Fair Conduct Programme (FCP)

Liberty Financial Limited (Liberty) was founded on the values of fairness and financial inclusion. We remain committed to ensuring fair treatment for our people, customers and stakeholders. To help us uphold this commitment, we have a Fair Conduct Programme (FCP) in place, including policies, processes, systems and controls. The key matters of our FCP and how we meet the fair conduct principle are detailed below.

Why we established our FCP

The Financial Markets Amendment Act 2022 has an overarching principle that ‘financial institutions must treat consumers fairly’. The fair conduct principle gives financial institutions guidance on how to deliver fair customer outcomes. As a licensed financial institution, Liberty is required to establish, maintain, and implement an FCP which outlines how we maintain appropriate conduct towards customers in our business.

Governance and oversight of our FCP

Our FCP is approved and monitored by the Liberty Board, along with senior management committees the Liberty Board ensures fair customer treatment through ongoing monitoring and reporting activities. Annual assurance activities are conducted to assess the effectiveness of our FCP, ensuring it aligns with the fair conduct principle.

How we distribute our products and services

Our term deposit product is distributed directly via our website, phone and email. We also have an arrangement with an administration and custodian service that allows its clients to choose our term deposit product from its investment platform.

Our home loan products are distributed indirectly through licensed financial advisers who follow a Code of Conduct under the Financial Advice Provider licensing requirements.

Incentives for distributing our products are outlined in contractual agreements with aggregators who engage financial advisers or with the financial adviser directly (whichever applies).

How we review and monitor our products and services

Periodic monitoring is conducted to ensure products and services align with the fair conduct principle. Any deficiencies are escalated to senior management for review and action. Senior management develops and implements an appropriate action plan where required. Product and pricing changes require approval from both senior management and the CPP Committee.

How we train and oversee our people

We hire people with the relevant skills and experience for their roles, and provide support to them through induction processes, on-the-job training and supervision. Our people receive technical and topical training, including dedicated sessions on our FCP.

How we identify, monitor and manage conduct risks

Our compliance plan outlines regulatory obligations with designated persons accountable to oversee compliance with these obligations. Quarterly attestations are required to be completed.

Our risk management program identifies risks associated with conduct that fails to comply with the fair conduct principle.

How we communicate with our consumers

We communicate with you via phone, letter and email while our website and social media platforms allow us to reach you more broadly.

All advertising, marketing and disclosure materials are subject to a review and approval process before being released.

How long do we keep your personal information

We will not retain your personal information for longer than is required for the purposes for which the information may lawfully be used or for the purpose of discharging our obligations under relevant applicable legislation.

How we manage complaints and conflicts

You can contact a member of our team to raise any concerns directly. All complaints are recorded and reported to senior management as appropriate.

Complaints that require a formal response are reviewed by senior management. If we can’t resolve your complaint internally, you can escalate your complaint to our external dispute resolution scheme.

Employees can raise concerns with their team leader or as outlined in our Whistleblower Policy.

Updated: 7 February 2025