Use this policy if you:

• Operate or manage one or more unitised managed investment schemes
• Act as trustee of unregistered schemes rather than as a Responsible Entity
• Need a documented method for current unit value, issue and withdrawal prices
• Exercise discretion over valuations, buy/sell spreads or pricing frequency
• Want your unit pricing practices aligned with RG 94 good practice principles

It is suited to:

• AFSL holders operating unregistered managed investment schemes
• Trustees and investment managers of unitised funds
• Compliance officers responsible for unit pricing oversight
• Boards and investment committees approving pricing methodology

What this policy covers:

• Net asset value, gross asset value and the treatment of liabilities under AIFRS
• Issue (application) and withdrawal (redemption) price formulas
• Six discretions that may affect the unit price
• Valuation methods for hedge funds, direct property funds and mortgage funds
• Transaction charges and the buy/sell spread rationale
• Frequency, suspension and rounding of unit prices
• Deviation from the policy, with seven-year retention of discretion records
• Compliance Officer monitoring, error investigation and investor compensation

You receive an editable Word document with placeholders for your entity name, ACN and the date the board approves the policy, alongside an approvals and version history table, a key obligations table and a full definitions list. Schedule 1 is supplied with a worked example row already completed, covering capacity, the NAV and GAV formulas, a buy/sell spread of up to 0.30%, pricing each business day and rounding to four decimal places, so you have a model to follow for each of your own funds. Tailor it to your governing documents, disclosure documents and licence conditions, and take advice on your own circumstances before adopting it.

Use this policy if you:

• operate or oversee a managed investment scheme, trust, investment option or unitised pool
• calculate, review or publish unit prices, or supervise a provider that does
• need a documented, repeatable method for rectifying unit pricing and valuation errors
• must evidence to ASIC how each compensation decision was calculated and approved
• outsource unit pricing or fund administration and retain supervisory responsibility

It is suited to:

• Australian responsible entities and trustees
• fund managers, life companies and superannuation trustees
• pricing, operations, product and finance teams accountable for unit price accuracy
• compliance and legal teams managing the breach, IDR and remediation interfaces
• APRA-regulated entities, provided the policy is separately tailored to their prudential obligations

What this policy covers:

• a five-stage detect, contain, triage, escalate and plan workflow with an owner at each stage
• root-cause analysis and affected-population rules covering current, exited, transferred, deceased and uncontactable holders
• calculation methodology for unit and price reconstruction, investment performance, time value, fees, tax and consequential loss
• materiality thresholds, including the 0.30% RG 94 reference point, treated as guidance rather than a safe harbour
• payment methods for current holders, tracing obligations for exited holders and recovery from advantaged holders
• complaints and RG 271 assessment, reportable situations under sections 912D to 912DAA of the Corporations Act 2001 (Cth), and privacy, APRA and AFCA notifications
• outsourced provider oversight, notification testing, assurance rights and cost recovery
• seven schedules: configuration and fund inventory, error notification form, compensation assessment and approval, error and compensation register, communication plan checklist, closure and lessons-learned checklist, and regulatory reference guide

You receive an editable Word document with every purchaser input highlighted, including [Company Name], [insert name], [insert approving body] and [insert outsourced provider], so roles, thresholds, retention periods and fund details can be configured before approval. It carries a regulatory currency note current at 8 August 2026 and a reference guide to the Corporations Act, the ASIC Act, RG 94, RG 132, RG 78, RG 271 and RG 256. Obtain legal review before adoption — the policy is a starting point and does not account for your constitution, licence conditions, products, tax position or outsourcing model.

Use this policy if you:

• Hold an AFSL and provide financial services to wholesale clients
• Need a documented complaints process that your board has formally approved
• Want complaints captured in one register rather than across inboxes and file notes
• Review complaints at a regular compliance meeting and need a standing framework for it
• Are preparing for an audit or licence review and need your complaints handling evidenced

It is suited to:

• Australian financial services licensees with a wholesale client base
• Licensees whose complaints handling sits with a compliance officer
• Businesses that report complaint data to a board or compliance committee
• Licensees that outsource part of their dispute resolution process and remain responsible for it

What this policy covers:

• Who the policy binds, including directors, employees, contractors, consultants and committee members
• The definition of a complaint and the non-technical approach to identifying one
• The wholesale client position under sections 912A(1)(g) and 912A(2) of the Corporations Act 2001 (Cth)
• A two-step process: acknowledgement and early resolution within five business days, then the IDR Response
• When a written IDR Response is required and the limited circumstances in which it is not
• The three IDR Response outcomes: rejection with reasons, redress without acceptance and acceptance with a remedy
• Remedies including fee refunds, referral, financial assistance and compensation, and who may approve them
• Complaints Register requirements, quarterly compliance meeting review and systemic issue escalation

You receive an editable Word document with placeholders for your entity name, ABN, ACN, AFSL number and the date the policy is approved, plus a version control and approval history table, a key obligations table, a definitions table and two schedules — a Complaints Register and a complaints process flowchart. The regulatory position assumes a wholesale client base, so review it against your own licence authorisations and client mix and obtain advice tailored to your circumstances before adopting it.

Use this policy if you:

• hold an Australian financial services licence and must maintain adequate conflicts management arrangements
• act as trustee or investment manager of one or more managed investment schemes
• need conflicts of interest and related party transactions covered in a single document
• want a documented chain of responsibility between your compliance officer and board
• need declaration forms and a conflicts register your people can start using immediately

It is suited to:

• AFSL holders providing financial services to investors
• trustees and investment managers of managed investment schemes
• compliance officers, responsible managers and company secretaries
• boards and the investment or remuneration committees that advise them

What this policy covers:

• what a conflict of interest is, using the RG 181 definition, and the four circumstances that increase risk
• licensee obligations under section 912A of the Corporations Act 2001 (Cth), reg 7.6.03(g) of the Corporations Regulations and Condition 4 of Pro Forma 209
• general law and statutory duties of directors and officers, and trustee duties to investors
• related party transactions under Chapter 2E of the Corporations Act as modified by Part 5C.7, with unregistered scheme fund transactions carved out
• annual identification reviews across eight areas, plus six trigger events requiring an out-of-cycle review
• the board decision to avoid, control, control and disclose, or disclose each conflict
• disclosure that is timely, prominent, specific and meaningful, and quarterly reporting to the board
• breach handling, risk ratings, reporting to ASIC where required and seven-year record retention

You receive an editable Word document with four schedules: a description of conflict management arrangements pre-populated with five worked scenarios, a chain of responsibility, three declaration forms covering commencement, disclosure of a conflict and annual self-assessment, and a nine-column conflicts of interest register. Placeholders such as [Company Name] and [Company ACN] mark the fields you complete, and the key obligations table arrives populated with responsible persons, timing and cross-references. Because it does not account for your licence conditions, fund structure or risk profile, have it reviewed and tailored to your organisation before you adopt it.

Use this policy if you:

• Hold an AFSL authorising custodial or depository services
• Hold fund assets yourself under self-custody arrangements
• Appoint an external custodian, or a master custodian that engages sub-custodians
• Act as trustee or investment manager of one or more managed investment schemes
• Need a board-approved policy showing how you meet the RG 133 minimum standards

It is suited to:

• AFSL holders authorised to provide custodial and depository services
• Fund managers acting as trustee or investment manager of managed investment schemes
• Compliance officers preparing policies for board approval
• Licensees using master custodian and sub-custodian structures

What this policy covers:

• Document control and version history, a key obligations table with timing and responsible persons, and references to your breach reporting, conflicts, outsourcing and risk policies
• The obligations ASIC Class Order [CO 13/1410] imposes on licensees authorised to provide custodial and depository services
• The four RG 133 minimum standards: organisational structure, staffing capability, capacity and resources, and holding assets on trust
• Selecting and engaging custodians through your outsourcing policy, which must be reviewed at least every 13 months
• The fourteen matters a custody agreement must address: review and monitoring rights, written certification, manner of holding, instructions, liability, security interests, record-keeping and reporting, auditing, identity of agents, termination, breach reporting, arrangements with other parties, business continuity, and confidentiality
• Giving proper instructions signed by two authorised signatories, and maintaining the authorised signatory list
• A monitoring cycle of daily reconciliation, six-monthly compliance testing, annual custodian certification, an annual GS007 internal controls audit and an annual Compliance Officer review, with records kept for seven years
• Master custodian arrangements, including where sub-custodian terms are not reasonably practicable outside Australia

You receive an editable Word document with placeholders for [Company Name], the ACN and AFSL number, the board approval date and the location of each related policy, plus an Appendix A checklist to confirm everyone has been replaced. Purple drafting notes, green worked examples and four figures guide you through tailoring, and are deleted before adoption. Custody arrangements turn on your licence conditions and the structures you use, so have the completed policy reviewed by a qualified lawyer before your board approves it.

Use this policy if you:

• hold an AFSL and act as responsible entity of an unlisted managed investment scheme
• operate a fund that invests in real estate or direct property assets
• borrow under facility agreements that contain financial covenants
• need a written gearing policy and interest cover policy at individual credit facility level
• disclose gearing and interest cover to investors in offer documents and fund updates

It is suited to:

• responsible entities of unlisted property schemes offered to retail investors
• compliance officers who own and maintain the policy suite
• boards of directors approving borrowing and leverage settings
• fund managers responsible for facility agreements and covenant monitoring
• investment committees consulted on lender selection

What this policy covers:

• AFSL general obligations under section 912A and responsible entity duties under section 601FC of the Corporations Act 2001 (Cth)
• RG 46 Benchmarks 1, 2 and 3 and Disclosure Principles 1, 2 and 3, mapped section by section
• lender selection guidelines and indicative diversification thresholds by exposure level
• gearing ratio, net gearing ratio and look-through gearing calculations, each with a worked example
• interest cover ratio calculation and the starting position on interest capitalisation
• quarterly covenant review, disclosed target ranges and a nominal 5% escalation buffer
• a covenant monitoring and escalation flowchart, with breach recording in the compliance register
• a key obligations table and an appendix mapping every section to its regulatory source

You receive an editable Word document containing a definitions table, worked calculation examples and a drafting guide that is deleted before adoption, with placeholders for [Company Name], [Company ACN], [AFSL Number], the Board approval date and the location of each related document. The gearing thresholds, timeframes and covenant buffer shown in italics are drafting positions rather than fixed requirements, and a mortgage scheme, credit fund or listed vehicle will need the regulatory references and defined terms adapted. Check the template against the current version of RG 46 and your own facility agreements, and have it tailored to your organisation by a qualified lawyer.

Use this template if you:

• are establishing an investment committee for a fund, trust or managed investment scheme
• want the committee to advise rather than exercise delegated investment authority
• are replacing an informal committee arrangement with a documented charter
• need quorum, voting and escalation rules that will stand up to scrutiny
• report investment recommendations to a board or trustee board

It is suited to:

• fund managers, wholesale investment managers and private capital businesses
• trustees and responsible entities of funds and managed investment schemes
• corporate groups establishing an advisory investment committee
• AFS licensees aligning committee practice with their licence conditions
• boards running one committee per fund or a shared committee across several funds

What this template covers:

• advisory status, the limits on committee authority and the matters that must be escalated to the board
• committee responsibilities across strategy, asset allocation, acquisitions, disposals, due diligence and external manager appointments
• the information and factors a recommendation must consider, including valuation, liquidity, ESG, sanctions and conflicts
• membership, eligibility, appointment, removal, alternates and the roles of chairperson, chief investment officer, secretary and members
• meeting mechanics: frequency, notice periods, papers, quorum, attendance by technology, voting and written resolutions
• conflicts of interest, chairperson conflicts and related party matters
• reporting to the board, minutes, record ownership, induction, annual effectiveness review and two-yearly charter review
• four schedules: charter configuration, an indicative annual work plan, an investment recommendation record, and a meeting agenda and minutes checklist

You receive an editable Word document with a seven-step implementation guide, a populated definitions table and four schedules, including a quarterly work plan and an agenda and minutes checklist that can be adopted largely as drafted. Highlighted fields such as [INSERT LEGAL ENTITY NAME], [INSERT ACN], [INSERT AFSL NUMBER] and the Schedule 1 settings for quorum, voting threshold and meeting frequency are marked for completion. Reconcile the charter against your trust deed, constitution, investment mandate and board delegations, and obtain legal advice on your own circumstances before adoption.

Use this policy if you:

• Hold an Australian financial services licence and promote or distribute financial products
• Market and distribute those products to wholesale clients
• Do not issue regulated disclosure documents such as a Product Disclosure Statement or Financial Services Guide
• Need a documented review and approval pathway for marketing material before it is released
• Need to manage the hawking prohibitions in the Corporations Act 2001 (Cth)

It is suited to:

• AFSL holders acting as trustee or investment manager of a managed investment scheme
• Fund managers distributing to wholesale investors under an information memorandum
• Compliance Officers responsible for reviewing marketing material before release
• Boards approving a marketing and distribution policy as part of a wider compliance suite

What this policy covers:

• Policy ownership, board approval, annual review and a key obligations table mapping each obligation to its timing, responsible person and reference
• ASIC's RG 234 good practice guidance on returns and risks, fees and costs, comparisons, ratings, awards, past performance and forecasts, testimonials, restricted terminology, and target audience
• The principles ASIC applies in deciding whether advertising is misleading or deceptive, and the substantiation expected for each statement
• Channel controls for mass media and social media, audio, film and video, internet, outdoor advertising, and consumer testing
• Disclosures required on stationery, signage, websites, apps and social media pages, including general advice warnings and past returns disclosure
• The Compliance Officer review process for marketing material, with escalation to an external compliance or legal services provider
• The hawking prohibitions in sections 736, 992AA and 992A of the Corporations Act, what counts as unsolicited contact and good practice for real-time interactions
• Schedule 1, a Marketing Material Checklist covering principal, company details, general advice warnings, restricted words, past performance, fees and direct marketing opt-out

You receive an editable Word document with bracketed placeholders for your company name, ACN and issue and approval dates, ready to populate and take to your board. It reflects ASIC's guidance in RG 234 and RG 38 together with the hawking provisions of the Corporations Act, and should be reviewed by a qualified lawyer and tailored to your licence conditions, product range and client base before adoption.

Use this policy if you:

• issue financial or credit products to retail clients and must make target market determinations
• distribute products issued by another person and need documented reasonable-steps controls
• operate wholesale-only products and want a governance overlay without assuming statutory DDO applies
• need to evidence product governance to your Board, ASIC or an assurance reviewer

It is suited to:

• financial product issuers, responsible entities and trustees
• fund managers and AFS licensees
• credit licensees and product distributors
• compliance, risk and legal teams accountable for product governance

What this policy covers:

• DDO perimeter assessment and the rule that no product proceeds to retail distribution without classification
• governance roles for the Board, Product Governance Committee, Product Owner, Compliance, Risk, Legal and Internal Audit
• a five-stage product lifecycle covering concept, design, approval, distribution and monitoring
• minimum TMD content, the appropriateness requirements and target market granularity
• issuer and distributor reasonable steps, marketing controls and distributor due diligence
• monitoring data, periodic and trigger reviews, and the 10 business day review and notification timeframes
• significant dealing assessment, material product change, suspension and closure
• wholesale-only products, conflicts, remuneration, vulnerable consumers, training and record retention of up to seven years

You receive an editable Word document with eighteen numbered sections, eight schedules and a regulatory update table current to 8 August 2026. Highlighted fields such as [INSERT LEGAL ENTITY NAME], [INSERT ACN], [INSERT APPROVING BODY] and [INSERT ROLE] configure the policy for your entity, and Schedule 1 sets your committee composition, reporting frequencies and review month. Obtain legal review before adoption so the policy reflects your products, authorisations and distribution model.

Use this policy if you:

• hold an Australian Financial Services Licence and provide financial services
• need a documented process for identifying, assessing and reporting breaches
• want internal deadlines that leave time to assess significance before the 30-day clock runs
• need a breach register that records incidents whether or not they are reported
• want your Compliance Officer and board to have defined roles in the process

It is suited to:

• AFSL holders with a Compliance Officer and a board of directors
• licensees acting as trustee or investment manager of managed investment schemes
• compliance teams documenting escalation and investigation timeframes
• boards reviewing Reportable Situations and rectification at their next meeting

What this policy covers:

• the types of Reportable Situation, from significant breaches of a Core Obligation to gross negligence and serious fraud
• the Core Obligations under sections 912A and 912B of the Corporations Act 2001 (Cth), and the parts of the Financial Services Law caught by section 912D(3)(b)
• the deemed significance tests, covering offence penalties, civil penalty provisions, misleading or deceptive conduct and material loss or damage
• the general significance assessment applied where no deemed test is met
• a four-step process: report to the Compliance Officer within 14 days of detection, determination within ten days, report to ASIC within 30 days, board review at the next meeting
• investigation handling, including escalation to the board after twenty-five days and the Investigation Reportable Situation that arises on the 31st day
• a key obligations table setting the timing and responsible person for each duty
• Schedule 1, a breach register covering reporting and detection dates, entities and fund or client affected, description and root cause, impact and level of risk, and corrective and preventative action

You receive an editable Word document with placeholders for [Client Name], the ACN and AFSL number, and the date the policy is approved by the board, together with a version history table and the Schedule 1 breach register. Sections 1 and 2 explain the regime and section 3 sets out the policy itself, so timeframes and role titles can be adjusted to match how your organisation operates. It is a starting point rather than advice on your licence conditions, so have it reviewed and tailored before you adopt it.

It is best suited to:

• ADIs (banks, credit unions, building societies);
• Insurers (general, life and private health);
• RSE licensees and superannuation trustees;
• Other prudentially regulated entities subject to CPS 230 Operational Risk Management; and
• AFSL holders and related entities that rely on external service providers for critical operations.

The template is structured to:

• Make it clear that outsourcing does not outsource accountability for prudential or conduct obligations;
• Define critical operations, material business activities and material service provider arrangements;
• Set out roles and responsibilities for the Board, CEO/senior management, Operational Risk / Compliance, business units and Internal Audit;
• Walk through the full outsourcing lifecycle – identification, materiality assessment, due diligence, approval, monitoring, BCP testing and exit/termination;
• Embed APRA’s expectations on offshoring (including prior consultation and enhanced due diligence);
• Articulate the organisation’s risk appetite, limits and concentration risk settings for outsourcing;
• Summarise regulatory reporting and notification requirements to APRA in a practical table; and
• Provide document control, review and maintenance sections, plus clear definitions for key CPS 230 / outsourcing terms.

The policy has been drafted with CPS 230, SPS/HPS 231, the Corporations Act, ASIC Regulatory Guides 104 and 259, the Privacy Act and the ACL in mind, so you can adapt it confidently across different licence types.

You receive an editable Word document with placeholders for your company name, governance bodies and licence details, so it can be tailored quickly to your own outsourcing framework.

It is suited to:

• APRA‑regulated entities (including where CPS 520 Fit & Proper is relevant);
• AFSL/ACL holders and other ASIC‑regulated businesses with formal governance structures;
• Growing, mid‑sized or more mature corporates with an established compliance or risk function;
• Corporate groups with multiple entities that require consistent whistleblowing standards.

What this template covers:

• Purpose, goals and organisational commitment to speaking up and ethical behaviour;
• Who is covered by the policy (eligible whistleblowers, including employees, officers, contractors and related parties);
• What conduct can be reported and which disclosures fall outside whistleblower provisions;
• Detailed reporting channels (internal contacts, alternate contacts, external regulators, auditors and legal practitioners);
• Options for anonymous reporting and how anonymity is protected in practice;
• Investigation process: receipt, assessment, investigation, reporting to senior management and the Board;
• Protections against detriment and retaliation, including escalation pathways where retaliation is suspected or has occurred;
• Ongoing training, communication and onboarding requirements;
• Governance, Board reporting, policy review and document control;
• Legislative and regulatory sources, including Corporations Act Part 9.4AAA, ASIC RG 270, ASIC information sheets and (where relevant) APRA prudential standards.

You receive an editable Word document with placeholders for your organisation name, roles, reporting channels and governance details, so it can be adapted across different regulated businesses. This template is best suited to growing, mid‑sized or more mature organisations – particularly APRA/ASIC‑regulated entities – that need a robust internal reporting and investigation framework with formal reporting and governance processes.