RM Supervision Policy V3.0 FINAL 4 FEBRUARY 2013

BANK FINANCIAL

PLANNING

Regional Manager Supervision

Policy & Processes

Westpac

4 FEBRUARY 2013

WBC.507.002.0490

Regional Manager Supervision – Policy & Processes V3.0 FINAL 4 FEBRUARY 2013

TABLE OF CONTENTS

1. INTENT 1

1.1 FORWARD 1

1.2 BACKGROUND 1

1.3 HOW DO WE MEET THESE OBLIGATIONS? 2

2. POLICY 3

2.1 RESPONSIBILITIES OF REGIONAL MANAGERS 3

2.2 ROLES AND RESPONSIBILITIES 5

2.3 INCIDENT MANAGEMENT 6

2.4 FREQUENCY OF ACTIVITIES 7

2.5 DOCUMENTING EVIDENCE OF SUPERVISION CONDUCTED 9

2.6 PEOPLE CAPABILITY INTELLIGENCE (PCI) 9

3. HOW TO INSTRUCTIONS 10

3.1 PLANNER PROFILE RECORD 10

3.3 QUARTERLY SIGN OFF 11

3.4 TEAM MEETINGS 11

3.5 LIVE OBSERVATIONS 11

3.6 FILE REVIEWS 12

3.8 ACTION PLANS 12

3.9 COACHING PLAN 14

3.10 FILE MANAGEMENT POLICY 14

4. MONITORING OF SUPERVISION ACTIVITIES 15

4.1 RESPONSIBILITIES OF STATE HEAD 15

4.2 ADDITIONAL MONITORING: 16

4.3 CONSEQUENCES OF NON-COMPLIANCE 16

REFERENCE DOCUMENTS 18

DOCUMENT CONTROL 19

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1. INTENT

1.1 FORWARD

This document outlines the role and responsibilities of Regional Managers in respect to the

supervision of their direct report representatives operating under our various licensed

entities including the Westpac Financial Planning business.

This document outlines:

✓ The obligations that must be met by the business with respect to monitoring and

supervision;

✓ A list of the activities for which each Regional Manager is accountable;

✓ A description of how Management will monitor the compliance of the Regional Manager

with this policy; and

✓ The toolkit which will be used by Regional Managers to document their performance of

the key compliance and risk activities.

1.2 BACKGROUND

As the holder of an Australian Financial Services Licence, Westpac has an obligation to

ensure that it has measures in place for monitoring and supervising the people who act on

its behalf. These monitoring and supervisory activities allow us to determine whether our

representatives are complying with financial services laws. In particular, s912A(1)(ca) of the

Corporations Act 2001 states that a financial services licensee must take reasonable steps

to ensure that its representatives comply with the financial services laws.

The Australian Securities and Investments Commission has provided guidance to the

industry as to how it expects AFSL holders to comply with this legislation. Most of these are

highlighted in Regulatory Guide 104: Licensing: Meeting the General Obligations. The

sections pertaining to this document are detailed below:

RG 104.70 To ensure your representatives comply with the financial services laws, we

consider that you need to monitor and supervise them.

RG 104.72 The level of monitoring and supervision your representatives need will

depend on the nature, scale and complexity of your business (eg. The

function your representatives perform, whether your business operates from

one or a number of locations etc).

RG 104.73 We do not think that you need to scrutinise every activity of your

representatives. However, we expect you will have measures that:

(a) Allow you to determine whether your representatives are complying with

the financial services laws (including your licence conditions); and

(b) Include a robust mechanism for rectifying any breaches.

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RG 104.74 We expect your measures for monitoring and supervision will include

carrying out appropriate background checks before you appoint new

representatives. These checks could include referee reports, searches of

ASIC’s Register of Banned and Disqualified Persons and police checks etc.*

RG 104.75 Your measures for monitoring and supervision will normally show how you:

(a) Keep track of who your representatives are, what role they perform

and whether they are appropriately authorised;

(b) Ensure your representatives (including your authorised

representatives) act within the scope of what you have authorised

them to do;

(c) Ensure your representatives understand your compliance

arrangements;

(d) Monitor your representatives’ compliance; and

(e) Respond to compliance failures.

*Appropriate background checks will be conducted by the People team and the Operations

Governance team.

1.3 HOW DO WE MEET THESE OBLIGATIONS?

The Westpac Financial Planning business meets these obligations through two means which

separate the duties of Supervision from those of Monitoring. In the current business

operating model, the responsibility for monitoring is placed with the Risk, Advice & Private

Wealth unit, which independently monitors the Advice business. The processes which are

involved in this monitoring are recorded in the Risk Solutions Advice, Monitoring Policy and

Processes document.

The Supervision task is closely linked to the line management of the representatives and is

fully documented and described within this document.

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2. POLICY

2.1 RESPONSIBILITIES OF REGIONAL MANAGERS

Regional Managers are responsible for ensuring that all representatives who report to them

are adequately supervised in the performance of their roles.

Supervision is about how we hire, lead, train, develop and performance-manage our

representatives in order to raise the quality of advice given and provide a superior customer

experience. This function is separate from the supervision activities undertaken by the

Planner Supervision and Governance team.

The Regional Manager is accountable for ensuring that the following is performed for each

representative in their region:

RESPONSIBILITIES REGIONAL MANAGER ACTIVITIES

• Ensuring that only appropriate people

are employed into positions of trust.

• Ensure that the relevant People and/or

Compliance teams conduct the

appropriate background checks.

• Performance management and

counselling for all planners who fail to

meet standards.

• Ensure all new planners attend

induction training.

• Conduct customer file reviews for high

and extremely high risk planners.

• Attend live observations with planners.

• Conduct planner one-on-one meetings

to gauge how planners are tracking

against requirements.

• Identify skills gaps and organise

training.

• Ensure that all Remedial/Compliance

Action Plans and Development Plans are

completed.

• Provide formal counselling.

• Ensuring that planners are meeting pro-

rata targets for continuing education &

training requirements.

• Note training requirements as a

standard agenda item at team

meetings.

• Monitor via Planner one-on-one

meetings.

• Check People Capability Intelligence

(PCI) or e-academy on a regular basis

and follow-up with planner as

necessary.

• Ensuring that planners are submitting

plans for pre-vetting as required.

• Action any notification provided by the

Pre-vet team about individual planners

• Ensuring that customer files meet at • Check that planners and planner

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least minimum compliance standards. assistants are using available tools such

as the Customer File Checklist to assist

in maintaining customer files.

• Conduct regular file reviews for high

and extremely high risk planners and

coach planners on issues found.

• Compliance training.

• Ensuring that all customer complaints

are recorded in Relationship Builder (RB)

and that customer files are forwarded to

the Complaints team as required.

• Note complaints as a standard agenda

item at team meetings.

• Check Relationship Builder (RB)

regularly.

• Discuss at Planner one-on-one

meetings.

• Managing service-related complaints. • Discuss customer servicing

requirements at Planner one-on-one

meetings and with planners as

complaints arise.

• Provide coaching after joint field

interviews with planners and

customers.

• Ensure complaints are being handled in

line with Financial Planning Complaints

Handling Policy and Processes

• Monthly review of the Untraded Cash-

in-Wrap report.

• Discuss requirements and provide

coaching at Planner one-on-one

meetings.

• Note Cash-in-Wrap issues as a

standard agenda item at team

meetings.

• Adherence to the File Management

policy.

• Provide training to planners and

planner assistants in team meetings.

• Discuss at Planner one-on-one

meetings as required.

• Ensuring that all remedial action plans

(RAPs), compliance action plans (CAPs)

and action plans (APs) are finalised

within required timeframes.

• Ensure all action items have been

completed in a timely fashion and to an

acceptable standard.

• Sign off and finalise action plans within

PCI- refer section 3.8.b for further

details on evidence requirements.

• Discuss at Planner one-on-one

meetings.

• Discuss at team meetings.

• Ensuring that incidents are raised and

managed within required timeframes.

• Follow-up of all outstanding

remediation in order to close incidents

in a timely manner.

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• Note incidents as a standard agenda

item at team meetings.

• Discuss at Planner one-on-one

meetings.

• Ensuring that representatives comply

with current compliance policies and

relevant Codes of Conduct.

• Discuss compliance policies at team

meetings.

• Provide coaching on the Codes of

Conduct.

• Ensuring that planners have recorded

gifts and hospitality or other forms of

Alternative Remuneration as required.

• Note Alternative Remuneration as a

standard agenda item at team

meetings.

• Review Gifts & Hospitality Register-

refer Operational Risk Activity Calendar

• Ensuring that procedures and controls

are in place to manage customers of

planners

• Check customer lists and promptly

assign customers to other, appropriate

planners within required timeframes.

• Ensure that all customer files are

retained by the business.

• Ensuring that all remedial/compliance

actions have been finalised for planners

and/or customers transferring into your

region.

• Check planner’s past audit report.

• Discuss at Planner one-on-one

meetings as appropriate.

2.2 ROLES AND RESPONSIBILITIES

There are a number of supervision activities that a Regional Manager must undertake to

fulfill their obligations for the appropriate supervision of their planners.

These supervision activities include:

- File Reviews

- Live observations

- One-on-One discussions

- Team Meetings

During this supervision Regional Managers will directly monitor the ability of a planner to

perform their role.

If the Regional Manager deems an activity by a planner to be outside of business policy, it is

the Regional Manager’s responsibility to ensure it is appropriately remediated. In some

circumstances, the Regional Manager may also be required to engage their State Head and

the Planner Supervision and Governance team.

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The following table outlines the remediation framework where an issue is identified:

Issue Responsibility Remediation

Low to Medium Rated Issue

File Review Issue

• Minor issue found during file

review

• Planner

• Regional Manager

• Regional Manager to record issues

found and create Action Plan (AP)

in PCI

• Planner will be required to

remediate issue(s) identified by

Regional Manager.

• Regional Manager to ensure

completion of remediation in PCI.

High Rated Issue

File Review Issue

• No customer file

• No advice document

• Systemic Issue

• Planner

• Regional Manager

• State Head

• Planner Supervision

• Regional Manager to record issues

found

• Planner will be required to

remediate issue identified by

Regional Manager.

• Regional Manager to ensure

completion of remediation in PCI.

• State Head is to be engaged and

confirmation provided when

remediation is completed.

• Planner Supervision to be engaged

where Regional Manager requires

additional support for completion

of remediation item.

2.3 INCIDENT MANAGEMENT

Regional Managers are also responsible for ensuring that they have adequate controls and

procedures in place to identify and raise incidents in accordance with the BT Financial Group

Incident Management Policy.

Any significant compliance or operational risk incidents must be identified and recorded in

ACCORD. Incidents include:

✓ A compliance breach;

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✓ A complaint which could result in significant damage to our business reputation;

✓ Suspected internal fraud;

✓ Loss or theft of confidential customer data; and/or

✓ A financial loss of $20,000 or more to the Advice business.

2.4 FREQUENCY OF ACTIVITIES

A risk-based approach to the frequency of supervisory tasks to be conducted by Regional

Managers has been adopted. The key principles are:

✓ New representatives require 3 files to be reviewed per quarter for the first 12 months of

their appointment. In addition, there is also a requirement for 2 live observations and 3

one-on-one meetings per quarter;

✓ Representatives who are rated High or Extremely High Risk according to the

Consequence Management Policy require a greater level of supervision per quarter.

✓ Representatives who are considered Low to Moderate Risk according to the Consequence

Management Policy require less supervision per quarter.

The following table outlines the activity and requirements:

Activity New Planners (within 12 months of

Start Date)

Low Supervision (Low or Moderate

Risk Planners)

High Supervision (High or Extremely

High Risk Planners)

File Reviews 3/Qtr Nil 4/Qtr

Live

observations

2/Qtr 1/Qtr 2/Qtr

One-on-Ones 3/Qtr 1/Qtr 3/Qtr

Team Meetings 1/Qtr 1/Qtr 1/Qtr

Please note that all requirements in the above table represent the minimum requirements of

the Regional Manager Supervision policy. As direct managers of financial planners, it is

expected that all Regional Managers will apply professional judgment if circumstances

warrant additional file reviews, coaching sessions, formal training or team meetings.

Refer to the Advice Exit Guide which outlines your additional responsibilities (including

additional file reviews) when a planner leaves Westpac.

Consequence Management

The Consequence Management risk rating that applies to each representative from the last

month of the previous quarter will be used by PCI to calculate the required number of

activities for the next quarter. For example, a minimum of 4 file reviews (plus 2 joint

meetings and 3 one-on-one meetings) will be required where a planner is rated as

High/Extremely High Risk in the last month of the previous quarter.

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File Review Selection Process

The file review selection process is to include a mix of complex advice (e.g. Gearing and/or

SMSFs) and other non-complex advice (e.g. Risk or Investments) and some Execution Only

sales where appropriate. The file review selection process should only include advice since

the planner’s last compliance review to gauge the planner’s current skills and behavior (to

the previous compliance review). Refer to the File Review Selection Guide for further

information.

File Review Selection Process – New Planners

A Regional Manager is required to review 3 files for a new representative per quarter for the

first 12 months of their appointment. Where a new representative has not provided advice

to 3 customers in a quarter the Regional Manager must:

- Complete the file review on the available files recording the information in PCI.

- Review the planner’s revenue report to ensure there is no further evidence of lodged

business.

- Where advice has been provided, the Regional Manager is to review the identified

file/s as part of the normal file review process.

- Where there is no evidence of new advice (or a number to meet the file review

requirements) the Regional Manager must complete a total exception for the

remaining file/s. The PCI system records the already entered file reviews in the

system.

Low Supervision Planners – High Risk Scenario Report

Where a planner is identified on the High Risk Scenario report and is considered a Low

Supervision Planner (according to Consequence Management Points), the Regional Manager

is still required to review the exception (file) found.

Where this falls outside of the normal supervision activities, the Regional Manager is to

complete this file review in addition to the normal file review activity.

The file review is to be completed through PCI.

File Sampling (Not a Full Compliance Review)

Customer files which have been reviewed under the RM Supervision process should not be

seen as a “pre-compliance review” check for a planner’s full compliance review. The

purpose of this policy is to ensure that an appropriate number of files are reviewed on a

regular basis for each planner. Files reviewed under this policy that are subsequently

reviewed by the Planner Supervision team compromise both the quality of the file sample

and the legal obligation to effectively supervise all planners. It is expected that Regional

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Managers will manage planner expectations in this regard. In addition, Regional Managers

are required to continue conducting RM Supervision activities even in the same quarter as a

planner’s compliance review to ensure the ongoing regularity and overall effectiveness of

the Regional Manager supervisory activities- refer to the File Review Selection Guide for

further information.

2.5 DOCUMENTING EVIDENCE OF SUPERVISION CONDUCTED

As holders of an Australian Financial Services Licence, Westpac may be required to

demonstrate how it manages the supervision and monitoring of all representatives to

regulators and other industry bodies. Therefore, all activities that Regional Managers

undertake as part of the supervision process must be documented as evidence that all

representatives are complying with financial services laws. In order to fulfill this

requirement, Regional Managers should use the tools and systems made available for

completion of the necessary activities.

The following tools are provided to Regional Managers to enable them to document the

completion of the activities.

Activities must be completed through PCI

1. File Reviews

2. Live observations

3. One on Ones (History/New Activity)

Tools for download accessible through the Regional Manager Leadership Centre

1. File Review (Checklist)

2. File Review (Checklist – with Guidance)

3. Superior Coaching Session Notes

4. Team Meeting Agenda

5. Team Meeting Guide

6. Planner One-on-One Meeting Tool

7. File Review Selection Guide

8. Coaching Plan Tool

2.6 PEOPLE CAPABILITY INTELLIGENCE (PCI)

PCI system was developed as a way to record individual planner capability across the advice

businesses.

Regional Managers are required to record the following in PCI:

✓ File reviews (File Reviews)

✓ Live observations

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✓ Any other contact with planner including separate coaching, emails, phone and other

conversations (history)

PCI user guides are available on the PCI User Guides SharePoint.

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3. HOW TO INSTRUCTIONS

3.1 PLANNER PROFILE RECORD

Regional Manager’s must retain a Planner Profile Record for each of their representatives.

Except for the Recruitment Activities information retained in a representative file, all other

records and notes are to be completed and retained in PCI.

1. Recruitment Activities

The standard personnel file must contain copies of all of the documents

which were used during the recruitment process. As mentioned earlier in this

document, the relevant People or Operations Governance team will conduct

all background reference checks for new Westpac representatives.

2. Planner One-on-One Meetings

Regional Managers must record all Planner One-on-One Meetings with the

representative in PCI. Documentation completed during planner one-on-ones must

be stored in the PM Supervision Evidence SharePoint (not in PCI)

3. Live observations

Regional Managers must record all Live observations with the representative in PCI.

Questions in PCI relating to Live observations are mandatory and must be completed

in its entirety. Documentation completed during live observations must be stored in

the PM Supervision Evidence SharePoint (not in PCI)

4. File Reviews

All file reviews completed by Regional Managers must be recorded in PCI

under File Reviews. The File review checklist in PCI must be completed in its

entirety.

There is no longer any requirement to maintain paper copies of the file

review checklists. Refer to the File Review Selection Guide for further

guidance on file selection.

5. Remedial Action Plans (RAPs)/Action Plans (APs)

Any actions plans resulting from the supervision of the planners are created

and tracked through PCI.

6. Coaching/Training

Development Plans are recorded in this section of PCI.

7. Compliance Reviews

Records for the Compliance Reviews (and associated compliance action plans

(CAPS)) conducted by the Planner Supervision and Governance team are

recorded and retained in PCI.

8. Miscellaneous

Any other appropriate documentation/evidence that is relevant to

demonstrate supervision activities (eg. Pre-vet release confirmation,

Induction attendance or qualifications/accreditations) can be recorded in the

History section of PCI or under the associated Appointment.

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Please note: There will be no requirement to maintain paper-based files for the

Regional Manager Supervision Recruitment activities once they can be produced and

stored in PCI.

3.3 QUARTERLY SIGN OFF

Regional Managers must ensure that all activities completed for their planners are up to

date on a quarterly basis within PCI. State Heads are also required to ensure that the

allocated activities are completed in a timely manner and review the quality and

comprehensiveness of RM Supervision activities as per Section 4.1 of this policy.

In addition to file reviews, live observations, planner one-on-ones and team meetings you

are required to complete the activities specified in the Operational Risk Calendar on a

quarterly basis.

Activities listed within the Operational Risk Calendar are categorised by the frequency of

supervision required, to assist you to incorporate the activities into your everyday work

schedule. These topics along with the RM Monthly Conversation Packs, should be used for

discussion at team meetings.

3.4 TEAM MEETINGS

Through utilising the Advice Way team meeting agenda and formats, Regional Managers are

required to document and maintain a register for their region which will document the

agenda, contents and minutes of the team meetings that they hold. Regional Managers are

encouraged to use these regular meetings to address any common issues they have found

through their supervision activities. When formal training is conducted within these team

meetings, there is potential for Continuing Education (CE) points to be assigned to the

formal training. As training and presentations are developed for specific issues, these

should be held in a central register so that the Regional Manager will have presentations

available to them to address a variety of needs. Regional Managers are also encouraged to

invite subject matter experts on areas of identified concern to present at team meetings.

3.5 LIVE OBSERVATIONS

Regional Manager can record the outcomes from the live observations that they attend with

planners and their customers under ‘Live observations’ in PCI. These will be used to

highlight any deficiencies and form the basis of any remedial actions and or training

programs that are required to improve a planner’s performance.

Regional Managers should ensure that they attend a mix of ‘first interviews’, ‘plan

presentations’ and ‘reconnect/rediscover’ meetings. Where a planner requires coaching in a

particular area or aspect you may conduct ‘role plays’ as part of your live observation

activities. However, role plays must not make up more than 50% of the accumulated yearly

target for live observations.

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To support competency-based assessment and coaching, Regional Managers are required

to attend, or dial into, interviews where advice containing a recommendation for a

structured product with a capital protected feature is presented to a client. Attendance will

be required until the planner is deemed competent.

3.6 FILE REVIEWS

One of the key activities of supervision to be carried out is the customer file review.

Regional Managers are to record and complete the File Review Question set available in PCI

when undertaking a file review. The questions are designed to cover a number of high risk

issues and allow the Regional Manager to provide feedback and coaching. Where a

significant issue is uncovered, the Regional Manager must escalate the issue using the Roles

and Responsibilities process outlined in section 3.8.a

3.7 PLANNER ONE-ON-ONE MEETINGS

The Planner One-on-One meeting tool linked to the planner scorecard has been

incorporated into the RM Supervision Policy. This tool should be used to capture

discussions with each planner and as an action tool. This document should be loaded into

PCI once the Planner one-on-one meeting has been held.

3.8 ACTION PLANS

This is a tool for the Regional Manager to use to document the actions which have been put

in place for a planner and to measure both the completeness and effectiveness of the

agreed actions. These documents can also be used by others who are involved in the

remediation of a planner but all information should be contained within the planner’s file.

a. File Review – Action Plans

During the completion of the quarterly file reviews the Regional Manager may identify

possible exceptions on the file. This will result from a question from the file review

question set is answered ‘No’ or ‘In-Part’.

To remediate this exception the Regional Manager is to create an Action Plan for the

planner within PCI – File Review. The action plan should:

- Select the ‘cause’ of the action plan

- Provide a commitment date for the planner to complete the action plan (60 days)

- Add the action to the action plan and a detailed comment

- Track completion of the action plan by the due date

- All evidence to support the completion of the action plan must be saved in the PM

Supervision Evidence SharePoint:

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Where a high rated exception is found (e.g. no Advice Document, inappropriate advice,

non-disclosure of fees, no product replacement) the Regional Manager should engage

the Planner Supervision and Governance team for guidance.

b. Compliance Review – Action Plans

Compliance Action Plans (CAP) are automatically created when an exception has been

identified during a compliance review.

The CAP is issued to the Planner, together with the compliance report, after the review.

The CAP will contain a list of actions, which the Planner is required to complete, for each

exception found.

A due date (60 days from creation) will be assigned to each action item. Once issued, a

CAP remains open until all the action items for the CAP are closed.

A notification email is sent to the Regional Manager when a CAP is created and also

reminder emails as due dates approach.

In tracking completion of an Action Plan and Compliance Action Plan the Regional

Manager should:

- Discuss the CAP raised with the Planner to ensure their understanding of why the

CAP (and action plan) was raised.

- Monitor the completion of the CAP by the planner within the 60 day timeframe.

- Once all the action items for a CAP are marked as complete, the Regional Manager

must then mark the CAP itself complete (close off the CAP). The Regional Manager

and Planner are required to sign the compliance report to confirm the completion.

- The signed report and the evidence to support the completion(subject to the risk

based approach outlined below) must be saved in the PM Supervision Evidence

SharePoint:

The compliance review rating and the weighting associated with the compliance

requirement/question not met will determine whether evidence needs to be sighted and

centrally stored. Please refer to table below:

Compliance Review Outcome Exception Weighting Action and Evidence Requirements

Effective Low • No evidence required

Qualified Medium • RM to sight.

• Planner to retain evidence on

customer file.

Low • No evidence required

Requires Improvement High • RM to sight and save a copy of

evidence in SharePoint.

• Planner to retain evidence on

customer file.

Medium • RM to sight.

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• Planner to retain evidence on

customer file.

Low

• No evidence required.

Where a CAP falls outside of its due date, it will result in consequence management

points being applied as per the Consequence Management Policy

c. Compliance Review – Action Plans (Planner Resignation)

Where a Planner intends to resign from Westpac and has an outstanding

Compliance/Remedial Action in place the Regional Manager should:

- Request completion of the CAPS/RAPS prior to the Planner’s departure date.

- Where a CAP/RAPS remains open post this date, the Regional Manager must engage

another Planner (representative) to complete the CAP/RAP. The CAP/RAP can remain

assigned to the previous Planner, however, notification of its completion from PCI

will continue to be sent to the Regional Manager.

- The Regional Manager should ensure this CAP/RAP is completed by the CAP/RAP due

date.

Refer to the Advice Exit Guide which outlines a Regional Manager’s additional

responsibilities when a planner leaves Westpac.

3.9 COACHING PLAN

The coaching plan tool breaks down informal coaching into measurable steps and

documents the time spent with the planner to improve their performance. Appropriate

documentation of this coaching is an important tool in demonstrating the time which is

spent actively coaching the planners in acceptable behaviours.

3.10 FILE MANAGEMENT POLICY

Regional Managers are responsible for ensuring adherence with the relevant Customer File

Management Policy as updated from time to time.

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4. MONITORING OF SUPERVISION ACTIVITIES

4.1 RESPONSIBILITIES OF STATE HEAD

To review and test for comprehensiveness of completed RM Supervision activities, State

Heads are required to:

1. Enquire as to the supervisory work Regional Managers have completed;

2. Observe and/or attend Regional Managers conducting their supervision activities (eg.

Planner one-on-one meetings, team meetings, live observations and file reviews);

3. Review and test for comprehensiveness.

4. Record their attendance or review activities in PCI on a quarterly basis within 2 weeks

of the end of the quarter.

In order to demonstrate compliance with the Regional Manager Supervision Policy, State

Heads are required to attend and review at least 10% of the three supervisory activities of

the Regional Manager Supervision Policy, namely:

1. File reviews;

2. Live observations; and

3. Planner One-on-One Meetings

The following examples are provided for reference purposes only and you will need to

consider the quarterly targets from information available in PCI each quarter.

File Reviews:

Assuming a Regional Manager has 30 file reviews to conduct for the quarter; State Heads are

required to check a minimum of 3 file reviews for this Regional Manager (i.e. 10% of their

quarterly target). State Heads or their qualified delegate are not expected to re-do the file

reviews, but must be satisfied that Regional Managers are following the correct process and

be in a position to provide coaching as necessary. This requirement should be repeated for

every Regional Manager in your team each quarter.

Note: Where file review tasks have been delegated to a qualified delegate; State Heads are

still responsible and accountable for the file review.

Planner One-on-One Meetings:

Assuming that one of your Regional Managers has 10 Planner one-on-one meetings to

conduct in a quarter, you are required to attend a minimum of one meeting (i.e. 10% of their

quarterly target) either in person or via telephone hook-up if travel is not feasible. This

requirement should be repeated for every Regional Manager in your team each quarter.

Live observations:

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Assuming that one of your Regional Managers has a target of 10 live observations to

conduct in a quarter, you are required to attend a minimum of one live observation for that

Regional Manager in the quarter (ie. 10% of their quarterly target). This requirement should

be repeated for every Regional Manager in your team each quarter.

Quarterly Team Meetings:

The purpose of these meetings is to provide a forum for educating planners, addressing

business issues and to ensure that the broader messages of the Westpac Group are

communicated effectively to planners.

To confirm the effectiveness of team meetings, State Heads should provide:

• Verbal feedback from Regional Managers as to the content of their team meetings; and

• Review of team meeting agenda and minutes

The 10% testing measurement does not apply to team meetings.

Supervision activities are based on a targeted approach:

✓ New Regional Managers require a higher level of supervision within the first 12 months

of their tenure.

✓ Regional Managers who are on performance management require a greater level of

supervision per quarter.

✓ Regional Managers who have demonstrated experience in Practice Management and do

not fall into the other categories can be reviewed on a less frequent basis.

4.2 ADDITIONAL MONITORING:

1. The tracking of complete/incomplete supervisory activities will be monitored by the

Advice Management team.

2. Planner Risk Insight (PRI) initiated compliance reviews (ie. Compliance Reviews outside

of the normal cycle when a need is identified) around potential high risk issues will be

conducted by the Planner Supervision team at its discretion.

The results of monitoring performed by the Planner Supervision team will be reported to

Heads of Advice as well as the Advice Leadership Team Risk Review Committee.

4.3 CONSEQUENCES OF NON-COMPLIANCE

The Advice Leadership Team Risk Review Committee can exercise its discretion in

determining the consequences for a Regional Manager who does not comply with this

policy.

Consequences may include, but are not limited to, any or all of the following:

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✓ Feedback to be provided;

✓ Formal warnings to be placed on personnel files;

✓ Performance counselling;

✓ An unsatisfactory rating on performance appraisals;

✓ Denial of attendance at Conference;

✓ Denial of Bonus payment;

✓ Suspension of employment;

✓ Changes to employment conditions; or

✓ Termination of employment.

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REFERENCE DOCUMENTS

Link to policies Consequence Management Policy

Customer File Management Policy

Financial Planning Complaints Handling

Policy and Processes

BU Instructions • PCI User Guides

• Regional Manager Leadership Centre

• PM Supervision Evidence SharePoint

(CAP Management)

• Accord

• RM Monthly Conversation Packs

• Advice Exit Guide

Tools • File Review Selection Guide

• File Review (Checklist)

• File Review (Checklist – with Guidance)

• JFW Superior Coaching Session Notes

• Team Meeting Agenda

• Team Meeting Guide

• Planner One-on-One Meeting Tool

• Coaching Plan Tool

• Customer File Checklist

• Operational Risk Calendar

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DOCUMENT CONTROL

Version Status Date Alteration from previous version

1.0 Draft 30/11/07 First Draft for initial circulation and comments

1.1 Draft 07/01/2008 Draft for use in Pilot

1.2 Final 10/12/2008 Review of policy, including tools

1.3 Final 30/03/2009 Addition of Attachment 4.10

1.4 Final 22/07/2009 Revision of Section 2.5 – Monitoring of Supervision Activities

and the addition of Attachment 4.11 – State Head Attestation

Tool. Enhancement of table in Section 2.1 to include Regional

Manager duties included in the Regional Manager Attestation

document.

1.5 Final 01/10/2009 Updated RM & State Head Attestation tools plus a general text

update. Re-numbering of Section 2.

1.6 Final 27/11/2009 Added guidance on the 10% measurement relating to the State

Head Attestation tool.

1.7

Final 18/02/2010 General revision of policy document to incorporate Regional

Manager sign-off for the State Head attestation process.

Update of Section 3.10 – File Management.

1.8 Final 01/10/2011 Revision of RM Supervision policy with an update to:

- The inclusion of a Roles and Responsibilities section

- Amendments made to the Regional Manager Activity

requirements (e.g. file reviews_

- Change to the file selection methodology

- Revision of RM Supervision Question Set including

guidance and inclusion of an escalation process.

2.0

Final 31/01/2012 Revision of RM Supervision policy with an update to:

- Removal of Low Risk File Reviews from the RM

Quarterly obligations.

- Update to include File Selection Methodology and

guidance.

- Removal of RM Supervision tools with a SharePoint link

to the documents.

- Introduction of an Action Plan reference guide.

- Introduction of guidance where a planner is exiting the

business and remaining Action Plans.

2.1 Draft 19/06/2012 ‒ Update section 3.8.b Compliance File review Action

Plans. Retention of CAP evidence depends on weighting

of exception.

‒ Attachments 4.10 and 4.11 removed from policy,

retained as policy tool and saved in SharePoint

2.2 Draft 14/09/2012 ‒ Compliance Sign off

2.3 Draft 27/9/2012 ‒ Reviewed after Ops Manager review

2.4 Draft 12/12/2012 ‒ PO sign off

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3.0 Final 04/02/2013 ‒ PUBLISHED

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