Unity’s Fair Conduct Programme

As a licenced Financial Institution under the Financial Markets Conduct Act.


As a licenced Financial Institution under the Financial Markets Conduct Act (FMC Act), Unity is required to comply with the principle of treating consumers fairly.

This principle includes:  

  • paying due regard to consumer interests 
  • acting ethically, transparently and in good faith 
  • assisting consumers to make informed decisions 
  • ensuring the services and products that we provide are likely to meet the requirements and objectives of likely consumers, and
  • not subjecting consumers to unfair pressure or tactics or undue influence.

This is particularly important when we:

  • design services and products for consumers 
  • offer to provide services and products 
  • provide services and products, and
  • have any dealings or interactions with a consumer in relation to our services or products.


We outline how we comply with the principle in our Fair Conduct Programme (FCP). Our FCP covers the following:

  • The Role of the Fair Conduct Programme at Unity

How our Fair Conduct Programme was designed to meet the nature, size and complexity of Unity, and the policies, controls, systems and processes that support fair conduct at Unity. 

  • Roles and Responsibilities

Governance and management responsibilities in relation to fair conduct culture. It’s everyone’s responsibility to treat consumers fairly.

  • Meeting legal obligations

Our commitment to meeting all legal obligations, and how we manage these obligations.

  • Reviewing and maintaining the Fair Conduct Programme

How we assess the effectiveness of the Fair Conduct Programme, including how consumer feedback and complaints are documented and considered.

  • Product design and management

How we ensure the design, management, distribution and review of our products and services is fair to consumers and how we remediate deficiencies identified.

  • Consumer care and handling conflicts

Our commitment to conducting ourselves in a manner consistent with the fair treat principle, ensuring potential conflicts are mitigated and consumers interests are considered throughout the life cycle of a product. We do not offer incentives to our staff for selling Unity products.

  • Conduct Risk Management

How we identify, monitor and manage conduct risks that fail to meet the fair conduct principle. What our process is for mitigating and remediating any failings in conduct should they occur. Our training expectations of employees to ensure they can comply with the fair conduct principle and demonstrate competency, knowledge and skill in their role.

Intermediated distribution

We may distribute our lending products through intermediary relationships such as third-party brokers. All intermediaries are financial advice providers or financial advisors and therefore regulated under the FMC Act. Intermediaries must meet contractual and legal obligations to Unity. They must always treat consumers fairly, and concerns with intermediaries’ conduct should be raised immediately with the intermediary.

Intermediaries receive a commission from Unity; however, the rate of commission is fixed and is based on each individually successful application, rather than total volume/value targets.

Our extra care consumers

Where we identify a potential vulnerability in a consumer, we take extra care to ensure we are always treating the consumer fairly. Our employees follow our Vulnerable Consumer Guidelines that describes how we identify and manage relationships with consumers who may be experiencing a vulnerable event.

Informed decisions

It’s important that consumers feel confident to make informed decisions on our products and services. We design our communications, forms, website and marketing material so that it is simple and effective yet still includes key information consumers need to make an informed decision.

Complaints

We are committed to providing the best possible service to our consumers every day. If you have a concern or complaint about any part of our products or services, please tell us so that we can try to fix it.

For further information on our complaints process, visit unitymoney.co.nz or call us on 0800 229 943.

If our internal complaints process does not resolve your complaint to your satisfaction, you have access to a free, independent dispute resolution service, and that service may help investigate or resolve your complaint.

We are a consumer of Financial Services Complaints Limited, which you can contact at:

Freephone: 0800 347 257
Phone: +64 4 472 3725 (from overseas)
Email: complaints@fscl.org.nz 
Website: www.fscl.org.nz
Postal Address: PO Box 5967, Wellington 6140