Foreword from AFIA CEO Diane Tate

AFIA is committed to advancing a world-class finance industry and our members are at the forefront of creating more efficient, competitive and innovative finance for Australians. 

AFIA members participate across the entire finance industry in Australia and include banks, finance companies, vehicle and equipment financiers, vehicle and fleet providers, and fintechs that operate in consumer, business and commercial lending markets

This Code is Australia’s first non-bank lending and specialist banking industry code. It sets out the standards of practice and expected customer service outcomes for our members and reflects our members' commitment to customers through the promotion of a culture of integrity, transparency and fairness in the finance industry in Australia. 

AFIA has introduced this Code to help support positive outcomes for customers and financial firms by promoting good practices that support compliance with legal obligations, reflect customer and community expectations, and strengthen trust and confidence in the finance industry. 

This Code provides a framework for prudent, responsible and ethical conduct, fosters transparency and fairness, promotes accountability and explains how our members will comply with their legal obligations. It also explains what our members will do if things go wrong, including how our members will manage complaints, support customers experiencing financial difficulties, and help customers experiencing vulnerability. 

By adhering to this Code, our members contribute to an efficient, competitive, sustainable, inclusive and resilient finance industry, which ultimately benefits customers, financial firms and the economy. This Code will continue to evolve in line with industry developments and customer and community expectations.



Part A – Introduction

1.The Australian Finance Industry Association (AFIA) Code of Practice (the Code) was published on 16 September 2025 and is effective from 1 October 2026 (the Effective Date). Compliance with the Code is subject to transitional arrangements until the Effective Date. The transitional arrangements are set out below at paragraph 18.

2.The words β€œwe”, β€œus” and β€œour” apply to an AFIA member and/or an entity in an AFIA member's group who is a Code Member.

3.The words β€œyou” and β€œyour” refer to you as our Customer.

4. Other words and phrases that have special meaning are identified with capital letters and are set out in the Definitions section.

Scope of this Code

5. A list of Code Members can be found at [AFIA Website Code page].

6.This Code applies to credit, finance and novated lease products and services we provide to Consumer and Small Business customers in Australia, subject to the exclusions set out in this Code. For simplicity, we refer to these collectively as β€œproducts” in this Code. This Code also applies to guarantors and co-borrowers where we specifically refer to them.

How we define β€˜Small Business’

For the purposes of this Code, we have adopted the Unfair Contract Terms legislation definition of Small Business which means a business that:

  1. employs fewer than 100 people at the time the contract is signed; or
  2. has a turnover for the last income year of less than $10,000,000; and
  3. the upfront price payable under the contract does not exceed $5,000,000.

7. These products include but are not limited to:

  1. secured and unsecured consumer finance, including credit cards, personal loans, lines of credit or overdrafts, mortgages for residential and investment purposes (including home loans and chattel mortgages) and vehicle finance;
  2. secured and unsecured business finance, including lines of credit, debtor and cashflow finance, asset and equipment finance, fleet and vehicle finance; and
  3. novated leases.

8. This Code applies so long as we are the issuer of your product. If another entity becomes the issuer of your product and that other entity is not a Code Member, this Code will not apply to that other entity. This Code sits alongside the overarching laws, licensing obligations (where applicable) and regulatory frameworks that apply to us. If there is any conflict between this Code and relevant laws, those laws prevail.

Exclusions from this Code

9. This Code may offer some guidance more broadly, but it does not apply to products we provide to commercial property, government or semi-government customers, or Large Corporate Customers. This Code also does not apply to bailment facilities because bailment is a common law relationship between a bailor and a bailee, and not a credit, finance or novated lease product as per paragraph 6.

10. This Code does not apply to AFIA Members who are signatories to an equivalent industry code that applies to Consumer and Small Business finance and lending activities in Australia. The AFIA Board will, acting reasonably, determine the criteria for an equivalent code. For these purposes, AFIA Members who are signatories to the Banking Code of Practice or the Customer Owned Banking Code of Practice are not subject to this Code. However, these AFIA Members may still elect to become a signatory to this Code.

11. This Code does not apply to AFIA Members who are signatories to an equivalent industry code that applies to Consumer and Small Business finance and lending activities in Australia. The AFIA Board will, acting reasonably, determine the criteria for an equivalent code. For these purposes, AFIA Members who are signatories to the Banking Code of Practice or the Customer Owned Banking Code of Practice are not subject to this Code. However, these AFIA Members may still elect to become a signatory to this Code.

12. This Code does not apply to other entities we own or related bodies corporate who do not provide products covered by this Code to Consumers or Small Business.

13. AFIA has separate codes of practice for Buy Now Pay Later (BNPL Code), Online Small Business Lenders (AOSBL Code) and Insurance Premium Funding (IPF Code). Customers who deal with AFIA Members who are signatories to the BNPL, AOSBL or IPF Codes will continue to have the protections afforded by these codes until they are transitioned into this Code.

14. AFIA also operates the Car Rental Code of Practice, which will remain separate from this Code.

Structure of this Code

15. AFIA members participate in different finance sectors and markets, and for this reason we have divided this Code into different sections to help you find the customer protections relevant for your circumstances.

16. This Code contains general and specific commitments by us to you. They are found in:

  1. General Commitments (Part A);
  2. Specific Commitments for Consumer Finance (Part B);
  3. Specific Commitments for Small Business Finance (Part C).

AFIA Industry Guidelines

17. AFIA has published industry guidelines, protocols and other documents on some areas of the Code or related matters that may help members understand how to interpret and apply the Code or develop new approaches to systems, policies or processes. These industry guidelines, protocols or documents do not form part of this Code. AFIA’s current industry guidelines are published on the AFIA website.

18. After the publication of this Code, we have a period of time until the Effective Date to ensure that our arrangements to provide our products to you meet the requirements set out this Code. These transitional arrangements will end after the Effective Date of this Code.

19. This Code will apply to a new product or a guarantee for which you enter into an agreement with us on or after the Effective Date.

20. For ongoing products that we were providing you as at the Effective Date, or where a guarantee was in place before the Effective Date, or where documentation was sent to you before the Effective Date, the existing terms and conditions of that product or guarantee will continue to apply. If we provide you with revised terms and conditions after the Effective Date, those revised terms and conditions will comply with this Code.



Part B – Our Key Commitments to You

We will be fair and honest in our dealings with you

21.We will act honestly and with integrity. We will be fair and responsible in our dealings with you. We will be clear in our communications with you.

We will focus on customers

22.We aim to deliver a positive customer experience over the life cycle of your product.

23. We will provide you with different ways to contact us – for example, by phone, or through our website or app, or through other communication channels. For some products, we may have more specific or limited ways to communicate due to the manner in which your product is offered, including for example, where a product is entirely online or managed by a third party.

24. We will use plain language and avoid using unnecessarily complex legal and technical words as much as possible when communicating with you. However, there may be times where this is unavoidable (such as when the law requires us to use particular words or to communicate with you in a particular way).

We will comply with our industry and legal obligations

25. We will comply with our obligations under the law and this Code. If we don't, and you are impacted, we will correct this in accordance with our legal obligations and our agreement with you.

26. If you are a Consumer and your contract with us is regulated under the National Consumer Credit Protection Act 2009 (NCCP Act), we will make an assessment about whether the credit contract is 'not unsuitable' for you. Schedule 1 of this Code provides additional information about how we will do this.

27. Loans that are for predominantly business or commercial purposes are not regulated under the NCCP Act. We will only provide our products to you where we believe you meet our product and lending requirements. Schedule 3 of this Code provides additional information about how we will do this.

We will deliver high standards of service

28. We will take reasonable steps to ensure our products are reasonably fit for their intended purpose and are as described in our terms and conditions, disclosures, marketing materials, and agreements with you.

29. We will respond to questions about the features of our products and how they work. We may do this in different ways (such as by publishing FAQs on our website or app).

30. We will not engage in pressure sales tactics.

31. We may require you to obtain independent advice before entering into a contract with us. We will tell you if this applies to you. You may need to get your own financial, legal or taxation advice if you have queries or questions about how our products may impact your financial or personal circumstances.

We will provide clear information about our products

32. We will give you clear and useful information about our products to help you make an informed decision about whether to use them.

33. Before you enter into a contract with us for a product, we will give you information about:

  1. our product terms and conditions;
  2. fees and charges;
  3. interest (if this is applicable), or the total amount payable and the repayment amount (although this does not apply to revolving facilities, for example, where the total amount to be repaid depends on your use of the facility);
  4. any other pre-contractual disclosures required by law; and
  5. how we will notify you about any changes.

34. We will continue to provide you with clear and useful information over the life cycle of your product, including about any changes to the product, and any changes to your or our obligations.

35. We may give this information to you in different ways where the law allows us to (for example – in electronic and digital formats). Our terms and conditions will describe how we will communicate with you.

36. We will ensure disclosures about our fees and charges are up to date and accurate.

37. We will review our policies (such as credit assessment procedures, and the design and distribution framework for our products) in accordance with our review procedures or whenever events indicate that a review is required to ensure that our policies are current, comply with the law and align with our commitments in this Code.

We will ensure our staff and representatives are trained and competent

38. We will ensure that people who are authorised to act on our behalf (for example, our employees, agents, and authorised credit representatives (ACRs) where applicable) are adequately trained and are competent to engage with you in relation to our products.

We will tell you about commissions and other benefits we pay to Intermediaries

39. We (or our Intermediaries if we require it under our arrangements with them) will make information available about commissions and other benefits that might be paid to the Intermediary in connection with the distribution or referral of our products. For the avoidance of doubt, this does not include remuneration paid in relation to marketing and advertising of our products.

40. If you are a Consumer, we will disclose the amount of remuneration or other benefit if it is ascertainable at the time we make the disclosure.

41. If you are a Small Business customer or your product is not regulated under the NCCP Act, our terms and conditions, term sheet or other document related to your contract will refer to commissions or other benefits that we may pay to an Intermediary in connection with the distribution or referral of our products.

We will deal fairly with complaints

42. We will handle complaints promptly and fairly. We will make information about how you can make a complaint and how we manage complaints available on our website, app or other platforms we use, including information about timeframes for considering and responding to complaints.

43. We will provide you with clear information on what to do if we do not resolve your complaint in a way that is acceptable to you. This information may be different depending on the product we provide to you. See Part D of this Code for more information.

We will support and promote this Code

44. We will make this Code publicly available including, for example, via links to the AFIA website on our website or in our app or digital platform.

45. We will support the monitoring, supervision and ongoing effectiveness of this Code and ensure our staff are trained to put it into practice.

46. We will implement systems and processes to support our compliance with this Code, including taking steps to address any issues if necessary.



Part C – Treating Customers Fairly

Accessibility

47. We will take reasonable steps to ensure that any website, app, or methods we use to communicate with you meet the kinds of accessibility standards (for example, the Web Content Accessibility Guidelines) that are relevant to our business and the methods by which we communicate with you.

48. If we become aware or you tell us that you need extra help to access our products because of accessibility factors (for example – because you are a person with disability or communication, hearing or visual impairment or language barriers) we will treat you with sensitivity, respect, understanding and empathy. We will take reasonable measures to support your interactions with us, having regard to the type of product and the channel the product is normally distributed through. This might include referring you to free external support services (such as interpreters or the National Relay Service).

Use of Technologies

49.If we use customer-facing artificial intelligence (AI) as part of our business operations to provide products covered by this Code to you, we will have risk management processes to identify and mitigate risks in its use and we will monitor its operation to ensure it is compliant with relevant laws and standards that apply to us.

50.Customer-facing AI can include the autonomous or semi-autonomous analysis of data and content using sophisticated techniques and tools. It can also create content or output that is not programmed or copied from existing data, but is generated based on patterns, structures and examples learned from large datasets.

Privacy and Confidentiality

51.We will handle your information, and information about your use of the product, in accordance with our Privacy Policy and the law.

52. We will comply with the privacy legislation including the Privacy Act 1988 and the associated standards in the Australian Privacy Principles, and the Privacy (Credit Reporting) Code 2024 (if applicable to us) which sets standards about participation in credit reporting and management of information and data (such as the collection, processing, storage, maintenance, use, transfer and disclosure of your personal information or data to other parties).

53.We will publish our Privacy Policy on our website, in our app or on our platform.

54.We will treat information that you give us or information that we collect about you (including through data collection techniques, such as screen scraping) in accordance with our Privacy Policy and the law.

Information and Data Protection

55.We will take reasonable steps to protect your personal information and data from misuse or loss and from unauthorised access, modification or disclosure. This may include asking you to re-verify your identity from time to time.

56.We will regularly review the security and reliability of our information systems.

57.We will aim to implement and maintain information security controls that are commensurate with the size and extent of the information risks and cybersecurity threats we may face.

58.We will apply security measures or access controls that are reasonably appropriate or necessary for the product you have with us (for example – account registration, password protection and/or multi factor authentication).

Security Measures and Controls

59.If we use additional security measures or controls (such as multi-factor authentication) to verify your identity, open an account or access our products, we will have regard to relevant standards and authentication protocols (including standards published by the Australian Government from time to time) when designing or updating our systems.

Scams and Fraudulent Activity

60.To help protect you from scams and fraudulent activity, we will not:

  1. ask you for information like passwords, PINs or secure access codes in an unsolicited email, text, phone call or message;
  2. ask for remote access to your computer or devices to β€œfix a problem” or send you software to download; or
  3. ask you to make payments through unusual mechanisms (such as stored value cards or gift cards), or urgently transfer your assets or funds to another place to keep them β€œsafe”.

61.If you receive an unsolicited contact asking for this type of information that appears to be from us or you are not sure whether a communication is legitimate, you should contact us via the contact details on our website, app or platform or another trusted source (such as the contact number on the back of your debit or credit card) to check.

62.If you believe you may have been the victim of a financial scam or some other fraudulent activity that involves our products or you notice suspicious or unusual activity in relation to your product, you should contact us as soon as possible. You can also contact Scamwatch or the police if you think a crime has been committed. IDCARE may also be able to help you in relation to identity theft.

Customers Experiencing Financial Difficulties and Other Hardship

63.Financial difficulties or other hardship can occur for a range of reasons that are out of your control, including but not limited to:

  1. change in income or employment status;
  2. relationship breakdown;
  3. illness or injury;
  4. natural disasters.

64.If we become aware or if you tell us that you are experiencing financial difficulties or other hardship, we will work with you to identify ways we may be able to provide support in accordance with our policies. We encourage you to tell us about your circumstances as this is the best way to help us help you.

65.We will tell you how to contact us about financial difficulty and other hardship assistance arrangements on our website, our app or other digital platforms we may use.

Consumers

66.If your contract with us is regulated under the NCCP Act, you should tell us as soon as possible if you are experiencing financial difficulties or other hardship. You can do this yourself or through someone else you appoint to act on your behalf (for example - a lawyer, accountant, financial counsellor, or legal aid officer). We may ask you or the person acting on your behalf to complete a form to confirm you have provided your consent for the person to act for you.

67.We will provide information on our website, app or digital platform about how to contact us if you are experiencing financial difficulties or other hardship. We may also contact you to discuss your situation if it becomes apparent to us that you may be experiencing financial difficulties or other hardship.

68.We may ask you to give us information to help us understand your financial difficulties or other hardship and consider how we could help. Any help we can provide will depend on your circumstances and the information you give us.

69.We may provide you with a temporary or simple arrangement to help you or we may agree with you on a new repayment arrangement (called a β€œcontract variation”). If we agree on a contract variation, this will be in writing (including in electronic form where permitted by law and our agreement with you).

70.We are not required to offer a temporary or simple arrangement or a contract variation, but we will provide assistance if we think it will help you recover your financial situation. We will tell you about the support we can provide after we have considered your circumstances and the information you have given us.

71.There are circumstances where we may not offer you a temporary or simple arrangement or contract variation, including (but not limited to) where we reasonably believe:

  1. your financial position cannot be restored; or
  2. it will, or is likely to, make your circumstances worse; or
  3. you will not have an ability to repay the amounts you owe us after the period of financial difficulty or other hardship ends; or
  4. we do not have sufficient information to substantiate your financial hardship.

Small Business Customers

72.If you are a Small Business customer and you tell us you are experiencing financial difficulties, we may consider reasonable modifications to your repayment arrangements or other terms and conditions of your contract, insofar as possible within our credit policies. We are not required to do so, but we will do our best to explore options that may help your business through a temporary period of difficulty.

People Experiencing Vulnerability

73.We are committed to helping customers who are experiencing vulnerability. If we become aware or if you tell us that you may be experiencing vulnerability, we will treat you with sensitivity, respect, understanding and empathy. We recognise that vulnerability may be temporary in some cases and/or can happen to anyone.

74.Characteristics of vulnerability may include (but are not limited to):

  1. cognitive or other impairment;
  2. family or domestic violence (including financial abuse);
  3. age-related financial abuse;
  4. mental health issues;
  5. addiction-related issues;
  6. serious illness or injury;
  7. insecure housing or homelessness;
  8. language or literacy barriers;
  9. issues related to cultural norms and expectations; or
  10. other personal or financial circumstances – for example, incarceration or institutionalisation, the serious illness or death of a partner or close family member, a relationship breakdown or some form of natural disaster.

75.We may not be aware of your vulnerability unless you tell us about it. If you tell us about your circumstances, we will consider how we can help to address the financial implications for the product we provide to you.

76.If you want to appoint someone to act on your behalf in your dealings with us, we will provide you with clear information about how you can do this.

77.The misuse of our products by another person (whether they are related or known to you, or not) to inflict economic, financial or emotional abuse on you is unacceptable. If we become aware this is occurring, we will do what we reasonably can to help minimise or stop the misuse.

Deceased Estates

78. If you are the executor of a deceased estate or are otherwise entitled at law to deal with a deceased estate, we will do what we reasonably can (and as permitted under relevant laws, such as succession and privacy laws) to help you resolve or deal with the customer’s financial affairs with us as quickly as practicable.

Transparent Debt Recovery Practices

79. If a debt recovery process becomes necessary, we will act in accordance with our legal obligations. This includes (where relevant depending on whether your loan is regulated under the NCCP Act) our obligations to tell you about late or missed payments, to issue you with a written notice of a default prior to commencing legal proceedings or taking other enforcement action, and to generally give you a reasonable opportunity to remedy the default. However, if we reasonably think that the default cannot be remedied, we may have rights under your contract and at law to take action without telling you first.

80. We will only use as agents, and sell our debts to debt collectors, that to the best of our knowledge comply with the ACCC and ASIC Debt Collection Guideline.

81. The steps we may take to recover or on-sell your debt may be different depending on what type of Customer you are, the product you have, and the terms of your contract with us.

82. Schedule 1 sets out more information for Consumers about our debt recovery practices.

83. Schedule 3 sets out more information for Small Business customers covered by this Code about our debt recovery practices.



Part D – Resolving Complaints Promptly and Fairly

Enforcing Your Rights

84. This Code is part of a range of customer protections that are available to you, including under Australian laws. The types of rights and protections that apply to you depend on what type of customer you are and what type of product we provide to you. You are able to hold us accountable for our obligations in a number of ways including through (but not limited to) internal and external dispute resolution, legal action, or by reporting an alleged breach of this Code by us to the AFIA Finance Industry Code Compliance Committee (CCC). More information about the CCC is set out in Part E.

We Will Have Internal Dispute Resolution Arrangements

85. We will have an internal process for handling complaints in relation to our products. This internal dispute resolution (IDR) process should help to resolve most complaints.

86. We are committed to responding to complaints in a way that is:

  1. prompt and efficient;
  2. consistent with relevant laws, the obligations in our contract with you and relevant guidance (such as ASIC Regulatory Guides 271 and 277).

87. We will explain how we deal with complaints in your contract or other documentation (such as our credit guide or terms and conditions) or via other sources, including on our website or app, as applicable.

88. If you have made a complaint to us, we ask you to be available to communicate with us during the complaint process. We may not be able to deal effectively with your complaint if you are not available to respond to our reasonable requests for information.

You Will Have Access to External Dispute Resolution

89. If we are not able to resolve your complaint to your satisfaction, you will generally be able to escalate your complaint to an external dispute resolution (EDR) scheme, mediation scheme or alternative process for dealing with a dispute.

90. The Australian Financial Complaints Authority (AFCA) is the EDR scheme for financial-related complaints by individuals and small businesses (as defined by AFCA) in Australia. We will tell you if we are an AFCA member and your rights to make a complaint to AFCA (if your complaint falls within AFCA’s jurisdiction). However, AFCA may not consider complaints in relation to all of the different types of products offered by AFIA members and in some cases the EDR or mediation scheme may be different.

91. The Australian Small Business & Family Enterprise Ombudsman (ASBFEO) can assist Small Business customers and family enterprises that are in dispute with other businesses or Australian Government agencies. ASBFEO can provide information about dispute resolution options, access to mediation and alternative dispute resolution processes.

92. State-based Small Business Commissioners (SBCs) also offer mediation and impartial assistance to help parties in dispute come to an agreement. Depending on the State you are in, SBCs can offer formal mediation sessions conducted by a professional mediator.

93. We will provide you with information about how to contact AFCA (if we are a member and your complaint is within AFCA’s jurisdiction), or if we make it available – another applicable EDR scheme, mediation scheme or alternative process for dealing with a dispute – if we are unable to resolve your complaint through our internal complaint handling processes.

94. There may be circumstances from time to time where we will not participate in EDR, a mediation scheme or alternative process for dealing with a dispute (although this does not apply if we are an AFCA member) – for example, if we reasonably believe:

  1. there is a genuine risk that conduct of the EDR, mediation or alternative process might result in customer harm to you or a co-borrower or a guarantor; or
  2. there is a potential or actual workplace safety risk for our employees or representatives.

Farm Debt Mediation

95. If you are our customer and you are a Farmer and you are eligible for and request farm debt mediation then we will comply with the process under relevant State-based farm debt mediation legislation or State-based mediation schemes.



Part E – Code Compliance

96. The AFIA Finance Industry Code Compliance Committee (CCC) is an independent committee appointed by the AFIA Board that operates separately from the industry association. The CCC has been established to monitor compliance with this Code. The CCC operates under a Terms of Reference and can consider alleged breaches of this Code that are brought to its attention by a customer or any other party, or through its own monitoring and review processes.

97. You can report us to the CCC if you believe we have acted in a way that is not consistent with this Code. We will cooperate and comply with all reasonable requests of the CCC in the performance of its monitoring and investigation activities.

98. The CCC does not deal with individual complaints or disputes between you and us about our products. You should contact us in the first instance about any complaint or dispute that relates to the product we provide to you. We will consider your complaint in accordance with our complaint handling processes.

99. If the CCC investigates an alleged breach and if it determines that we have breached the Code, it can require us to take corrective measures. The CCC can also impose a range of sanctions depending on the nature of the breach. More information about the CCC including how to contact the CCC can be found here AFIA FICCC.



Part F – Operation and Review of the Code

100. Australian Finance Industry Association Limited ACN 000 493 907 (AFIA) owns this Code and is responsible for its content, management and updating as required, and for providing sufficient resources to support administration of the Code.

101. This Code operates alongside and is subject to existing laws and regulations. It does not limit your rights under those laws and regulations. Where there is any conflict or inconsistency between this Code and any Australian law or regulation, that law or regulation prevails to the extent of that conflict or inconsistency.

102. AFIA will review this Code 3 years after it becomes effective, and every 3 years after that, or sooner if directed to do so by the AFIA Board.

103. The AFIA Board may – after consultation with and seeking comments and suggestions from the CCC, Code Members and other organisations and people it considers appropriate – review and amend the Code at any time.

Definitions

AFIA Finance Industry Code β€” Definitions

Schedules to the Code

These Schedules set out additional information about specific products offered by us. The Schedules describe in more detail how we will meet our commitments to you under this Code and form part of the Code.

A Schedule only applies to the product referred to in it. If there is an inconsistency between the detail in a Schedule and any other section of the Code, the detail in the Schedule will prevail to the extent of the inconsistency.

Schedule 5: Insurance Premium Funding

Introduction

5.1 This Schedule applies to Insurance Premium Funding Products.

About Insurance Premium Funding Products

5.2 Insurance premium funding allows individuals or businesses to pay their insurance premiums in manageable monthly instalments instead of a lump sum.

5.3 Insurance premium funding is a finance arrangement where we pay the total annual premium of an insurance policy on your behalf. You then repay us in monthly instalments over a specified period, typically ranging from six to twelve months. This can relate to a single insurance premium or can allow for the consolidation of multiple insurance premiums into a single payment plan.

Obtaining an Insurance Premium Funding Product

5.4 We may allow you to apply for an Insurance Premium Funding Product in different ways, for example:

  1. by applying to us directly (where we make this available to you);
  2. by referral to us from another entity in our corporate group; or
  3. being introduced to us by a finance or insurance broker or other adviser who is not part of our corporate group.

Terms and conditions for our Insurance Premium Funding Products

5.5 If you are proposing to obtain a contract for an Insurance Premium Funding Product with us, we will give you:

  1. our terms and conditions;
  2. a statement of our fees and charges; and
  3. information pertaining to proposed remuneration to be paid to an Intermediary.

5.6 We will do this before a contract for an Insurance Premium Funding Product is made with us. This information may be provided in one or more separate documents.

5.7 The Insurance Premium Funding Product contract documentation will set out whether you can make an Early Repayment and the terms of that Early Repayment.

5.8 We will make sure any fees and charges payable to us because of the Insurance Premium Funding Product (such as Late Payment Fees or direct debit Dishonour Fees) are reasonable having regard to our costs.

5.9 We will regularly review the effectiveness of our disclosure of our fees and charges to you.

When we lend to you

5.10 When we lend to you, we:

  1. expect you to provide honest and accurate information to us when applying for an Insurance Premium Funding Product or when applying to renew an existing Insurance Premium Funding Product;
  2. will use a risk assessment process to assess whether the Insurance Premium Funding Product is suitable for your circumstances and meets your needs; and
  3. will periodically review this risk assessment process and associated criteria for our Insurance Premium Funding Product.

Remuneration arrangements

5.11 We will offer only clear and transparent remuneration arrangements to our Representatives, Intermediaries or Intermediary Group (Broker Group) and/or Authorised Representative Network, and other third parties involved in the referral, marketing or distribution of our Insurance Premium Funding Product to you.

5.12 Where we pay Intermediary Remuneration in connection with an Insurance Premium Funding Product, before (or if this is not practicable, at the time) you enter into the Insurance Premium Funding Product contract, we will:

  1. clearly tell you:
    • the nature and type(s) of Intermediary Remuneration or other benefits that we are aware the Intermediary or Intermediary Group (Broker Group) and/or Authorised Representative Network is to receive in respect of, or that is attributable to, the service provided in relation to the Insurance Premium Funding Product that a reasonable person in the circumstances would consider could influence them in the provision of the service;
    • when and how it is payable by us to them (e.g. if it is payable before or after acquiring the Insurance Premium Funding Product);
    • such other information as required by law; and
  2. answer any questions you have about the above.

5.13 Pursuant to clause 5.12, we will only pay:

  1. a Commission to an Intermediary, and no other fees; or
  2. a Service Fee to an Intermediary Group (Broker Group) and/or Authorised Representative Network, or licensee, except for where the licensee is an Intermediary.

5.14 We may pay an Intermediary Group (Broker Group) and/or Authorised Representative Network, or licensee a Commission instead of a Service Fee in limited circumstances, such as payment may be in addition to a Service Fee where there is a clear distinction in roles, or where additional services and value are provided, or where both the services of an Intermediary and/or an Intermediary Group (Broker Group) and/or Authorised Representative Network are offered.

5.15 Where we have entered into a Multi-year Agreement, it is expected these agreements contain termination clauses with a 60-day written notice period for termination by either party, unless the agreement requires a different notice period.

5.16 We will not pay any remuneration or benefit to an Intermediary and/or Intermediary Group (Broker Group) and/or Authorised Representative Network and/or Representative to the extent prohibited by law.

5.17 We will use best endeavours to require that our Representatives, Authorised Representative Network, Intermediaries and/or Intermediary Group (Broker Group) comply with relevant industry codes, particularly those aspects that relate to the management of conflicts of interest and the disclosure of remuneration or other benefits that the Intermediary and/or Representative is to receive in distributing the Insurance Premium Funding Product to you.

Information about our Insurance Premium Funding Product

5.18 On the first page of the agreement for the Insurance Premium Funding Product contract or the quote you accept, or on the digital screen we use to sell our product to you, we will clearly set out some key features of the proposed Insurance Premium Funding Product, including:

  1. the term of the Insurance Premium Funding Product contract;
  2. the loan amount;
  3. the Total Cost of Credit, comprising the total of the interest expense, application fee, Intermediary Remuneration and any other fees;
  4. the Total Repayment Amount, comprising the total of the loan amount and the Total Cost of Credit;
  5. the Annual Percentage Rate (APR);
  6. the Average Monthly Repayment;
  7. any other information we think may assist you (including a Total Interest Percentage);
  8. details of any security taken in consideration for the Insurance Premium Funding Product (if any); and
  9. the steps that we could take if you default on a payment to us.

Explanation of the Annual Percentage Rate

5.19 We will provide you with information about the Annual Percentage Rate (APR) to accompany the disclosures in clause 5.18. This disclosure will be:

The APR is the rate that is used to calculate the cost of the loan taking account of the reducing balance of the Loan Amount, expressed as an annual rate. For the purposes of calculating the APR, the cost of the loan is exclusive of fees.

The APR is indicative and assumes the loan starts on the inception date of the insurance policy(ies) being funded. The Total Repayment Amount (including Application Fee) will not exceed the sum shown even though the APR will differ if the date of acceptance of the offer is later than the inception date of the insurance policy.

The APR is not a term of the offer and is provided to allow a simple comparison of insurance premium funding products.

Notifying changes to your Insurance Premium Funding Product

5.20 Subject to clause 5.21, or unless a longer period is required by law, we will give you at least thirty days' prior notice before we change your Insurance Premium Funding Product. However, any agreed changes can commence from the time the change is agreed with you, or from a later agreed time.

5.21 We may give you a shorter notice period, or no notice, if:

  1. any default is unable to be remedied;
  2. it is reasonable for us to do so to manage a material and immediate risk relating to the nature of the relevant default, your particular circumstances, or the value of the security; or
  3. we have already given you a period to remedy the default, and you have not remedied that default.

5.22 Any commitment we may make to notify you by electronic methods is subject to you keeping us informed of, as applicable, your current electronic contact information.

Copies of documents, statements and other information

5.23 We will, at your request, give you a copy of:

  1. the Insurance Premium Funding Product contract (including the terms and conditions, and the standard fees);
  2. a statement of your outstanding balance; and
  3. any notice we previously gave to you which is relevant to us exercising our rights.

5.24 We will do this within ten Business Days of your request.

5.25 If, for some reason, we are unable to provide a document within these timeframes, we will advise you of this, together with the expected timeframe for providing the document.

5.26 Documents may be provided in electronic form, including in the form of a computer-generated record, or in any other form as mutually agreed.

Trained and competent representatives

5.27 We will make sure that our Representatives are well trained so that they can competently do their work and understand this Code and how to comply with this Code.

5.28 We will regularly review the effectiveness of our training programs for our Representatives. This includes:

  1. having policies and procedures for our Representatives that require them to conduct their services appropriately;
  2. only allow our Representatives to provide services that match their expertise;
  3. require our Representatives to hold any licence the law requires;
  4. require our Representatives, when they are providing a service to you, to tell you the service we have authorised them to provide and that they are acting on our behalf;
  5. require our Representatives to first get our approval before subcontracting any services they perform on our behalf;
  6. require our Representatives to tell us about any complaint received by them or breach of this Code by them when acting on our behalf, as soon as reasonably practicable but no later than two (2) Business Days;
  7. require our Representatives to provide reasonable cooperation and make available to the CCC any information relevant to their and our compliance with the Code;
  8. ensure records of our Representatives' training are kept for at least seven (7) years and make the records available for examination by the Code Compliance Committee on request;
  9. measure the effectiveness of our Representatives' training by appropriately monitoring their performance;
  10. require additional or remedial training to address any identified deficiencies or improvements required in our Representatives' training and ongoing development; and
  11. maintain and keep current a training and development plan for our Representatives that is appropriate for the services provided by them or to be provided by them in the future.

5.29 If we are aware that our Representative's performance does not meet the relevant standards of this Code, or you raise any concerns with us about the conduct of our Representatives, then we will address this. For example, we may terminate our contract with them, commence disciplinary action or require they undergo further training.

5.30 In respect of any Intermediary, Intermediary Group (Broker Group) and/or Authorised Representative Network we use, we will also ensure that:

  1. we provide them with up-to-date information in relation to our products, services, policies and procedures;
  2. they are kept informed of our hardship policies and processes;

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