monitoring and supervision of representatives plan 1.introduction ============== 1. one of the requirements of an a

Monitoring and Supervision of Representatives Plan
1.INTRODUCTION
==============
1.
One of the requirements of an AFS Licence is that we have in
place policies, and procedures to ensure that our staff and
representatives deliver Financial Services and Products in a
fair, honest and efficient manner.
2.
This plan sets out how we monitor and supervise our staff and
representatives to ensure that this is consistently achieved.
It also details what corrective action and reporting is
required in any situations where this is not achieved.
3.
For the purposes of this plan staff includes any Authorised
Representatives who provide Financial Services Advice
appointed by the business.
2.Supervision and Monitoring
============================
4.
The supervision and monitoring of staff is implemented by the
integrated use of various Policies and Procedures of the
business.
5.
The Training Policy and Procedures (Training Policy and
Procedures) of the business spells out how we ensure that each
staff member and representative has and maintains the
appropriate training required to perform their role in a fair,
honest and efficient manner.
6.
The Compliance Policy and Procedures (Compliance Policy and
Procedures) of the business spells out how we ensure that all
activities of the business are compliant with all relevant
laws, regulations, codes etc. By its very nature the Policy
involves the checking of various activities undertaken by
staff and representatives.
7.
The External Representative Policy and Procedures (External
Representative Policy and Procedures) of the business spells
out our approach to appointing Spotters and Referrers,
Distributors and Authorised Representatives. It includes
specific information requirements to enable us to assess the
suitability of any Authorised Representative/Distributor
applicant. It also includes the use of a formal Authorised
Representative/Distributor agreement and additional specific
monitoring and review processes for our Authorised
Representatives/Distributors.
8.
Our External Representative Policy and Procedures specifically
makes our Authorised Representatives subject to our Training,
Compliance and Complaints Policies and Procedures.
9.
The Appraisal process of the business provides for a formal
annual review of the performance of each staff member against
the individual performance and training goals agreed. This
includes a formal knowledge and activity review.
10.
The Complaints Policy and Procedures (Complaints Policy and
Procedures) of the business applies to all staff and
representatives and provides an early warning system of any
problems relating to the performance or activities of staff
and representatives.
11.
The Organisation Chart of the business provides details of all
reporting lines for all staff including Authorised
Representatives and Distributors.
12.
The annual business planning process and the formal Business
Plan ensures that all aspects of the business are reviewed at
least annually, including the performance and contribution of
all staff, Authorised Representatives and Distributors. This
review also includes a review of the authorisations issued.
13.
All other Business Policy documents include a review trigger
where there is a clear failure of a Policy to deliver the
anticipated outcomes.
14.
Each staff member (via Letter of Engagement) and Authorised
Representative / Distributor (via Agreement) is provided with
information on the importance of Compliance and the remedies
available to the business in the event of non compliance with
any of the Policies or Procedures of the Business.
15.
The timing of any formal independent external review of the
application and effectiveness of all Policies and Procedures
relied upon within the business will be decided and documented
in our annual Business plan.
16.
Most staff are on fixed annual salaries. Some staff may be
entitled to financial bonuses based on various performance
criteria. It is our policy to not tie such bonuses solely and
directly to sales.
17.
Where staff are paid directly on the basis of sales we
incorporate additional safeguards in our appraisal process to
specifically address the management of this.
18.
Some employees are also directors/equity partners in the
business and as such are entitled to dividends generated by
the business and other director benefits. These dividends and
benefits are not tied specifically to sales or commission
earnings.
19.
The remuneration of each Authorised Representative/Distributor
is negotiated individually. The precise terms of the
remuneration are included in the formal Authorised
Representative/Distributor Agreement. The remuneration
structure provides for payment of earnings generated less a
Service fee percentage and a Monthly Management Fee.
20.
The Authorised Representative/Distributor Agreement makes us
responsible for all costs associated with Training, Monitoring
etc. The Authorised Representative is responsible for any
External Dispute Resolution scheme fees payable on complaints
lodged regarding the Authorised Representative.
21.
The Authorised Representative agreement has a specific clause
that provides for us to reduce the remuneration payable to the
Authorised Representative where they fail to meet our
requirements in relation to Training, Compliance, Complaints
and other AFS Licensee obligations.
22.
Our External Representative Policy and Procedures and our
Authorised Representative /Distributor Agreements state that
they will not usually be allowed to be Authorised
Representatives for any other Licensee.
23.
Our Authorised Representative/Distributor Agreements
specifically requires that they do not act outside the scope
of their authorisation. It also contains guidance on the
specific requirements that we have on how they act and hold
themselves out to clients.
24.
Our External Representative Policy and Procedures, Authorised
Representative Agreement and our Compliance Policy and
Procedures all specifically address the requirement for the
Authorised Representative advise us of any changes and for us
to advise ASIC of such changes within 10 days.
25.
Any changes to the authorisation of an Authorised
Representative requires Responsible Manager approval and is
subject to the External Representative/Compliance/Training
Policies and Procedures and requires an amended Agreement to
be put into place.
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