The complainant was of the view that a Bank’s loyalty programme was discriminating against senior clients and their ability to earn rewards.


The Bank explained that this is not the case and special considerations are given to senior clients. Senior clients are in fact able to participate in the programme with lesser requirements and from a certain age the clients are exempt from the qualifying criteria.


Our Office could not find proof that people of a certain age group are excluded from the loyalty programme. The Bank has the same criteria for everyone and has even reduced the requirements for older customers. The fact that one customer does not specifically qualify for the loyalty programme does not render the programme discriminatory as the qualifying criteria were not age but required a certain amount to be deposited to qualify. Unfortunately, not all Bank customers, no matter their age, will be able to qualify for the loyalty programme.


Principle: A Bank is entitled to exercise its commercial discretion in conducting its business if such an exercise does not involve discrimination. In this instance, it appears that the Bank’s refusal is based purely on the qualifying criteria not being met, and not age.

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