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Fit & Proper Policy

Code GOV-004
Domain Governance & Accountability
Owner Chief People Officer
Status Draft
Applicability External — Fit and proper vetting is a human governance and regulatory process. The platform's audit trail evidences compliance but does not execute the vetting process.
Jurisdiction NZ + AU
Business domain BD10
Review date 2027-03-25

Outside platform boundary

Fit and proper vetting is a human governance and regulatory process. The platform's audit trail evidences compliance but does not execute the vetting process.

Regulations: CoFI Act 2022 · CPS 520 Fit and Proper · DTA Governance Standard

Purpose

Govern the platform's obligations for assessing and maintaining the fitness and propriety of directors and senior managers, consistent with APRA CPS 520, the NZ CoFI Act, and applicable accountability regime requirements.

Scope

All directors and senior managers of the platform in NZ and AU whose appointments are subject to fit and proper requirements under applicable prudential or financial services legislation.

Policy statements

The platform SHALL assess the fitness and propriety of all directors and senior managers before appointment and at least annually thereafter. The assessment SHALL cover honesty, integrity, reputation, competence, capability, and financial soundness, as required by APRA CPS 520 and the NZ CoFI Act.

Fit and proper assessments SHALL be conducted by or under the direction of the Chief People Officer, with legal input from the General Counsel. Assessments for Board directors SHALL be overseen by the Board Nomination Committee or equivalent.

No individual SHALL be appointed to a position subject to fit and proper requirements unless a satisfactory assessment has been completed and approved. Board appointments SHALL require Board approval following a satisfactory assessment.

The platform SHALL maintain a register of individuals subject to fit and proper requirements, the status of their current assessments, and any conditions or undertakings attaching to their appointment.

Where a fit and proper assessment reveals information that calls into question an existing appointee's fitness or propriety, the matter SHALL be escalated immediately to the Board Chair (for directors) or CEO (for senior managers). The Board SHALL determine the appropriate response, which may include suspension, removal, or regulatory notification.

The platform SHALL notify the relevant regulator of any appointment or departure of an individual subject to mandatory regulatory notification requirements, within the timeframe required by that regulator. Notification obligations include APRA CPS 520 and NZ CoFI Act requirements.

Fit and proper assessments SHALL be conducted with appropriate confidentiality. Assessment records SHALL be retained for the longer of seven years or the period required by applicable law.


Satisfying modules

(No modules assigned yet — manual process)


Part of Governance & Accountability · Governance overview Compiled 2026-05-22 from source/entities/policies/GOV-004.yaml