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Beyond Compliance: Building Trust

Executive Lead, EU/NFR Program, ANZ

2025-11-10 00:00

ANZ Chief Executive Nuno Matos recently appointed Les Vance to lead the bank’s Non-Financial Risk uplift, known as Program PACT (People, Accountability, Customers and Trust).

Vance previously spent 14 years with Westpac, with time as that lender’s Group Executive for financial crime and compliance and led their enforceable undertaking response. More recently he was the CEO of PEXA’s Australian business.

Vance talks to bluenotes about the road ahead for ANZ as it continues to address this crucial area which is a key component in the ANZ 2030 strategy. 

After two decades of running businesses and major programs, one of the main lessons I learned is that efforts to uplift what is now called non-financial risk are so much bigger than a simple “risk program” with a fixed end date. 

This is about achieving a larger cultural and business transformation focussed on consistently running the business well, reliably delivering for customers and respecting the community and regulatory context in which we operate. 

In April, ANZ announced it had entered a Court Enforceable Undertaking (CEU) with APRA for matters relating to non-financial risk management and risk culture. In September, ANZ then announced it had entered into an agreement with the Australian Securities and Investments Commission (ASIC) to resolve five matters within its Australian Markets and Australia Retail businesses that were the subject of separate regulatory investigations.

This is a crucial time for ANZ to be addressing the larger issues which have given rise to this. Our future performance relies on getting this right. 

In my experience, these issues are typically the result of a company that has become too complex and - at times - distanced from understanding its customers and the processes by which we get things done. The issues highlight how we clearly need to improve the way we manage our operations, our customer outcomes and our non-financial risks.

But in pursuing a career in which I tackled substantial issues around risk in the past, it has taught me valuable lessons about the effects of real change within the many layers of large organisations.

Primary among these is a belief that if we focus on risk – without an understanding of how the entire organisation works, the quality of experience we need to provide our customers and the legitimate expectations on us given our critical role in the Australia, New Zealand and internationally - our response will be too narrow and reactive. 

It will not get to the root of the problems we are trying to face and that means we will inevitably face these problems again.  

The road ahead

There is a lot to build on and be proud of at ANZ. 

We are one of Australia's leading companies with millions of customers. You don't get to that position without having a lot to take pride in. 

But on the other hand, our performance and quality are not where we need them to be. Frankly, we need to change that.  

Anyone who has had anything to do with their local sporting club knows a good team isn’t built by throwing away all the great achievements you have made simply because you want to get better. They also know that you don’t stay a good team over the years without ongoing commitment on how you continue to grow talent and improve teamwork.

Building a better culture starts with seeing what great things you are doing already and looking honestly at where you can improve.

As someone who has spent time throughout the years dealing with culture at both banks and at the local sporting clubs - I can see the similarities.

The journey ahead is about keeping the important things that make ANZ unique but ensuring we have the mindset that we should always continue to learn, and we can always get better.  

Who we are

Wherever I have worked I have always anchored my understanding of the way ahead by thinking of our customers - what do they need from us, how we can help them with what they want, the experience we provide and how we make them feel.  

That’s most closely felt by the people who deal with our customers every day - those working in branches or contact centres and our relationship managers.

These employees do the jobs they do because they care. They want to do the best they can for customers.  

It’s not uncommon in large organisations that through difficult policies, processes and systems it can be made hard, and it can be made confusing. The chance of error is much higher when things are really hard and really complex.

The question that we have to keep turning our minds to is, ‘how do we make it easy for these people who are dealing with our customers to consistently get it right?’. 

So too with the increasingly important digital experiences we provide for our customers. Is it really easy and intuitive for them to do everything they need to do? And does it “just work” reliably all the time?

What is Non-Financial Risk? 

When you think about non-financial risk, it should not be over-intellectualised, seen as “something extra” or put in the corner as another job on the “to-do” list.

It's about asking, how do you run your business well? It's no more complex than that. 

It means looking after your customers and making it simple for them. The service quality for customers should be central and the approach you take to servicing customers means you should always try to be reliable. And if we do get it wrong or make a mistake, owning that, looking after the customer and putting them right, fixing the underlying problem so it doesn’t happen again and learning from it so we continue to get better.

But how do you get there? 

Robust processes which are repeatable and consistent are key. If you have those, you can use information clearly and prioritise where you're going to focus your resources and efforts - all the while accounting for customer risk and business benefits. 

The need for speed

Ultimately, the key to this is all about pulling in the same direction.

ANZ has a strong collaborative culture, and the one thing businesses should always be mindful of is how you can still be collaborative and respectful, but without allowing decisions - and actions - to drift. 

Speed comes from not wasting time but getting to the heart of the issue and really nailing it - moving and executing well. This means you are not having to redo things over and over again. 

That’s  really important because there is nothing that’s going to get us in more strife than knowing there’s a problem and doing nothing about it or not actually fixing things properly when we do find them. 

Feedback loop

The greatest thing about positive cultural change is that as it happens - our people will begin to feel it. 

If you look after your customers and you're doing the right thing by your customers, you're making it easier for them. You have happier customers. Your frontline staff become happier because they're not trying to deal with all those frustrations. 

This will mean we should be able to spend less time fixing up things that have gone wrong and more time on how we add more value to our customers. 

If you can start to see the environment simplifying, you can see it being easier to navigate, you can start seeing us being able to execute cleanly. Instead of fixing the issues of the past, you're putting efforts into more productive areas. 

Don’t misunderstand me - this isn’t about ignoring any negative issues that emerge. But what it does mean is we should find the issues ourselves rather than other people raising them for us. And we should be able fix it and fix it properly the first time.  

This will happen over time and achievements will be made at different paces. 

If we focus on the positives of making the business better through reliably delivering for our customers and making it easier for them - and easier for all of us - then we will succeed.

Les Vance is Executive Lead, EU/NFR Program at ANZ

Click here to read more about ANZ's commitment to uplifting non-financial risk

anzcomau:Bluenotes/Policy,anzcomau:Bluenotes/Leadership-and-Management,anzcomau:Bluenotes/anz-results
Beyond Compliance: Building Trust
Les Vance
Executive Lead, EU/NFR Program, ANZ
2025-11-10
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The views and opinions expressed in this communication are those of the author and may not necessarily state or reflect those of ANZ.

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