Our approach to human rights | Policies and reporting - NAB

Our approach to human rights

As well as being a signatory to the UN Global Compact, our commitment to respecting human rights is demonstrated by being signatory to, or otherwise guided by, several international standards and frameworks which incorporate human rights requirements. These include:

Respecting human rights shapes the way we embrace, support and treat our people, customers and communities. Our policies, practices and due diligence processes emphasise the requirement for all colleagues to respect human rights and avoid complicity in human rights abuses.

Read more about who we are.

Our policy

NAB’s Group Human Rights Policy sets out requirements for human rights to be incorporated into related policies, processes, frameworks and action plans that apply across NAB and our controlled entities (the Group). Our Group Human Rights Policy is approved by our Board and sets out requirements for how we address human rights in our interactions with customers, employees, suppliers and communities.

The Group Human Rights Policy applies across our business – mapping how we address human rights in our policies, practices and business operations.

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 2026 Sustainability Data Pack.

Human rights risk areaHow we reduce our risk
Our own operations
  • Operational risk assessment processes consider risks associated with business changes.
  • We consider ESG risk, including human rights and corporate structure changes.
  • People policies are in place covering diversity and inclusion, health, safety and wellbeing, accessibility, and gender equity.
Our customers
  • The Group performs a risk-based screening of business customers to determine whether they are in a high ESG risk-related sector or undertaking activities which may have high associated ESG risk (including human rights risk). Industry sectors and transactions with identified higher ESG risk (including human rights risk) require more detailed due diligence. The sectors are outlined in our High-Risk Sectors and Sensitive Areas list and Modern Slavery Matrix. For more detail refer to the Sustainability Risk Management section of our 2026 Annual Report (PDF, 16MB).
  • As a signatory to the Equator Principles, NAB considers the Equator Principles human rights requirements on relevant project-related transactions.
  • The Group has a Customers Experiencing Vulnerability Framework (PDF, 1MB) to help customers through serious illness, financial abuse, elder abuse, domestic and family violence and financial hardship.
Our supply chain
  • Standard contract clauses and our Supplier Sustainability Principles (PDF, 8MB) incorporate human rights related requirements.
  • New and recontracted suppliers undergo base level ESG screening, with those suppliers in higher ESG risk industry sectors also undergoing more detailed due diligence.
Our investment services
Our community
  • We have programs that address aspects of human rights in the community. This includes First Nations support, accessibility and financial resilience. 
  • Community impacts of project-related finance are considered in meeting the Equator Principles requirements where relevant.
  • Technology-enabled abuse is increasingly recognised as a feature of human impact crimes, particularly where perpetrators exploit digital channels to continue coercive, threatening or controlling behaviour. In practical terms, technology gives perpetrators another avenue to reach vulnerable people, including where traditional communication channels have been blocked or limited. This can include the misuse of online platforms, mobile services, digital accounts and payment systems to stalk, intimidate, harass or exert control over a victim-survivor.

    Within a financial services context, this abuse can present through the use of transaction descriptions, small-value payments, repeated transfers or other account behaviours that are designed primarily to deliver a harmful message or maintain unwanted contact. What may appear on its face to be a routine transaction can, in reality, carry significant human impact where the narrative attached to the payment is abusive, threatening or coercive. For vulnerable customers, this can reinforce fear, reduce their sense of safety and demonstrate that the perpetrator is able to continue exerting control through systems intended for legitimate financial activity.

    Criminals and perpetrators continue to adapt their methods developing increasingly sophisticated ways to misuse legitimate financial products and digital channels to facilitate harm. As these typologies continue to evolve, NAB's financial crime response must also continue to evolve through ongoing enhancement of detection capabilities, intelligence-led monitoring, operational processes and cross-functional collaboration to identify emerging risks and better protect vulnerable customers.

    NAB has been working to strengthen the identification of financial abuse through improved detection of transaction-based abuse and narrative abuse, including the misuse of payment description fields. This work recognises that financial crime typologies are not limited to traditional proceeds-of-crime activity but can also include behaviours that cause direct harm to individuals and communities. Better identification of these indicators supports earlier recognition of potential abuse, more informed escalation pathways and a stronger ability to intervene where banking products or services are being misused to harm vulnerable customers.

    This capability continues to be explored and enhanced through collaboration between financial crime teams and vulnerability teams, with a shared focus on improving detection, strengthening customer protection and reducing opportunities for perpetrators to exploit financial channels. Ongoing uplift in analytics, operational processes and frontline awareness will be important to ensure that suspicious or harmful behaviours are identified in a way that is both risk-based and sensitive to customer safety.

    The objective is to better protect vulnerable customers while supporting a broader organisational response to human impact crimes and technology-enabled abuse.

  • NAB regularly assists state and federal law enforcement agencies (LEA) on law enforcement investigations. For example, in one matter, a review of the customer’s NAB holdings found behavioural indicators and unusual transaction patterns consistent with alleged child offending. NAB’s investigation into this customer and its intelligence sharing assisted the LEA to further its investigations.

    In late 2025, NAB received a referral from a state-based law enforcement agency involving a young person suspected of online solicitation and the distribution of child exploitation material. What began as a financial review quickly revealed a far more serious and complex picture of vulnerability, coercion and exploitation.

    Early analysis identified that the young person had been receiving multiple payments from an unrelated adult NAB customer. The transaction references attached to those payments raised immediate concerns, suggesting coercion, threats and sexual exploitation. At that stage, the adult customer had not been identified by police, making financial intelligence a critical starting point for further inquiry.

    As NAB continued to review the adult customer’s accounts, further indicators emerged that pointed to broader criminal activity, including suspected drug dealing and fraud. The review also suggested the adult may have had control over the young person’s known contact details. On one occasion, the adult attended a NAB branch with the alleged young person who was observed with bruising to their face and neck, adding to concerns about the level of harm and control involved.

    Further police inquiries established that the young person had been living away from home for two years and had become caught in a destructive situation involving illicit drugs and sexual exploitation. Police investigations ultimately identified another adult who was obtaining sexual services from the young person in exchange for illicit drugs, accommodation, transport and other material gain.

    The seriousness of the matter escalated further when search warrants were executed at the adult’s home. Police located child abuse material relating to the young person, along with evidence consistent with individuals harboured in a sexual servitude-like environment. Two additional children found at the address were removed and placed into care.

    The adult NAB customer first identified through financial analysis remains subject to ongoing investigative action in connection with child exploitation matters. The case highlights the important role financial intelligence can play in identifying hidden harm, surfacing indicators of exploitation and supporting law enforcement efforts to protect vulnerable people.

Managing concerns and grievances

The Group recognises that it is important to listen and respond to concerns raised by customers and other stakeholders on a wide range of issues, including human rights. The Group is committed to doing business in a responsible manner which includes how the Group manages our 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 covered in our Human Rights Grievance Process (PDF, 565KB).

Customers or other externally impacted third parties can send concerns or feedback to grievances@nab.com.au, NAB Resolve (our complaints team), our independent customer advocate and our FairCall whistleblower service (PDF, 577KB) with details of the issue. Guidance on how to raise a concern is available in various languages, under the ‘Guidance in other languages’ 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
  • non-English speaking languages in the countries in which NAB operates.

You can also send grievances 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. Appropriate action may involve referring the matter to relevant authorities and/or engaging with the customer. Remediation processes will be considered if modern slavery is found to be occurring.

NAB actively promotes a Speak Up culture aimed at allowing everyone to feel welcome, included and empowered to express views, opinions, and concerns. We have established the Group Whistleblower Program as a safe and confidential channel for raising concerns about potential wrongdoing. The program is available to employees, directors, officers, former employees, contractors, suppliers, subcontractors and agents of the Group and subsidiaries across our operations.

Our Group Whistleblower Protection Policy (PDF, 577KB) outlines how to make a report, how we support and protect whistleblowers, and how reports are investigated. Concerns can be reported by contacting KPMG’s FairCall Service.

The FairCall Service is an independently monitored external hotline and reporting service operated by KPMG on behalf of the NAB Group. Concerns about potential wrongdoing can be reported, anonymously if preferred, via the following channels.

Full contact details for all channels and countries are available in the Group Whistleblower Protection Policy (PDF, 577KB).

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

Reporting on our performance

Our Performance and reporting and Policies and resources pages include more information on the actions we’re taking and how we manage human rights. The related documents listed below also detail additional information.

Related policies, frameworks and action plans

We recognise human rights concerns can arise in our own operations and 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 Free, Prior and Informed Consent (FPIC), and improper land acquisition.

In Australia, actions to address these concerns are included within the publication of NAB’s 2024-2027 Reconciliation Action Plan (PDF, 8MB), through continuing to progress our Inclusion and Diversity Strategy Framework and Accessibility Action Plan (PDF, 2MB), 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 women in senior leadership cohort target, and a target for staff that identify as Māori. Our annual reporting suite, modern slavery statements and BNZ’s sustainability reports include more details on how we’re addressing human rights.

NAB’s Group Human Rights Policy is implemented through 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, and within our credit, investment and supply chain related policies and requirements.

Refer to Performance and reporting and Policies and approach pages for more information on these areas, which are also addressed through the related documents listed below:

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