Legislation defines the Fair Conduct Principle as:

• paying due regard to consumers’ interests
• acting ethically, transparently, and in good faith
• assisting consumers to make informed decisions
• ensuring the products and services it provides are likely to meet the requirements and objectives of likely consumers (when viewed as a group)
• not subjecting consumers to unfair pressure or tactics, or undue influence.

A summary of the Programme:

• Christian faith principles are central to our purpose and values and provide a genuine foundation for the Fair Conduct Principle in our operations. Our Fair Conduct Programme is founded on our values of Faith, Care, and Stewardship.
• We distribute our products directly to most of our customers. In all communications with customers, staff must embody our Code of Conduct and comply with all applicable standard operating procedures – this ensures efficient and effective customer support. Where a third party distributes our products to customers, we require regular confirmation that their operations are compliant with the Fair Conduct Principle. The terms of our products are the same across all distribution channels.
• As mentioned elsewhere on our website and in our Product Disclosure Statement, we recommend that new and existing customers take independent legal and financial advice before making investment and borrowing decisions.
• We annually train our staff on the content of our Fair Conduct Programme and also our Code of Conduct. These trainings help staff identify fair conduct issues, and be aware of conduct expectations.
• Our Conduct Issues Management Process requires staff to report fair conduct issues to our Head of Legal, Risk & Compliance (HoLRC) for recording. The HoLRC then approves and implements the appropriate remediation plan.
• We maintain a variety of Conduct-Related Registers and the HoLRC reviews these registers periodically to identify any fair conduct issues and any required update to our Fair Conduct Programme.
• The HoLRC reports to the Risk Committee (a delegation of the Board) every 2 months on the content and progress of remediation plans evidenced in the Conduct Issues Resolution Register.
• Annually, the HoLRC reviews our Fair Conduct Programme and reports to the Board on our fair conduct compliance.

Please see the Complaints section below for details on how to let us know about any fair conduct issues you think have arisen.