Conflicts of Interest and Gifts Register

Purpose. This register records every actual, potential or perceived conflict of interest declared by staff and every gift or benefit over 100 dollars received from a lender, insurer, referrer or client, and how each is managed.

1.What must be recorded

Staff must declare any personal, family or financial interest that could influence, or appear to influence, their work for a client, including a referral relationship, a shareholding in a lender or insurer, a family member who is a client, or outside employment. Every gift, hospitality or benefit over 100 dollars from a lender, insurer, referrer or client must be recorded within five business days of receipt.

• Referral and introducer relationships
• Family members who are clients or lenders
• Shareholdings and outside business interests
• Gifts, hospitality and conference sponsorship
• Volume bonuses or incentive offers

2.How conflicts are managed

The Compliance Manager will assess each declaration and record the control, which will be one of: disclose to the client in writing, reassign the work to another staff member, or decline the work. A conflict must not be managed by disclosure alone where it would affect a best interests decision.

3.Gifts and benefits

Gifts over 300 dollars must be declined or surrendered to the firm unless the Managing Director approves in writing. Hospitality from lenders and insurers must be recorded and must not be accepted in the month before a panel review. Cash or cash equivalents must never be accepted.

4.Current entries

The register currently holds 14 open entries, including three referral arrangements with accountants and a real estate agency that are disclosed on every affected credit guide, a broker's spouse employed by a panel lender managed by reassignment of that lender's files, and two conference sponsorships from insurers recorded in August.

5.Review

The Compliance Manager will review the register quarterly and report to the Managing Director. Staff must confirm their declarations are current at the annual compliance attestation.