ASIC’s Superannuation Senior Executive Leader, JANE ECCLESTON reflects on ASIC’s Indigenous Financial Services Framework and the steps trustees should take to better meet their First Nations members’ needs.
ASIC published the Indigenous Financial Services Framework in February 2023, as part of our commitment to support positive financial outcomes for First Nations peoples. The Framework outlines key learnings and outcomes developed through thorough consultation with a broad range of stakeholders on First Nations peoples’ access to and engagement with the financial system. At every stage, the voices of First Nations people were prioritised and elevated. Our key learnings from this process have been tested and confirmed by First Nations consumers and communities as important concepts to be acknowledged and understood.
The outcomes identified in the Framework require the financial services industry as well as ASIC and relevant Government agencies to work together to address the unique challenges experienced by First Nations consumers. These outcomes include:
• reducing the impact of harms and misconduct on individuals and communities
• providing accessible and appropriate financial products and services, increased holistic service provision and delivery
• positive and culturally appropriate experiences when engaging with the financial services industry and other service providers
• improved financial outcomes and financial wellbeing for First Nations consumers, and
• building stronger partnerships and cross-agency collaboration.
ASIC is using the key learnings to inform our ongoing work, and we recommend that superannuation trustees incorporate these important learnings as part of their efforts to improve financial outcomes for their First Nations members.
The Framework has identified four key learnings. These are:
i. First Nations peoples had unique, established economies before colonisation that continue today and should be understood, respected, and maintained
ii. First Nations peoples have been prohibited and excluded from participating in the Australian financial system by historic legislation and policies, including from paid employment and the superannuation system
iii. Financial wellbeing affects all aspects of First Nations peoples’ lives, and
iv. First Nations peoples have many different versions of financial success that need to be accepted and empowered.
Building on these learnings, ASIC has established three dedicated and ongoing engagement streams. The first is an Indigenous Advisory Group, which will allow ASIC to continue to further understand the needs, experiences and objectives of First Nations peoples, when engaging with and accessing the financial system.
The second stream is a Cross-Government Engagement Group to facilitate Government agency collaboration on key challenges for First Nations consumers, and to share insights, information and opportunities for collaboration to better service the needs of First Nations communities.
The third stream continues ASIC’s engagement across the financial services industry to specifically achieve the Framework outcomes, focusing on opportunities identified through previous industry workshops. ASIC will continue to facilitate these conversations, connect industry stakeholders and showcase best practice engagement and outcomes for First Nations communities.
Superannuation trustees have been involved in the development of ASIC’s Framework. Trustee engagement included industry-specific workshops in May 2022 and 2023, which focused on identifying opportunities to consider innovative approaches to long-standing challenges with access and engagement to superannuation for First Nations members. The Framework continues to build on and complement the important work of the Indigenous Super Working Group (ISWG) hosted by the Australian Institute of Superannuation Trustees (AIST).
Trustees should use the Framework to better meet their obligation to deliver good financial outcomes for First Nations peoples.
The superannuation industry has been a strong believer and advocate for the value of superannuation. But superannuation is for all Australians. Trustees must act in the best financial interests of their members and deliver superannuation services efficiently, honestly, and fairly – this includes First Nations members. Trustees should proactively think about, understand, engage with and be involved in building solutions to the long-standing and complex challenges faced by First Nations consumers.
The Framework is a tool trustees can use to better understand the needs of their First Nations members, identify opportunities to learn and engage, and make meaningful changes to facilitate members’ engagement with and access to their superannuation.
We expect trustees to read the Framework and reflect on the key learnings and how these are relevant to their funds. Over time, to the extent appropriate we expect trustees to build engagement channels, programs, activities and products to accommodate the unique experience of First Nations consumers and build solutions to some of the unique challenges First Nations consumers face.
To better serve First Nations members, trustees first need to know their members. There are opportunities for trustees to use currently available data, as well as to seek additional data, to better understand their membership base. We acknowledge that this is a challenge. However, data points like postcodes, employers and/or employer locations, along with direct questions to members, can be used to start building this picture.
We encourage trustees to think innovatively about how to use the data, such as for:
• understanding the challenges, experiences and needs of First Nations members as a specific consumer cohort
• understanding any opportunities for flexibility in application of fund policies or practices to overcome barriers to First Nations members’ constructive engagement with or access to superannuation
• providing insights that can assist in delivering positive financial outcomes for First Nations consumers, and
• measuring the impact of specific First Nations programs, services, and engagement channels.
One of the easiest things that trustees can do to engage with and benefit from the Framework is participate in the upcoming virtual Indigenous Super Summit on 22 June 2023, which is being hosted by ASIC. Previous Summits were hosted by the AIST over 2015-2019, as part of the AIST’s facilitation of the Indigenous Super Working Group (ISWG).
This year’s Indigenous Super Summit will facilitate conversation and encourage increased understanding of the complex challenges experienced by First Nation Peoples in accessing or engaging with superannuation. The Summit will provide opportunities to leverage learnings across the industry as well as regulators, including innovative solutions and best practice approaches. Trustees can also join the ISWG and other cross-industry initiatives (such as the First Nations Foundation’s financial wellbeing events) to collaborate and promote better experiences for First Nations consumers.
Trustees should also consider establishing a Reconciliation Action Plan (RAP) for their funds, which outlines activities and actions to be taken to progress the reconciliation journey, and meaningfully engaging with that RAP.
We expect trustees to reflect on the learnings in the Framework and on how the learnings can inform the way they support and engage with their First Nations members. Trustees also need to learn from First Nations communities what best practice face-to-face engagement and communication looks like using a ‘strengths-based’ approach, focusing on capacities rather than deficits. This approach recognises the capability of growth, learning and change.
Meeting the needs of First Nations member should not be an afterthought or an ad-hoc initiative for trustees. We recommend that trustees actively make use of data and consider the business case for initiatives targeted at seeking stronger access and engagement with their First Nations members, just as they already do for other cohorts of members.
Trustees can better engage with First Nations members in a variety of ways to reduce barriers and build understanding in relation to their superannuation. We encourage trustees to consider:
• providing resources, disclosure documents and information in accessible formats using plain-English language, or in First Nations languages, particularly where funds have significant member bases in regional/remote areas and language barriers exist
• using culturally appropriate images, videos and resources catered to First Nations cohorts with the purpose of improving understanding of superannuation and communicating complex terms and concepts, and
• engaging, and partnering with, financial counsellors and other ‘on-the-ground’ support services to develop a stronger understanding of the experiences of First Nations members and their needs and to identify opportunities to better facilitate access to their superannuation.
Trustees can facilitate First Nations peoples’ access to the benefits of superannuation and better meet their needs by building internal processes and procedures that support engagement in a culturally sensitive and appropriate way. For instance by:
• establishing First Nations peoples’ membership processes and procedure guides and delivering training to contact centre staff to build and develop internal cultural competency
• having a dedicated call line for First Nations members, which is serviced by culturally competent and informed staff where appropriate
• embedding the use of AUSTRAC guidance on alternative identification into fund processes and procedures, and ensuring staff proactively offer information about alternative identification options where appropriate,
• proactively engaging with the ATO’s administrative process to help facilitate engagement between potential beneficiaries and the relevant superannuation funds
• ensuring that any communications about death benefits are accompanied by culturally appropriate disclosures, including warnings of references to deceased people, and processes for interaction with family members under such circumstances are also culturally appropriate, and
• continuing to build solutions to respond to other challenges experienced by First Nations members.
For further information about ASIC’s priorities relating to First Nations consumers and our reconciliation journey, refer to:
• ASIC’s Indigenous Outreach Program
• ASIC’s Indigenous Financial Services Framework | ASIC
• ASIC’s Reconciliation Action Plan January 2023 – January 2026
For event information or to register for the 2023 Indigenous Super Summit, visit Financial Services Industry Engagement | ASIC