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ANZ.800.390.0004 Internal use only Aligned Dealer Group {ADG) Authorised Representative Recruitment & Authorisation Procedures Version 5.0 December2017 Description: Key Principles: Tools and References: Further assistance: Version control Version Released 1.0 1 Sept 2013 1.1 1 October 2013 2.0 1 April 2014 3.0 1 April 2015 Procedure This document describes the procedures and processes that must be undertaken to meet the obligations required under the ADG Authorised Representative Recruitment & Authorisation Standard. This document is divided into 4 sections: Recruitment Appointment o Pre-approval tasks o Authorisation Set-up & Induction Termination Recruitment- initial due diligence and fact finding steps must be taken to determine whether the prospect has strong potential and should move to the Appointment stage. Appointment- minimum requirements and competencies in line with ANZ standards must be reviewed and checked for each Adviser/Practice before the authority can be issued. Set-up & induction- processes must be followed to ensure new Advisers/Practices are set-up, enabled and inducted consistently and in a timely manner. Termination- processes relate to whether or not the Licensee retains responsibility for the provision of advice to clients or if another Licensee with assume responsibility, as well as the termination of authority and cessation of all Licensee services and system access. ADG Authorised Representative Recruitment & Authorisation Standards Recruitment Fact Find Appointment checklist Termination checklist Contact: Adviser Appointments team E: CONFIDENTIAL Owner Approved by Summary of changes Next review Adviser Head of Operations & Projects, Aligned New internal procedures September 2014 Appointments Licensees Adviser Head of Operations & Projects, Aligned Update September 2014 Appointments Licensees Advice Process GM, Advice & Open Market Channels Update April 2015 & Systems Advice Process GM, Advice & Open Market Channels April 2016 & Systems Page 1 of 68 Version 5.0 December 2017

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Page 1: Aligned Dealer Group {ADG) Authorised Representative

ANZ.800.390.0004

Internal use only

Aligned Dealer Group {ADG) Authorised Representative Recruitment & Authorisation Procedures Version 5.0 December2017

Description:

Key Principles:

Tools and

References:

Further

assistance:

Version control

Version Released

1.0 1 Sept 2013

1.1 1 October 2013

2.0 1 April 2014

3.0 1 April 2015

Procedure

This document describes the procedures and processes that must be undertaken to meet the

obligations required under the ADG Authorised Representative Recruitment & Authorisation

Standard.

This document is divided into 4 sections:

• Recruitment

• Appointment o Pre-approval tasks o Authorisation

• Set-up & Induction

• Termination

Recruitment- initial due diligence and fact finding steps must be taken to determine whether

the prospect has strong potential and should move to the Appointment stage.

Appointment- minimum requirements and competencies in line with ANZ standards must be

reviewed and checked for each Adviser/Practice before the authority can be issued.

Set-up & induction- processes must be followed to ensure new Advisers/Practices are set-up,

enabled and inducted consistently and in a timely manner.

Termination- processes relate to whether or not the Licensee retains responsibility for the

provision of advice to clients or if another Licensee with assume responsibility, as well as the

termination of authority and cessation of all Licensee services and system access.

ADG Authorised Representative Recruitment & Authorisation Standards

Recruitment Fact Find

Appointment checklist

Termination checklist

Contact: Adviser Appointments team

E: CONFIDENTIAL

Owner Approved by Summary of changes Next review

Adviser Head of Operations & Projects, Aligned New internal procedures September 2014 Appointments Licensees

Adviser Head of Operations & Projects, Aligned Update September 2014 Appointments Licensees

Advice Process GM, Advice & Open Market Channels Update April 2015 & Systems

Advice Process GM, Advice & Open Market Channels April 2016 & Systems

Page 1 of 68 Version 5.0 December 2017

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4.0 April 2017 Advice Process & Systems

GM, Advice & Open Market Channels April 2018

5.0 December 2017 Advice Operations & Initiatives

GM, Advice & Open Market Channels November 2018

ANZ.800.390.0005

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Table of Contents

Overview .......................................................................................................................... 6

1. Recruitment .............................................................................................................. 6

1.1 Initial Due Diligence ...................................................................................................................... 6

1.1.1. Generating recruitment leads ............................................................................................... 6

1.1.2. Contacting lead to assess recruitment potential .................................................................. 7

1.1.2.a) Recruitment Fact Find for practices and advisers ....................................................................... 7

1.1.3. Adviser proposal developed ................................................................................................. 8

1.1.4. Adviser proposal presented .................................................................................................. 8

1.1.5. Adviser accepts proposal and a formal letter of offer/terms & conditions sent to Practice 8

1.2. Offer Letter / Terms & Conditions (new Practices only) .............................................................. 8

1.3. Sending the Application Kit to the Applicant ............................................................................... 8

2. Australian Banking Association – Reference Checking & Information Sharing Protocol 10

3.1. Pre-approval steps ..................................................................................................................... 11

3.1.1. Application for Authority .................................................................................................... 12

3.1.1.a) Receipt of Application Documents ............................................................................................ 12

3.1.1.b) Contacting SDM / RPM / PDM .................................................................................................. 12

3.1.1.c) Contacting Applicant ................................................................................................................. 12

3.1.1.d) Setting up a new Adviser File .................................................................................................... 13

3.1.1.e) Adding the Applicant’s details to internal registers .................................................................. 14

3.1.2. Minimum standards and competencies ............................................................................. 14

3.1.2.a) Assessing the Applicant’s Educational Qualifications for RG146 compliance ........................... 17

3.1.2.b) Review of Recommended Products by CIO (if transferring with a book of clients) ................... 18

3.1.2.c) Advice Assurance Review ........................................................................................................... 18

3.1.2.d) Background checks .................................................................................................................... 20

3.1.2.e) Reference Checks ....................................................................................................................... 27

3.1.3. Additional Licensee specific procedures ............................................................................. 28

Technical Competency test (RI Advice only) ........................................................................................... 28

3.1.4. Additional checks for new Practices only ........................................................................... 28

3.1.4.a) Review of financials ................................................................................................................... 28

3.1.4.b) Practice background checks ...................................................................................................... 28

1.1.2.b) Risk Adviser Review ................................................................................................................... 29

3.1.4.c) Marketing Materials & Website ................................................................................................ 30

3.1.5. Waivers or variations to standard appointment process ................................................... 30

3.1.6. Subsidiary / Non-controlled entity arrangements .............................................................. 31

3.1.7. Due diligence sign off .......................................................................................................... 31

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3.1.8. Final approval ...................................................................................................................... 31

3.1.9. Delegated authority ............................................................................................................ 33

3.2 Authorisation steps ..................................................................................................................... 33

3.2.1. Legal Agreements ................................................................................................................ 34

3.2.1.b) Authorising a Trustee ................................................................................................................ 35

3.2.2. ASIC Notification ................................................................................................................. 35

2.2.3. Authorisation Notification ............................................................................................ 36

Inform Applicant of successful Application ............................................................................................. 36

Authority Notice ..................................................................................................................................... 37

3.2.4. Transfer Agreement - transition of brokerage (if applicable) ............................................. 37

3.2.5. Updating Internal Registers ................................................................................................ 37

3.2.6. Notify Licensee Support Staff.............................................................................................. 37

3.2.8. Maternity Leave (if applicable) ........................................................................................... 38

3.3 Confirmation / Follow-ups .......................................................................................................... 38

4. Set-up & Induction ................................................................................................... 39

4.1. Welcome email to the Applicant ............................................................................................... 39

4.2. Licensee Support Staff enable access to systems and services ................................................. 40

4.2.1. Adviser Website Access ...................................................................................................... 41

4.2.2. Brokerage system set up and access .................................................................................. 41

4.2.3. Brokerage transition – client transfers and Adviser codes ................................................. 41

4.2.4. Financial Services Guide and Adviser Profile ...................................................................... 42

4.2.5. Induction ............................................................................................................................. 43

4.2.7. Ongoing Training system..................................................................................................... 43

4.2.8. Professional Indemnity Insurance ....................................................................................... 43

4.2.9. Research Tools .................................................................................................................... 44

Mercer and Chant West access .............................................................................................................. 44

4.2.10. Stationery Ordering .......................................................................................................... 44

4.2.11. Technology, data conversion & access to advice templates ............................................ 45

Process for RI & FSP ................................................................................................................................ 45

Process for M3 ........................................................................................................................................ 45

4.2.12. Vetting Standards .............................................................................................................. 45

4.2.13. Website - Licensee public website listing ......................................................................... 46

4.3. Quick Reference Guide: Set-Up & Induction ............................................................................. 46

5. Termination Procedures .......................................................................................... 47

5.1.1. Terms of Agreement – preparing for termination .................................................................. 48

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5.1.1.a) Receipt of resignation ...................................................................................................... 48

5.1.1.b) Adviser File and Termination/Cancellation checklist ...................................................... 48

5.1.1.c) Notifying the Adviser of their obligations and the next steps in the termination process

...................................................................................................................................................... 48

5.1.1.d) Payment of outstanding debts ........................................................................................ 49

5.1.1.e) Review of Tripartite arrangement (if applicable) ............................................................ 49

5.1.1.f) Review of outstanding complaints, incidents & remediation .......................................... 49

5.1.1.g) Licensee sign off on any outstanding matters ................................................................. 49

5.1.2. ASIC Notification - Revocation of Authority ............................................................................ 49

5.1.3. Client Communication ............................................................................................................ 50

5.1.4. Transfer Deed .......................................................................................................................... 50

5.1.5. Client Release Letter ............................................................................................................... 50

5.1.6. Transferring Client Register to another internal Adviser (if applicable) ................................. 51

5.1.7. Authorising an Xplan Data Conversion (if applicable) ............................................................ 51

5.1.8. Exit Survey ............................................................................................................................... 51

5.1.9. Notification of termination to all Licensee Support Staff ....................................................... 51

5.1.10. Removal of services & system access ................................................................................... 51

5.1.10.a) Notifying Brokerage ....................................................................................................... 52

5.1.10.b) Cancelling software ....................................................................................................... 52

5.1.10.c) Updating internal registers ............................................................................................ 52

5.1.10.d) Cancelling Website Access / Stationery ID .................................................................... 52

5.1.10.e) Cancelling Adviser Website access ................................................................................ 52

5.1.10.f) Cancelling Training System Access ................................................................................. 52

5.1.10.g) Cancelling Research Tools .............................................................................................. 53

5.1.10.h) Cancellation of PI Insurance Cover ................................................................................ 53

5.1.11. Retention of Client Data ....................................................................................................... 53

5.1.12. Destruction of Adviser’s personal information after termination ........................................ 54

6. Australian Banking Association – Responding to a Request ...................................... 54

Email Template to Make Request to Other Licensee........................................................ 55

ABA Consent Form Protocol ............................................................................................................. 56

ABA Industry Reference Checking Form .......................................................................... 64

Xplan data conversion process ........................................................................................ 68

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OVERVIEW There are four stages in the Aligned Dealer Groups (ADGs) Recruitment & Authorisation procedures.

This document outlines the sequence of actions that must be undertaken in each stage in order to

achieve compliance with the ADG Authorised Representative Recruitment & Authorisation Standards

and to manage the associated risks.

1. RECRUITMENT The recruitment of a new Adviser / Practice requires initial fact finding and due diligence to

determine whether the prospect will be an appropriate cultural fit within the group and to ensure

minimal risk to the Licensee if the prospect is appointed. This is the responsibility of the Licensee

Practice Development team (RPM/SDM/PDMs).

Recruitment activities are the responsibility of the Licensee Practice Development teams and the

primary purpose is to gather information to assess the Applicant’s suitability and compatibility to

join an ANZ Licensee.

The key steps in the process are as follows:

Generating recruitment leads

Contacting leads to assess recruitment potential

Holistic Adviser proposal developed

Holistic Adviser proposal presented

Adviser accepts proposal and letter of offer / terms & conditions (containing commercial

terms) sent to Practice

1.1 Initial Due Diligence 1.1.1. Generating recruitment leads Currently, recruitment leads are generated/sourced by:

Licensee Practice Development Managers (RPM/RMs)/ Sales Development Managers (SDMs)

OnePath Business Development Managers – leads passed to central team for execution

These leads typically come from:

Existing aligned Advisers

Newly recruited Advisers

Cold calling targeted group – e.g. AFS

1.

Recruitment

2.

Appointment

(Pre-approval +

Authorisation)

3. Set-up & Induction

4.

Termination

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1.1.2. Contacting lead to assess recruitment potential 1.1.2.a) Recruitment Fact Find for practices and advisers

Once the lead has been received, the Licensee RPM/SDM/RM contacts the Adviser to assess their recruitment potential. If the lead is considered strong potential, the RPM/SDM/RM must complete a Recruitment Fact Find to ascertain key information about the Practice.

The high-level due diligence questions in the Recruitment Fact Find are for internal use only and cover:

How complex is the business structure of the Practice

Financial profile of the business

Types of exposure to known areas of business concern eg exposure to agribusiness, sub-prime mortgages, illiquid investments, high gearing etc

Details of previous Licensee – any concerns re poor reputation etc

Where the adviser will act as an Authorised Representative or Director of another AFSL where one or more of its license conditions are the same as the ADG’s. The ADG must decline the application unless it receives specific approval that the conflict and its potential impact is understood and accepted by stakeholders based on advice from in-house legal (s917C Corporations Act)

Where the adviser will act as an Authorised Representative or Director of another AFSL where none of its license conditions are the same as the ADG being joined, the ADG must determine if it will cross endorse the Authorised representative or decline the application whilst the adviser remains an Authorised representative of another AFSL

Details of compliance history

Complaints and litigation history (if any)

Any other concerns eg physical office security, staff turnover, recent acquisitions or divestments etc

Initial due diligence and fact finding should be undertaken by the licensee before an application is

completed by the applicant/s.

The Licensee Practice Development team (RPM/SDM/RMs) is responsible for any additional

information or fact finding required by the individual Licensees for the purposes of assessing the

Applicant’s cultural fit with the Licensee or for the purposes of segmentation.

Information gathered during this recruitment phase should be provided to the Adviser

Appointments team so a copy can be saved on the Applicant’s file and considered as part of the

overall assessment of the Application.

! It’s important to note that where applicable the Adviser / Practice should not resign from their current authority until new agreements are approved and new agreements are issued.

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1.1.3. Adviser proposal developed Following initial contact with Adviser, the Licensee RPM/SDM/RM negotiates/consults with the Adviser to develop a proposal.

1.1.4. Adviser proposal presented After negotiations have concluded, and provided all parties agree they wish to move forward, the Licensee RPM/SDM/RM provides the proposal to the Adviser, and acts as the ‘go to’ for any additional queries/requests.

This step may also involve a ‘Meet the Manager’ day for Practices with high brokerage/FUM or a group of Practices from the same licensee. This would typically involve key Licensee staff (e.g. General Manager, Practice Development Manager) and key OnePath service stakeholders (e.g. Research, Technical Services, Compliance).

1.1.5. Adviser accepts proposal and a formal letter of offer/terms & conditions sent to Practice Upon Adviser acceptance of the proposal, the Licensee prepares a formal letter of offer and or terms & conditions for the Practice (if applicable). The letter of offer is sent to the Practice and a copy is provided to the Adviser Appointments team. The terms & conditions are included in the CAR agreement which is executed once the application is approved.

1.2. Offer Letter / Terms & Conditions (new Practices only) As outlined in Section 1.1.5. above, upon completion of the initial due diligence and providing there

are no major issues which may pose a risk to the Licensee’s AFSL, the Licensee will issue an Offer

Letter and or Terms & Conditions to the new Practice which outlines any key terms in writing, such

as incentives and next steps involved in the transition. The Letter of Offer and or Terms & conditions

is conditional on the Practice and Adviser/s meeting all of the required standards as outlined in Stage

2: Appointment and is therefore revocable.

1.3. Sending the Application Kit to the Applicant Once a Letter of Offer (Practices only) has been sent and/or approval has been given for the

application process to proceed, the Application Kit must be sent to the Authorised Representative.

This is the responsibility of the RPM/SDM/PDM.

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The Application Kit is sent by the following teams and contains the following documents:

Application Kit FSP RI M3

Responsibility to send to Applicant SDM RPM SDM

Individual and or Corporate Authorised

Representative Application form/s

Research due diligence spreadsheet / New

Adviser Fund Manager Information Spreadsheet

Adviser Systems Registration Process

Questionnaire

N/A

Statutory Declaration (only to be completed if

audit reports cannot be provided by applicant)

The application documents can be located using the following file path:

FSP: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments

\Adviser Appointments & Resignations\Document Control\Applications Forms

RI: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments \Adviser Appointments & Resignations\Document Control\Applications Forms

o Licensee can access via - R:\Practice Development\RPM\RPM Toolkit\RECRUITMENT\New Practice & Adviser Transition Document Requirements

M3: Advice Delivery\04. Advice Process and Systems\03. Operations and Payments

\Adviser Appointments & Resignations\Document Control\Applications Forms

The prospect now moves to Stage 2: Appointment for further assessment.

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2.AUSTRALIAN BANKING ASSOCIATION- REFERENCE CHECKING & INFORMATION SHARING PROTOCOL

This purpose of the ABA Protocol is to promote improved reference checking during the recruitment

process for all new financial advisers.

It is designed to share the performance history of the Financial Advisers focusing on the previous 5

years of their compliance, risk management and advice quality records. Below are the steps for ABA

Protocol process when seeking information from the current subscribing licensee:

1. ABA Protocol Consent Form to be signed by the adviser and returned to the

SDM/PM/RM

2. The signed ABA Protocol Consent Form will be forwarded to the Adviser Appointment

Team with applications and supporting documents.

3. Adviser Appointment Team will forward a copy of the signed ABA Protocol Consent Form

with a request to perform an ABA Reference check to the email inbox CONFIDENTIAL and upload a copy to Adviser Hub.

4. The Risk Liaison Officer will access the email inbox and create a file for the adviser and

enter details in to the ABA Protocols Requests Log. They will then send a request with a

pdf of the signed ABA Protocol Consent Form to the key contact person of the other

Subscribing Licensee.

5. Refer to Appendix for the ABA Protocol Subscribers Key Contact List and email template

for ABA Protocol request

6. The information collected will date back to the previous 5 years of employment with any

of ABA Subscribing Licensees.

7. The ABA Protocol Reference Check Form request is to be completed in writing and

returned by the current licensee within 10 business days of receiving the request.

8. Once the Risk Liaison Officer receives the completed ABA Protocol Reference Check

Form, they will review the completed form . Once reviewed the completed form will be

forwarded in an email to the Adviser Appointments Team with any concerns highlighted

in the email. The Adviser Appointment Team will upload the completed ABA Protocol

Reference Check Form to Adviser Hub under the Onboarding case for the Applicant.

9. Adviser Appointment Team will provide the completed ABA Protocol Reference Check

together with all due diligence documentation to Head of Advice Quality and Assurance

and the Licensee Head for review and final sign off.

PLEASE NOTE: The ABA Protocol Reference Check process applies to advisers employed by a

Subscribing Licensee.

I OJ For more information please refer to Australian Bankers Association website

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Record keeping

The ABA Protocol Reference Checks and ABA Protocol Consent Forms are uploaded to Adviser Hub

by the Adviser Appointment team for record keeping purposes. The Risk Liaison Officer will maintain

records for each adviser request on the Advice Risk Shared Drive

Appointment

Stage 2 is the Appointment stage where due diligence and checks are conducted on all individual

prospects wishing to join an ANZ Aligned Licensee.

This stage comprises both pre-approval steps and authorisation steps, and is the primary

responsibility of the Adviser Appointments & Resignations Officer (referred to as ‘Adviser

Appointments team’ throughout the document), unless otherwise specified.

3.1. Pre-approval steps The pre-approval steps involved in assessing the application of a potential Authorised

Representative with an ANZ Aligned Licensee (the Licensee) consist of the following processes:

Receipt of Application documents: o Checking that all relevant forms have been returned and completed correctly o Checking all supporting documents have been supplied (Identification, Education,

Training & Accreditation documents, last two Compliance Reports, product information)

Confirming receipt of Application Form with RPM/SDM/PDM

Setting up a new Adviser File (both in Outlook and windows explorer)

Adding Applicant’s details to the internal registers (planner movements spreadsheet)

Completing minimum due diligence checks, namely: o RG146 Compliance: Adviser Development team assesses the Applicant's educational

qualifications for RG146 compliance o Recommended Product Review: Research Team assesses the Applicant's product

listing against the current APL (if applicable) o Advice Assurance Review: Advice Assurance reviews two previous audit reports

(excluding green advisers) o Conducting background checks: Adviser Appointments team conducts Police, Credit,

Bankruptcy, ASIC, Financial Adviser Register (FAR), APRA, Sanctions, internet, social media, and where applicable, Work Entitlement Checks

o ABA Protocol Reference Check Risk Liaison Officer will perform the ABA Protocol process. For additional information please refer to ABA Subscribing Licensees are located on ABA Website.

o Reference checks: A minimum of 2 professional references, including previous licensee (if applicable) must be completed by the RPM/SDM/PDM.

Completing any other Licensee specific processes (if applicable)

Additional background checks are completed on the Practice by the Adviser Appointments team, including a Company credit check (VEDA), ABR review (to check the ABN, if the business is registered to receive GST and if there is a trading name) and an APRA disqualification check. Information on the Trustees of a Trust (if applicable) must also be

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collected. Checking that all minimum due diligence checks have been completed and appropriate sign-offs obtained

Forwarding the file to the Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) for final approval (this can be done either in soft copy email, or providing the hard copy file for review)

3.1.1. Application for Authority

3.1.1.a) Receipt of Application Documents

Each application must be reviewed for completeness by the RPM/SDM/PDM prior to submission to

the Adviser Appointments Team

! Note: if minimum information is not provided, and the Applicant has not been granted a waiver or exemption regarding this information then the Application process cannot continue.

! The exception is if an existing Authorised Representative is applying to join an existing practice within the same Licensee. In these circumstances no additional checks are required (assuming all minimum standards and competencies have been met and are up-to-date), however, sign off by the Licensee General Manager (or delegate) must be granted prior to the new agreements being issued.

3.1.1.b) Contacting SDM / RPM / PDM

Contact the SDM/RPM/PDM via an email containing the following information:

1. Confirm receipt of the Applicant’s application documents 2. List any information or documents that are missing and may cause delays in the

Appointment process 3. Inform them to ask the Applicant to forward any outstanding documents (if applicable) to

you as soon as possible so the Appointment process is not delayed further 4. Inform the SDM/RPM/PDM that you will keep them informed of the progress of the

Applicant’s application and will confirm any outstanding documents being received (if necessary) It is the responsibility of the RPM/SDM/PDM to keep the Applicant informed of the progress of their application

5. Ask them to confirm the next steps and manage the Adviser’s expectations in regards to the process as outlined in Section 2.1.1.c).

3.1.1.c) Contacting Applicant

To give the Applicant a better understanding of the Appointment process the RPM/SDM/PDM team

should inform the Applicant of the following key points, including:

Confirming receipt of the Application documents

If the Applicant has not completed the documents as required or has not submitted all

supporting Education, Training & Accreditation documents or Compliance Reports, request

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that they attend to this immediately and forward to you as soon as possible so as not to hold

up the Appointment process.

The estimated timeframe from the date of receipt of the complete set of application

documents to a final approval is generally at least three to six weeks.

They will be kept informed of the progress of their Application and you will confirm any

outstanding documents being received (if necessary).

The Licensee needs to ensure that appropriate due diligence has been conducted and final

sign-off is received from the appropriate stakeholders prior to a potential new Adviser

resigning from their previous licensee.

The background checks that will be performed (Police, Credit & Bankruptcy, ASIC, FAR, APRA, Sanctions screening, internet & social media, References)

o It’s important for them to submit their details for the police check as early as possible

as authorisation cannot be made until a clean police check has been returned by the

Federal Police, which can take 1 to 3 weeks (approximately).

Adviser Development Team to review Qualifications for RG146 compliance, and specialist Licensee accreditation (if applicable)

Research Team to assess the Applicant's product listing against the current APL (if transferring book)

Advice Assurance Team to review previous two compliance audits (unless green adviser)

Enhanced Due Diligence may require an onsite or desk review of client files.

Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) will review file for approval

Explain that set-up of software, stationery and other services etc will occur in Stage 3 Set-up & Induction if and when they are approved, however, encourage them to submit the following as soon as possible so that preparation steps can commence: o Adviser Systems Registration process questionnaire – to assist with Xplan set-up and

data conversion process o Research due diligence spreadsheet / New Adviser Fund Manager Information

spreadsheet - this includes product listing and Adviser Codes so that Client/brokerage transition preparation steps can be completed.

3.1.1.d) Setting up a new Adviser File

Set up a new softcopy Adviser folder go to:

Advice delivery\04. Advice Process and Systems\03. Operations and Payments\Appointments &

Resignations\ Due Diligence\Adviser Due Diligence

Copy and paste the template file structure re-naming it with the relevant name under the licensee

group. The file should contain the following sub headings:

Adviser Application

Brokerage

Compliance

Correspondence

Qualifications

References

Research Review

Social Media Checks

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Print out the Authorised Representative Appointment Checklist and place with the Adviser

Application. Checklist Location: Advice Delivery\04. Advice Process and Systems\03. Operations and

Payments\Appointments & Resignations\Authorisation\Authorisation Administration\Appointment

Tools\ADG. File documents received from Applicant in relevant sections of Adviser File

If applicable set up a soft copy file for Practices. Go to:

Advice Delivery\04. Advice Process and Systems\03. Operations and Payments\Appointments &

Resignations\ Due Diligence\Practice Due Diligence

Copy and paste the template file structure re-naming it with the relevant name under the licensee

group. The file should contain the following sub headings:

Brokerage

Compliance

Correspondence

Financials

Marketing

Practice Application

Product Review

Ensure copies of all information, documents and sign-offs in relation to an CAR Application are saved

in this directory.

3.1.1.e) Adding the Applicant’s details to internal registers

Add the Applicant’s details to the following internal registers:

Advice Delivery\04. Advice Process and Systems\03. Operations and Payments \Adviser

Appointments & Resignations\Reporting\Planner Movements

Find the “Listing and Stats” spreadsheet for the relevant year and month.

3.1.2. Minimum standards and competencies

A number of due diligence and background checks are performed by teams within Advice Delivery.

In the event the minimum standard cannot be obtained from the potential Applicant (Adviser),

prescribed escalation steps need to be followed.

A summary of these escalation steps are as follows –

Due Diligence/Background

Check

Exception noted in due diligence/background

check

Escalation required

Adviser qualifications Must confirm in writing Applicant’s qualifications

have been reviewed. Outcome of the review –

Satisfactory – requirements met

Adviser Development

ANZ.800.390.0017

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Further information required / review required – documents/evidence are incomplete

Declined/Approved subject to approval – recommendations to remediate gap or application may be declined

Licensee specialist

accreditation

Must confirm in writing Applicant’s specialist

accreditation qualifications have been reviewed.

Outcome of the review –

Satisfactory – requirements met

Further information required / review required – documents/evidence are incomplete

Declined/Approved subject to approval – recommendations to remediate gap or application may be declined

Adviser Development

Advice Assurance Review Must confirm in writing Applicant’s previous

compliance audit reports have been reviewed.

Outcome of the review –

Satisfactory – no apparent compliance issues

Enhanced due diligence required – compliance issues identified and further investigation is required

Advice Assurance

team

Advice Assurance Review –

previous compliance audit

reports unable to be provided

Applicant must complete a Statutory Declaration

Waiver must be obtained from Licensee General Manager and Head of Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

In the event the

parties don’t agree,

escalate to General

Manager, Aligned

Licensee and Advice

Standards.

Police Check In the event of a disclosable outcome the matter must be referred to Head of Advice Risk and Compliance and Group Investigations

Head of Advice Risk

and Compliance and

Group Investigations

Credit and Bankruptcy Check In the event credit rating is below 500 or there are adverse results, notify Licensee General Manager and Head of Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

ANZ.800.390.0018

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ASIC Check Where the applicant will act as an Authorised Representative or a Director of more than one AFSL, provide search results to Licensee General Manager and Head of Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

Banned and Disqualified

Register

Any exceptions identified must be notified

to Licensee General Manager and Head of

Advice Quality and Assurance

N/A – Potential

candidate is unable to

be onboarded

Tax Practitioners Board (TPB) Applicant is not registered with the TPB

(note that the applicant can still be on

boarded only if the Practice agrees to the

Corporate Advice Model and supervisory

obligations. The Licence needs to confirm

these arrangements via completion of the

Corporate Advice Model Supervisory

Checklist)

Licensee

Supervisor/Licensee

General Manager

ASIC Enforceable

Undertakings Register

Any exceptions identified must be notified

to Licensee General Manager, Head of

Advice Quality and Assurance and Head of

Risk Wealth Advice and Distribution

N/A – Potential

candidate is unable to

be onboarded

Financial Advisers Register

(FAR) Any exceptions identified must be notified

to Licensee General Manager and Head of

Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

APRA check – Enforceable

Undertaking and

Disqualification Check

Any exceptions identified must be notified

to Licensee General Manager and Head of

Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

Sanctions Check Any exceptions must be notified to the

Wealth MLRO, Licensee General Manager and Head of Advice Quality and Assurance

Wealth MLRO, Licensee General Manager and Head of Advice Quality and Assurance

Internet and social media

check Any discrepancies identified must be notified to Licensee General Manager and Head of Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

ANZ.800.390.0019

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ANZ.800.390.0020

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Applicant is not entitled to work in

Australia

Applicant unable to provide certified true

copies of 100pt identification

Any concerns identified must notified to

Licensee General Manager and Head of

Advice Quality and Assurance

If an Applicant fails the test, a decision is required by the Licensee General Manager if on boarding the applicant should continue

• Alternatively, the Licensee may provide a waiver or authorisation conditional on completion within a certain timeframe. The waiver must be signed by the Licensee General Manager and Head of Advice Quality and Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

Licensee General

Manager and Head of

Advice Quality and

Assurance

Licensee General

Manager

3.1.2.a) Assessing the Applicant's Educational Qualifications for RG146 compliance

Send the Applicant's qualifications, educational details, and CPO history for the last 3 years to the

Adviser Development team to review to assess for RG146

compliance. CPO history should include TASA hours for advisers who are already TPB registered .

The Adviser Development team must confirm in writing that they have reviewed the Applicant's

qualifications, including the outcome of their review and whether the outcome is:

Procedure

• Satisfactory- all requirements met- where evidence of qualifications for all RG146

knowledge areas and skills is provided and currency of knowledge has been demonstrated;

OR

• Further information I review required- where documents/evidence provided are

incomplete; OR

• Declined/Approved subject to recommendation- where gaps are identified in

qualifications or CPO history, recommendations will be made to either remediate that gap

OR the application may be declined.

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I

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A copy of this written confirmation must be kept in the Applicant’s file under ‘Qualifications’.

Licensee Specialist Accreditation

Review the Application and supporting documents to determine whether the Applicant wishes to be

accredited in any specialist advice areas. If so, forward details to Adviser Development team for

specialist accreditation assessment.

The Adviser Development team must confirm in writing that they have reviewed the Applicant’s

specialist accreditation qualifications, including the outcome of their review and whether the

outcome is:

Satisfactory – all requirements met – where evidence of accreditation is provided and

currency of knowledge has been demonstrated; OR

Further information / review required – where documents/evidence provided are

incomplete; OR

Declined/Approved subject to recommendation – where gaps are identified in

accreditations or CPD history, recommendations will be made to either remediate that gap

OR the application may be declined

A copy of this written confirmation must be kept in the Applicant’s file under ‘Qualifications’.

3.1.2.b) Review of Recommended Products by CIO (if transferring with a book of clients)

When an Adviser and/or Practice is transitioning a book of business the CIO team is responsible for

the review of the products against the Licensee’s Approved Product List to establish if there are any

products transitioning to the Licensee’s AFSL, which may be considered higher risk.

This review must be undertaken prior to the new Adviser/Practice joining the group. The CIO team

must attest to having completed this review by confirming in writing to the RPM/SDM/PDMs and the

Adviser Appointments team. In this review the CIO team will advise if they have any major concerns

with the transitioning book.

All reports are forwarded to the Risk Adviser together with the Recruitment Fact Find and Advice

Assurance review for assessment of the due diligence level required. (i.e. standard or enhanced).

3.1.2.c) Advice Assurance Review

Review of prior Compliance Audit Report

The Advice Assurance team is responsible for the review of the Applicant’s previous two compliance

audit reports to ensure there are no issues or concerns which may lead to a client complaint in the

Applicant’s previous compliance history. This team is also responsible for conducting the enhanced

due diligence steps (when required).

The Advice Assurance team must complete their review and provide a written recommendation as

to whether Enhanced Due Diligence should occur (via a 5 files review per Adviser) or otherwise. This

should be communicated in writing to the RPM/SDM/PDMs, the Risk Adviser and the Adviser

Appointments team.

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This review must be undertaken prior to the new Adviser/Practice joining the group and the Advice

Assurance team must attest to having completed this review by confirming in writing to the Adviser

Appointments team (informing the Risk Advice) and advising whether the outcome is:

Satisfactory – no apparent compliance issues based on compliance reports provided; OR

Enhanced due diligence required – compliance issues identified and further

investigation via client file review or licensee intervention required – Advice Assurance

team to provide details.

If the Applicant is unable to provide copies of two previous compliance audits then the following

applies:

the Applicant must provide a reason why they cannot provide audit reports and complete a

Statutory Declaration, which states the following:

“I declare that during my employment as an Authorised Representative of

…….…………………………………(Licensee), I had reviews conducted and have complied with the provisions

of the financial services law, industry codes and internal organisational standards. There have been

no formal complaints made against me registered in my internal complaints register, nor have any

breaches been reported to ASIC under s912D. Where I have breached the above stated standards and

legislation, I have disclosed these in writing to <Licensee>.”; and

Enhanced due diligence must be undertaken via a review and assessment by the Advice

Assurance team of a minimum of 5 client files (per adviser) ahead of the appointment. The

Licensee General Manager (or delegate) and Head of Advice Quality and Assurance must be

notified of this prior to commencement of the Enhanced due diligence.

In the event that the Applicant has only been in the industry for a limited time and has not had two

(2) compliance audit reports completed and / or has no client files that can be reviewed then a the

Applicant must complete a Statutory Declaration (as above) and a waiver must be obtained from the

Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate)

(with the Risk Adviser informed).

A template Statutory Declaration form is saved here:

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Adviser

Appointments & Resignations\Authorisation\Statutory Declaration

Enhanced Due Diligence Review

In the following instances Enhanced due diligence must be undertaken via a review and assessment

by the Advice Assurance team of a minimum of 5client files (per Adviser) ahead of the appointment:

Where the Recruitment Fact Find due diligence assessment has identified that an enhanced

due diligence review is required;

The outcome of the Recommended Product Review is ‘Further information / review

recommended’ or the outcome of the Advice Assurance Review is ‘Enhanced due diligence

required’. Or

As part of the overall assessment of application completed by the Risk Adviser (refer to the

Risk Adviser section).

ANZ.800.390.0022

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If a concern is raised during the file review process, then the review should be broadened to ensure

appropriate due diligence. This review is carried out by the Advice Assurance Team via an on-site

review or remotely through Xplan (if applicable). This review may also cover the following area:

Complaints register and full details of any complaint

Incident/Breach Register and full details of any incident

Conflict of Interest Register

Alternative Remuneration Register

Business set up

Referral Arrangements/ Comingling

Depending on the business risks identified, there may be a requirement to conduct a practice focused Enhanced due diligence.

On completion of the Enhanced due diligence review, the Advice Assurance Team will provide a

report on their findings to the Risk Adviser, Licensee General Manager (or delegate) and the Head of

Advice Quality and Assurance (or delegate) to determine whether further action needs to occur or

the appointment needs to be rejected.

If Enhanced due diligence and access to previous client files or compliance reports is not possible,

provide the details to the Licensee General Manager (or delegate) and the Head of Advice Quality

and Assurance (or delegate) for advice on next steps and whether a waiver can be approved in this

instance.

3.1.2.d) Background checks

Police check

As part of the Application Process, Applicants must undergo a Police check. The standard process is

that Authorised Representatives must not be appointed until the return of a clean police check.

In some instances, however, the Applicant can be appointed on a conditional basis prior to the Police

Check clearing provided the following conditions are met:

A minimum period of five business days has passed after receipt of the police check Interim Report notification

Approval has been given by the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate) )

the Adviser has signed a Statutory Declaration.

The Police checks are lodged through First Advantage and conducted by the Australian Federal

Police. Police checks are valid for 6 months and the cost of the check is covered by the Licensee. A

First Advantage police check case is lodged online at: https://cspi.fadv.com/cspi/

ANZ.800.390.0023

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To lodge the police check case:

The Applicant is then sent an automated email with logon details so that they can logon to the site

and complete the relevant documents in order for the Police check to be completed. Therefore it is

essential that the email address is correct for the adviser to proceed.

The Australian Federal Police will send back a Certificate confirming whether or not there are any

disclosable outcomes.

! Crucial: It generally takes up to 1 week for the Australian Federal Police to send back the Certificate when using First Advantage, however, if the check goes into further investigation the process can take longer so it is important to lodge the police check case ASAP.

In the event of a disclosable outcome the matter must be referred to the Head of Advice Risk

Compliance (or delegate) for review and further reference to Group Investigations. A Police Check

Decision Outcome form must be completed and provided together with the decision from Group

Investigations and the National Police Certificate to the Licensee for acceptance and sign-off. Place a

copy of all Police check documents in the Applicant’s File in the “Compliance” section.

Head of Advice Quality and Assurance Head of Advice Quality and Assurance

SBU: select relevant dealer group Email Template: select ‘Invitation Email – OnePath’ Package: select ‘Standard Criminal Check v1’

Enter the applicants first & last names, email address, and

Cost Code (this is either FSP, RI, M3, etc).

Select ‘Order Case’

ANZ.800.390.0024

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Credit & Bankruptcy check

A Credit & Bankruptcy check on the Applicant is performed through Veda Advantage. Veda's

Individual Trading History Reports provide you with credit information on an individual along with a

summary of key credit and adverse information on each alias or related organisation. For example,

an Individual Commercial Trading History Report includes individual identity details, commercial

credit information, trading history summary table and a summary of business relationships.

Visit the Veda website https://www.vedacheck.com Enter your Username and password (refer table below)

On the left hand side of the Home page, select "Working with Individuals"

For Type of Information you require, select "VedaScore Financial Commerical 1.1"

Type of Credit you are providing will be "Commercial"

Input the following mandatory fields for the Applicant: o Surname o First Name o Gender o Birthdate o Drivers Licence number o Current address (residential)

Enter the following mandatory credit enquiry data: o Account type: 30 day account o Amount: $0 o Role: Principal

Click on the Submit button to process the request

Save the PDF Report in the Adviser's file

The Licensee will be invoiced for any credit checks conducted

Make a note on the Appointment Checklist if the credit rating is below average (in the 500s

and lower) or if there are Adverse results in the summary and ensure that the Licensee

General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate)

is notified.

ASIC checks

Authorized Representative Register

To identify Applicant’s existing Licensee, go to the ASIC website:

https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-

state=1kmezcfzc_13

Enter Applicant's Surname or ASIC Authorised Representative Number

Select the "Australian Financial Services Authorised Representative" Register

Click the Search button

Any existing Licensee details will appear in the results section

Screen capture the results page and place in the Adviser File in the “Compliance” section

Where the Applicant will act as an Authorised Representative or a Director of more than one AFSL, search for each AFSL number and print out the latest “License Authorisation Conditions” of the other Licensee(s). This must also be flagged with Compliance & the Licensee General Manager (or delegate).

ANZ.800.390.0025

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Australian Credit Representative Register (if applicable)

Go to the Australian Credit Representative Register: https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-state=1kmezcfzc_13

Enter Applicant's Surname or ASIC Authorised Representative Number

Select the “Credit Representative” Register then Click "Search"

Screen capture the results and place in Adviser File in “Compliance” section

Banned & Disqualified Register

To check the Banned & Disqualified Register, return to the ASIC Connect page of the ASIC website:

At mid page there is a drop down called “Select Register”, select "Banned & Disqualified"

Register.

Enter Applicant’s Surname and Given Name then Click "Go"

Screen capture the results and place in the Adviser File in “Compliance” section

Tax Practitioners Board (TPB)

All advisers must be registered with the TPB before they can be authorised under any of the

Licensees. If the adviser is not registered, they must register themselves and provide evidence of this

(i.e. TPB certificate) before they can be authorised on ASIC.

To check if an adviser is registered with the TPB go to:

http://www.tpb.gov.au/TPB/Finding_and_using_a_practitioner/Search_the_register/tpb/agent_regi

ster.aspx

Enter the advisers name into the search field and click “Search”

Take a screen shot of the results and save in the advisers due diligence folder

Enforceable Undertakings Register

To check the Enforceable Undertakings Register go to:

http://www.asic.gov.au/online-services/search-asics-registers/additional-searches/enforceable-

undertakings-register/

Control F on this page, do not use the page’s search function

Enter Applicant’s Surname and Given Name then Click "Go"

Screen capture the results and place in Adviser File in “Compliance” section

Financial Advisers Register (FAR)

To check the Financial Adviser Register go to: https://www.moneysmart.gov.au/investing/financial-

advice/financial-advisers-register

Type in the Applicant’s name

Tick the Terms & Conditions check box

Click ‘Search’

Screen capture the results and place in the Adviser File in “Compliance” section

ANZ.800.390.0026

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ANZ.800.390.0027

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APRA check

An APRA disqualification check must also be conducted on the Applicant to ensure they are not, or

have not been banned by APRA. Go to:

http://www.apra.gov.au/crossindustry/pages/disqualification-register.aspx

• Control F on this page

• Search the APRA disqualification register by surname and/or entity name.

Sanctions check Sanctions (also known as embargoes) are steps taken by a national government or international

organisation intended to bring about changes in the policy or behaviour of others. They are often

imposed on countries to prevent crimes against humanity, financing of terrorists and terrorist acts,

the sale of weapons of mass destruction, illegal arms trading and narcotics trafficking.

ANZ Economic & Trade Sanctions Policy aims to protect ANZ's reputation and manage its risk

globally in relation its sanctions obligations.

Sanctions screening must be conducted on all new Advisers applying to become an Authorised

Representative of an ANZ Aligned Licensee. It is illegal for us to do business with anyone on the

Sanctions list.

This check is conducted via World-Check.

1. Go to: http://www.world-check.com/

2. Login using ADG username and password as follows:

o Username:

o Password:

• Enter the advisers full name into Worldcheck

• If 'hits' are displayed check the category. If the Worldcheck category is "Political Individual"

these can be ignored and no further action is required. For all other "hits" compare the DOB to the advisers DOB. If the difference in DOBs is greater than 1 year (plus or minus) then this can be treated as de-identified and no further action is required.

• If the DOB difference is less than 1 year, or no DOBis available refer to Wealth MLRO or email 'AML Compliance') to obtain further guidance.

3. If it is determined that the person with the 'hit' is the same person as the adviser, ensure

that the Wealth MLRO is informed and await instructions. Also notify the Licensee General

Manager and Head of Advice Quality and Assurance (or delegate) if any discrepancies are

found.

• If it is determined that the person with the 'hit' is not the same then the application can

proceed.

• Appropriate records need to be retained to evidence the decision making processes

Screening of all existing Authorised Representatives must also be conducted on an ongoing basis.

This is currently done weekly by sending a consolidated spreadsheet of all existing Authorised

Representatives across all ADG Licensees to the ANZ FlO Office every Friday. This is coordinated

centrally on behalf of the ADGs.

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This spreadsheet can be found: \Adviser Appointments & Resignations \ Reporting \ Sanctions

Checking\Running List

Internet & social media check

An internet Google search (www.google.com.au) must be conducted on the Applicant to check for:

Any evidence of illegal / criminal activity

Inappropriate content on social media sites ie Facebook, Twitter, LinkedIn

Areas that may require a specialist review such as advice, newsletters, articles, blogs either via newsletters, or other social media including YouTube etc.

Relationships that haven’t been disclosed (where a conflict could exist, eg property developers, credit providers, Stock brokers or other relationships)

Affiliations/ past conduct that are inconsistent with what would be acceptable to licensee.

Media quotes or reports that could give rise to concerns for the licensee.

Type the Applicant’s name into the search engine and include catch words, examples such as:

Gambling

Property

Gearing

SMSF

FX (forex)

Agribusiness

Borrowing

Where the Applicant has a common name include the Adviser’s old dealer group name, or their Business name.

If any discrepancies are identified during this search they must be printed off and provided to the Licensee General Manager (or delegate) and Head of Advice Quality and Assurance (or delegate) for review as part of appointment process.

Entitlement to Work in Australia check

Adviser Appointments team must check the nationality of the Applicant to ensure they are entitled

to work in Australia. This is done by checking the Applicant’s passport, birth certificate or marriage

certificate for Australian citizenship.

If the Applicant is not an Australian Citizen then check with the Department of Immigration and

Citizenship to ensure that the Applicant holds a current working visa or has Australian residency. This

check is done using the Visa Entitlement Verification Online (VEVO) system, a free internet service.

Before undertaking a search in VEVO you will need to request to see the Applicant's foreign

passport. You should check the personal details page of their passport to verify the person's identity.

You will then need to obtain their permission to check their visa details. Only holders of non-

Australian passports can be checked in VEVO.

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You will firstly need to register to use VEVO (as accounts expire after a relatively short period of

time). To register for VEVO, use the following link: http://www.immi.gov.au/e_visa/vevo.htm

Select "VEVO for Organisations"

Select "Register for VEVO"

Press "Register Now" and "I agree to the terms and conditions"

Complete the registration details including business and contact details and ABN

For VEVO Category, select "Work entitlements"

For Industry type, select "Finance and insurance"

For Description of industry, enter "Financial Planning Dealer Group"

When you have submitted the registration request, you will receive an email in the next few days.

Once you have obtained your Logon ID and password, logon to VEVO using the above link.

Select "VEVO for Organisations"

Select "Logon to VEVO"

Press "Query Now" and "I agree to the terms and conditions"

Enter Logon ID and password

Using the Applicant's passport, you can enter the following information into the VEVO system:

o name o date of birth o passport number o passport country of issue

Save a copy of the work entitlement confirmation page and place in the Adviser's file.

Identification check

When reviewing the Applicant’s Application form and supporting documents, the Adviser

Appointments team must complete a 100 points identification check. The Adviser identification

documents are to satisfy AML requirements and copies of identification must be certified as true

copies in line with ANZ’s list of authorised persons, which includes:

A Justice of the Peace

An officer / employee with 2 or more continuous years of service with one or more Australian financial institutions, finance company or AFSL holder. (e.g. ANZ, NAB, Elders, M3, etc)

An accountant who is a member of the ICAA, CPA or NIA.

An Applicant can easily provide 100 points identification by providing a combination of the following

documents:

copy of Passport (70 points)

Australian Driver’s License (40 points)

Copy of full Birth certificate (not extract) (70 points)

Medicare card (25 points)

Credit or Account card (25 points)

Utility Bill (20 points).

ANZ.800.390.0029

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For more information on Primary or Secondary documents for identification purposes, refer to the

Identification Check – 100 points checklist can be found:

03. Operations & Payments\ Appointments & Resignations\Authorisation\Authorisation

Administration\Appointment Tools\ADG

Copies of this identification must be kept with the Adviser’s file under ‘Compliance’.

Note: Where there are non-AR directors, certain background checks need to be completed for these

directors. These checks include:

Search of the ASIC Banned & Disqualified Register*, the Authorised Representative Register*, the Enforceable Undertakings Register*, the Financial Advisers Register (FAR), and the Authorised Credit Representative Register (if applicable)*

Search of the APRA Disqualification Register*

Sanctions check*

3.1.2.e) Reference Checks

A minimum of two (2) references familiar with the Applicant’s ability to provide advice must be provided. The criteria for the references are as follows:

References must be professional business references.

One referee is required from the Applicant’s previous Licensee (if applicable, eg green adviser would not have a Licensee reference). The application can be approved subject to a satisfactory Licensee reference being obtained prior to Agreements being issued. This is in situations where the applicant does not want their current Licensee made aware of their intention to resign.

Business referees must be Australian Residents and have known the Applicant for a minimum of 2 years.

Business references must be obtained verbally using the Licensee’s reference checking form

Licensee references can be provided verbally using the Licensee reference checking form or via a written reference

Referees cannot be family members or other members of the Applicant’s business or members of the recruiting Licensee’s staff (eg Regional Managers, SDMs, RPMs, product BDMs) due to potential conflicts of interest.

Reference Checks must be performed as part of the Application process, as follows:

Ensure that the relevant Reference checking consent forms have been signed by the Applicant (Refer table below for specific sections that must be signed in each Licensee’s Application forms)

Send an email to the person responsible for conducting the Licensee Reference Checks (refer table below) requesting that they contact the referees supplied by the Applicant and record the referee’s answers and comments on the Work Reference Check Form.

Attach a copy of the Work Reference Check Form found at: Advice Delivery\04. Advice Process & Systems\03. Adviser Appointments & Resignations\Authorisation\Authorisation Administration\Appointment Tools (under the relevant licensee folder)

Upon receipt of the completed Reference Check Form, place in the Applicant’s Adviser File under ‘References’.

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Note: The reference checks must be completed by the Licensee’s RPM/SDM/PDM/RM and the reference interview is in line with Standards Australia guidelines (AS 4811—2006) Employment Screening and the associated Handbook, HB 323-2007, Employment Screening Handbook.

3.1.3. Additional Licensee specific procedures

Technical Competency test (RI Advice only)

RI requires Applicants to complete an industry knowledge test. The test is conducted via Kaplan

Professional Kudos Testing. Should the Applicant fail this test, a decision is required by the Licensee

as to whether onboarding the applicant should continue. Alternatively the Licensee may provide a

waiver or conditional appointment on the basis that any gaps are addressed in the Advisers training

plan.

This test can be waived if the Applicant is known to have competent industry knowledge.

Alternatively an Applicant can be given a conditional authorisation, which allows them to complete

the test within 30 days of appointment. The waiver or conditional appointment must be signed by

the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or

delegate) and kept on file.

3.1.4. Additional checks for new Practices only The following additional pre-approval steps must be conducted on new Practices:

3.1.4.a) Review of financials

As part of the due diligence on a new Practice, the Licensee requires confirmation that the entity

applying for a Corporate Authority is financially sound. This is captured via a question in the

Corporate Application form regarding confirmation that the key attributes of the entity are

financially sound. As part of the Application form, sign-off from two (2) Directors (if applicable)

acting on behalf of the entity is required.

RI Only

RI Advice requires the Senior National Manager Advice & Operations of the Licensee to review the

most recent Profit and Loss statement of the company to ensure it is a profitable business. The

Senior National Manager Advice & Operations must sign off that they have completed this review.

3.1.4.b) Practice background checks

Company Credit check

A Credit & Bankruptcy Check on the Company is performed through Veda Advantage. To request the

report:

Visit the Veda website https://www.vedacheck.com

Enter your Username and password

On the left hand side of the Home page, select " Organisations"

Input the following mandatory fields for the Applicant:

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o ABN or ACN o Account type: 30 Day account o Amount: $0 o Role: Principal

Click on the Submit button to process the request

From Product List drop down, Select “Company Business Trading History” and GO

Save the PDF report in the Practice file

The Licensee will be invoiced for any credit checks conducted

Make a note on the Appointment Checklist if the credit rating is below average (in the yellow and

lower) or if there are adverse results in the summary. Refer to this report to determine Company

Directorship for the drafting of the Corporate Agreements.

ABN review

If a new applicant wishes to come on board with their own Practice, an ABN search must be done to

ensure that the business is registered with the Government and is registered to receive GST. To

perform this search you go to: http://www.abr.business.gov.au/Index.aspx

Type in the ABN that has been provided by the applicant and click on the “Search” button. The details of the company will then show up. Take a screen capture of the results (include any trading names) and save in the Practice due diligence file.

APRA Disqualification Check

An APRA disqualification check must also be conducted on the Practice (entity). To perform the

APRA disqualification check, use the following link:

http://www.apra.gov.au/crossindustry/pages/disqualification-register.aspx

Search the APRA disqualification register by entity name. Take a screen shot of the results and save

in the Practice due diligence file.

1.1.2.b) Risk Adviser Review

The Recruitment Fact Find must be sent to the Risk Adviser (or delegate) to assess the level of due diligence required, namely:

Standard; or

Enhanced – client file review/ and or practice review

The following documentation must be included for the recruitment fact find review to be completed:

Recruitment Fact Find

Application form

CIO review (where applicable)

Advice Assurance review

Waivers (where applicable)

Internet and social Media Check

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If enhanced due diligence is required then notification, together with the reasons, must be sent to the Licensee General Manager (or delegate). Adviser Appointments is also notified of the recruitment fact find review findings. If the Licensee wishes to proceed with application, the Advice Assurance team is notified and a review of 5 client files (per Adviser) must be completed.

The outcome of this review must be provided in writing to the Licensee General Manager and the Head of Advice Quality and Assurance (or delegate) to determine whether the Applicant is suitable to move forward in the process.

3.1.4.c) Marketing Materials & Website

All Practices must adhere to the Licensee’s Marketing and Professional Standards guidelines, found

on respective intranet sites. This also applies to the Practice’s website.

Send an email to the Marketing team requesting that they provide details of the Licensee’s brand

guidelines to the practice (save a copy of this request in the Practice due diligence folder). During the

pre-authorisation period, Adviser Appointments will email the Practice details to the Marketing

team, who will email a copy of the brand guidelines to the adviser and request a copy of their

licensee branded material, once they have been authorised.

Following authorisation, it is up to the adviser to email their marketing materials and website to the

Marketing team to demonstrate that they have read, understood and implemented the required

brand guidelines in their Practice.

Note: New practices using Licensee branding are provided with design templates during the set-up

process, which ensures adherence to Licensee standards.

Send an email to the Marketing team requesting that they provide details of the Licensee’s

brand and marketing standards to the practice, and coordinate a review of the practice’s

collateral and website with the Professional Standards team. A copy of this can be found

Appointments & Resignations\Authorisation\Email Templates\Appointments.

File a copy of the confirmation from marketing that this will be done on the Applicant’s file.

3.1.5. Waivers or variations to standard appointment process If a waiver or request for a variation to the standard Appointment process is received for an

Applicant, these requests must be forwarded to both the General Manager of the Licensee (or

delegate) and the Head of Advice Quality and Assurance (or delegate) ADG for approval. Ensure a

copy of the waiver/variation approval by both parties is kept on the Applicant’s file (hard or soft-

copy).

! If approval of the waiver or variation is not received by both parties then the standard appointment process must be followed.

! If the Applicant’s previous Licensee is PIS, AAA, Storm or AFS, additional questions and due diligence may be required above the standard appointment process. Refer any

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cases to the Licensee General Manager (or delegate) and the Head of Advice Quality and Assurance (or delegate) for further guidance on what is required in these circumstances.

3.1.6. Subsidiary / Non-controlled entity arrangements ANZ’s Standard and Procedures outlined in regards to ADG Authorised Representative Recruitment

and Authorisation also apply to subsidiary / non-controlled entity arrangements with ANZ eg Elders

Financial Planning.

In instances where a waiver or variation from the standard procedure is requested the final sign-off

lies with the Licensee, and sign-off by the Head of Advice Quality and Assurance (or delegate) is not

required. In these instances the subsidiary / non-controlled entity must accept the risks associated

with them accepting any exceptions. This should also be escalated to the Managing Director – Advice

& Open Markets. Where appointment occurs these need to be referred to the Advice Business

Controls & Governance team to capture in reporting and escalate.

3.1.7. Due diligence sign off Once all of the pre-approval steps above have been completed, provide the files and checklist

(Adviser File and/or Practice File) to the Adviser Appointments team supervisor (or delegate) for

review of due diligence completeness and sign-off. The Adviser Appointments team supervisor must

sign-off on the Appointment Checklist that all steps in the process have been satisfactorily completed.

3.1.8. Final approval The Application must now be submitted to the Licensee General Manager (or delegate) and the

Head of Advice Quality and Assurance (or delegate) for final approval. The process is as follows:

1. Standard applications with no waivers or variations

Email Head of Advice Quality and Assurance (or delegate) the completed and signed Appointment checklist

Include Licensee sign off in email (either on checklist or attached email approval)

Copy Licensee General Manager (or delegate) in on the email

The Head of Advice Quality and Assurance (or delegate) must confirm back in writing that the application is approved

2. Applications containing waivers &/or variations

Send to Licensee General Manager (or delegate) for approval / review first

Forward licensee's recommendation and relevant docs to Head of Advice Quality and Assurance (or delegate) for approval

The Head of Advice Quality and Assurance (or delegate) must confirm back in writing that the application is approved

Both parties must sign-off on the checklist or via email approval that the Application has been

approved and a copy must be kept on the Applicant’s file.

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Escalation Process

In the event that the Risk Adviser and Head of Advice Quality & Assurance recommend that the

application does not proceed, but the Licensee disagrees, the application must go to the Managing

Director – Advice & Open Markets (or delegate) (MD A&OM) for final review and decision.

Special Conditions on Appointment

Where an applicant has been approved subject to additional conditions such as when the first audit

is scheduled or additional prevetting requirements (Special Conditions), these conditions must be

documented. The Special Conditions must be provided by Head of Advice Quality & Assurance (or

delegate) to the Adviser Appointments team to include in the Advisers Letter of Appointment.

Both the Adviser & the SDM/RPM/PDM must sign the Special Conditions and return to the Adviser

Appointments team. The SDM/RPM/PDM will be responsible for ensuring that the adviser adheres

to the Special Conditions on appointment.

Notification and Reporting

Where an appointment has been escalated for approval to the MD A&OM this information must be

forwarded to the Advice Business Controls & Governance team for inclusion in appropriate

reporting.

Where an appointment has been approved with Special Conditions, the Advisor Appointments team

will provide a final confirmation to the relevant licensee staff and advice delivery teams. The Advice

Business Controls & Governance team for inclusion in appropriate reporting and the Licensee

General Manager and MD A&OM for awareness.

The Adviser Appointments team will forward to the Advice Business Controls & Governance

team information on appointments which have been escalated to the MD A&OM for approval

and/or which have been approved with special conditions.

The Advice Risk Officer (Governance) will maintain this information in a tracking register for each

Licensee. Advisers will be tracked until any special conditions have been met. If the condition

involves a compliance review or vetting, Kathy will obtain that information from CoMetrix or

the Advice Quality & Assurance team. In regards to tracking other conditions (for example,

enhanced supervision or mandatory use of the ANZ Paraplanning team), the Licensee General

Manager or Supervisor will be required to provide updates at the Licensee Risk Forum.

The Advice Risk Officer (Governance) will provide an extract from the adviser onboarding

tracking register to the Risk & Compliance Adviser for tabling at the monthly Licensee Risk

Forums.

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If there are any issues with an adviser not meeting any special conditions, the matter is to be

escalated to the Consequence Management Committee (CMC) by the Risk & Compliance

Adviser.

The Advice Risk Officer (Governance) is to receive a copy of the minutes from the Licensee Risk

Forum in order to process any updates to the tracking register.

CMC outcomes will then be reported in the Advice Quality & Assurance Update for the quarterly

Advice Risk and Compliance Board Committee.

! Note: if the Head of Advice Quality and Assurance or the Licensee General Manager is away then the responsibility can be passed on to the delegated authorities as outlined in the table below in section 2.1.9.

3.1.9. Delegated authority The table below provides details on who has delegated authority to undertake the key sign off /

approval responsibilities identified in the absence of the primary authorised person:

Primary Authority Delegated Authority (in order)

Head of Advice Quality and Assurance Manager Risk & Compliance

Risk & Compliance Adviser

Head of Advice Delivery

Licensee General Manager National Manager Licensee Operations

Operations & Payments Manager

Operations & Payments Supervisor

Head of Advice Process & Systems Operations,

Advice Delivery

3.2 Authorisation steps The post-approval authorisation steps involved with the Appointment of an Adviser / Practice with

the Licensee comprise the following:

Legal Agreements - Organise Individual Authorised Representative Agreement and

Corporate Authorised Representative Agreement (if applicable)

ASIC notification - Upload the Authorised Representative on the ASIC Register

Initial Appointment notification (only applicable for Advisers/Practices not already

registered with the TPB) – issue the Initial Appointment letter which is subject to successful

TPB registration.

Authorisation notification – Inform Applicant of successful Application and issue Authority

Notice. (Where an Initial Appointment notification was issued, adviser must provide TPB

registration evidence before this can be issued).

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Transfer Agreement – transition of brokerage – start the process to arrange Client Transfers

with Fund Managers (if applicable) and organise new Adviser codes (if required)

Update Internal Registers with the Authorised Representative’s details

Notify all Licensee support staff of Applicant’s appointment

Authority probation (if applicable)

Maternity leave (if applicable)

3.2.1. Legal Agreements All Authorised Representatives need to complete and sign an Authorised Representative Agreement.

Corporate Authorised Representative Agreements will be required if a company is to become a

Corporate Authorised Representative.

Agreement templates are located under:

Advice Delivery\04. Advice Process & Systems\Appointments &

Resignations\Document Control\Agreement Templates

Schedule 1 (in each agreement) and the RCTI Agreement need to be pre-populated before organising for the agreement to be signed.

Refer to section 2.2.1.a) below for information on internal agreement execution and signing

requirements.

Once the agreements have been executed, scan a copy into:

Advice Delivery\04. Advice Process & Systems\Appointments &

Resignations\Document Control\Agreement Soft-copies

Send a hard copy of the agreements to the Adviser/Practice and keep a copy on file.

3.2.1.a) Agreement execution and signing requirements

A Power of Attorney Deed for each of the Aligned Licensees (RI, FSP, M3) has been executed, which

allows a number of pre-defined Senior Executives (appointed as an attorney to the company) to

execute and enter into “Standard Form Agreements” under Power of Attorney.

The Standard Form Agreements that can be executed in this manner are listed in the Annexure to

the respective Deed and include Standard Representative Agreements, Transfer Deeds,

Confidentiality Agreements, Tripartite Deeds etc.

This means that these Standard Form Agreements can now be executed using the “Execution by

Authorised Signatory” execution clause (our preferred clause) or the “Execution by Power of

Attorney” execution clause.

The roles that have been appointed as an attorney of their company (and can therefore execute

under this power) are:

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RI FSP M3

Head of RI

Senior National Manager Advice & Operations, RI

General Manager, Advice & Open Market Channels

Head of FSP

Senior National Manager Advice & Operations, FSP

General Manager, Advice & Open Market Channels

Head of M3

Chief Operating Officer M3

General Manager, Advice & Open Market Channels

3.2.1.b) Authorising a Trustee

A Trust has no legal capacity and cannot enter into any contracts or agreement, therefore the

Licensee cannot authorise a Trust.

In instances where a Trust is involved the following important points should be noted:

Licensee must authorise the company in its capacity as Trustee

The Trustee will hold legal title to the clients and holds them beneficially for

the beneficiaries of the Trust.

Both the Trust and Trustee details must be documented in the Agreement and on the RCTI

agreement.

o The Trustee A.C.N and the Trust ABN should be used to clarify the links between the

two entities and reduce the confusion of noting 2 ABNs.

o Ensure the ABN that is recorded in the RCTI Agreement is the ABN for the entity that

is being Authorised

This allows for the licensee to deposit funds into the bank account attached

to the trust without the need for any further documented instructions.

This is often requested for taxation purposes by the practice.

3.2.2. ASIC Notification We must inform ASIC of the Authorised Representative joining the Licensee once their application

has been approved and the Authorised Representative has:

o resigned from their previous Licensee (if applicable) o received a Letter of Release from their previous Licensee (if applicable) and o signed the Authorised Representative agreement (and Corporate Authorised

Representative agreement if required) o Checked both ASIC connect & the FAR to ensure their previous Licensee has revoked

their authorised representative status

Note: Licensee AFSL numbers are as follows:

FSP RI/FPW M3/Elders

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AFSL Number 237590 238429/357306 244252/224645

To authorise an Adviser under one of the above Licensees, go to:

https://asicconnect.asic.gov.au/public/faces/landingPage?_afrWindowMode=0&_afrLoop=1354881

648512000&_adf.ctrl-state=fufcjsljy_4

Note: Each Adviser Appointments Officer must have their own individual login for this site.

A detailed procedure document on how to authorise an Applicant on ASIC Connect can be found in:

Advice Delivery\04. Advice Process & Systems\03.Operations & Payments\Appointments &

Resignations\Authorisation\Authorisation Administration\Appointment Tools\ADG

To obtain the AR number for a green adviser once you have authorized them go to: https://connectonline.asic.gov.au/RegistrySearch/faces/landing/ProfessionalRegisters.jspx?_adf.ctrl-state=12uu3zw0qt_16

Select "Professional registers" on the bottom right hand side of the page

Enter the AFSL Number in the correct field

Select the "Australian Financial Services Licensee" Register

Click the Search button

Click on “Show all representatives” towards the bottom of the page

Type the Adviser's surname in the “Start from” box and click “Go To"

The Adviser should be shown

Click on their name and details of the Adviser should appear

Record the AR Number on the Checklist

Enter the Adviser’s Authorised Rep Number on all internal registers Follow the above steps of the CAR has not previously been authorised.

2.2.3. Authorisation Notification Initial Appointment notification (only applicable for Advisers/Practices not already registered with the TPB) Issue the Initial Appointment letter which is subject to successful TPB registration. Inform applicant of their ASIC number and TPB registration requirements. The Adviser/Practice must complete and return an acknowledgement that they understand they cannot provide advice until Adviser Appointment issues their Final Authorisation Notice following their TPB registration.

Authorisation notification – Inform Applicant of successful Application and issue Authority Notice.

(Where an Initial Appointment notification was issued, adviser must provide TPB registration

evidence before this can be issued).

Inform Applicant of successful Application

Inform Applicant of successful Application/Authorisation and outline the following topics (where

applicable):

a. Legal agreements b. Welcome Email/Pack c. Vetting standards

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Note: Where an Initial Appointment notification was issued, the adviser must provide TPB

registration evidence before this can be issued.

Authority Notice

Once the Licensee has authorised a new Adviser, prepare the Authority Notice letter.

Templates can be found here:

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments

& Resignations\Authorisation\Authorisation Administration\Appointment Document Pack

If any other conditions of authority (eg: restrictions) are required, obtain wording from the

Licensee and get sign-off from Compliance to add to the Authority Notice. Save a copy of the

Authority Notice in their file for future reference.

3.2.4. Transfer Agreement - transition of brokerage (if applicable) Generally, when a book of business is being transferred from one Licensee to another, the Adviser

will need to adhere to the exiting requirements of the Licensee they are leaving with respect to

client communications. A release of clients from the former Licensee will usually not occur until the

Licensee has entered into a Transfer Agreement with the previous Licensee.

These Agreements must be submitted to the Licensee’s Legal Representatives for sign-off before

they can be executed and returned to the previous Licensee who will then issue a client release

letter. The Transitions Team manages this sign off process and will then use this letter to contact the

fund managers to transition the payment of commissions from the previous Licensee as part of

Stage 3: Set-up & Induction.

3.2.5. Updating Internal Registers Update all internal registers with the Adviser/Practice’s details. These include:

Licensee Register Location (file path)

RI, Fortnum & FSP Listings and Stats (monthly

register)

T:\Adviser Appointments &

Resignations\Reporting\Planner Movements

M3 Listing and Stats (monthly

register)

MyWorkSpace

T:\Adviser Appointments &

Resignations\Reporting\Planner Movements

https://secure.mydigitalspacelive.com/index.a

sp?site=30&p=security/logon.asp

3.2.6. Notify Licensee Support Staff Send an email to all Licensee Support Staff and Advice Delivery teams informing them of the Adviser

being authorised. Template emails for each Licensee can be found in: Advice Delivery\04. Advice

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Process & Systems\03. Operations & Payments\Appointments & Resignations\Authorisation\Email

Templates

This email initiates the set-up and enablement of relevant services for the new starter as outlined in

Stage 3 Set-up & Induction.

3.2.8. Maternity Leave (if applicable) When an existing Adviser goes on maternity leave, their status is changed to inactive on the “Planner

Movements” register

For RI & FSP the Licensee ceases deducting PI premiums from the Practice for the duration of the

maternity leave. To arrange this send an email to the Brokerage team instructing them to cease

deduction of the PI.

M3 continues to deduct premium from Corporate Authority.

The authority will remain active with ASIC and the Adviser is required to maintain CPD.

3.3 Confirmation / Follow-ups It is important that all of the Appointment procedures (pre and post-approval) are confirmed as

completed or followed up until completed.

It is essential that at all stages of the Appointment process the Adviser is kept informed of the

progress by their RPM/PDM/SDM as well as any potential issues which could prolong their

Appointment.

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4. SET-UP & INDUCTION Once an authority is issued, multiple teams are involved in the set-up and induction process for new

starters.

The process for the new starter is initiated as follows:

4.1. Welcome email to the Applicant The following information is sent to the new applicant:

FSP RI M3

Welcome email

Authority notice/letter of

appointment (hard copy) (hard copy)

AR/CAR Certificate

Authorisation T&Cs N/A (hard copy)

Copy of Licensee AFSL N/A N/A

Copy of PI Policy N/A Accounts Team

Copy of signed Representative

Deed (hard copy) (hard copy)

Copy of Vetting Standards (hard copy) (hard copy)

FSG* Marketing Engine

Adviser Profile* Marketing Engine

Adviser code – Fund Manager

request form

N/A N/A

Intranet login ARC RI Prac Dev team N/A

Stationery ordering login Marketing

Team/Bluestar

Marketing

Team/Bluestar

N/A

Adviser Stamp template N/A N/A

PI Payment form N/A Accounts Team

Notification that they have been

added to distribution list for

Licensee

newsletter/communications

Focus Point RI Report Business Operations

Team

Notification that they have been

added to Licensee website N/A N/A

Quick Reference Guide: Set-up &

induction – NEW – (effective 1 Sept

2013)

(hard copy) (hard copy)

* Note: the FSG & Adviser Profile must be given to the Adviser before they can provide any advice.

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4.2. Licensee Support Staff enable access to systems and services The Adviser Appointments team sends an email to the following teams as part of the Authorisation

procedures (Refer Section 2.2.6.) notifying them of the new appointment, which initiates the set-up

and enablement of the following services for the new starter:

Team Service / System

Bluestar Marketing Engine FSG & Adviser Profile

Adviser Appointments ARC login details (in welcome email) (FSP only)

Marketing Public website (RI only) – add Adviser/Practice

Adviser Appointments Professional Indemnity cover (applied automatically once

authorised)

Adviser Development Training System/Learning Management System

Adviser Development Induction programs/training/accreditation

Advice Systems & Support Advice template access

Advice Systems & Support Technology system (Xplan & CommPay) licenses and access

Advice Systems & Support Data conversion process

Advice Systems & Support Research tools - ChantWest & Mercer access

Investment Research Research tools – Morningstar access

Marketing Stationery ordering & printing access

Marketing Add to email distribution lists for communication (RI & FSP)

Marketing Public website (FSP only) – add Adviser/Practice

OnePath distribution OnePath BDM allocation

Operations & Payments Brokerage system set-up and access to DMS Online

Operations & Payments Client transition process and transition of brokerage,

including new Adviser code set-up with Fund Managers

Practice Development Licensee Adviser / Practice lists

Practice Development Adviser Services website login details (RI)

Advice Assurance Vetting program an d clearance

A high-level overview of the set-up procedures and processes for each of these services / systems is

provided below. For more detailed procedure or process information, refer to the relevant teams.

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4.2.1. Adviser Website Access The Licensee's Adviser website (ARC, Adviser Services, M3 Website) is an accessible resource centre

for all Authorised Representatives.

Once the Adviser has been appointed and an email is sent notifying all Licensee Support Staff,

Adviser website access is set-up as follows:

1. FSP: Adviser Appointments team will send a welcome email to the Authorised Representative

with details of website login and password.

2. Rl: Practice Coordinator notifies Authorised Representative of website login and password

3. M3:Systems and Support Team will send a welcome email to the Authorised Representative with

details of website login and password

4.2.2. Brokerage system set up and access A crucial part of the set-up process is the establishment of the Adviser on the Brokerage System so

they can be remunerated .

Send an email to the Brokerage team ( CONFIDENTIAL

CONFIDENTIAL requesting the Adviser be set up on the OMS Online System and

provide the Brokerage team with the following information:

Banking Details: Bank Name, Branch, BSB, Account Number, Account Name

Practice Details: Practice Name & Practice ABN

Contact Details: Email Address

Proposed start date Dealer split (this needs to be confirmed in writing by the Licensee Practice Development team or in

the letter of offer/terms & conditions)

Use the following documents to provide this information to the Brokerage team:

• Commissions Update Form & Bank Account Details form

4.2.3. Brokerage transition- client transfers and Adviser codes If a book of business is transferring, the Transitions Team) is responsible for reviewing the

Applicant's list of product issuers to ensure the Licensee has an RCTI agreement in place to be able

to receive brokerage from the product issuer. If no agreement is in place then the Transitions team

liaises with the product issuer and the Licensee to establish an agreement.

The Transitions team requires the completion of a spreadsheet to enable it to determine which fund

managers we do not have an RCTI agreement with and to organise the transfer of the brokerage:

Procedure

• Advice Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments & Resignations\Document Control\ Transitions

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The incoming Adviser/Practice should complete this form and email it to [email protected].

Any issues found are to be reported to the RPM/SDM/PDM for review and acceptance.

Client Transfers are necessary if the newly appointed Adviser has existing clients with their previous

Licensee. The previous Licensee will forward a Release Letter to the Adviser authorising for us (the

new licensee) to facilitate Client Transfers on behalf of the Adviser.

Forward the Release Letter to the Transitions team (Adviser Appointments team for M3) with a list

of the Adviser's current Adviser codes with their previous licensee. Ask the Transitions team to

organise the client transfers as per the Release Letter and have clients and brokerage transferred

from all the applicable fund managers.

4.2.4. Financial Services Guide and Adviser Profile RI & FSP

The Marketing Team/Bluestar will organize for the new Adviser/s to be issued with login details for

the Bluestar Online Marketing Engine. It is through the engine that Advisers will order copies of the

FSG, and create their Adviser Profiles.

Once an Adviser logs on and creates their adviser profile, they need to submit their order which will

come to the Adviser Appointments inbox for review and approval.

The Adviser Appointments Officer needs to click on the link in the email which will take them

to the online profile for review

Review the documents details to ensure they are correct:

o ABN

o Entity name

o AR & CAR numbers

o Contact details

o Issue date

o Iteration number

o Areas of advice (ensure they have accreditations for any specialist areas selected)

o Background information

If applicable, send a screen shot of the Adviser’s background information to Advice Delivery

Compliance for review if you are unsure if the wording is appropriate

If the profile is acceptable, save a PDF before you approve the order and save in Advice

Delivery\04. Advice Process & Systems\03. Operations & Payments\Appointments &

Resignations\Adviser Profiles\Current\dealer group\adviser name

If the details are incorrect, you must reject the order and provide details to the adviser in

regards to the amendments that need to be made

Templates can be accessed via:

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &

Resignations\Document Control\Adviser Profile Templates

ANZ.800.390.0045

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M3 & Elders

The SDM will send through a drafted profile for review with the application. Review and approve or

deny with requested changes. If a draft profile has not been submitted with the application, draft

the adviser profile and save as a PDF. Send the drafted profile to the adviser (in PDF format). The

adviser profiles are saved in Advice Delivery\04. Advice Process & Systems\03. Operations &

Payments\Appointments & Resignations\Adviser Profiles\Current\dealer group\adviser name

4.2.5. Induction Adviser Development has established a framework for a comprehensive induction solution that is

consistent across all ADGs, although M3 is more involved in the planning stage.

Adviser Development has provided ADG Practice staff with a tool to support new advisers in

adopting Licensee required business practices and co-ordinates Orientation Sessions on

request from the ADG.

For M3: Induction program materials (checklists, webinars and presentations) are

embedded within ‘My Workspace’ and / or loaded onto the website for deployment by the

licensee.

4.2.7. Ongoing Training system To ensure Advisers satisfy their ongoing training obligations, the Licensee provides access to an

online training tracking and planning solution for the ongoing Professional Development

requirements of the Financial Services Industry.

When Adviser Appointments notifies Adviser Development of a new appointment, the Adviser Development team must set up the new starter and allocate a training plan based on the adviser’s Authority type. The training plan includes:

Initial mandatory learning articles which must be completed within 3 months from the date of appointment. If the training is not completed, this will be escalated to the Consequence Management Committee to determine the best course of action.

o Fortnum - “Fortnum New Starter Mandatory Learning” o RI - “New Starter Mandatory Assessments” o FSP – “New Starter Mandatory Assessments” o M3 – “New Starter Mandatory Assessments”

The Adviser Development team is responsible for communicating the completion of all training to the Adviser and the Licensee, as well as checking for completion within the required timeframe. A detailed process on setting up an adviser can be found: xxxxxxxxxxxxxxxx

4.2.8. Professional Indemnity Insurance The Licensee’s Professional Indemnity Insurance Policy provides cover to Authorised Representatives

automatically once ASIC notification of Authority is complete.

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The Licensee’s PI cover only covers activities performed in their capacity as Authorised

Representatives of the Licensee. As part of the Application process, all Advisers must complete a PI

Declaration form.

PI premiums are charged to the Adviser / Practice by the Licensee as follows:

FSP: Authorised Representatives must to complete and return the PI Payment Form (sent to

them as part of the Welcome email). Prior to sending the form, the PI Insurance Calculator is

used to work out the pro-rata amount payable by the Adviser. Enter the start date and

amount payable in a tailored PI Payment Form.

o The form is located:

Advice Delivery\04. Advice Process & Systems\03. Operations &

Payments\Adviser Appointments &

Resignations\Authorisation\Authorisation Administration\Appointment

Tools

o The adviser should forward the completed form to the Brokerage team for

processing.

RI: All Authorised Representatives are charged a fixed amount for PI. This is deducted from

their brokerage on a monthly basis.

M3: Authorised Representatives must complete and return the PI Declaration Form as part

of the appointment process

o Once the form is received and Authorised Representative is appointed the Accounts

Team raise these invoices for payment. This will be a pro-rata amount dependent

upon the start date.

4.2.9. Research Tools

Mercer and Chant West access

Adviser Appointments team sends a spreadsheet to the Advice Systems & Support team on a weekly basis (note: if no new starters are appointed then the spreadsheet is not sent that week).

The Advice Systems Support team then notifies the Research Houses and asks them to set up the new users and notify them of their login details.

Spreadsheet is kept in: Advice Delivery\04. Advice Process & Systems\03. Operations & Payments

\Appointments & Resignations\Authorisation\Research Access\In Progress

4.2.10. Stationery Ordering The process for stationery ordering varies by Licensee as follows:

FSP: Once the Adviser Appointments team has sent the Marketing team the pre-

authorisation email, the team will set up an adviser log in to the Marketing Engine. Once the

adviser is authorized they will receive the log on details and can use this system to create

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their stationery. Alternatively, they can organize stationery through their own local supplier,

adhering to the brand guidelines and seeking Marketing team sign-off before using.

RI: Once the Adviser Appointments team has sent the Marketing team the pre-authorisation email,

the team will set up an adviser log in to the Marketing Engine. Once the adviser is authorized they

will receive the log on details and can use this system to create their stationery. Alternatively, they

can organize stationery through their own local supplier, adhering to the brand guidelines and

seeking Marketing team sign-off before using.

M3: the standard process for M3 is that Adviser / Practice arrange the printing of their own

stationery.

4.2.11. Technology, data conversion & access to advice templates The approved software platform for ADG Licensees is Xplan, including a CommPay module for Fee

Disclosure Statement (FDS) generation.

Process for RI & FSP

The Adviser Appointments team must notify the Advice Systems & Support team to set this up on

behalf of the Adviser by forwarding the Advice Systems Technology Set-up Form to the team as soon

as it is received from the Adviser/Practice.

! Note: this form may be submitted with the Application documents. If so, it should be submitted to the Advice Systems Support team as soon as it’s received so they can assess the Applicant’s requirements and tentatively schedule any required data conversions with IRESS and system set-up work.

In some cases, Xplan training and set-up may be organized via the SDM / Practice Development

Coach well before this stage of the appointment process.

This team also manages the data conversion process, as well as access to Advice templates via Xplan.

Appendix 1 contains process maps for a Standard and Custom Data Conversion.

Process for M3

The Advice Systems & Support team is notified to set this up on behalf of the Adviser by receiving

the Systems Technology Set-up Form from either the adviser appointment team, SDM or for the

Authorized Representative directly.

4.2.12. Vetting Standards The Vetting Program ensures that Advisers are producing advice which meets the Licensee’s expected standards prior to being provided to clients.

In regards to new starters, Vetting is applied to all new entrant Advisers immediately after the

successful completion of their induction.

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! All vetting requires each advice document to be approved before it is presented to a client.

It is important for both Licensees and Advisers to have confidence that an appropriate level of

competence can be demonstrated in giving advice across a range of types of authorisations and

specialist accreditations. Consequently Advisers need to progress through pre-vetting for each of

their specific authorisations and specialist accreditations according to the following groupings:

Authorisation Accreditation

Risk Protection Self Managed Super Fund (SMSF)

Superannuation & Investment Direct Equities

Retirement Planning Gearing

Business Insurance

Aged Care

The Adviser Appointments team must include a copy of the Vetting Standards as part of the

Welcome email/pack. Refer to the Advice Vetting Standard for further details.

4.2.13. Website - Licensee public website listing Once a new Adviser / Practice starts they are added to the Licensee’s public website by the following

teams:

RI: Marketing team

FSP: Marketing team

M3: N/A - These are not added to the M3 Website

4.3. Quick Reference Guide: Set-Up & Induction It is important that all of the Set-up & Induction procedures are confirmed as completed and done so

in a timely manner.

To help manage Adviser / Practice expectations around this process and to ensure they know who to

contact if they have any queries regarding the set-up of these services and systems the Adviser

Appointments team sends the ‘Quick Reference Guide: Set-up & Induction’ to all new starters in

their Welcome email/pack.

A copy of this is located:

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments

\Appointments & Resignations\Authorisation\Authorisation

Administration\Appointment Document Pack

It is then the Adviser/Practice’s responsibility to contact the relevant teams if they have any issues

regarding set-up and enablement of Licensee services.

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5. TERMINATION PROCEDURES When an Authorised Representative leaves the Licensee, the Senior National Manager Advice &

Operations needs to determine the following:

Last Date with Licensee (Resignation Date)

Client Register being released with Authorised Representative to new Licensee

Client Register being transferred to another Authorised Representative within the Licensee

New contact details for the Adviser

Once this information has been obtained, the following tasks need to be completed:

Terms of Agreement – preparing for termination o Receipt of resignation o Adviser File & Termination/Cancellation checklist o Notifying the Adviser of obligations and next steps in the termination process o Settlement of Outstanding Debts (if any) o Review of Tripartite Arrangements (if any)

Revoking the Authorised Representative’s Authority on ASIC Website

Client Communication (by Adviser/Practice)

Signing Transfer Deed to allow release of clients

Client Release Letter for New Licensee (if applicable)

Transferring Client Register to another Authorised Representative (if applicable)

Forwarding Exit Survey to Adviser for completion

Notifying all Licensee Support Staff

Authorising an Xplan Data Conversion (if applicable)

Removing access to services and systems on termination date: o Cancelling Software o Removing Adviser's Details from Lists and Database o Cancelling Website Access / Stationery ID o Notifying the Brokerage Team o Cancelling OnTrack access o Cancelling Research Tools

Retaining copies of client files / information in case of future complaints of litigation

Destroying adviser personal information after termination

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5.1.1. Terms of Agreement – preparing for termination

5.1.1.a) Receipt of resignation Practices must provide written notification as outlined in their Agreement in advance of their date of

termination unless otherwise agreed by both parties to the agreement. Advisers must provide a

period of notice as specified in their individual agreement unless otherwise agreed with their

employer/Licensee.

A copy of this resignation notification must be kept on the Adviser’s file.

5.1.1.b) Adviser File and Termination/Cancellation checklist Locate the hard copy Adviser’s File. Print out Termination Checklist and place in the Adviser File

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &

Resignations\Authorisation\Authorisation Administration\Cancellation Tools\ADG

Complete all steps as required in the Termination/Cancellation checklist.

It is imperative that all documentation relating to the Authorised Representative is maintained and

kept in their file, including any emails sent during the termination process.

This information should be kept for reference purposes, any potential disputes/queries relating to

the termination and for any auditing requirements.

5.1.1.c) Notifying the Adviser of their obligations and the next steps in the termination process Upon receipt of the notification of resignation notify the Adviser of their obligations under their

Agreement and provide an overview of the next steps in the process (using the standard email /

booklet template), ie:

Adviser to send the Licensee a copy of the negative consent letter for approval. Attach the relevant negative consent letter template as guidance.

Adviser to provide contact details for the new licensee.

Once the negative consent period has expired, confirm whether any clients chose to opt out.

Licensee to provide a client release letter to the new licensee (excluding the clients who have opted out).

If applicable, the Licensee will authorise an Xplan data conversion after the negative consent period. In the meantime, the new Licensee can liaise and book in the conversion directly with IRESS, but Licensee will need to give final permission after the negative consent period.

Exit survey – Adviser to complete prior to departure. This is not compulsory for them to complete and return. The exit survey is not sent to the adviser if they have been terminated by the Licensee.

Licensee to terminate the Adviser's AR status on the agreed termination date.

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5.1.1.d) Payment of outstanding debts Advisers/Practices must settle all outstanding debts before the Licensee will revoke their Authority.

Debts incurred by an Authorised Representative would generally relate to PI Insurance Premiums (if

paying via weekly deductions), software subscription and DMS Online.

The Adviser Appointments team should:

Send an email to Brokerage / Finance team requesting outstanding debt amounts (if any)

Request Accounts draw up an Invoice for the outstanding amounts

Take copy of Invoice and place in Adviser’s File

Send Invoice to Adviser with payment options

Confirm payment of the invoice before terminating the Adviser.

5.1.1.e) Review of Tripartite arrangement (if applicable) The Finance Department (RI & FSP) maintains a register of Tripartite Agreements for M3 all tripartite

agreements are noted against the Adviser in ‘My Workspace’. Determine if the departing Practice

has a Tripartite in effect. If so, the Licensee is required to notify the third party of the resignation of

the Practice per the terms of the agreement.

5.1.1.f) Review of outstanding complaints, incidents & remediation On termination of the Agreement, the Licensee requires the Incidents & Disputes team (Advice

Delivery Compliance & Professional Standards) to notify them of any outstanding complaints,

incidents & remediation. This must be provided in writing and a copy kept on the Adviser’s file.

A template email can be found in: Advice Delivery\04. Advice Process & Systems\03. Operations &

Payments\Appointments & Resignations \Authorisation \Email Templates\Terminations

5.1.1.g) Licensee sign off on any outstanding matters The Licensee must provide final sign off prior to termination of a Practice that all outstanding

matters have been resolved. This must be provided in writing to the Adviser Appointments team and

a copy kept on the Adviser’s file.

5.1.2. ASIC Notification - Revocation of Authority To ensure that the Authorised Representative is no longer recognised as an Authorised

Representative with the Licensee, the Adviser Appointments team is responsible for revoking their

Authority from ASIC Connect & the FAR. Go to:

https://asicconnect.asic.gov.au/public/faces/landingPage?_afrWindowMode=0&_afrLoop=1354881

648512000&_adf.ctrl-state=fufcjsljy_4 Note: Each Adviser Appointments Officer must have their

own individual login for this site. A detailed procedure document on how to terminate an Applicant

on ASIC Connect can be found in:

Advice Delivery\04. Advice Process & Systems\03. Operations & Payments \Appointments &

Resignations\Authorisation\Authorisation Administration\Appointment Tools\ADG

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5.1.3. Client Communication As required under the terms of their Agreements, the Adviser/Practice is required to notify their

clients that they wish to transfer the client’s portfolios and information to the new Licensee. They

are required to provide them with the means to object to this transfer and remain a client of current

Licensee. To do so, they must send them a negative consent letter in advance of their termination

date. Specific requirements are outlined in the Agreement, however, this letter is generally required

to be sent a minimum of 35 days in advance of termination. The client letter must be in line with the

Licensee’s letter template, a sample of which is included in the Agreement.

5.1.4. Transfer Deed The new Licensee must sign the Licensee’s Transfer Deed before a client release letter can be issued

to release the book of business. Should the new Licensee request changes to the Transfer Deed, it

must be approved by the Licensee’s Legal representatives before obtaining the signature of the new

Licensee. Once approved by legal, the Deed is issued in duplicate for signing by the new Licensee. On

receipt of both copies of the Deed, arrange for execution by the Licensee Authorised Signatory.

5.1.5. Client Release Letter Letter template location: Advice Delivery\04. Advice Process & Systems\03. Operations & Payments

\Appointments & Resignations\Authorisation\Authorisation Administration\Cancellation Tools

Once the negative consent period has expired and the Adviser has confirmed whether any clients

chose to opt out, the Adviser Appointments Officer needs to prepare the Release Letter and have

this signed by the Licensee General Manager (or delegate). The Release Letter authorises the Life

Companies and Fund Managers to transfer the brokerage and servicing rights of the Adviser’s Client

Register to the New Licensee. It contains the following information:

Name of Authorised Representative(s)

Authorised Representative Number(s)

Licensee agrees to transfer brokerage and servicing rights of Client Register to New Licensee

Any clients to be excluded from the transfer

New Licensee responsible for any write backs incurred after Release Date

Place electronic soft copy as well as hard copy of letter in Adviser File

Email a copy of the letter to the Adviser and the new Licensee

For any clients who elect to remain with the Licensee a new Adviser will need to be nominated to

service them. The Licensee is responsible for managing this process and notifying clients of their new

Adviser.

Once the allocation is made to the new Adviser, and at termination date, send notification to the

Advice Systems and Support team requesting the re-allocation of the Xplan data to the new Adviser.

It is the Licensee Practice Development team’s (RPM/SDM) responsibility to secure the client files

from the Practice and provide them to the new Adviser.

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5.1.6. Transferring Client Register to another internal Adviser (if applicable) If the Authorised Representative is transferring their Client Register to another Adviser within the

same Licensee, the following process applies:

Adviser Appointments team will notify the Practice that it is their responsibility to organise

client transfers to the new Adviser, send requests to the relevant Fund Managers and follow

them up.

5.1.7. Authorising an Xplan Data Conversion (if applicable) If applicable, once the negative consent period has expired, send an email to Advice Systems and

Support requesting that they authorise an Xplan data conversion excluding any clients who have

opted out. Advice Systems and Support will send this email to the relevant contact person at IRESS.

If all clients are transferring to the new Licensee, Advice Systems can accept the ‘Notification of

terminated Adviser/Practice’ sent to all Licensee support staff as instruction to begin the conversion.

Note: in regards to the client data in Xplan, the Licensee retains a snapshot of this data in case of

future complaints or litigation.

M3 Process

A terminated Authorised Representative must inform their new Licensee that there is to be a data

conversion within XPlan. M3 Systems and Communication area then receives a request from Iress to

removed data from the Xplan site.

5.1.8. Exit Survey The Exit Survey should be sent to all departing Advisers, with the exception of those Advisers /

Practices that are terminated by the Licensee or ANZ.

The exit survey is included in the ‘Notice of Obligations upon Resignation’ email sent to the Adviser.

If the adviser completes and emails back a survey, email this to the Licensee General Manager

and/or Senior National Manager Advice & Operations for their records.

5.1.9. Notification of termination to all Licensee Support Staff The Adviser Appointments team sends and email to all Licensee Support Staff advising them of the

terminating Adviser / Practice, which then prompts them to shut-down and remove access to all

Licensee systems and services on the termination date.

5.1.10. Removal of services & system access On the termination date of the Adviser / Practice, the Licensee Support teams will turn off access to

the Licensee services and systems as follows:

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5.1.10.a) Notifying Brokerage The Brokerage team must be informed when an Adviser is leaving so that they can make the

necessary adjustments to the DMS System.

It is the responsibility of the Authorised Representative’s new Licensee to arrange the transfer of

business with the Life Companies and Fund Managers.

The Brokerage team will continue to receive and process brokerage on behalf of the Adviser for a

period of 90 days during the transition process. This brokerage will be passed on to the Adviser with

the Licensee's margin deducted as per normal.

5.1.10.b) Cancelling software Upon notification of termination by the Adviser Appointments team, the Advice Systems & Support

team will cancel any Xplan licences, if this has not already been organised.

5.1.10.c) Updating internal registers It is important that the Adviser/Practice’s details are removed from all Lists, Databases and Outlook

Email Address Books when they decide to leave to ensure they don’t receive any unintended emails

or mail outs after their resignation date.

Refer back to the Authorisation task: “Updating Internal Registers” for details of all internal registers.

5.1.10.d) Cancelling Website Access / Stationery ID Once an email is sent advising all Licensee Support Staff of the termination, this will prompt the

Marketing Team to organise cancellation of the Adviser’s website access and stationery ID (FSP & RI

only).

This process is managed by the Systems and Communication team for M3.

5.1.10.e) Cancelling Adviser Website access Once an email is sent advising all Licensee Support Staff of the termination, this will prompt the

following teams to cancel access to the Licensee’s Adviser Website:

RI Adviser Services – Licensee Practice Development team

FSP ARC – Adviser Appointments team

M3 – Systems and Communication team

5.1.10.f) Cancelling Training System Access The Adviser Development team will manage cancellation of training system access. A detailed

procedure on how to do this can be found: xxxxxxxxxxxxxx

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5.1.10.g) Cancelling Research Tools Send an email to the following teams requesting that they notify the Research Houses to remove

access for the departing Adviser:

Advice Systems & Support – Mercer & Chant West access

Investment Research team – Morningstar access

5.1.10.h) Cancellation of PI Insurance Cover When an Adviser leaves they are noted as a “Past Adviser” on the Licensee’s Professional Indemnity

Insurance Policy from their resignation date.

This means that the Adviser will be covered for all business written whilst they were an Authorised

Representative with the Licensee but not for business written after their resignation date.

When an Adviser’s Authority is revoked on the ASIC register, this will be taken as having notified the

PI Insurer of the Authorised Representative's departure.

5.1.11. Retention of Client Data As part of the Termination process, the Licensee must obtain a copy of the departing Adviser’s client

files/information in case of future complaints or litigation. The current process is as follows:

RI: the Licensee retains a snapshot of all client data in Xplan.

FSP: the Licensee retains a snapshot of all client data in Xplan (if applicable). If the Adviser /

Practice does not use Xplan then a copy of client data is provided by the Adviser to the

Licensee on a USB stick/CD.

M3: Transfer deed under section 4.6 states that: o The New Licensee will ensure that, within 90 days of this agreement, the

Representative will provide copies to M3 of all client files on disk where advice has been provided while under the licence of M3. The documents required are:

File notes and Fact Finders Risk Profile questionnaires SOAs, SOAAs and ROAs

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5.1.12. Destruction of Adviser's personal information after termination After a period of 7 years from when an Authorised Representative leaves a Licensee, unless there

are specific business requirements to retain the information the Licensee must take reasonable

steps to destroy or de-identify all personal information (both hard-copy and soft-copy files) relating

to that individual.

I~ Note: this process also applies in instances where an Applicant withdrew their application or their application was unsuccessful ie information must be kept for 7 years

and then destroyed or de-identified.

G. AUSTRALIAN BANKING ASSOCIATION- RESPONDING TO A REQUEST

In responding to an ABA Protocol Reference Check request from other licensees that has been

received in the ABA email inbox, the Risk Liaison Officer will ensure the

following steps:

Procedure

• Request applies to a Financial Adviser providing personal advice on Tier 1 financial products,

within the last five years.

• Cross check the adviser name against Financial Adviser Register

https:/ /www.moneysmart.gov.au/investing/financial-advice/financial-advisers-register

• Confirm the adviser name has been employed by our ANZ Group (eg: ANZFP, Financial

Services Partners, Millennium3, Elders, Rl Advice)

• Create a folder for the adviser on the ABA Reference Checking folder on the Advice Risk

Share drive and enter details into the ABA Protocol Requests Log

• Create a Standardized Reference Checking Form using the templates in the share drive.

• Email the advisers supervisor to answer QS) "Was there an inquiry or investigation by the

Current/Previous Licensee in progress at the time of the Financial Adviser's

termination/resignation?" and Sa) "Is the Financial Adviser aware of any of these enquiries

or investigations?"

• Complete all sections of the ABA Reference Checking form with factual information by

accessing information in CoMetrix, Adviser Hub, COR, Compliants Register, Incidents

Registers and Reportable Breaches.

• Only include factual information based on our reports, documentation or records.

• Completed form to be sent to licensee head (or delegate) for approval.

• Completed form emailed in pdf format to the requesting licensee by COB 10 business days

after receiving the request.

• Update the ABA Requests log and the adviser file on the share drive.

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Internal Response Timeline

1. Risk Liaison Officer to complete the ABA Protocol Reference Check Form within 5 working days

2. Risk Liaison Officer to forward the completed draft of ABA Protocol Reference Check form to

the Licensee Head ( or nominated delegate) by day 6 if not earlier for review and sign-off

before responding to requesting Licensee.

3. The Licensee Head (or nominated delegate) to review and provide final sign-off within 5

working days if not earlier before it is responded to the requesting Licensee.

NOTE: If an adviser has been reported to ASIC for any breaches, the information disclosed in the

ABA Protocol Reference Check form must be forwarded to Legal Team for review of the wording.

Record Keeping Risk Liaison Officer to record the signed ABA Protocol Consent Form and completed ABA

Protocol Reference Check Form on our Shared Drive in a folder created for each adviser

Risk Liaison Officer to update the ABA Protocol Log for incoming requests and necessary

information

EMAIL TEMPLATE TO MAKE REQUEST TO OTHER LICENSEE

DEAR < Sir | Madam >

< Our Licensee Name> is a subscribing AFSL to the ABA Protocol, and we are requesting

information from < Other Licensee Name> also a subscribing AFSL to the protocol), for < Adviser Full

Name >, and AFSL < Number>

In accordance ABA Protocol, would you please provide your responses within 10 working days by

CBB DAY | DATE| MONTH| YEAR

A copy of the signed ABA Protocol Consent Form and ABA Industry Reference Check Form for your

reference.

We look forward to your response within 10 business days. Thank you for your cooperation.

Kind Regards,

Risk Liaison Officer

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ABA Consent Form Protocol

RI Advice Group Pty Ltd

Consent to the collection, use and disclosure of information

By applying for this position you consent to and expressly authorise RI Advice Group Pty Ltd (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to RI Advice Group Pty Ltd information about your current or previous employment or appointment for the purpose of RI Advice Group Pty Ltd assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:

(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and

supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning

your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.

Information collected by RI Advice Group Pty Ltd will be used by RI Advice Group Pty Ltd for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure).

If you become appointed/employed by RI Advice Group Pty Ltd or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by RI Advice Group Pty Ltd (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf

Declaration

I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Ri Advice Group Pty Ltd and understand that my consent will continue indefinitely.

Release

I release RI Advice Group Pty Ltd any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the RI Advice Group Pty Ltd reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.

ANZ.800.390.0059

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Full name (print):

________________________________

Adviser ASIC ID

________________________________

Signature:

_______________________________

Date:

________________________________

ANZ.800.390.0060

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Procedure Page 58 of 68 Version 5.0 December 2017

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Financial Services Partners Pty Ltd

Consent to the collection, use and disclosure of information

By applying for this position you consent to and expressly authorise Financial Services Partners (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Financial Services Partners information about your current or previous employment or appointment for the purpose of Financial Services Partners assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:

(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and

supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning

your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.

Information collected by Financial Services Partners will be used by Financial Services Partners for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure).

If you become appointed/employed by Financial Services Partners or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Financial Services Partners (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf

Declaration

I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Financial Services Partners and understand that my consent will continue indefinitely.

Release

I release Financial Services Partners any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Financial Services Partners reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.

ANZ.800.390.0061

Page 59: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 59 of 68 Version 5.0 December 2017

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Full name (print):

________________________________

Adviser ASIC ID

________________________________

Signature:

________________________________

Date:

________________________________

ANZ.800.390.0062

Page 60: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 60 of 68 Version 5.0 December 2017

Internal use only

Millennium3 Financial Services Pty Ltd

Consent to the collection, use and disclosure of information By applying for this position you consent to and expressly authorise Millennium3 Financial Services Pty Ltd (Millennium3) (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Millennium3 information about your current or previous employment or appointment for the purpose of Millennium3 assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:

(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and

supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning

your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) any compensation paid due to your compliance, risk management or advice activities.

Information collected by Millennium3 will be used by Millennium3 for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure). If you become appointed/employed by Millennium3 or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Millennium3 (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf

Declaration

I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Millennium3 and understand that my consent will continue indefinitely.

Release

I release Millennium3 any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Millennium3 reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.

ANZ.800.390.0063

Page 61: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 61 of 68 Version 5.0 December 2017

Internal use only

Full name (print):

________________________________

Adviser ASIC ID

________________________________

Signature:

________________________________

Date:

________________________________

ANZ.800.390.0064

Page 62: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 62 of 68 Version 5.0 December 2017

Internal use only

Elders Financial Planning Pty Ltd

Consent to the collection, use and disclosure of information By applying for this position you consent to and expressly authorise Elders Financial Planning Pty Ltd (Elders) (which for the purposes of this consent includes any of its related entities) and any persons or organisations acting on its behalf, to collect and use, and any of your current or previous employers/principals/licensees to disclose to Elders information about your current or previous employment or appointment for the purpose of Elders assessing your application for employment/appointment and complying with the ABA's Reference Checking & Information Sharing Protocol (Purpose). You agree that the information that may be collected, used and disclosed includes, but is not limited to, information in relation to:

(i) the scope and length of your authority (ii) your compliance record, including any results/outcomes from any internal monitoring and

supervision programs (audits) (iii) other risk management history, including in relation to any inquiry or investigation concerning

your conduct that was in progress at the time of your departure (iv) material incidents or ASIC reportable breaches caused or contributed to by you (v) Any compensation paid due to your compliance, risk management or advice activities.

Information collected by Elders will be used by Elders for the Purpose and will be treated confidentially (unless disclosure is required or authorised by law or regulatory order, or you consent to a particular disclosure). If you become appointed/employed by Elders, or one of its related bodies corporate, you also consent to and expressly authorise the disclosure of your personal information and information relating to your appointment/employment held by Elders, (including the information set out above relating to that employment/appointment), to anyone who is seeking to employ you or engage you as their Authorised Representative or Credit Representative or in any other capacity or to a person acting on their behalf

Declaration

I declare that I have read and understood the content of this consent form, including the future disclosures that may be made of my information if I become employed/appointed by Elders and understand that my consent will continue indefinitely.

Release

I release Elders any current or previous employer, principal or licensee and its or their related entities, employees, officers, agents and representatives (Releasees) from liability for any loss, damage, claim or cause of action (including in relation to any obligation of confidence), I may otherwise have had in connection with or arising from the collection, use or disclosure of my information for the Purpose (including the Elders reliance on the information) unless such liability is due to the gross negligence, malicious or fraudulent action of the Releasee.

ANZ.800.390.0065

Page 63: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 63 of 68 Version 5.0 December 2017

Internal use only

Full name (print):

________________________________

Adviser ASIC ID

________________________________

Signature:

________________________________

Date:

________________________________

ANZ.800.390.0066

Page 64: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 64 of 68 Version 5.0 December 2017

Internal use only

ABA INDUSTRY REFERENCE CHECKING FORM

INDUSTRY REFERENCE CHECKING FORM

Financial Adviser (Full

Name):

ASIC ID:

Date completed:

Completed by:

All information should relate to the period up to 5 years preceding the date of the request. (Hand

written notes will not be accepted).

Background

1. What is the scope of the Financial Advisors authority?

2. For what period?

Response Applicable Dates

Compliance, Risk Management and Advice Quality.

Questions 2-4 should be answered in relation to the Financial Advisors compliance, risk management

and advice quality only

3. What are the Financial Advisor’s internal monitoring and supervision program (Audit)

results/outcomes

Response Applicable Dates

Guidance for Current/Previous Licensees:

Include description of the meaning of the audit result at the time, the results/outcomes was

determined and as it was applied

4. Has the Current/Previous Licensee undertaken any of the following which has caused or

contributed to by the Financial Adviser’s action/ in action (e.g. not in system or Licensee

issue)

ANZ.800.390.0067

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a) Reported a breach to ASIC (whether under the corporations Act s912D or otherwise

Response Applicable Dates

Guidance for Current/Previous Licensees: Include the nature/type of breach reported.

b) Identified a material incident

Response Applicable Dates

Guidance for Current/Previous Licensees:

A material incident could be identified through internal assessment or external notification (i.e.

regulatory investigations, complaints received etc.) When assessing the materiality of an incident,

consideration should be given, but not limited to the factors listed below.

It is up to the Current/Previous Licensee to determine the extent to which the factors contribute to

the assessment of materiality on an incident by incident basis.

i. The actual or potential impact on the client, including financial loss

ii. The number or frequency of similar previous incidents

iii. The relevance or importance of the breached obligation in managing risk for the client and/

or the current/previous Licensee

iv. Whether the incident resulted in an intervention or action by the Current/Previous Licensee

as a consequence of the incident and in order to correct the situation

v. Complaints received including the nature, type and frequency of the complaints, and/or

vi. Known civil actions resulting from the provision of financial advice

c) Provided compensation as a result of an impact on any of the Financial Adviser’s client base

due to the compliance, risk management and advice activities of the Financial Adviser.

Response Applicable Dates

Guidance for Current/Previous Licensee:

ANZ.800.390.0068

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Procedure Page 66 of 68 Version 5.0 December 2017

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Compensation refers to a financial payment offered to a client and/ or any other non-financial

remedy given to a client e.g. free financial advice. When considering the impact on the client base,

consideration should be given, but not limited to:

i. Whether categories of the client base were affected, for example all clients who received a

particular category of Tier 1 financial product advice or recommended a particular product

or strategy, and/ or

ii. Significance, as determined by the Current/Previous Licensee, of the amount of

compensation made.

The Current/Previous Licensee is not required to disclose actual compensation amounts paid, nature

of the non-financial compensation provided, or the reasons for providing compensation. The

Current/Previous Licensee is also not required to disclose compensation provided on commercial

terms, where this does not relate directly to the compliance, risk management and advice activities

of the Financial Adviser.

5. Was there an inquiry or investigation by the Current/Previous Licensee in progress at the

time of the Financial Adviser’s termination/resignation?

Response Applicable Dates

a) Is the Financial Adviser aware of any of these enquiries or investigations (Yes/No)

Guidance for Current/Previous Licensees include the following:

i. Progress/ status of the inquiry/ investigate on, and

ii. Cause/ trigger of the inquiry/ investigation.

If the inquiries/ investigations undertaken by the Current/Previous Licensee into the Financial

Adviser are in the early stages, provide

Information on the status of the inquiry/ investigation.

ANZ.800.390.0069

Page 67: Aligned Dealer Group {ADG) Authorised Representative

ABA Protocol Subscribers Key Contact List

Financial Planning (AFSL 232706) Charter Planning (AFSL 234665) Hillross Financial (AFSL 232705) ipac (AFSL 234656) SMSF

234664)

Financial Planning (AFSL 234527) Elders Planning (AFSL 224645) Financial Services (AFSL 237590) Millennium3 Financial Services

Ri Advice Group (AFSL 238429)

Group (Westpac): Magnitude Group (AFSL Financial Group (AFSL 240687)

Banking Corporation (AFSL 233714)

BW Financial Advice (AFSL 230727) ICo>mnlon;' '"'lth Financial Planning (AFSL 231139) IComnlonv.e,,lth Private (AFSL 314018) Commonv.ealth

(AFSL 238814) Count Financial (AFSL Financial Wisdom (AFSL 231138)

Procedure

Version 5.0 December 2017

CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL

ANZ.800.390.0070

Internal use only

Page 67 of 68

Page 68: Aligned Dealer Group {ADG) Authorised Representative

Procedure Page 68 of 68 Version 5.0 December 2017

Internal use only

XPLAN DATA CONVERSION PROCESS

ANZ.800.390.0071

..... ft , . .,. .. ,, Standard Data Conversion Process

RPM I RPC

Adv ice S yOt <!,. Support

New Practice

I STAIIDARD l'ldicrii'O so da)'S b'5~d.3".3o:rJYe.f'5Jxl I DATA r---------; COHVfRSIC»>

...... --

Custom Data Conver sion Process

Advi c:e S yOte,. Suppo rt

I I CUSTOM ! DATA

I COII'I£IIS10II I

.-------------------------~~~--~_,,

r--===---.---- Rt FreYOI.3 '/ It' s. ~t.·~~e:c~~ b'J I-B"'CV

I I I I I I I r.o.:t:e-J fJY;N.• IvllleeSi5·':ef"!S.~

f:IP Th s s~~~~lr'~ ?r.s.~

=a-.. 1--------------------~ I RPM I RPC

New Practice

RE I :! c.s~.bl ::, e>..S:S ':OC.OI"""4le~e 'J" sstec Al!'vfco llrstef'l"' 5 I~ o~to It, &. cp:c -~ dc6 r04' a,ne;• , e:..:s. ':0 ca-pe·e ... I

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