AGL responds to the latest rule change request to the Australian Energy Market Commission (AEMC) proposing to introduce a regulated family violence framework in the National Energy Customer Framework (NECF). As one of the first energy retailers in Victoria and across the NECF states to implement a family and domestic violence policy, both at a corporate and customer level, AGL welcomes the opportunity to provide its insights, experiences and observations to the AEMC

Family violence is one of the most grave and serious harms affecting our society, the consequences of which have far-reaching economic and social ripple effects throughout communities. Perpetrators can seek to interfere with a victim-survivor’s access to essential services through the accumulation of debt and unfair debt practices, compromise the victim-survivor’s plans to escape through unauthorised access to personal information, or control how victim-survivors access their energy account. As one of Australia’s oldest providers of essential services, AGL understands the central role it can play in supporting and protecting customers experiencing family violence. 

The rule change request proposes to introduce regulations similar to those under Part 7 of the Energy Retail Code of Practice in Victoria. While AGL strongly agrees that there is a need to support our customers who may be experiencing family violence, we challenge whether a strict regulatory framework is the best placed mechanism to offer this support. One of the most critical aspects is that victim-survivors of family violence (and their advocates) retain the agency and autonomy to represent their best interests. Strict regulatory intervention may result in unintended and negative consequences that could inadvertently take this agency away. We understand that the experiences and circumstances of victim-survivors can be vastly different, but each are equally sensitive and complex, therefore, it is imperative that essential service providers have the freedom to support their customers in a way that is meaningful, dignified, and safe for those who need it most.

AGL proposes an alternative approach whereby the AEMC, industry, consumer groups and support services work together to develop a guide on best practice principles for supporting customers affected by family violence. For example, the guide could outline;

• A checklist or toolkit of indicators, and how to offer respectful and timely assistance in a way that is safe and appropriate for victim-survivors.
• Education on different types of family violence and cultural context.
• Good/best industry practice on responding to family violence, including insights, experiences, and the consumer perspective on how different situations can be handled by the retailer.
• A responsible approach to credit collections and managing joint debt liability. 
• National and international case studies, including insights from family violence frameworks in other sectors and jurisdictions. 
• Elements which should be included in family violence training programs for employees (such as those listed in the Australian Banking Association’s Industry Guideline on Preventing and responding to family and domestic violence).
• Referrals to approved and accredited external support services that can be provided to the customer.

There is precedence in the energy sector of the establishment of voluntary industry guides as a less stringent and more flexible approach to manage sensitive social and economic issues.

While AGL’s preference is that the AEMC recommend the development of a best practice Guideline, if the AEMC proceed to amend the National Energy Retail Rules then AGL believes the adoption of the Victorian framework in its entirety will result in lower implementation and ongoing compliance costs as the Victorian framework was modelled primarily on retailer practices at the time.

Read the full submission here. 

If you may be experiencing family violence and need further support, access AGL’s national Family & Domestic Violence Policy, for more information. Contact information for other external support services related to family and domestic violence are available in the Policy. If there is an immediate threat to your safety, call emergency 000.