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  • 1. Commonwealth Bank of Australia Disability Action Plan October 2008 Commonwealth Bank of Australia ABN 48 123 123 124
  • 2. Table of Contents Page Page 2 of 18
  • 3. 1. Introduction 1.1 Context The Commonwealth Bank is one of Australia’s leading providers of integrated financial services including retail, business and institutional banking, funds management, superannuation, insurance, investment and broking services. The Bank has the largest customer base of any Australian bank and employs more than 35,000 people. Our customers have more opportunities to access financial services than those of any other financial institution. Customers can access funds through:  Australia’s largest ATM and EFTPOS networks with approximately 3,300 proprietary ATMs and more than 187,000 EFTPOS terminals  Australia’s largest branch network.  A relationship with Australia Post that provides retail banking services at approximately 3,800 outlets  More than 514 Australia Post sites that service our small business customers  120 private agencies providing retail banking services  24 hours a day, seven days a week telephone banking services  24 hours a day, seven days a week online facilities that include NetBank for Internet banking and CommSec the country's most popular online broking service The Bank continues to undertake transformational change to its culture, service systems and people engagement models to improve its customer service focus. Page 3 of 18
  • 4. 1.2 Aim of the Disability Action Plan The Bank has developed and implemented this Disability Action Plan (DAP) to ensure that equity of access to its services is increasingly offered to all customers who wish to use them, and ensure that staff with disabilities are not discriminated against. 1.3 Definition of a Disability The Disability Discrimination Act (DDA) 1992 (Commonwealth) defines disability in relation to a person as:  total or partial loss of a person's bodily or mental functions  total or partial loss of a part of the body  the presence in the body of organisms causing disease or illness  the presence in the body of organisms capable of causing disease or illness  the malfunction, malformation or disfigurement of a part of the person's body  a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction  a disorder, illness or disease that affects a person's thought processes, perception of reality, emotions or judgement or that results in disturbed behaviour The relevant objective of the Disability Discrimination Act is to eliminate, as far as possible, discrimination against persons on the grounds of disability in the provision of services relating to banking, insurance, superannuation and the provision of loans, credit or finance. This action plan will assist the Bank to comply with the requirements of the Disability Discrimination Act by identifying our legal responsibilities through extensive operational auditing. More importantly, however, this plan will continue to raise awareness, amongst our staff and customers, of the principle of inclusion that underpins our service and employment philosophies. Page 4 of 18
  • 5. 1.4 Plan development The DAP was introduced in 2004 with input from all areas of the Bank that serve and support customers. The Bank conducts regular audits of customer access points to identify areas where service could be improved for customers with disabilities. We also assessed the Bank's services against the banking industry’s standards for electronic banking. The DAP in draft form was referred to various community groups and submitted to the Bank’s Executive Committee for approval before lodgement with the Human Rights and Equal Opportunity Commission (HREOC). The DAP is regularly updated to specify the outcome of successfully completed actions, identify any new actions and provide a status update on actions still in progress. 1.5 Consultation The Bank periodically may consult with key community groups as part of the ongoing development of the DAP. Groups that may be engaged in discussions with the Bank include:  Human Rights and Equal Opportunity Commission (HREOC)  National Council on Intellectual Disability  Women with Disabilities Australia  Blind Citizens Australia  Australian Association of the Deaf  Australian Federation of Deaf Societies  Head Injury Council of Australia  Physical Disability Council of Australia  National Ethnic Disability Alliance  National Association of People with AIDS  National Disability Services  Carers Association of Australia  Council on the Ageing Page 5 of 18
  • 6. 1.6 Voluntary Standards for Electronic Banking Accessibility The Bank, as a member of the Australian Bankers' Association (ABA), worked with the Human Rights and Equal Opportunity Commission, the Accessible E-Commerce Forum and other stakeholders to develop voluntary industry standards that aim to improve accessibility to electronic banking – ATMs, Internet, EFTPOS and Telephone Banking - for persons with disabilities. The Bank currently meets many of these voluntary standards and is using this DAP to adopt many more. To view the Australian Bankers’ Association’s voluntary standards on Electronic Banking Accessibility follow the links below:  Automatic Teller Machines (ATM) http://www.bankers.asn.au/ArticleDocuments/ATM.pdf  Electronic Funds Transfer Point of Sale (EFTPOS) http://www.bankers.asn.au/ArticleDocuments/eftpos.pdf  Automated Telephone Banking http://www.bankers.asn.au/ArticleDocuments/IVR.pdf  Internet Banking http://www.bankers.asn.au/ArticleDocuments/WEB.pdf Page 6 of 18
  • 7. 2. Goals and Actions The Bank: • Provides access to banking and financial services for our customers in a number of different ways. • Supports employees with a disability and their managers in the workplace. The following points summarise the goals we have set and the actions we have taken or are committed to taking to improve the accessibility of our services and workplace. 2.1 Premises Actions in this section will be completed to help achieve the goal of all premises being accessible to persons with disabilities. The Bank has:  Established a process to monitor changes to the Building Code of Australia and relevant Australian Standards as they relate to access for persons with disabilities.  Audited all branches, using qualified personnel, to identify areas of non-compliance with the Building Code and Standards so that these could be rectified.  Continued to upgrade branch accessibility, with the majority of all branches now accessible to customers with a disability.  Designed and installed new branch equipment and fixtures to improve access for persons with a disability. For example new counters with wheelchair access and new telephones with larger numerals and buttons for customers with vision impairments.  Added to the site selection process for new retail premises and new business banking premises, the need to assess each site in terms of the access requirements for customers and staff.  Completed construction of a new office building in Parramatta that is fully accessible by any staff with a disability.  Established a new design for branches that incorporates accessibility improvements for all customers, including those with a disability. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Ensure all new Business Banking sites comply or have a plan Ongoing detailing how they can comply with the Disability Discrimination Act in relation to accessibility for persons with a disability. 2. Upgrade branch premises to provide access for customers with a Ongoing disability, subject to building heritage and existing site constraints. 3. Construct three new office buildings in Sydney Olympic Park which December are fully accessible for all staff, including those with a disability. 2009 Page 7 of 18
  • 8. 2.2 ATMs Actions in this section will be completed to help achieve the goal of all ATM banking services being accessible to persons with disabilities. The Bank has:  Consulted with and gained feedback from community groups on how to improve ATM banking services.  Installed 75 ATMs with enhanced frontal access and over 1100 audio enabled ATMs improving accessibility to customers with a disability.  Provided information on the Bank’s website that will enable customers to locate ATM banking services with improved accessibility features. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Actively consider the needs of persons with disabilities in relation Ongoing to ATM banking services. 2. Upgrade our ATMs to include features that specifically assist Ongoing persons with disabilities. These include audio capability, easier frontal access, improved identification signage and increased lighting. 3. Continued, regular provision of information on the Bank’s website Ongoing to keep customers informed of locations of ATMs which assist persons with disabilities. 4. Install in every branch which offers an ATM banking service, one Ongoing audio enabled ATM. Page 8 of 18
  • 9. 2.3 EFTPOS Actions in this section will be completed to help achieve the goal of providing merchants with EFTPOS facilities that allow ease of access to electronic banking services for customers with a disability. The Bank has:  Ensured that all EFTPOS terminals comply with ‘priority one’ Australian Bankers’ Association voluntary standards for electronic banking.  Upgraded 78,000 EFTPOS terminals, representing 43% of our terminals, to comply with over 90% of ‘priority two’ Australian Bankers’ Association voluntary standards for electronic banking.  Continued the rollout of a new EFTPOS terminal that includes increased character size and background contrast on terminal display as well as greater differentiation between keys. For example increased spacing between buttons and exaggerated tactile difference between number buttons and special function buttons. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Continue to comply with ‘priority one’ voluntary standards in Ongoing relation to EFTPOS machines. 2. Endeavour for 55% (99,000 terminals) of the Bank’s EFTPOS fleet June to comply with “priority two” voluntary standards on Electronic 2009 Banking. The result of this will be easier and clearer swiping of cards and pressing of buttons. 3. Ensure that approximately 65% (108,000 terminals) of the Bank’s June EFTPOS fleet will comply with the identified voluntary standards on 2009 Electronic Banking. Page 9 of 18
  • 10. 2.4 Internet Actions in this section will be completed to help achieve the goal of providing equity of access to internet banking for all customers. The Bank has:  Ensured employees and technology partners who develop and maintain our Internet sites have access to relevant guidelines on improving access to and useability of our websites. This includes the Australian Bankers’ Association voluntary standards for electronic banking.  Made changes to our Internet sites to improve accessibility and navigation for vision impaired people and customers using screen reading technologies. Examples of this include providing a text equivalent for every non-text part of our sites, eliminating any flickering text or images, allowing login without the use of mouse and providing a method to register using the telephone instead of online. In addition, visually disadvantaged customers may request a ‘comfort voice’ security token which provides the increased security offered by two factor authentication.  Simplified our Internet sites for easier usage. Examples of this include ensuring plain English is used, minimising the number of keystrokes needed for transactions and making tutorials available to assist users access our online services.  Advised all customers of any significant web site changes and provided instructions on what has changed to ensure continued use of our services.  Trained call centre staff on how customers with disabilities access online services.  Developed a testing process which considers World Wide Web Consortium (W3C) guidelines on Web Accessibility Initiatives (WAI) and Australian Bankers’ Association voluntary standards for electronic banking. Also developed a program where disability support groups provide input and undertake testing of our Internet Banking site (NetBank).  Added a function on the CommBank web-site where visually-impaired customers can enlarge the font to make it easier to read.  Redeveloped both the retail banking section of the ‘Personal Centre’ of the commbank.com.au website as well as the ‘About Us’ (shareholder information section) to improve accessibility by adhering to the voluntary Australian Bankers’ Association standards. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Web development teams will consider the Australian Bankers’ Ongoing Association voluntary standards for electronic banking when designing and developing web sites. 2. CommBiz, the Bank’s Business website, will undergo compliance Ongoing testing to improve access and useability through the voluntary standards for electronic banking. 3. Future redevelopment of other sections of the commbank.com.au January website will be completed on a project by project basis. 2009 Page 10 of 18
  • 11. 2.5 Telephone Banking Actions in this section will be completed to help achieve the goal of providing equity of access to telephone banking for all customers. The Bank has:  Commenced offering a choice of automated or operator assisted Telephone Banking services 24 hours a day, 7 days a week.  Ensured the Bank’s General Telephone Banking system complies with ‘priority one’ Australian Bankers’ Association voluntary standards for electronic banking.  Ensured that the Bank’s General Telephone Banking system complies with most ‘priority two’ and ‘priority three’ Australian Bankers’ Association voluntary standards for electronic banking.  Assessed and developed a strategy to implement technology upgrades required by the General Telephone Banking system to meet ‘priority two’ Australian Bankers’ Association voluntary standards for electronic banking.  Provided telephone typewriter (TTY) banking services that specifically assist customers who have a hearing or speech impairment.  Provided clear information to hearing impaired and speech impaired customers about how to utilise services offered by the National Relay Service, both online and in ‘how to use’ telephone banking material.  Replaced the Bank’s main Interactive Voice Response (IVR) technology platform so that the General Banking telephone system meets all ‘priority one’ and ‘priority two’ Australian Bankers’ Association voluntary standards for retail electronic banking. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Continue to comply with ‘priority one’ Australian Bankers’ Ongoing Association voluntary industry standards in relation to the General Banking telephone system. 2. Continue offering operator assisted banking through our Telephone Ongoing Typewriter service (TTY) on 1800 240 889 from 8am to 8pm Monday to Friday. Page 11 of 18
  • 12. 2.6 Staff Awareness Actions in this section will be completed to help achieve the goal of raising staff awareness and understanding of the Bank’s commitment to provide equity of access to banking services for all Australians. The Bank has:  Communicated the content of the DAP and annual updates to employees.  Ensured employees are aware of our Telephone Typewriter (TTY) service for hearing impaired customers and Braille statements for vision impaired customers.  Continued to offer fee exemptions to customers who are unable to use self-service banking because of a disability. These exemptions can be found in the relevant account Terms and Conditions, accessible on the commbank.com.au website.  Continued to make available Equal Employment Opportunity (EEO), discrimination and harassment policies to all employees via the Bank’s Human Resources intranet site.  Launched a diversity awareness on-line learning program in 2007. The program, available to all employees, looks at the various myths that exist with regard to diversity, including employing a person with a disability.  Identified disability as one of the Bank’s five key diversity areas (for 2008-2010), which are endorsed and supported by the Bank’s Diversity Council, chaired by the CEO.  Provided employees with information on the Bank’s DAP and showcased employee disability case studies on the Bank’s Diversity intranet site.  Launched a new and refreshed Group Orientation program in September 2008. The program includes an updated EEO module which provides information on the Bank’s obligations under the Disability Discrimination Act, employee rights and responsibilities and directs employees to the DAP. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Continue to profile disability case studies on the Bank’s Ongoing Diversity intranet site. 2. Provide disability awareness training to hiring managers (as part Ongoing of our relationship with Disability Works Australia) Page 12 of 18
  • 13. 2.7 Communication Actions in this section will be completed to help achieve the goal of raising awareness in our customers, our shareholders and the broader community of the Bank’s commitment to provide equity of access to banking services for all Australians. The Bank has:  Provided online access to the Bank’s DAP in an accessible format for interested community groups or customers.  Provided information on the Bank’s website about services designed to improve access for customers with disabilities. For example locations of audio assisted ATMs.  Communicated periodic updates of the DAP to interested community groups. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Continue to communicate details of improvements to our services Ongoing and facilities providing equity of access to banking services. Page 13 of 18
  • 14. 2.8 Technology Actions in this section will be completed to help achieve the goal of having specialised technology available for use by staff and customers with a disability. The Bank has:  Made available to staff clear instructions on the process to request specialised hardware or software that will better enable staff with disabilities to carry out duties in the working environment.  Developed a process to consider the needs of persons with a disability at the concept phase of any new systems and technology projects.  Removed the need for customers to fill in deposit and withdrawal forms at Branches.  Continued to issue Braille Statements and Audio Statements to vision/hearing impaired customers that request this service.  Continued to offer operator assisted banking through our Telephone Typewriter service (TTY) to hearing impaired customers.  Committed to ongoing work with the Australian Bankers Association to establish guiding principles around authentication methods for banking services which will balance accessibility with other considerations like security.  Provided visually based (shown with subtitles) customer and marketing information on in-branch televisions. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Periodically review the specialised hardware on offer to better Ongoing enable staff with disabilities to carry out their duties in the working environment. This includes keyboards, mouse, screens and telephones. 2. Review the process to consider the needs of persons with a Ongoing disability at the concept phase of any new systems and technology projects. Page 14 of 18
  • 15. 2.9 Staff Employment Actions in this section will be completed to help achieve the goal of complying with the Disability Discrimination Act in relation to staff employment. The Bank has:  Reviewed the Bank’s EEO policy with specific focus on disability discrimination.  Provided employees with disabilities and their managers with an information resource about workplace adjustments. The Managers Guide to Working with Employees with a Disability is available to all employees via the Bank’s intranet and aims to provide information on: - Why team members with a disability are important to the Bank. - Performance, Feedback and Reviews for staff with a disability. - Information about disability types and support available.  Provided information and support to employees who are carers by placing information and a link to Carers Australia website on the Bank’s Human Resources intranet site.  Established a partnership with beyondblue, the national depression initiative and conducted workshops for employees on how to deal with mental health issues in the workplace.  Partnered with Diversity Dimensions to place a small number of individuals with mild physical and intellectual disabilities, across the organisation.  Entered into a relationship with Disability Works Australia to increase the number of new staff with a disability. Actions which have commenced or are about to commence include: Action Desired Completion Date 1. Work with Business Units to identify employment opportunities for Ongoing people with a disability and liaise with Disability Works Australia to place suitable candidates. 2. Promote mental health awareness workshops during mental health November 2008 week. 3. Conduct a review of the Bank’s health and wellbeing initiatives to March 2009 improve their effectiveness, including those relating to people with a disability. Page 15 of 18
  • 16. 2.10 Measuring effectiveness Actions in this section will ensure the effectiveness of this DAP by confirming that commitments made are being met as well as evaluating if any new policies and programs are to be added. All of these actions are ongoing: Action Process 1. Establish and  The Bank will establish and maintain a working group of maintain a subject matter experts from each area that has committed to working group for complete an action within this document and interested the DAP parties. 2. Monitor progress:  The Diversity team and working group will monitor the progress made against each action contained within the DAP.  If required, the DAP will be updated. 3. Review content:  The Diversity team and the working group will review the content of the DAP annually to ensure the actions remain relevant to the Bank’s business and objectives, and to the overall aims of the DAP. 4. Add new  The Diversity team will develop and maintain a register of commitments: issues and concerns brought to the attention of the Bank by customers and staff with disabilities.  The Diversity team and working group will discuss ways to improve accessibility, for example by assessing emerging technologies or new standards.  If required, the DAP will be updated. Page 16 of 18
  • 17. 3. Contacts and Links 3.1 Commonwealth Bank Customer Relations 1800 805 605 or the online feedback form For feedback about our DAP, feedback about technology that is available to assist persons with disabilities, other suggestions, compliments or complaints about the Bank's services. 3.2 Human Rights and Equal Opportunity Commission (HREOC) Michael Small (Disability Policy Officer) http://www.hreoc.gov.au 3.3 Australian Bankers' Association To view the standards for providing access to electronic banking services for persons with disabilities click on the following link: http://www.bankers.asn.au/Default.aspx?ArticleID=344 3.4 AUSLAN (Australian Sign Language) Interpreters Deaf Services QLD: Phone: (07) 3892 8500 Fax: (07) 3392 8501 Email: dsq@deafsq.org.au Online: https://www.secure-vault.com/~qds/irform.php Deaf Society of NSW: (Also covers the ACT) Phone: (02) 8833 3611 Fax: (02) 8212 5836 Email: interpreting@deafsociety.com Online: http://www.deafsocietynsw.org.au/interpreting/index.html Victorian Deaf Society: Phone: (03) 9473 1117 or (03) 9473 1118 Fax: (03) 9473 1144 Email: vais@vicdeaf.com.au Online: http://vais.vicdeaf.com.au/ Royal South Australian Deaf Society: (Also covers Northern Territory) Phone: (08) 8223 3335 Fax: (08) 8223 7536 Email: interpreting@deafcando.com.au Online: http://www.deafcando.org.au/ Tasmanian Deaf Society: Phone: (03) 6249 5144 (Hobart) Fax: (03) 6249 8818 Phone : (03) 6331 9766 (Launceston) Email: reception@tasdeaf.org.au WA Deaf Society: Phone: (08) 9441 2623 Fax: (08) 9441 2600 Email: bookings@wadeaf.org.au Online: http://www.wadeaf.org.au/form.php?fid=5 Page 17 of 18
  • 18. Glossary ABA Australian Bankers' Association ABA Standards The Australian Bankers’ Association's standards for access to electronic banking services for persons with disabilities Accessibility Providing customers with disabilities equity of access to banking services ATM Automatic Teller Machine AUSLAN Australian Sign Language CommSec The Commonwealth Bank's Internet broking service DAP Disability Action Plan DDA Disability Discrimination Act 1992 (Commonwealth) EEO Equal Employment Opportunity EFTPOS Electronic Funds Transfer at Point of Sale HREOC The Human Rights and Equal Opportunity Commission IVR Interactive Voice Response NDS National Disability Services NetBank The Commonwealth Bank's Internet banking service The Bank Commonwealth Bank of Australia TTY Telephone Typewriter - typing attachment that allows the hearing or speech impaired to communicate via the telephone W3C World Wide Web Consortium which has published internationally recognised guidelines for making web content accessible to people with disabilities. WAI Web Accessibility Initiative is one of the standards set out by the W3C to help people with physical disabilities to access the internet. Page 18 of 18