Maintaining systems

The sample Fair Trading Act compliance policy can be used as a basic in-house standard of conduct for Fair Trading Act compliance.

The sample policy:

  • provides for the key requirements that all employees of the enterprise should know about in order to achieve compliance with the Fair Trading Act; and
  • can be used off the shelf or adapted to take into account business size, complexity, existing internal control framework, communication approach and any business or industry-specific terms.

The check sheets have been developed for use by individuals within the business to self-test the business' own compliance with the Fair Trading Act. Like the sample policy and complaints handling register, these check sheets support the business in improving and maintaining the quality of its customer service relating to the Fair Trading Act. Similar to an audit, the value of using the check sheets will be in identifying issues in a timely fashion and giving management the information they need to make a commitment to Fair Trading Act compliance and resourcing. Specific benefits from using the check sheets can include:

  • testing over time will provide information about changes and trends in Fair Trading Act compliance within the business;
  • employees and/or management can easily complete the tests;
  • ┬átesting can be performed as frequently as management requires;
  • self-testing of Fair Trading Act compliance can assist employee's personal development and support engagement and collaboration in continuous improvement activities;
  • testing can identify the areas where further training may be required;
  • tests can be used off the shelf or adapted by the business to take into account specific needs and operating environment; and
  • effective management reporting of Fair Trading compliance across the business or branch by branch enabled by regular testing.

Reviewing Systems

Any compliance programme should be periodically reviewed to ensure that it remains relevant, comprehensive and effective.

Records should be kept of:

  • measures taken by staff to ensure compliance programme, and what was done to correct mistakes;
  • any problems identified by the compliance programme, and what was done to correct them;
  • customer complaints and how they were handled; and
  • competitor complaints, or Commission investigations, and what if any changes resulted from them.

These will be useful in reviewing and amending compliance procedures.

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