedback, to ensure compliance with the Group’s Code of Conduct, internal policies and effective management oversight
• Offering temporary or permanent modifications to loan terms when required

Across the Group, while the approach may vary across markets in-line with local regulations, programmes to assist retail banking borrowers in financial distress are detailed in local Collections departmental guidelines that comply with the Group policy requirements.
Each collection and recoveries process is designed to be transparent, efficient, and supportive, ensuring that both the Bank and the clients have the required information to manage the account and the financial distress situation.

All staff responsible for dealing with clients in financial distress are required to undergo mandatory training prior to commencement of any collection activities. In particular, training topics include the Group’s Code of Conduct and Ethics, principles of ‘treating clients fairly’, approaching situations with a client-centric mindset, understanding the client’s situation and using the right negotiation skills.
Existing staff also undergo regular training to refresh and reinforce appropriate ways of dealing with clients who are undergoing financial distress. Communications guidance is regularly updated to reflect common circumstances encountered in our markets.

Where external collections agencies are utilised, these agencies also undergo assessment and due diligence in accordance with the Group’s sourcing standards. Their staff must undertake the same training as the Group’s internal Collections teams and are subject to monitoring to ensure their conduct complies with Group Collections standards.

The retail collection process typically begins with a service-oriented reminder sent to the client. This could be in the form of an email, SMS, or a phone call, reminding them of the overdue payment and encouraging them to settle their account promptly and avoid late fees.

In cases where clients may face financial distress and are willing and able to pay through modified payment plans, the Collections team will have the due conversations and work with these clients to negotiate loan modification (further details below), settlement and payment plans that are affordable to ensure the best outcome for both parties.

Based on the strategic approach and the operating rhythm adopted, certain markets may utilise third party collections agencies, which specialise in recovering outstanding debts, to handle certain segments of collections and recoveries cases. The external agencies utilised are subject to ongoing oversight from the Group throughout the entire process to ensure adherence to the Group’s principles of respecting client rights and ensuring that all collection practices are ethical and lawful.

Loan modifications

Loan modification options may be offered to our clients in accordance with local regulations and the Group’s internal credit policies, which consider the most recently available information on the client’s income, expenditures and circumstances. Collections staff managing these arrangements are trained to discuss options thoroughly with clients to agree on restructured payments that are in alignment with their financial situation.