14. RECRUITMENT PLAN
The following documents HR Processes that will be followed for Employees / Contractors should they be required in the future:
Recruitment / Processes to ensure adequate candidate checksIf we decide to hire any further loan writers, we will ensure that they are fit and proper persons and in particular have not committed any serious offence, been bankrupt, refused or disqualified by a professional or regulatory body, or in any other way adversely commented upon, unless that matter is explained to our satisfaction.
We will obtain the following:
· recent criminal history check
· recent credit/bankruptcy check
· character declaration
· employment contract
· ASIC banned or disqualified persons check
· independent reference check
· conflict of interest declaration
· verification of qualifications
In particular, we will ensure that all brokers have obtained a Certificate IV Financial Services (Finance/Mortgage Broking) by 30 June 2014.
We will ensure that any external credit representative we appoint is a member of an ASIC approved external dispute resolution scheme.
Employee / Contractor Induction / Processes to induct them within the organisation.
OH and S policy is provided and office orientation / workplace orientation is conducted
Provide roles and responsibilities documentation
Provide processes and procedures manual(s)
Provide compliance manual
Document and issue software, hardware and equipment that is supplied to employee / contractor
Performance Review / Representatives files will be examined on a periodic basis (10% of files / applications will be internally audited to ensure documentary evidence is consistent with the processes set out in the loan application guidance used internally).
Performance review interview
· Set timeframe for review
· Check previous written review
· Review performance against goals and expectations
· Ensure authorisations remain appropriate
· Review any non compliance issues
Succession Planning / Where employees / contractors are meeting their goals and expectations, we aim to provide opportunities for further development.
We aim to ensure that a knowledgeable labor supply exists to replace personnel leaving the organization regardless of the reason.
Our goal will be to train internal staff (who have expressed an interest in further development) with the required knowledge and skills to fill key positions as part of a recognized succession plan.
Where this plan involves recognized qualifications, this function will be outsourced to a recognized training provider.
Performance Management / Processes and tools to counsel an employee for poor performance including disciplinary process and issuing of warnings.
If a review of representative files demonstrates minor inconsistencies in the product selection process (and the associated supporting documentation), representatives will be investigated to understand how the issues are occurring and be sufficiently mentored to ensure any gaps in the process are rectified.
Any issue that is addressed above will be recorded on the non compliance register and a note will be added into the representative file for performance coaching.
These issues recording in the non compliance register will be monitored for a period of 3 months to ensure that any contravention has been rectified in the particular representative’s processes. If there are more representatives working within the business, an internal training and development session will be scheduled to ensure the non compliance is not prevalent in the organisation.
Counselling for Misconduct / Processes and tools to counsel an employee for misconduct including disciplinary process and issuing of warnings.
If any issue of non compliance is found to have been consistent, deliberate and malicious, we will take immediate action to sanction that representative. This conduct includes significant repetition of any infringement where counselling and mentoring had been initiated previously.
If ASIC makes a banning order against a current or former representative of the licensee under Division 2 of Part 2-4 of Chapter 2 of the Act; or the court makes an order disqualifying a person who is a current or former representative of the licensee under Division 3 of Part 2-4 of Chapter 2 of the Act, We will, if instructed by ASIC, take all reasonable steps to provide the following information in writing to any person in relation to whom the representative engaged in a credit activity on behalf of the licensee within a period of three years before the order was made:
· the name of the representative;
· if the representative is a credit representative, the credit representative number allocated to the representative by ASIC;
· the terms of the order; and
· contact details of the licensee for dealing with enquiries and complaints regarding the banning or disqualification or the conduct of the representative.
Termination procedures / If, after appropriate warnings have been issued for poor performance and counselling has also failed, termination procedures will be initiated if required notices have been issued in the appropriate timeframes.
In addition, upon termination of an employee or representative, We will ensure that appropriate notifications are provided in the designated time frame.
Key Person Requirements
If any of the key people cease to be officers of the licensee or to perform duties on behalf of the licensee with respect to its credit business:
We will within five business days after that event:
(a) notify ASIC in writing that the person ceased to be an officer of the licensee or to perform duties on behalf of the licensee with respect to its credit business, and the date on which this occurred; and
(b) lodge with ASIC an application for variation of this condition that includes the following:
· the name and address of each person that the licensee proposes to rely on as a replacement key person;
· the date on which that person commenced, or will commence, duties on behalf of the licensee with respect to its credit business; and
· the educational qualifications and experience of that person; or
· if we are not proposing to rely on any replacement key person, a detailed description of how we will continue to comply with the Act and the conditions of the licence.
geoffrey thomas mckenna
abn 73 732 994 243
132 WINGROVE street • fairfield • 3078
mobile: 0405 447 131
Phone: 03 9443 0083 • Fax: 03 9443 0042