Background Screening & Fit and Proper Policy¶
| Code | PPL-004 |
| Domain | People & Culture |
| Owner | Chief People Officer |
| Status | Draft |
| Applicability | External — Background screening for the operating entity's employees. Delivered through HR onboarding processes and external screening providers. |
| Jurisdiction | NZ + AU |
| Business domain | BD11 |
| Review date | 2027-03-25 |
Outside platform boundary
Background screening for the operating entity's employees. Delivered through HR onboarding processes and external screening providers.
Regulations: CPS 520 Fit and Proper · NZ Employment Relations Act¶
Purpose¶
This policy establishes the minimum requirements for background screening of prospective employees and ongoing fit and proper assessments for individuals in key or sensitive roles. It protects the bank, its customers, and the financial system from the risks posed by employing individuals who lack the integrity, competence, or character required for their position.
Scope¶
This policy applies to all prospective employees and contractors prior to engagement. Enhanced screening requirements apply to Accountable Persons under the Australian Financial Accountability Regime, individuals with access to customer funds or sensitive financial systems, AML/CFT designated roles, and any role classified as key personnel under the bank's prudential obligations. Ongoing monitoring requirements apply to all key personnel roles for the duration of employment.
Policy statements¶
The bank SHALL conduct pre-employment background screening on all prospective employees before any offer of employment becomes unconditional. No individual SHALL commence employment, or be granted access to customer data or financial systems, until all required screening checks have been completed and assessed as satisfactory.
Pre-employment screening SHALL include, as a minimum: verification of identity documents, verification of the right to work in the relevant jurisdiction, criminal history check, verification of relevant qualifications and professional registrations, and reference checks with at least two former employers. Additional checks SHALL apply to key personnel roles as set out below.
All Accountable Persons, executives, and individuals in key personnel roles SHALL be subject to enhanced screening, which SHALL include: a comprehensive criminal history check across all jurisdictions of prior residence, a credit history check, a check against regulatory registers and sanctions lists, and a review of any prior regulatory findings, professional disciplinary actions, or civil litigation involving financial misconduct. The enhanced screening assessment SHALL be reviewed by the Chief People Officer and General Counsel before a conditional offer is made.
The bank SHALL maintain a fit and proper assessment framework that documents the criteria applied to each role classification, the screening components required, and the threshold for satisfactory outcome. The framework SHALL be reviewed at least annually by the Chief People Officer in consultation with the Chief Risk Officer and General Counsel.
Where a screening check reveals a matter of concern, the outcome SHALL not be used as an automatic bar to employment. The bank SHALL conduct a structured assessment that considers the nature, seriousness, and recency of the matter, its relevance to the role applied for, and any rehabilitation or mitigating factors. The assessment SHALL be documented and the outcome approved by the Chief People Officer.
The bank SHALL conduct periodic re-screening of all key personnel at intervals not exceeding three years, or immediately upon becoming aware of a material change in circumstances such as a regulatory finding, criminal charge, or significant adverse credit event. Individuals SHALL be required to self-declare any material change in circumstances as a condition of their employment.
All screening outcomes and fit and proper assessments SHALL be stored securely and retained for a minimum of seven years after the end of the individual's engagement. Access to screening records SHALL be restricted to HR, Legal, and Compliance personnel on a need-to-know basis.
The bank SHALL co-operate fully with APRA, the Reserve Bank of New Zealand, and other regulators in any review of the fitness and propriety of its key personnel, including providing access to screening records on request.
Satisfying modules¶
(No modules assigned yet — manual process)
Part of People & Culture · Governance overview
Compiled 2026-05-22 from source/entities/policies/PPL-004.yaml