Newsletter Creator
Breach of Privacy Template
Apology email to recipient of incorrect information
Dear Client,
I am writing to apologise for an error in which you were sent information intended for another client. We take confidentiality very seriously and regret this incident. Could you please delete the email and any attachments, and confirm once this has been done.
Thank you for your understanding, and please donβt hesitate to contact us if you have any concerns.
Kind regards,
Details of breach to be sent to direct manager
Dear (Manager)
I am writing to report a privacy incident that occurred on (insert date). While emailing a client, I mistakenly sent information intended for another client to the wrong recipient.
Details of the incident:
Date and time of incident:
Client who received the information:
Client whose information was disclosed:
Description of how the error occurred: (brief description β e.g., selected the wrong email address from the address book, autofill error, etc.)
Type of information disclosed:
Actions taken so far:
An apology email has been sent to the recipient, requesting deletion of the email and confirmation.
Any other actions taken, e.g. phone call, IT support contacted, etc.
Please let me know if further steps are required or if a formal breach report needs to be completed.
Yours Sincerely,
Booking Meeting Room (Auckland)
Instructions for booking an Auckland meeting room (and checking it is available when you want it)
Go to your calendar
Select a day and time to do an invite to a meetingβ¦as the picture below. Put in a title, then go to Invite Attendees, add in who you want to invite to the meeting, the click on the Location button:
The Location button will pop up with two options to book, the top one is the large boardroom, the second one is the small meeting room next to the boardroom.
Double click on the room you want, then choose OK. If you want to see if it is available then click on the little button called Room Finder, it will show you availability.
When you save the meeting, emails will go to the people you have invited and also to the room you invited. The room will email you back straight away to tell you if it is available.
All Office Contact Details
MTG Auckland β Contact Details
Maurice Trapp Group Auckland β Head Office
Level 2, 14 Jervois Road Ponsonby Auckland 1011
(entrance off Redmond St)
Brent Wright (Director)
Mobile 021 2700088
Email: brent@mauricetrapp.com
Address: 101 Athenree Road, RD1 Katikati 3177
Minimum team numbers to maintain essential services
Directors: 1
Senior Managers: 2
Administration Team: 4
Financial Advisers β Risk: 4
Financial Advisers - Mortgages: 2
Location / Building Information
Level 2, 14 Jervois Road β entrance to the building is off Redmond Street next to D&M Hair
Access by lift or stairwell (concrete). Stairwells only accessed by swipe card unless opened by the building manager
Out-of-hours access by Swipe Card and key
Building locks at 6 pm and reopens at 7 am
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Soft copy β Emergency Response Plan
Office hard copy β TBA
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations
Internet and phone line accessibility
Updated as of 7/03/2025
MTG Cambridge β Contact Details
MTG Cambridge
66 Queen Street Cambridge 3434
Karyn Powell
Mobile: 027 348 3388
Email: karyn@mauricetrapp.com
Address: 13 Stevenson Place Leamington
Full-time employed Team Members
Directors: 0
Senior Manager/ Financial Adviser (Risk): 0
BCP Leader: 1 - Karyn Powell
Administration Team: 2 - Karyn Powell, Rachel Easto
General Insurance Brokers: 0
Minimum team numbers to maintain essential services
Directors: 0
Senior Manager/Financial Adviser: 0
Administration Team: 1
General Insurance Brokers: 0
Location / Building Information
Standalone house facing road front
Access by key via side door under carport
Property alarmed. First responder David Cooney β Landlord
Building access available 24/7
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Sian Johnson β offsite hard copy β 70 Selwyn Crescent, Milford
Soft copy β Emergency Response Plan
Office hard copy β 66 Queen Street, Cambridge
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations:
Internet and phone line accessibility
As of 7/03/2025
MTG Christchurch β Contact Details
KSL Insurance Ltd
6 Hazeldean Road, Addington
Jack Radford (Senior Manager)
Mobile: 021 627049
Email: jack@ksl.co.nz
Team members
Senior Manager: 1 - Jack Radford
Administration Team: 0.5 - Ben Empson
Financial Advisers β Risk: 2 - Kevin Seque & Sharon Empson
Minimum team numbers to maintain essential services
Directors: 0
Senior Manager: 0
Administration Team: 1
Financial Advisers: 1
Location / Building Information
Building access available 24/7
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Sian Johnson β offsite hard copy β 70 Selwyn Cres, Milford
Soft copy β Emergency Response Plan
Office hard copy β
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Updated as of 13/7/2025
MTG Hamilton β Contact Details
Maurice Trapp Group Ltd β Hamilton
Unit A3, Level 1, 1 North City Road, Rototuna Hamilton 3281
Brent Wright (Director)
Mobile 021 2700088
Email: brent@mauricetrapp.com
Address: 101 Athenree Road, RD1 Katikati 3177
Full-time employed team members
Directors: 0
Senior Manager: 1 - Sandra Sutton
Administration Team: 0.5 - Elite Chan-Tan
Financial Advisers β Risk: 3 - Lee Amodeo, Mark Armstrong, Nick Blincoe
Minimum team numbers to maintain essential services
Directors: 1
Senior Manager: 1
Administration Team: 0
Financial Advisers β Risk: 1
Location / Building Information
Level 1, Rototuna Village, 1 North City Road, Rototuna Hamilton 3281
Access by Stairs and lift
Office accessed by: Swipe card for building access and key to office
Building access available 8am to 5pm without swipe or key. Security cameras operating
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Soft copy β Emergency Response Plan
Office hard copy β TBA
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations
Internet and phone line accessibility
Updated as of 13/7/2025
Employee Lab (Lewis Limited) β Napier
Employee Lab β Group and Employee Benefits
H Central
131 Heretaunga Street East
Hastings 4122
Tim Jones (Senior Manager)
Mobile: 021 660834
Email: tim@mauricetrapp.com
Address: 20 Tripoli Street Onekawa, Napier
Full-time employed team members
Senior Manager/ Financial Adviser (Risk Group and Employee Benefits): 1 - Tim Jones
Administration Team: 5 - Sarah Jones, Gretchyn McLean, Charlotte Sandbrook, Kristy MacNeill, Greer McNeilly
Financial Advisers β Risk Group and Employee benefits: 1 - Tim Jones
Minimum team numbers to maintain essential services
Directors: 0
Senior Manager/Financial Adviser: 1
Administration Team: 3
Financial Advisers: 1
Location / Building Information
Access is via the carpark on Karamu Road
Building access available 24/7 with key. No shared access and no alarm.
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Soft copy β Emergency Response Plan
Office hard copy β TBA
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations
Internet and phone line accessibility
As of 13/7/2025
MTG Tauranga β Contact Details
Maurice Trapp Group Tauranga
Shop A3A Level 2 Bethlehem Town Centre, SH2, Bethlehem Tauranga 3110
Brent Wright (Director)
Mobile 021 2700088
Email: brent@mauricetrapp.com
Address: 101 Athenree Road, RD1 Katikati 3177
Full-time employed team members
Directors: 2 - Brent Wright, Rupert Gough
Executive Director: 1 - Rupert Gough
Office Manager: 1 - Janeen Flower
Admin Staff: 2 - Louvaine Wreaks, Shearene Lombard
Financial Advisers β Risk: 4 - Chris Brown, Susie Wright, Melanie Paterson, Natalie Jarman
Minimum team numbers to maintain essential services
Directors: 1
Office Managers: 0
Administration Team: 1
Financial Advisers β Risk: 2
Location / Building Information
Shop A3A Bethlehem Town Centre is upstairs next to the Unichem Chemist β the same level as the Town Centre Management office
Access by staircase (concrete). Stairwell only accessed by external key.
Office accessed by internal key
Building access available 24/7
Location of Plan
Brent Wright β offsite hard copy β 101 Athenree Road, RD 1 Katikati
Soft copy β Emergency Response Plan
Office hard copy β TBA
Relocation Site Preferences / Options
Work from home suitable alternative
Limitations:
Team members feeling isolated
No access to printer/scanner
Possible loss of productivity
Security exposure
Communication
Primary comms would be by mobile phone, landline, email or Zoom
Limitations
Internet and phone line accessibility
Updated as of 7/3/2025
Staff Delegations of Authority
Last updated: March 2025
Key Decision Maker β All Offices
Maurice Trapp
Responsible for all Governance and Risk Management decisions across the company.
Provider Relationships and Vendor Communications
Brent Wright
Overarching responsibilities including:
Provider and vendor relationship management
Communication of plans with suppliers
Also responsible for:
Management of cash flow
Authorising emergency payments
Approving employment of temporary staff
Ensuring staff welfare
Analysing cost of downtime vs recovery options
Reconstitution, Insurance & Client Communications
Rupert Gough
Responsible for:
Development and execution of Reconstitution Plans
Managing General and Risk Insurance for Directors and staff
Overseeing Client Communications during crisis or change
IT and Business Systems β Essential Services Support
Regions: Auckland, Tauranga, Hamilton, Cambridge
Rupert Gough β Lead
Sandra Sutton β Support
Region: Napier
Sarah Jones
Region: Christchurch
Jack Radford
Responsibilities:
Ensure continuity of information systems and equipment
Deploy and manage collaboration tools (e.g., Zoom, remote access)
Ensure availability of electronic and hardcopy records
Group and Employee Benefits β All Offices
Sian Johnson
Tim Jones
Responsible for operational continuity and response in all matters related to Group and Employee Benefits schemes.
Staffing, Communications & Health and Safety
Rupert Gough
Responsible for the following across all regions:
Communication of plans with employees and partners
Identity and access management
Vulnerability handling and disclosure
Oversight of mass sick leave or health crises
Recruitment of part-time or replacement staff
Website and Social Media Updates
Rupert Gough
Responsible for client communication via MTGβs website and social media across the following regions:
Auckland
Tauranga
Napier
Hamilton
Cambridge
Christchurch
Policies - Licensee
Reviewed: 09/09/2025 β Rupert Gough
Compliance Assurance
INTRODUCTION
A strong compliance process helps to ensure that we meet not only our regulatory and legal obligations but deliver a good customer experience as well. We do this by ensuring that we have effective policies and procedures in place. Our controls are how we ensure that we are complying with our policies.
Compliance is an outcome of conforming to a rule or standard. The rule may come from a law or regulation, or our internal business rules such as a policy or code of conduct. This means that we need to follow both external rules and internal rules and/or standards.
COMPLIANCE LINKS
Compliance is how our business meets these rules and standards.
Whenever legislation changes, we need to implement a process to meet the new requirements. We need to be sure that we meet all the legal and regulatory requirements for our business. This compliance assurance program sets out how we do this.
PURPOSE
Our business has developed systems and procedures to comply with:
Financial Markets Conduct Act 2013 (the Act);
Financial Markets Conduct Regulations (the Regulations);
Financial Market Authority (FMA) guidance notes and monitoring reports; and
Our internal policies, processes and organisational standards.
This program is to ensure that our business has adequate and effective arrangements to challenge and test:
The design and operation of our processes and controls; and
The adequacy of our compliance activities.
The program provides information on:
Roles and responsibilities for overseeing compliance within our business;
The regulatory obligations to be met by our business;
The procedures in place to comply with our obligations; and
How compliance with these procedures will be monitored.
COMPLIANCE COMMITMENT
Maurice Trapp Group is committed to a strong customer-focused culture which is underpinned by robust and compliant processes. Our staff play an integral role in fulfilling, monitoring and reporting on compliance obligations.
We aim to empower our staff to do the right thing and know how to do it.
Recognising, reporting and remediating breaches is the responsibility of all staff. We have a no blame policy regarding breaches, but not so regarding failure to report or remediate any breaches
COMPLIANCE FRAMEWORK
Our compliance framework is the structured business processes we have implemented to comply with our regulatory obligations and ensure good business practice. It includes the day to day activities to check compliance.
| Elements of our compliance framework |
|---|
| Our Code of Conduct (MTGβs Code of Conduct & Ethics) |
| Identify our key business risks; and identify our regulatory obligations |
| Implement policies, procedures and controls to meet the obligations; and maintain business registers to record key business information |
| Educate and train our staff |
| A compliance calendar to remind us when compliance activities are due |
| A program to validate our compliance framework (our compliance assurance program) |
How we develop our compliance framework:
For each relevant business procedure, we identify the regulatory obligation;
We note the obligations on a register called our compliance obligations register;
We ensure that there is a policy or procedure in place that staff members need to follow to meet the obligation;
We note the controls in place for each obligation and determine the level of risk for the business;
We provide training to staff and contractors on our policies and procedures and explain their regulatory obligations;
We test and monitor that the controls are in place and working as intended; and
We address any control weaknesses and improve as required.
ROLES & RESPONSIBILITIES
All staff in our business are required to comply with the law, the Code of Professional Conduct for Financial Advice Services and our business policies. Some roles have specific responsibilities for checking compliance as follows:
FAP Licensee
The name of the license holders are Maurice Trapp Group, FSP107344 and The Mortgage Lab FSP587228. The FAP Licensee must meet the licensing criteria as well as the standard and specific conditions of the license. An annual regulatory return will be provided to the FMA as required.
Financial Advisers
Financial advisers must provide compliant financial advice as required by the FAP Licensee. Financial advisers must have their client files reviewed on a periodic basis as determined in the annual compliance assurance program.
Business Risk Manager
The name of our Business Risk Manager (BRM) is Rupert Gough. The BRM is responsible for:
Ensuring that our policies, procedures and controls are regularly reviewed and updated.
Keeping track of regulatory changes and making business changes as required.
Providing compliance training to new staff.
Sharing compliance reports and information.
Completing internal compliance testing and monitoring checks.
Filing regulatory reports and returns.
Reviewing any business registers such as complaints, conflicts of interest, breaches etc.
Identifying emerging trends or issues and alerting the business owner.
Business Owner
The responsibility of the business owner is to ensure that Maurice Trapp Group is meeting its regulatory obligations. While certain functions of the FAP Licensee may be outsourced, the responsibility remains with the business owner.
REGULATORY OBLIGATIONS
The first part of our compliance framework is to identify what rules and standards our business needs to meet.
The new financial advice regime sets new requirements. These can be found in:
Financial Services Legislation Amendment Act 2019;
Financial Markets Conduct Act 2013;
Regulations for new disclosure requirements (not yet available); and
The Code of Professional Conduct for Financial Advice Services.
Regulators, law makers and industry bodies publish additional information on the requirements. This material provides valuable information to help us to comply. These may include:
Guidance notes;
Industry reports;
Association training material;
Codes of practice;
Industry best practice; and
Standards.
Business Activities, Products & Services
We list all the key activities for our business. This covers our key operational processes, including how we deal with clients, third parties, vendors and/or suppliers.
We identify the people, systems and processes involved in each business activity. For example, all sales activities involve interactions with clients and are recorded in our client file notes.
Applicable Areas of Law
We also identify other areas of the law that apply to our business. These include:
Advertising and promotion;
Consumer protection;
Employment law;
Fair trading or fair dealing;
Intellectual property;
Privacy and data protection; and
Workplace health and safety.
Keeping Up to Date
We keep up to date and determine the compliance obligations imposed on our business by:
Reading information supplied on government or FMA Websites
Reading brochures and any other handouts available
Consulting with a compliance advisor, accountant or our lawyer
Going directly to the primary sources of law (legislation and regulations)
Subscribing to a third-party information service
OBLIGATIONS REGISTER
We create a register of the regulatory rules. This our βObligations Registerβ.
The Obligations Register records all of our business compliance obligations. The register includes the relevant rules, tasks or actions we need to take. The Obligations Register is set out in text form for easy analysis.
Reviewing our Business Processes & Controls
Throughout the year we test and monitor our business processes and controls that are required by law and those material to our business, to ensure that they are working and are effective. Where possible, testing is done independently of those involved in the day-to-day process and oversight.
Key controls are those that are effective in reducing a high-risk issue. Key/critical controls are the ones that are checked and/or reported against most often.
The object of a control is to modify the risk in some way, i.e. to reduce the likelihood and/or impact of the risk.
Control Effectiveness
Best practice is for controls to be tested at least annually to ensure that they are working, appropriate and relevant. Depending on the nature and importance of the control, some controls will be assessed more frequently.
| Control Effectiveness Checklist | |
|---|---|
| Control exists and is documented |
It wonβt work if it doesnβt exist. If we can prove the control happened, itβs generally considered more effective than a control with no evidence of having occurred. |
| Control is well designed |
The strength of control should be assessed/reviewed. The timing of the control should closely relate to the activity. What is the cost-benefit of running the control? |
| Control is operating as intended | Can we evidence that the control is in place and is working properly? |
| Control has not failed |
Have there been any risk events during the last 1β2 years? How many? Why didnβt the controls work? |
| Control has been independently reviewed |
The control should be reviewed by someone who didnβt design it and doesnβt use it regularly. Independent review provides better insights about the effectiveness of the control. |
For each control identified/in place, our Internal Compliance Person uses a control testing template to assess effectiveness of the control. Our template is provided in Appendix 3.
Testing will Consider
The nature of the control and how often it is performed;
The size and content of the sample will be relevant to the process;
The risk rating of the process β higher risk processes will be subject to more frequent control testing;
Dependency on other controls; and
Exceptions in the control effectiveness, and how they have been reported and investigated.
Control Methodology
A combination of the following methods may be used to help evaluate control effectiveness and design:
| Control methodology | |
|---|---|
| Subject Matter Expert |
It wonβt work if it doesnβt exist. If we can prove the control happened, itβs generally considered more effective than a control with no evidence of having occurred. |
| Risk indicators |
The strength of control should be assessed/reviewed. The timing of the control should closely relate to the activity. What is the cost-benefit of running the control? |
| Independence |
Outcomes of independent compliance reviews and/or testing provide good evidence of effectiveness of controls. The person conducting the test will not have been involved in designing or implementing the control. |
| Sample testing | A selection of a representative sample of controls. For example, we might test 10% of the new clients onboarded over a 12-month period. |
Control Effectiveness Scale
Once tested, the design and effectiveness of a control can rated as follows:
| Rating | Effectiveness |
|---|---|
| 4 |
Very good The control is always reliable, efficient and easy to audit. The control is operating effectively and will mitigate or detect risk in most circumstances. |
| 3 |
Good The control is mostly reliable and effective and can be audited. While the control mitigates most aspects of the risk, it could be strengthened. |
| 2 |
Adequate The control is usually reliable but not always effective. It may be difficult to audit. |
| 1 |
Poor or Ineffective The control is unreliable, ad hoc or poorly documented and does not leave an audit trail. The control may be poorly designed. The control does not provide enough protection and may not control the risk. |
Our Compliance Calendar
We need to complete some of our obligations within a certain timeframe. For example, once a year we pay our membership fee to belong a disputes resolution scheme.
A compliance calendar is a simple way to record when these actions are due and remind us to check that they have been done. By setting up a compliance calendar we:
Know our compliance obligations due each month;
Schedule time to complete checks; and
Confirm the actions that have been completed.
Our Compliance Calendar is here.
Some tasks need to be completed frequently e.g., monthly. These are noted in the βreoccurringβ section. Other tasks may only be required occasionally and are noted in the βad-hocβ section.
Compliance Assurance Program
The Compliance Assurance Programme (CAP) is the in-depth process we implement to challenge and test our compliance. The focus is on whether our compliance framework has been designed properly and is operating effectively.
The testing and design of the tests are done by a person independent of the people involved in the day-to-day processes and/or oversight.
The CAP is approved every year by the business owner. It aims to provide assurance on whether the business is meeting its regulatory obligations and where processes and controls require strengthening.
To achieve our approach to compliance assurance is to focus on:
The types and levels of risk in our business;
Testing and monitoring the design and effectives off our systems and processes; and
How involved our business owner is in overseeing business functions
Reporting
The results of our compliance testing will be reported to the business owner and the SMT to evidence how we know that we comply.
Governance
INTRODUCTION
The board has responsibility for the affairs and activities of the company, which in practice is achieved through delegation to the Managing Director together with the Senior Leadership Team (SLT), and others, who are charged with the day-to day leadership and management of the business. The Managing Director is the principal representative of the company to our stakeholders
POLICY STATEMENT
We will meet all our license obligations and ensure good conduct is achieved by all directors, employees, contractors and financial advisers
The board has appointed a Senior Leadership Team (SLT). The objective of the SLT is to assist the board to monitor the adequacy and effectiveness of MTGβs policies, procedures and controls in fulfilling its obligations under the Financial Markets Conducts Act (FMCA) and in the performance of its obligations as a Financial Advice Provider (FAP) Licensee.
The responsibilities of the SLT are as follows:
Overseeing the design, implementation and operation of MTGβs risk management framework (including key controls) to ensure that it continues to operate effectively within the risk appetite set by the board
Monitoring, and reporting to the Board on, new and emerging sources of risk and the controls and mitigation measures put in place to deal with those risks
Reviewing the effectiveness of the Compliance Management Framework for identifying, monitoring and managing compliance with relevant obligations
Review the compliance processes that are in place to anticipate and effectively manage the impact of regulatory change on MTGβs operations
Guiding management to establish and maintain a sound risk culture, and reporting to the Board on risk culture-related matters that affect MTGβs ability to operate consistently within its risk appetite, including any desirable changes to the risk culture
Liaise with and engage external auditors and risk & compliance suppliers
Ensure recommendations highlighted in internal compliance reports are actioned by management and advisers
Monitor internal controls instituted
Supervise special investigations when requested by the board
Any other duties and responsibilities which have been assigned to it from time to time by the board.
KEY PROCESSES
MTG addresses key compliance issues at bi-monthly SLT meetings. The MD is responsible for drawing to the boards immediate attention any material matter that relates to the financial condition of the company, any material breakdown in internal controls, and any material event of fraud or malpractice.
After each meeting the MD will report the SLTβs recommendations and findings to the board. The minutes of all SMT meetings shall be circulated to members of the board and to such other persons as the board directs.
The MD will present an annual report to the board summarizing the SMTβs activities during the year and any related significant results and findings.
CONTROLS
SMT
How implemented: Bi-Monthly Meetings
Responsibility & Frequency: Head of A&S β Bi-Monthly
REFERENCE
FMA β Standard Licensing conditions β Ongoing requirements
You must at all times continue to satisfy the requirements set out in section 396, and if applicable, section 400, of the FMC Act. Sections 396 and 400 of the FMC Act specify the requirements in respect of which the FMA must be satisfied in order to grant a licence, or authorise an entity as an authorised body. For example, the FMA must be satisfied that:
any prescribed criteria are met
your directors and senior managers are fit and proper persons
you are capable of effectively performing the service
there is no reason to believe you are likely to contravene your obligations
you are registered on the Financial Service Providers
Risk Management Policy
INTRODUCTION
Everyone in the business is responsible for identifying and managing risk. Poor risk management invariably increases costs and time spent on non-productive activities. Effective management of risk is essential for MTG to achieve its goals and objectives.
POLICY STATEMENT
We are committed to proactively and consistently managing risk in order to:
Enhance and protect company value by delivering on our commitments,
Allow the business to pursue opportunities in an informed way and align with our risk appetite,
Ensure a safe and secure environment for MTG staff, partners, and
Avoid negative publicity and reputational
KEY CONCEPTS
Risk is anything that can impact on our ability to achieve company goals and objectives and is therefore interconnected with our business plan and strategy. Risk is assessed in terms of a combination of the impact and likelihood of an event occurring and can be categorised according to the areas it could potentially impact.
These are:
commercial/financial sustainability;
performance of core services;
stakeholder confidence/reputation;
preparedness to manage and respond to a crisis;
people safety and resource availability; and
regulatory/contractual.
Risk appetite describes MTGβs tolerable levels of risk. It draws together risk metrics and risk management, so they can be translated into everyday business decisions, reporting and discussions. Risk appetite is set by the Board and reviewed annually.
Risk management is the process through which risk is managed and includes risk identification and reporting through to risk mitigation and allocating risk ownership.
As a business we need to be committed to ensuring rigorous risk management processes are in place.
To implement risk management effectively, it must be integrated into the business operations, projects, and decision-making processes. It is part of the business mindset and integral to the way we do things.
If we do not manage our risk effectively, this may result in
loss of revenue or increased costs (including from investigations, litigation, penalties, or damages)
negative publicity
reputational damage
the potential loss of clients
injury to MTG people and partners
RISK MANAGEMENT
The objective of our risk management framework is to ensure we operate within our agreed risk tolerance and risk limits. We do this by the:
effective and efficient continuity of operations;
safeguarding of our assets;
preservation and enhancement of our reputation;
reliability of internal and external reporting;
compliance with applicable laws and regulations
Creating and maintaining a culture consistent with our risk tolerance is an important element of operational risk management, as are our selection and recruitment processes.
ROLES AND RESPONSIBILITIES
The roles and responsibilities in relation to this policy are as follows:
Directors
The Company directors are:
Maurice Trapp
Brent Wright
Rupert Gough
The directors are required to:
Set the risk appetite for the business
Monitor and review the activities and reporting of the SMT
Senior Leadership Team
The SLT is required to
Promote a culture of proactively managing risks, aligned with this policy and the businessβ
Review the key business risks regularly and review the risk
Proactively mitigate key business
Review controls and their effectiveness in mitigating the
All Staff
Appropriately identify and manage the risks in their area of work.
Support Functions
The SLT will provide the framework to enable the identification of compliance obligations and the compliance controls embedded in the business that ensure our obligations are met. Wherever possible the risk and compliance frameworks will be aligned.
Independent assurance providers, including business assurance, external audit and regulators undertake periodic reviews to assess:
the effectiveness of internal processes and controls for managing risk; and
the effectiveness of relevant aspects of MTG risk management implementation as
KEY PROCESSES
We identify and define the key risks that our business could be exposed
Each key risk is recorded in the Risk
Risks are rated according how likely they are to occur and the impact if they did occur to provide a risk
We ensure that sufficient controls are in place to manage the
Controls are the specific activities undertaken to reduce the exposure to risk. The controls are reviewed and tested on a regular frequency. The frequency depends on the risk rating and the importance of the control.
MTG: Risk Rating Matrix
Appropriately identify and manage the risks in their area of work.
| Impact Risk Criteria | Insignificant | Minor | Moderate | Major | Severe |
|---|---|---|---|---|---|
| People (Health & Safety + other) |
Injuries or ailments not requiring medical treatment. Poor working environment. |
Minor injury or First Aid treatment case. Increasing and long-term absenteeism. High attrition rate. |
Serious injury causing hospitalisation or multiple medical treatments. Human error and skills shortage. Visa-dependent staff. |
Life-threatening injury or multiple serious injuries causing hospitalisation. Loss of key staff. |
Death or multiple life-threatening injuries. Significant loss of key staff. |
| Financial | 1% of budget or <$X more competition. |
1% of budget or <$X. Increased interest rates. Increasing competition. Reducing demand or service quality. |
>5% of budget or <$X. Cash-flow imbalance. Increasing claims. |
>10% of budget or $X. Online security breach or fraud. |
>25% of budget or >X. Significant fraud or breach. |
| Legal and Regulatory Risks | Minor breach of policy. | Multiple breaches. | Major breach or breaches. | Regulator enquiry or warning. | Regulator action or significant fine. |
| Operational Risks | Human error, low-impact mistakes. |
Cost/unavailability of resources. Operational errors requiring management intervention. |
Mis-selling, multiple errors or losses. | Theft, fraud, frequent errors or losses. | Significant error or loss which may result in business closure. |
| Technology Risk | Downtime due to IT interruption. | Third-party risk: IT software and/or hardware failures. | IT disruption. Systems failure. | Outdated technology. System outage. | Unauthorised access. Significant or prolonged outage. |
| Reputational | Negative client feedback. | Increase in complaints. | Coverage in local media & increased escalation. | Coverage in national media, loss of new/existing business. | Adverse national media coverage, regulator commentary. |
| Likelihood \ Impact | Insignificant | Minor | Moderate | Major | Severe |
|---|---|---|---|---|---|
| Almost Certain | Medium | High | High | Extreme | Extreme |
| Likely | Medium | Medium | High | High | Extreme |
| Possible | Low | Medium | Medium | High | Extreme |
| Unlikely | Low | Medium | Medium | High | High |
| Rare | Low | Low | Medium | Medium | High |
| Likelihood | Historical |
|---|---|
| Almost Certain | Is expected to occur in most circumstances |
| Likely | Will probably occur |
| Possible | Might occur at some time in the future |
| Unlikely | Could occur but doubtful |
| Rare | May occur but only in exceptional circumstances |
CONTROLS
Risk Register
How implemented: Risk Register is checked and updated prior to SMT meetings so that status is reported and assessed
Responsibility & Frequency: Business Risk Manager β Bi-Monthly
REFERENCE
FMA
Licensing requirements
FMCA 2013
431H: Liability for duties
Companies Act 1993
Section 131 β 138 sets out the Directors Duties.
Financial Management Policy
INTRODUCTION
Having sound financial management practices in our business will assist us to demonstrate how we meet our financial obligations. This helps to ensure that we have adequate financial resources for our business and to ensure that our finances are managed in a responsible way.
POLICY STATEMENT
We have a duty of care to comply with our Licensing conditions and the Companies Act 1993 in relation to the financial viability of our business
We ensure that we retain sufficient funds in our accounts to pay our debts as they are due and makes allowance for the unexpected such as, Insurance excess, claw backs etc.
We make allowances for ACC, Tax and GST and other known expenses.
We regularly monitor our financial resources and have 6x board meetings per annum to discuss budgets, cash flow and the Profit and Loss statement.
KEY PROCESSES
We ensure we have a good accounting software package (Xero) that can provide us enough reporting to show us how we are tracking financially
We assess the risk of our financial resources not being adequate to run our business, or a serious financial problem occurring; and take steps to prevent this risk occurring.
We put aside a portion of our income into a separate account to cover taxes, levies, potential commission reversals (clawbacks), and other periodic expenses.
We set a budget annually and review on a quarterly basis with our board
We set an annual cash flow forecast and compare how we are tracking against the cash flow every month to make sure that we remain on track.
We are aware that we must notify the FMA if a material change of circumstances
Expenditure levels and by whom are recorded in our delegations register
Financial updates are loaded daily to our Cube β Power BI financial reporting system, in order to give us real time financial information across the nationwide business.
CONTROLS
Reconciliation
How implemented: Bank Statements are reconciled monthly.
Responsibility & Frequency: CIFO β monthly
External accountant
How implemented: Financial accounts reviewed by external accountant
Responsibility & Frequency: CIFO β annually
Budget, Profit and Loss and Cash flows
How implemented: The budget, Profit and loss and Cash flows reviewed to track actual against forecast
Responsibility & Frequency: CIFO β monthly
Delegations Register
Spending levels set for staff
Responsibility & Frequency: CIFO
REFERENCE
FMA
Licensing requirements
Companies Act 1993
Part 8, 135 β Reckless trading
Part 1, 4 β Meaning of Solvency test
Material Issues & Breaches
INTRODUCTION
A material issue or breach typically refers to a significant violation or non-compliance with regulatory requirements, financial laws, or industry standards. The term βmaterialβ indicates that the issue or breach is substantial enough to have a significant impact on the affected parties, whether they are investors, market participants, or the overall integrity of the financial system.
Material issues or breaches may include, but are not limited to:
Non-compliance with regulatory requirements: Violations of laws and regulations governing financial markets, securities, or financial services.
Misleading or false information: Providing inaccurate or deceptive information in financial disclosures, reports, or other communications.
Market manipulation: Actions intended to artificially inflate or deflate the price of securities, commodities, or financial instruments.
Insider trading: Illegally trading securities based on non-public, material information.
Failure to disclose material information: Failing to disclose information that could significantly impact investment decisions or market conditions.
Risk management failures: Inadequate risk controls, leading to excessive exposure or losses.
Notification of material changes is a standard condition of our Full FAP Licence and applies where we materially change the nature of our financial advice service or manner in which we provide our financial advice service. The purpose of this standard condition is to ensure that the FMA are informed of any material changes that we make to our business, whether or not they may have an adverse effect on our ability to provide our financial advice service and whether or not they may relate to the requirements for issue of a licence being satisfied.
A Breach β It is possible that from time to time we may not be compliant with our obligations and be in breach. A material event is one where the confidentiality, integrity or availability of information and/or technology systems has been compromised.
We are required to identify when a breach occurs and put in place remedial action to rectify the breach. We record any breaches in our βMaterial Issues and Breaches Registerβ. Recording breaches, helps identify where things go wrong in our business and look for any emerging trends or systemic issues. It also helps make sure that our processes are fit for purpose, compliant and working correctly.
| Standard conditions for full FAP licence | Code of Professional Conduct for Financial Advice Services (Code Standard) | FMC Act |
|---|---|---|
| Standard condition 5 requires FAPs to have and maintain a business continuity plan that, among other things, includes procedures for responding to, and recovering from, events that impact on cybersecurity and continuity. FAPs must ensure information security of technology systems which, if disrupted, would materially affect the continued provision of your financial advice service, is maintained. FAPs are required to notify the FMA within 10 working days of discovering any event that materially impacts the information security of these critical technology systems. Under Standard condition 6, FAPs also need to ensure that policies, processes, systems, and controls are up to date and that they reflect any changes you may make to your business or service arrangements. | Code Standard 5 requires FAPs to ensure that client information is protected against loss and unauthorised access, use, modification, or disclosure. This includes maintaining physical and electronic security measures so that only authorised personnel of the FAP have access to client information. | The FMC Act imposes duties on persons who give regulated financial advice and on FAPs and interposed persons that engage them. These include the duty to comply with the standard conditions of the FAP licence and the Code Standards. FAPs are also required to exercise the care, diligence, and skill that a prudent person engaged in the occupation of giving regulated financial advice would exercise in the same circumstances. |
Reporting Requirements β General Reporting Conditions
MTG must, as soon as practicable, send details of the matter to the FMA:
When there is a change in the status of the FAP
Insolvency or bankruptcy
When there is any relevant proceeding or action (criminal) against β
The licensee, director or senior manager of the licensee
An authorised body or key personnel of the authorised body
When there are changes to the structure β
Changes to key personnel, director or senior manager β whether ceasing or starting
Name of legal structure changes
When a major business transaction takes place
Takeover, merger or acquisition
Reporting requirements β FMCA
MTG must, as soon as practicable, send details of the matter to the FMA:
has contravened, may have contravened, or is likely to contravene a market services licensee obligation in a material respect
a material change of circumstances has occurred, may have occurred, or is likely to occur in relation to the licence
information provided under section 395 (application for licence) or 404 (application for a verification) is false or misleading in a material particular
POLICY STATEMENT
If we have a material change or material breach within our business, we report these to FMA as soon as we become aware of them or within the required timeframe. The reporting timeframe is ten working days.
A material event is one where the confidentiality, integrity or availability of information and/or technology systems has been compromised. We do not need to notify the FMA of minor events, such as receiving a βphishingβ email.
KEY PROCESSES
When an potential material issue or breach occurs within our business we record the issue in our Material Issue and Breaches register and determine a suitable remedial pathway forward.
Our BCP sets out MTGβs βIncident Response Planβ that describes the course of action MTG will take to navigate the cyber incident
Where a possible material breach has occurred the business owner will notify the Managing Director who will make the final call as to whether the breach is in fact material.
If material, we then report the issue as soon as practical to the FMA or within 10 working days of becoming aware of the issue.
Staff and Adviser Training
In order to cultivate a culture of awareness of and commitment to cyber resilience within MTG we provide training support to staff so they are aware of their responsibilities.
We provide training on cyber risks that exist, and on how to respond to and report them.
Other Notification Requirements
We have other notification requirements mandated by legislation that may be triggered by a cyber incident. For example, under the Privacy Act 2020, if we have a privacy breach that either has caused or is likely to cause anyone serious harm, we will need to notify the Privacy Commissioner and any affected people as soon as practicable (see Privacy Policy)
KEY CONTROLS
Staff & Adviser Training
How implemented: LMS Training Module β Identification and response/reporting
Responsibility & Frequency: L&D Co-Ordinator β Annual
Staff & Adviser Training
How implemented: Regular Cyber Security Comms & Reminders
Responsibility & Frequency: MTG Newsletter
Material Issues and Breaches Register
How implemented: Identify when a breach/material issue occurs. Record any issues in Material Issues & Breaches Register
Responsibility & Frequency: Rupert G β Ongoing
REFERENCE
FMA
Licensing requirement β Standard condition notification of material changes
Companies Act 1993
431S β Protection of individual who reports breach
Related Policies
Privacy Policy
IT Systems & Security
BCP
Advertising & Fair Dealing Policy
π CPD Point Available For This Section π
OVERVIEW
Our marketing and advertising will accurately portray who we are and what we do. All marketing and advertising collateral will comply with legislation, regulation, and code, and will meet our good conduct obligations.
Documents and communication must be clear, concise, and effective.
This policy applies to all directors, employees, contractors, and financial advisers that are engaged by MTG/Mortgage Lab
INTRODUCTION
Advertising and marketing materials include any publicly available information that could influence a client in their decision-making process regarding a product or service.
Examples include brochures, newspaper/magazine/online ads, our website, social media platforms, business cards, flyers, and radio messages.
Given our diverse client base, clear communication is essential to avoid confusion or misrepresentation. Misleading or deceptive behaviour may breach both regulatory obligations and our internal standards.
PURPOSE
This policy ensures that:
All advertising and marketing by MTG is compliant.
No materials or activities mislead, confuse, or deceive clients.
REGULATORY OBLIGATIONS
Under Part 2 of the Financial Markets Conduct Act 2013 (FMC Act), the principles of fair dealing prohibit:
Misleading or deceptive conduct
False or misleading representations
Unsubstantiated representations
Unsolicited offers of financial products
The FMC Act provisions align with those in the Fair Trading Act 1986.
POLICY STATEMENT
All advertising and advertising materials created by MTG/Mortgage Lab must follow internal checks and the sign-off process.
This policy applies to all representations regarding the advice, promotion, and sale of products and services, including print, broadcast, digital, verbal, and promotional activities.
Mass Email Communications
Mass emails are defined as any email sent to more than 2% of the MTG client base.
No mass email (e.g. newsletters, promotional campaigns) may be distributed without prior approval.
Staff must prepare the wording for the intended mass email and submit it to management for review and sign-off.
Once approved, design and formatting will be completed by the MTG marketing team.
KEY PROCESSES
All advertising and promotional activities must:
Avoid misleading or deceptive content.
Contain no false or misleading claims.
Respect the trust and experience level of clients.
All staff with sales and advice responsibilities must:
Be trained on this policy at induction and through regular updates.
Be informed of all current advertising and promotions related to products/services they provide.
Immediately report any suspected breaches to a Senior MTG Manager.
Errors in published materials must be corrected promptly and communicated to affected clients. Outdated advertising must not be used.
WHEN TO SEEK APPROVAL
1. General Well-Wishing Messages: No approval required (e.g. holiday greetings).
2. Product-Specific Content: Compliance sign-off required.
3. Educational Content: May not require sign-off, unless content could be perceived as advice.
4. Market Opinions/Advice: Always requires compliance sign-off.
5. Risk Disclosures: Always requires compliance review.
SOCIAL MEDIA GUIDANCE
Posts referencing clients, products, services, staff, or processes must:
Be archived for at least seven years.
Avoid financial product opinions, recommendations, or guarantees.
Exclude any defamatory, harassing, or private client content.
Avoid negative references to competitors or internal staff.
Not disclose MTG proprietary or confidential business information.
CONTROLS
1. Training
Via CPD module on intranet
Responsibility: Head of Insurance & KiwiSaver / Head of Mortgages
Timing: Induction & Annual
2. Advertising Sign-Off
Notification sent to: Marketing VA (Anne), Rupert G, and Sian J
Annual audit: Rupert G (Compliance Assurance Programme)
3. Breach Reporting
Must be reported to Rupert G
Logged in Material Issues & Breaches Register and/or Complaints Register
Reviewed: Bi-Monthly SMT
See related policies
Complaints Policy
REFERENCE
Financial Markets Conduct Act 2013
Part 2, Fair Dealing sets out the obligations for misleading or deceptive conduct generally in relation to financial products and services. Click here for source;
A person must not, in trade, engage in conduct that is misleading or deceptive or likely to mislead or deceive in relation to any dealing in financial products; or the supply or possible supply of a financial service or the promotion by any means of the supply or use of financial services.
A person must not engage in conduct that is misleading or deceptive or likely to mislead or deceive in relation to any dealing in quoted financial products.
FMCA 2013
431P β False or misleading statements and omissions
Fair Trading Act 1986
The Fair-Trading Act 1986 protects clients against being misled or treated unfairly by traders or shops. The Act prohibits misleading and deceptive conduct, unsubstantiated claims, false representations and certain unfair practices. It also sets out when information about certain products must be disclosed to Clients and helps ensure products are safe. www.Client.org.nz/articles/fair-trading-act
Professional Indemnity Insurance Policy
INTRODUCTION
Professional Indemnity Insurance is a requirement for any adviser or business that is paid to provide professional advice or service. We have a duty of care to our clients, and therefore need to ensure we are adequately protected. PII covers legal costs and expenses incurred in any defence, as well as any costs that may be awarded. We ensure that we have an appropriate level of cover for the business.
The risk of a claim being made against us isnβt always determined by our skill or level of professionalism. There is always the risk of an unhappy client making a claim against us.
A Professional Indemnity claim could arise
Failing to provide promised services
Being negligent in rendering professional services
Providing substandard, incomplete, or incorrect work
Making mistakes or oversights
Any omissions in the provisions of your service
POLICY STATEMENT
MTG has taken the appropriate level of professional indemnity cover for legal and defence costs, as well as compensation payable to the party making the claim, up to stated policy limits. We use an external specialist provider for our PI cover.
KEY PROCESSES
We maintain an appropriate level of professional indemnity insurance to cover risks related to our business;
Our level of PI insurance cover is adequate and appropriate for the nature, scale and complexity of our business relating to our FAP licence;
We review our PI insurance annually to ensure we are adequately covered; and
We make sure we have enough resources to meet policy excess in the event of a claim
CONTROLS
Annual Policy Renewal
How implemented: Policy renewal is received, level of cover is checked against business requirements to see if still adequate or needs adjusting
Responsibility & Frequency: Head of Compliance β Annually
New Advisers Added/Leavers Removed
How implemented: When an adviser is added or removed to our FAP on the FSPR, they are automatically added to our Professional Indemnity Cover.
Responsibility & Frequency: Head of Channel - Automatic
Outsourcing Policy
INTRODUCTION
As a small business, we need to outsource some functions to third parties. Itβs important that we protect our reputation and your clients by conducting robust background checks, putting contractual agreements in place, and performing regular reviews to ensure suppliers of key functions are up to the task and can meet our expectations and Financial Advice Provider (FAP) obligations.
As a FAP, we are responsible for any functions that we outsource key FAP functions that might be outsourced
Oversight and compliance functions Record keeping and IT services (eg digital CRM)
Training services
Advice services (including digital advice)
The purpose of this policy is to set out the processes to follow if a key function is outsourced. While MTG can outsource a function we remain responsible for ensuring the service complies.
POLICY STATEMENT
When we outsource certain functions of our licence, we are aware that the provider is performing some of the licenced functions of our business. It is important then that we ensure that they will meet certain standards so that we meet with our regulatory obligations.
We complete due diligence on the business we are considering using by completing an outsource checklist and if we continue and use the services, we complete an outsource agreement outlining our expectations.
We must have contractual arrangements in place with each provider which enable us to monitor their performance and allow us to act if they do not perform. Records held by the provider must be readily available to us.
KEY PROCESSES
We will complete due diligence with the use of our outsource checklist to see if the business has the competence, knowledge, and skill to provide a compliant and reliable service on our
We will complete an outsourcing agreement with the provider that outlines the expected standards of performance and will also include a termination clause for non-performance or non-compliance.
We ensure that all information and records that the outsource provider holds will be available for inspection by the FMA on request.
We will complete a regular review to ensure that each provider is, and remains, capable of performing the service to the standard requirements to meet our licence obligations.
The frequency of the review will take a risk based approach.
CONTROLS
Outsource agreement and checklist
How implemented: Outsource agreement (Risk) and checklist to be completed and held on file
Responsibility & Frequency: Head of Compliance β Annually
REFERENCE
FMA
Licensing requirement β standard condition for Outsourcing
FMC Act 2013 (FSLAA)
431Q β Persons engaging others to give advice must ensure compliance with duties
Outsourcing Due Diligence & Approval Form
Fit & Proper Policy & Declaration
Fit & Proper and Capability Policy for Directors and Senior Managers
Purpose: The purpose of this policy is to establish clear guidelines and expectations regarding the fit & proper and capability requirements for individuals serving as directors and senior managers of MTG and Mortgage Lab
Scope: This policy applies to all individuals holding the positions of director and senior manager within MTG and Mortgage Lab.
Fit and Proper Standards: All directors and senior managers must meet fit and proper standards. These standards include:
Competence and Capability: Directors and senior managers are expected to have the necessary skills, knowledge, and experience to fulfil their roles effectively. This may involve having relevant qualifications, industry experience, and require ongoing professional development.
Integrity and Character: Individuals in these positions are expected to demonstrate high standards of integrity and ethical behaviour. Any history of dishonesty, fraud, or other unethical conduct will be considered when assessing fitness and propriety.
Regulatory Compliance: Individuals should have a good understanding of the relevant laws and regulations governing the financial services industry in New Zealand. Compliance with regulatory requirements is crucial for maintaining fit and proper status.
Reputation: The reputation of directors and senior managers will be a factor in determining fitness and propriety. Any past actions that could impact the reputation of MTG and Mortgage Lab, or the industry will be considered.
Conflict of Interest: Individuals in these roles should be able to identify and manage potential conflicts of interest appropriately.
Capability Requirements: Directors and senior managers are expected to possess the necessary skills, knowledge, and experience to effectively perform their roles. This includes:
Ongoing professional development to stay abreast of industry changes.
Compliance with educational and training requirements. For those in advice roles, completion of the NZCFS Level 5 and ongoing CPD is mandatory. For Directors and Senior Managers in non-advice roles then education and training as suitable to your role is required.
All directors and senior managers are required to annually complete MTGβs prescribed training modules accessed via our in house LMS (Refer T&D Policy).
Annual assessment via attestation of individual and collective capabilities to ensure alignment with the business strategy and regulatory requirements.
Appointment Process: The appointment of directors and senior managers will be conducted in accordance with the following process:
Nomination and vetting process to assess fit and proper criteria including completion of MTG/Mortgage Labs fit & proper attestation.
Evaluation of qualifications, experience, and competence relevant to the position
Approval by the Board and submission/approval from the FMA as required.
Ongoing Monitoring: Continuous monitoring of the fit and proper status and capability of directors and senior managers will be conducted through:
Annual reviews of qualifications, experience, and competence including internal and external CPD undertaken.
Monitoring of any conflicts of interest.
Reporting Requirements: Directors and senior managers are required to promptly report any changes in their fit and proper status or capabilities to the Board as required.
Consequences of Non-Compliance: Non-compliance with fit and proper standards and capability requirements may result in disciplinary action, including but not limited to removal from the position or other actions deemed appropriate by the Board and in accordance with regulatory guidelines.
Review and Revision: This policy will be reviewed annually to ensure its ongoing relevance and compliance with regulatory requirements. Any necessary revisions will be made promptly, and the updated policy will be communicated to relevant stakeholders.
CONTROLS
LMS
How Implemented: Prescribed training modules completed
Responsibility/Frequency: Compliance Manager β Ongoing
Attestation
How Implemented: All Directors & SLT members required to complete attestation
Responsibility/Frequency: Compliance Manager β Annually
See related policies
Training & Development Policy
REFERENCES
FMC Act
Licensing requirement β directors and senior managers are fair and proper persons to hold their respective positions
IT Systems and Security Policy
INTRODUCTION
As a business we are required under New Zealand law to make sure that we protect the privacy and information we hold on our clients and staff.
The loss of information could severely impact the way we operate and lead to reputational and financial damage.
The objectives of this IT security policy are the preservation of confidentiality, integrity, and availability of systems.
POLICY STATEMENT
We have established our IT security policy to ensure that all staff are aware of the computer security policies for maintaining a secure operating environment.
The policy also defines acceptable and unacceptable use and staffβs responsibilities for maintaining security when using and accessing our information systems.
There are three main objectives for IT security:
Confidentiality β protecting access to sensitive data from those who donβt have a legitimate need to use it
Integrity β ensuring that information is accurate and reliable and cannot be modified in unexpected ways
Availability β ensuring that data is readily available to those who need to use it
ACCEPTABLE USE
The types of activities that staff/contract advisers are encouraged to participate in and those considered acceptable practice when using systems include:
Research on the Internet related to developing professional skills related to oneβs position
Acquiring or sharing information necessary or related to the performance of an individualβs assigned responsibilities
Reasonable use of computing facilities for personal correspondence (e.g. sending personal emails, using Internet websites) so long as it does not interfere with productivity or consume sustained high-volume traffic
UNACCEPTABLE USE
The types of activities that are considered unacceptable practice include:
Use of company digital technology and Internet services for illegal or unlawful purposes. This includes but is not limited to intentional copyright infringements, software license infringements, obscenity, fraud, defamation, plagiarism, harassment, intimidation, forgery, impersonation and computer tampering (e.g. spreading computer viruses or destruction of data owned by others)
Intentionally using company digital technology and Internet services to visit Internet sites or receive information that contains obscene, pornographic, hateful or other objectionable material
Attempting to gain access to any computer system, information, or resources without the authorisation of the relevant owner
Knowingly or recklessly transmitting or distributing any information or material which contains a virus, worm, Trojan Horse, or any other harmful component
Posting, publishing, transmitting, or distributing any unsolicited advertising through mass electronic mail or other direct transmission
Using digital technology and Internet services to reveal or publicise restricted or proprietary information, including but not limited to: financial data, intellectual property, strategy documents, staff details, client databases, or access credentials
Using company digital technology or equipment to conduct personal business unrelated to Maurice Trapp Group and its subsidiaries
Excessive consumption of bandwidth for non-work-related purposes, including illegal downloading, streaming, or online gaming without a clear business or educational purpose
All use must comply with all applicable laws. Breach of this policy may be deemed a breach of contract and appropriate action will be taken.
USE OF AI SYSTEMS
The use of artificial intelligence (AI) systems is restricted to approved channels in order to protect client privacy and company data.
The use of AI systems is prohibited for all client-related activities, except in the following specific cases:
Meetings: AI features may be used in Zoom, Microsoft Teams, or Google Meet β but only if the meeting is held using a Maurice Trapp Group-funded account or its subsidiariesβ accounts.
Content Generation (e.g. emails, newsletters, blog posts): ChatGPT may be used for content creation but must be a paid account, not the free version
Other situations where formal approval has been given by Maurice Trapp Group or itβs subsidiaries (for example, if Trail CRM integrates AI).
All other use of AI tools or platforms for work-related activities β including client correspondence, document preparation, or data entry β is strictly prohibited. This includes free, personal, or unapproved AI tools.
Note that the use of AI such as Siri or Alexa for non-client functions falls outside of this policy.
This policy is in place because use of unapproved AI platforms may expose private client data to training datasets, which puts personal and sensitive information at risk.
KEY PROCESSES
The security practices that control access to information and computer systems.
The following apply:
Only MTG staff and authorised visitors are allowed to access the companyβs systems.
User accounts are to be created and managed by MTG, this includes:
The creation and deletion of all user accounts.
Periodic auditing of accounts to verify account status.
All user accounts are required to change passwords at least once every 6 months
Password should be strong and unique with a combination of upper- and lower-case characters and symbols.
Never disclosed to another user or staff member.
SECURITY
Computers are to be locked when users are away from their desk.
We regularly back the IT systems up and securely stores the backup information. Mortgage Lab emails, calendar and Google Drive documents are backed up daily by a third party called afi.ai.
Only reviewed and approved software is to be installed on company devices.
IT security software checked and updated including anti-virus software.
Training is provided to help advisers and staff identify phishing threats.
Network security is regularly checked by our IT outsource provider
Business Continuity Plan (BCP)
We regularly review our Business Continuity Plan (BCP) to make sure there would be minimal impact on the business and clients in the event of a natural disaster or any other interruption to our day-to-day business. The BCP includes contact details for staff and suppliers.
All staff are trained in this policy.
CONTROLS
Training register
How implemented: Training in the IT security policy and training register updated
Responsibility & Frequency: L&D Co-Ordinator
BCP
How implemented: BCP to be reviewed to ensure that it is up to date with latest IT details
Responsibility & Frequency: Head of Finance & IT
Material event
How implemented: Triggers a reporting obligation to the FMA
Responsibility & Frequency: Head of Finance & IT
Cyber Protection
How implemented: 2FA for Mortgage Lab emails and TrailCRM
Responsibility & Frequency: Head of Mortgages
REFERENCES
Privacy Act
The Privacy Act 2020 deals with the collection, storage and use of personal information about identifiable individuals and therefore principally affects Client marketing. Everyone in the organisation who handles personal information should have an understanding of the Information Privacy Principles and the objectives
Code of Professional Conduct for Financial Advice Services
Code Standard 5. PROTECT CLIENT INFORMATION
A person who gives financial advice must take reasonable steps to protect client information against loss and unauthorised access, use, modification, or disclosure.
FMA
Licensing requirement β condition re business continuity and technology systems.
See related policies
Privacy Policy
Material Issues and Breaches Policy
Policies β HR & Procedure Manual
Welcome
Congratulations on your appointment and welcome to the team at Maurice Trapp Group! We are excited that you have decided to join us and look forward to a long, happy and successful partnership together. For the purpose of Human Resource, this Manual applies to MTG branded and non-branded entities. Our business is primarily about providing our clients with βa certain futureβ and delivering exceptional customer service along the way. You have been recruited because we believe you can help us to deliver these high levels of customer satisfaction. We want to ensure that your interactions with other Maurice Trapp Group employees and our customers will reflect the value that Maurice Trapp Group places on, teamwork, initiative and our commitment to superior customer service.
The purpose of this Manual is to introduce you to Maurice Trapp Group, give you some information about our history, our clients and what we do. You will also find information about your terms, conditions and employment, our expectations around your behavior and our policies and procedures. This manual should be read in conjunction with your Contract of Employment.
This Manual is by no means an exhaustive guide to your employment with us. It has been developed to act as a resource and reference for you. The policies within this manual are easily listed and easily accessed via the contents page. This manual will be updated as required as our business evolves and grows. You will be notified of any changes as they occur. If you have any questions about the content please do not hesitate to contact Sian Johnson 09 6305884.
The story of Maurice Trapp Group starts in 2006 when Brent Wright and Andrew Lacy approached Maurice to gauge his interest in joining forces. At that stage, Brent and Andrew were both working in the Sales Management side of one of the larger Insurance Providers and Maurice owned and operated a very successful niche Business Risk Brokerage along with the help of Shari French. Brent and Andrew saw a gap in the SME market for quality Business Risk Insurance and Succession Planning advice. There was a need for more pragmatic, service-focused brokerage where the Advisers were willing to partner and grow with businesses and take on a role of a trusted business advisor.
Company founder Maurice Trapp is probably best known throughout the country and internationally, as the coach of the most successful Provincial Rugby Team in New Zealand. He coached the Auckland Rugby Team between 1987 and 1991, setting numerous records along the way.
At Maurice Trapp Group we are firm believers in listening to and learning from our clients, to ensure we establish individually tailored solutions to create and protect their financial growth, and as a result, providing them with a certain future. We put in place safety nets for those times when a business owner or business partner has a serious illness, trauma or accident that prevents them contributing to the growth and management of their business.
Another area of our expertise is in Succession Planning. Business owners in New Zealand invariably face the complicated problem of how to successfully exit the business they have created and managed for a number of years. We help to create succession plans and exit strategies for business owners so that they can exit their business on their own terms.
Maurice Trapp Group now works with over 700 SMEβs across all industries and has a client base of some 20,000 clients. We aim at all times to maintain the utmost levels of service for our customers and strive to place ourselves at the forefront of Business Risk Advisory Services within the Insurance industry.
During our journey, our Company has grown with the acquisition of like-minded Risk businesses, FPNZ Ltd, Warren Storm Life Brokers, Bassett Smith Brokers Ltd, KSL Insurance (Christchurch) and most recently Cooney Insurance Services (Cambridge) and Momentum Wealth (Whanganui). We also have Group specialists Lewis Limited/Group Health Solutions / MTG Employee Benefits and recently partnered with Mortgage Lab to provide a holistic financial servies nationwide. Our other specialty is Union-focused with our product offering available through Maurice Trapp Group Union Plus Ltd to union members and their workers.
The future will include further evolution, so we are delighted you have joined us at this very exciting time.
Business Overview β What We Do
MTG provides financial advice through three authorised body FAPs and financial advisers. These FAPs and financial advisers must comply with the MTG FAP Licensee Policy Manual.
The Maurice Trapp Group of companies provides the following insurance products and services to our clients:
Life Insurance
Trauma
Total and Permanent Disability
Key Person Cover
Income Protection
Medical/Health
KiwiSaver
Revenue Protection
Group covers
Share Purchase Cover
Succession Planning
Mortgage Advice
General compliance obligation
Maurice Trapp Group Limited (MTG) is the Financial Advice Provider (FAP) Licensee for Risk. The Mortgage Lab NZ Limited is the FAP Licensee for Mortgages.
As a FAP Licensee, we must always, meet the eligibility and standards of our FAP Licence. This means that we need to keep our policies, processes, systems and controls up to date and that they reflect any changes we make in the business.
We also need to ensure that our directors, senior managers, and any other relevant parties are, and remain, fit and proper persons to hold their respective positions.
As a user of this manual, if you identify any business changes or other changes required to the manual, please advise our Compliance Officer as soon as practicable.
You also have a responsibility to ensure that you are complying with the latest version of this manual.
Mission Statement
Maurice Trapp Groupβs mission is to help our advisers build and develop sustainable, profitable businesses supplying safety nets in the form of Risk Insurances for Businesses, Business Owners and Families. The outcome we work towards is β βA Certain Futureβ for our clients and their families.
Vision Statement
Our aim is to be:
Known for high-quality outcomes
Known for growth strategies
Known for superior quality service
Known for robust support and advice at claim time
Values
| Care | |
|---|---|
|
For our clients: Exceed customer expectations For each other: Work as a team and treat each other with respect and courtesy For the business: Participate and contribute For ourselves and our families: By recognising when step back, slow down and seek advice or help |
|
| Share | |
| Our Knowledge and Experience | Our Integrity |
| Our Attitudes: Lead by example | Our Reliability: Pursue excellence |
| Our Respect: Listen and communicate | Our Wins |
| Our Trust | |
| Dare | |
| To Lead | To Question |
| To Challenge | To back Ourselves and Each other β Have fun |
| To Fail and to Learn from that Failure | To be Courageous |
Your Employment
Your employment with Maurice Trapp Group and associated Companies is essentially governed by your contract of employment, in conjunction with this manual. The following section provides general information regarding your pay, conditions and our expectations of you.
Payroll
If you are a salaried/wages employee of MTG your pay cycle is weekly. Our pay week runs from Wednesday to Tuesday over a one week period and wages are processed on Wednesdays weekly. Depending on which bank you use, some people may be able to access their pay on Wednesday because this is the day payroll is actually processed. If you are on a Contract payment will be made to your nominated bank account on Thursday each week.
Wages will be automatically deposited electronically into the bank account details provided to Maurice Trapp Group Limited.
Taxation payments are automatically deducted from your salary. Please advise us if you are currently a member of a KiwiSaver scheme or if you would like to join KiwiSaver. Also please advise us if there is any other IRD deduction for you that we need to be aware of e.g. Student Loan.
KiwiSaver
A copy of the IRDβs Introduction to KiwiSaver follows:
KiwiSaver is a voluntary savings scheme to help set you up for your retirement. Most members will build up their savings through regular contributions from their pay.
KiwiSaver member benefits include contributions from your employer and the Government, as well as help to buy your first home.
Your role in KiwiSaver:
If youβre a salary or wage earner your employer enrols you in KiwiSaver when you start a new job. You can stay enrolled, or you can opt-out.
If youβre already employed but not a KiwiSaver member you can join either through your employer or through a KiwiSaver provider. Once youβve joined, you will not be able to opt-out.
If you stay enrolled youβll contribute either 3%, 4%, 6%, 8% or 10% of your before tax pay. If you do not choose a contribution rate, your employer will deduct the default rate of 3%. Youβll contribute through wage deductions.
MTGβs role in KiwiSaver:
MTG determines if new employees are eligible for automatic enrolment in KiwiSaver. We also enrol existing employees if they choose to opt in to KiwiSaver.
MTG sends the details of all enrolments to the IRD and will also send new employee KiwiSaver opt out requests.
MTG make KiwiSaver deductions from their employeesβ pay. They also make a compulsory minimum contribution of 3% towards our employeesβ KiwiSaver fund β unless we are already contributing to another superannuation fund for you.
MTG will also stop payments if their employee has a savings suspension, or if theyβre given notice by the IRD or you as our employee, that contributions are to stop.
Changing Pay Details
Please advise Payroll via email if you need to update any pay details (like amending your bank account). Please ensure you notify Payroll prior to the date from which you wish the change to be effective. All requests for changes should be made via email or via the Xero Me app.
Personal Appointments
We understand that occasionally dental, medical and business appointments are necessary but ask wherever possible you should make these outside your normal working hours or later in the day to ensure that they do not involve too much time away from the office. If you need to attend appointments during business hours please let your manager know.
Reimbursement of Expenses
Maurice Trapp Group will reimburse employees for pre-approved expenses, including travel expenses, incurred in the proper performance of their duties. Reimbursement will be subject to employees providing receipts or other evidence of payment and of the purpose of each expense, in a format reasonably required by Maurice Trapp Group. Employees will also be required to complete the Expense Reimbursement Form. Please ask Bernadette in accounts for this. We ask where possible that prior approval be requested by your direct line Manager for any business expenses paid personally.
Client Meetings:
MTG and Mortgage Lab wishes to minimise itsβ carbon footprint. Advisers are encouraged to make use of video meetings whenever possible. This is not only efficient for the adviser but is good for the environment. Some examples of when a video meeting isnβt appropriate:
if the adviser senses the client may be vulnerable (eg; English as a second language, being pressured by a third party to purchase, etc)
for applications with AIA Home Loans that require a face-to-face meeting for AML purposes
Flights:
Where possible, advisers are encouraged to offset their carbon emissions when flying. The airlines offer this at the time of purchase.
Information for the main airlines is here:
Induction
Introduction
This policy applies to all MTG employees and contractors.
Staff of MTG and contractors are our most important asset. Induction is a very important step to help new staff and contractors feel welcome and become fully committed to MTG.
Good induction sets the tone and expectations for staff and contractor relationships with MTG management and existing staff. It helps staff understand the purpose, functions and tasks of their role so they can perform at their best.
Policy
All new staff and contractors at MTG will go through induction before they start working within the business. The induction process is delivered over a period. It will include a follow-up once the person has had a chance to settle in; this is so that MTG can answer any questions the person might have.
Procedure
During the first week β and before starting work β the following steps must be completed:
Health & Safety
Provide a full health and safety briefing, including:
Risks and hazards in the workplace
How to report, isolate, minimise, or eliminate hazards
Explain workplace evacuation procedures
Orientation
Brief the person on key policies and procedures, and where to find them
Show the location of:
Toilets
Kitchen and break areas
Other key facilities
Ensure their workspace is set up correctly:
Check chair and desk height
Ensure there is sufficient space to work comfortably
Communication & Support
Identify key contacts:
Office contact person
Emergency contacts
Clarify hours of work and scheduled break times
Introduce the person to their co-workers
Discuss building access and issue any required security codes or passes
Assign a βwork buddyβ to help answer day-to-day questions
Training & Resources
Provide relevant information on:
Role-specific training
Access to learning and support systems
Where to go for ongoing help
Explain how their role contributes to the overall success of MTG
End-of-Day Check-In
Touch base at the end of the first day to:
Answer any immediate questions
Confirm that the induction checklist has been completed
Business Environment
Work Areas
As many employees at Maurice Trapp Group and associated Companies work in an open plan area, it is important that your workstation and or desk remain clean and tidy and free of boxes, papers and magazines. Our expectation is that your workstation will be tidied as much as possible at the end of every day. Any items that require storage should be put away, hard copy paper files should be kept to a minimum, with soft copies of files stored on the relevant shared drive electronically. Laptops should not be left on desks overnight and PCβs should be logged off at the conclusion of each day. Workstations must be locked when a desk is left unattended. Please do not store paperwork on the floor.
Security
It is the responsibility of every Maurice Trapp Group employee to ensure that this key/security swipe card (where required) is kept in safe custody. It must be returned on demand / or on termination of employment.
If building access devices are lost or misplaced, please notify Sandra immediately so that they can be cancelled and/or replaced.
Employees must ensure that all confidential/sensitive documents are stored safely at night. You should make sure that your personal belongings and valuables are secure at all times. Personal property is not covered by Company insurance.
Procedure
Paperwork with any sensitive or confidential Maurice Trapp Group information needs to be placed into the locked security disposal bins provided (Auckland, Tauranga) and/or shredded. Documents to be placed in the security bins and/or shredded include but are not limited to:
Company Information
Client information
Completed provider forms
Terms and conditions
Policies
If documents are placed in the security bin and need to be retrieved, see your manager for the key (Auckland only). For obvious reasons take extra care when shredding a document, ensure that it is ok to do so as it will not be able to be retrieved.
Noise Factor
Please try to avoid shouting at each other across the office and respect peopleβs busy periods or meeting times. Please keep your mobile phone ringtone at a respectable level.
Code of Conduct Policy
Purpose
This policy affirms Maurice Trapp Groupβs belief in responsible social and ethical behaviour from all employees. This policy clarifies the standards of behaviour that Maurice Trapp Group expects of all employees.
Principles
Our MTG Team members contribute to the success of our organisation and that of our Clients. Maurice Trapp Group fully endorse that all Team members not be deprived of their basic human rights.
Furthermore, our Team members have an obligation to the Business, our Clients and themselves to observe high standards of integrity and fair dealing. Unlawful and unethical business practices undermine employee and Client trust.
Policy
Our Code of Conduct policy applies to all employees and provides the framework of principles for conducting business, dealing with other employees, clients, providers and suppliers. The Code of Conduct does not replace legislation and if any part of it is in conflict, then legislation takes precedence. This policy is based on the following:
Act with and maintain a high standard of integrity and professionalism
Be responsible and scrupulous in the proper use of Company information, funds, equipment and facilities
Be considerate and respectful of the environment and others
Exercise fairness, equality, courtesy, consideration and sensitivity in dealing with other employees, clients and suppliers
Avoid apparent conflict of interests, promptly disclosing to a Maurice Trapp Group senior manager, any interest which may constitute a conflict of interest
Promote the interests of Maurice Trapp Group Companies
Perform duties with skill, honesty, care and diligence
Abide by policies, procedures and lawful directions that relate to your employment with Maurice Trapp Group and associated companies /or our Clients
Avoid the perception that any business transaction may be influenced by offering or accepting gifts
Under no circumstances may employees offer or accept money
Under no circumstances may employees conduct business for external entities during standard work hours of 8:30am to 5:00pm
Any employee, who in good faith, raises a complaint or discloses an alleged breach by another staff member of the Code/ Law, will not be disadvantaged. All disclosures will be dealt with in a timely and confidential manner.
Maurice Trapp Group expects co-operation from our Administration and Adviser Teams in conducting themselves in a professional, ethical, lawful and socially acceptable manner of the highest standards.
Any employee in breach of this policy may be subject to disciplinary action, including termination.
Should an employee have doubts about any aspect of the Code of Conduct, they must seek clarification from their Office Manager.
This policy will be regularly reviewed by Maurice Trapp Group and any necessary changes will be implemented by Management.
All advisers must be familiar with the code of professional conduct. The latest version is available from the Kiwi Adviser Network resources page.
Code of Professional Conduct β March 2021
Code of Ethics
1. Be inclusive
We welcome and support people of all backgrounds and identities. This includes, but is not limited to members of any sexual orientation, gender identity and expression, race, ethnicity, culture, national origin, social and economic class, educational level, colour, immigration status, sex, age, size, family status, political belief, religion, and mental and physical ability.
2. Be considerate
We all depend on each other to produce the best work we can as a company. Your decisions will affect clients and colleagues, and you should take those consequences into account when making decisions.
3. Be respectful
We wonβt all agree all the time, but disagreement is no excuse for disrespectful behaviour. We will all experience frustration from time to time, but we cannot allow that frustration to become personal attacks. An environment where people feel uncomfortable or threatened is not a productive or creative one.
4. Choose your words carefully
Always conduct yourself professionally. Be kind to others. Do not insult or put down others. Harassment and exclusionary behaviour arenβt acceptable. This includes, but is not limited to:
Threats of violence.
Insubordination.
Discriminatory jokes and language.
Sharing sexually explicit or violent material via electronic devices or other means.
Personal insults, especially those using racist or sexist terms.
Unwelcome sexual attention.
Advocating for, or encouraging, any of the above behaviour.
5. Donβt harass
In general, if someone asks you to stop something, then stop. When we disagree, try to understand why. Differences of opinion and disagreements are mostly unavoidable. What is important is that we resolve disagreements and differing views constructively.
6. Make differences into strengths
We can find strength in diversity. Different people have different perspectives on issues, and that can be valuable for solving problems or generating new ideas. Being unable to understand why someone holds a viewpoint doesnβt mean that theyβre wrong. Donβt forget that we all make mistakes, and blaming each other doesnβt get us anywhere.
Instead, focus on resolving issues and learning from mistakes.
Dress Code Policy
Maurice Trapp Groupβs objective in establishing a safe and comfortable environment includes setting some standards for workplace dress code. This is to enable all people to project a professional image that is in keeping with the needs of our clients and customers to trust us and for our own positioning. Because our industry requires the appearance of trusted professionals a relaxed but professional standard dress code is necessary for everyone.
Our team are expected to dress appropriately for their day and the outside parties they are meeting with. In the offices, Friday work attire can be casual. This requires a neat and well-presented manner at all times. Footwear is to be worn in the office at all times.
Drug and Alcohol Policy
Maurice Trapp Group regards itself as a responsible employer. We believe in maintaining a healthy work environment and promote legal compliance. This Policy is intended to safeguard employees, and contractors, but we also respect an individualβs choice and privacy.
For the purpose of this Policy βWorkplaceβ is defined to mean any place at which an employee or contractor is carrying out duties for Maurice Trapp Group (MTG) or itβs subsidiaries. It applies to employees and contractors who are working at Maurice Trapp Group and includes any client related functions or events, MTG vehicles (including vehicles hired by MTG or ABβs) and when employees or contractors are travelling on behalf of MTG. It also includes any other locations where the employee or contractor is present by reason of his/her employment/contract with MTG.
Alcohol Consumption
Alcohol is not to be consumed during working hours or on work premises unless an employee / contractor is attending an official function where that alcohol has been provided by MTG or an MTG client.
Where alcohol has been supplied at an official function by either MTG or MTG client, every employee is responsible for ensuring that his/her own consumption does not exceed the limits set by law as acceptable for driving under the influence of alcohol.
Where an employee is suspected of having consumed in excess of the level prescribed above, an MTG representative may refuse to provide the employee with any further alcohol.
Alcohol may seriously effect an employeeβs performance. Impaired performance may not only be a cause of detriment to an employeeβs health and safety, it may also be for other employees or MTGβs clients. As such, it is MTGβs policy that no employee will consume alcohol during work hours or attend work under the influence of alcohol.
Where an employee is at work under the influence of alcohol, or consumes alcohol to a level that exceeds reasonable consumption, this may result in disciplinary action up and including summary dismissal.
Drugs Prohibited
The use of illegal substances (βDrugsβ) in a work environment is likely to create unnecessary health and safety risks to employees and to others
MTG is of the clear view that it is impossible for an employee to discharge his/her responsibilities safely while under the influence of drugs. MTG is also firm that using Drugs has the potential to cause serious damage to MTG reputation and perception in the marketplace.
MTG enforces a strict drug-free environment at all times. The use of Drugs within the workplace, by an employee/contractor during work hours or where the employee/contractor is representing MTG is absolutely prohibited.
MTG/ABβs prohibits any employee/contractor to distribute, possess sell or use Drugs while employed/ contracted by or representing MTG on or off the premises.
Employees/Contractors are advised that a criminal conviction for drug related offences may also result in disciplinary action up to and including summary dismissal.
Damage to Property
Should any employee/contractor breach this policy and cause damage to MTG property under the care or control of MTG (including any company or rental vehicle) that employee/contractor will be liable for the cost of repair or replacement, and for the insurance excess. These amounts or any other amount due by the employee to MTG may be deducted from the employeeβs wages or salary.
In addition to the above, should an employee or contractorβs actions result in litigation and/or an insurance claim the employee will be responsible for all costs incurred by such processes. MTG will not provide any financial or other assistance in respect of such matters.
IT, Internet, Mobile Phones & Email Policy
Internet Use
The internet is provided by MTG for business use. Limited private use is permitted if the private use does not interfere with a personβs work and that inappropriate sites are not accessed e.g. social media, etc. βPrivate useβ does not include conducting business for other entities. Management has the ability and right to access the system at any time to check if private use is excessive or inappropriate.
Failure to comply with these instructions will be subject to appropriate investigation. In serious cases, the penalty for an offence, or repetition of an offence, may include dismissal. You need to be aware that some forms of internet conduct may lead to criminal prosecution.
Mobile Phones
We realise that Mobile Phones are part of life in this day and age. We ask that you use common sense in the workplace and limit the use of your mobile phone for personal reasons to breaks and emergencies only. This includes texting. Any excessive use of mobile phones during work hours may lead to disciplinary action.
Email Use
Email facilities are provided by Maurice Trapp Group (MTG) primarily for formal business correspondence. All email communications are backed up daily. Users must take care to maintain the confidentiality of sensitive and commercially important information.
Personal use
Limited personal use of email is permitted, provided it does not interfere with work responsibilities or performance. However, MTG management reserves the right to access and monitor incoming and outgoing email messages, as well as internet usage, at any time. This is to ensure usage is not excessive, inappropriate, or in breach of company policy.
Non-essential emails, including personal messages, should be regularly deleted from the Sent Items, Inbox, and Deleted Items folders to help prevent mailbox congestion.
All outgoing emails must include the approved MTG business disclaimer.
Prohibited use
To protect the business from the risks associated with email misuse, the following rules apply to all users:
Do not send any material by email that is defamatory, breaches copyright or confidentiality, or could damage the reputation of MTG or its relationships with staff, clients, suppliers, or any other associated parties.
Do not include content that is gossip about colleagues or that could be considered offensive, demeaning, persistently irritating, threatening, discriminatory, harassing, or bullying.
Do not send emails concerning sensitive personal matters unless authorised.
Do not access or read the email records of other individuals unless explicitly authorised by management. This access must be for legitimate purposes such as system maintenance, compliance checks, or fault resolution, and will be restricted to the minimum scope required.
Do not impersonate another person or use someone elseβs computer or email account without permission.
Do not use MTG email to conduct business activities unrelated to your role or the company.
Excessive personal use of email or social media β including mass emails, unnecessary βReply Allβ responses, or activities not related to your duties β is not permitted.
Compliance
Failure to comply with this policy is considered a performance issue. Breaches may result in disciplinary action, including verbal or written warnings. Serious or repeated offences may lead to dismissal.
Social Media Policy
These guidelines have been developed to assist you in using social media, to feel empowered to participate, whilst being mindful of your responsibilities to your social community.
Contact MTG Marketing Team (Key Staff Contacts) for approved company logos and more information on these guidelines if you are unclear on anything outlined in this document.
Accounts for Advisers
All Mortgage Lab / MTG advisers are encouraged to have social accounts such as Facebook, Twitter, and LinkedIn. They have become an essential tool to share news, and market updates and for making a personal connection with potential customers.
We recommend creating a separate business page for your profile for lead generation purposes.
Advisers must identify themselves as being from The Mortgage Lab if they are using their accounts for work in any way.
We suggest using The Mortgage Lab or a variation of it in your page name First name Surname Mortgage Lab and @firstnamesurnamemortgagelab.
Please ensure that you have verified your Facebook page.
You may not have your logo or your tagline typeset to appear like a logo.
You may have a cover photo of your choice, or choose a suitable graphic. We can provide you with a Mortgage Lab / MTG logo if you wish.
Social Media Guidelines
Identify yourself in the About section as a Mortgage Lab Adviser. Example: The Mortgage Lab are multi-award-winning mortgage specialist located nationwide. You can find out more at mortgagelab.co.nz or view my online profile: mortgagelab.co.nz/contact/.
Each social media page must have a link to the Stage 1 disclosure information: https://mortgagelab.co.nz/#important-info
Once the page has been created, you are responsible for its management. You may share sponsorships, events, news, and links to relevant market updates.
The URL will look like this: https://www.facebook.com/firstnamelastnameMortgageLab/ and @firstnamelastnameMortgageLab.
You may choose to regularly update your cover images to promote properties, events, sponsorships or suburb.
Please ensure all posts, comments, or shares are posted from the business page, not your page.
Interacting with The Mortgage Lab NZ Account
Advisers are encouraged to share and retweet material posted by the official Mortgage Lab branded account on social networking sites (e.g. @TheMortgageLab or The Mortgage Lab Facebook or Google My Business page).
Interacting with your Facebook Community
You must engage with your community regularly (at least 3 posts a week) and reply at least within 2 hours after a message was posted. Please delegate responsibilities to a trusted representative to manage your account on your behalf if you are busy.
Feel free to ask your followers for their opinions and feedback, encourage them to answer questions about their areas of interest.
A person who picked up on a mistake and provided genuine feedback to you to correct should be thanked in a personal message or tweet (try to avoid repeating the original error in the message). Example: Hi (First name), thank you for bringing this to our attention, the correction has now been made.
If someone offers a businesslike criticism of a property, service, or image but has their facts wrong, itβs good to reply, time permitting, to clarify the facts. Offer to continue the conversation in an appropriate forum either by phone, email, or private message.
Abusive, bigoted, obscene, sexist, and/or racist comments should be hidden immediately and the person should be blocked from the community. If the situation escalates, report it to management immediately.
Erroneous posts or tweets need to be corrected quickly and transparently. This applies to Mortgage Lab-related posts or tweets on personal accounts as well.
Privacy
You should be mindful that any opinions or personal information you disclose about your office/yourself/your business or colleagues may be linked to the Mortgage Labβs name and brand, even if pages are restricted to viewing only by friends.
This applies to both your professional and personal social media accounts and digital presence. We recommend customising your privacy settings on Facebook to determine what you share and with whom. However, virtually nothing is truly private on the internet.
Itβs all too easy for someone to copy material out of restricted pages and redirect it elsewhere for wider viewing. It is your responsibility to report any misuse of your information, images or personal details to Facebook authorities and the marketing team for assistance.
Please keep in mind
Any private response you make to a person could go public. Email, Facebook messages and Twitter direct messages may feel like private communications, but may easily find their way to the public domain.
In the case of an opinion or image that stirs significant controversy, management, as representative of the brand, is likely the best person to reply, rather than the person who created the content.
Any incoming message that raises the possibility of legal action should be reviewed by anMortgage Lab legal representative before a response is made. Alert the management immediately.
Posting
Mortgage Lab staff are encouraged to link to Mortgage Lab content in all formats.
Be mindful of competitive and corporate issues as you post links.
You should link to content that has been published online, rather than directly uploading or copying and pasting the material.
Exclusive Content
Only share approved company statistics provided by management.
Donβt be the first to break company news unless youβre authorised to do so.
Please keep confidential company information out of this arena.
Once any material has been published, you are welcome to post and tweet a link to it on your Social Media business pages.
You may not include political affiliations in your profile, business pages or accounts and should not make any postings that express political views.
When we are running a brand campaign, we ask that you please amplify the campaign/competition through your channels.
Please ensure the correct #hashtags are used when sharing specific campaign or competition-related content.
Opinion
Getting involved, and having an opinion and a voice will help you build an engaging and honest relationship with your community however, be aware that you represent The Mortgage Lab at all times.
Refrain from declaring your views on contentious public issues in any public forum that might be misinterpreted.
Steer away from bad-mouthing competitors, fellow Advisers, offices, the company or the industry.
Whenever possible, credit by linking to the Mortgage Labβs brand pages and feeds.
Donβt present yourself as speaking for The Mortgage Lab and be clear about what your role is with The Mortgage Lab.
Retweeting
Retweets, like tweets, should not be written in a way that looks like youβre expressing a personal opinion.
A retweet with no comment of your own can easily be seen as a sign of approval of what youβre relaying.
Measurement
Facebook Pages provide information about your pageβs performance, like demographic data about your audience and how people are responding to your posts.
You can use Pages to:
Understand how people are engaging with your page.
View metrics about your pageβs performance.
Learn which posts have the most engagement and see when your audience is on Facebook.
Social Media Links:
Private / Personal Use of Social Media
Maurice Trapp Group expects all employees, contractors and sub-contractors to uphold professional standards when using social media for any work-related purpose or when identifying themselves in connection with the business.
This policy applies to anyone who contributes to or performs duties such as:
maintaining a profile or page on any social or business networking site on behalf of Maurice Trapp Group (including LinkedIn, Facebook, Instagram, WhatsApp, Twitter or similar)
making comments on such sites as a representative of Maurice Trapp Group
writing or contributing to blogs or commenting on other blog posts on behalf of Maurice Trapp Group
posting comments on web-based forums or message boards in a business capacity for Maurice Trapp Group
No one may engage in any social media activity as a representative of Maurice Trapp Group without first obtaining written approval from management.
If an employee, contractor or sub-contractor is asked to contribute to any form of social media on behalf of Maurice Trapp Group, they must do so professionally and in a way that supports the best interests of the business.
All individuals must take care not to communicate any of the following on social media or any public platform:
confidential information relating to Maurice Trapp Group, its clients, suppliers or business partners
content that breaches privacy or publicity rights of any individual or business
any information about clients, suppliers or business partnersβwhether confidential or publicly knownβwithout their explicit authorisation
Confidential information includes any non-public information relating to Maurice Trapp Group, its clients or associated businesses in any form.
Private or personal use of social media
Maurice Trapp Group recognises that employees, contractors and sub-contractors may contribute content to websites, blogs and social or business networking platforms in their personal capacity. However, inappropriate behaviour on these sites can cause damage to the company, its reputation, and its relationships with employees, clients, suppliers or business partners.
For this reason, all staff must not publish material that identifies them as being associated with Maurice Trapp Group or its clients, partners or suppliers unless authorised.
Additionally, individuals must not post, send, forward or otherwise use any material that:
is intended to or could reasonably cause insult, offence, intimidation or embarrassment to others, including clients and business partners
is defamatory or could harm the image, reputation, financial performance or viability of Maurice Trapp Group or its associated parties
contains any confidential information about Maurice Trapp Group or its clients, suppliers or business partners
Compliance with this policy is mandatory. Any breach may result in disciplinary action. This may include formal warnings, suspension, removal of network access, or termination of employment or contractual agreements.
Use of company electronic equipment
The following are examples of unacceptable use of Maurice Trapp Groupβs electronic equipment. This list is not exhaustive:
downloading, distributing, printing or displaying content that is offensive, pornographic, discriminatory, harassing, illegal or otherwise inappropriate
sharing non-work-related material, such as jokes, chain emails, personal web links or private content
copying or using software or other materials in breach of copyright or licensing agreements
installing any software that has not been pre-approved by Maurice Trapp Group
If you become aware of any misuse of company systems or a breach of this policy, you must notify your manager.
If you are unsure whether a particular action or behaviour constitutes misuse, consult your manager for clarification.
Mental Health and Wellbeing
Mental health is best described as our state of mind, which varies over the course of our lives somewhere between good and poor.
Our mental well-being affects our ability to do our jobs, maintain healthy relationships, and cope with stress or anger.
Like physical health problems, mental health problems are very common. As Sir John Kirwan said βYouβre not alone if life is really hard for you at the moment. Anxiety and depression are really common in New Zealand. One in five of us are going to experience it this year. But it is different for everyoneβ¦β
This resource has been created to help support and encourage the discussion of Mental Health and Wellbeing for ourselves and those around us.
Useful files:
AIA Financial Advisers Wellbeing report 2023 β new-zealand-financial-advisers-wellbeing-report-2023
Back to Balance Workshop β Adviser Event February 2022 β back-to-balanace_handout.pdf
Apps for iPhone and Android
With numerous apps available for both Apple and Android phones, here are a few of the ones we like.
Calm β With the goal to help you improve your health and happiness.
Headspace β An app for people who want to learn and practice meditation
Mentemia β With Mentemia, youβll discover what things can help you feel more energised, more productive, and better equipped for whatever the world throws at you today.
Smiling Mind β An app for children, adolescents and adults who want to practice mindfulness and meditation.
Support and Resources
Alcohol Drug Helpline Alcoholdrughelp.co.nz β 0800 787 797 or text 8681 for support around alcohol and drugs, a free and confidential chat with a trained counselor, 24 hours a day, 7 days a week.
All Right? Allright.org.nz Since itβs launch in 2013, All Right? Has become a powerful champion for wellbeing in Canterbury, helping normalize conversations around wellbeing and mental health.
Citizens Advice Bureau NZ (CAB) cab.org.nz/ Help people know what their rights are and how to access services needed.
Community Law communitylaw.org.nz/ Legal problems can be serious and frightening, and for many people lawyers are completely unaffordable. But everyone has the right to high-quality legal help β thatβs where Community Law comes in.
depression.org.nz We all face challenges to our mental well-being, but there is a way through.
Engage Aotearoa engagenz.co.nz/copingkete/ The Coping Kete is home to over 160 strategies for surviving tough times safely and shifting unhelpful patterns of responding to distress.
Family Services Directory https://www.familyservices.govt.nz/directory/ A directory of Service providers that can help you and your family.
likeminds.org.nz Information around addressing stigma and discrimination associated with mental distress.
Mental Health Foundation of NZ mentalhealth.org.nz
Are you Ok? areyouok.org.nz/ Steps and support for safety for you and your whanau whenever youβre ready.
Five Ways to Wellbeing mentalhealth.org.nz/five-ways-to-wellbeing Five simple and proven actions (Connect, Give, Take Notice, Keep Learning, Be Active) to find balance, build resilience and boost mental well-being, that can help reduce the risk of developing mental health problems.
Five Ways to Wellbeing at Work Toolkit mentalhealth.org.nz/resources/resource/five-ways-to-wellbeing-at-work-toolkit β Includes fact sheets, tools, templates and team activities to introduce the Five Ways into your workplace to boost mental wellbeing and productivity.
MΔori Health Provider Directory https://www.health.govt.nz/your-health/services-and-support/health-care-services/maori-health- provider-directory
Introducing mindfulness https://mentalhealth.org.nz/resources/resource/tool-5-introducing-mindfulness
How to be more Mindful https://mentalhealth.org.nz/our-work/how-to-be-more-mindful
Open Minds mentalhealth.org.nz/workplaces/open-minds Online training materials and information to equip managers with the tools and confidence to talk about mental health.
Pink Shirt Day pinkshirtday.org.nz/ A national bullying prevention campaign to celebrate diversity and prevent bullying, with a workplace focus. Register now for updates regarding Pink Shirt Day, 10 May 2022.
The Anxiety Toolkit https://mentalhealth.org.nz/books/review/the-anxiety-toolkit-strategies-for-fine-tuning-your-mind- and-moving-past-your-stuck-points . Includes The Journal, a free online self-help tool, and includes specific advice on helping someone at work.
Ministry for Ethnic Communities ethniccommunities.govt.nz/ Provide information, advice and services to, and for, ethnic communities in New Zealand and administer funds to support community development and social cohesion.
New Zealand Defence Force health.nzdf.mil.nz/mind/building-mental-resilience/relaxation-and-breathing/
New Zealand Government Housing and Property https://www.govt.nz/browse/housing-and-property/
OUTLine Aotearoa outline.org.nz/ 0800 688 5463 (0800 OUTLINE) Confidential, free, all-ages support line, rainbow specialist counselling and trans peer group.
thelowdown.co.nz/ Straight up answers for when life sucks
sorted.org.nz A free government funded, independent agency dedicated to helping New Zealanders get ahead financially.
Te Hikuwai: Resources for Wellbeing β https://www.tepou.co.nz/initiatives/te-hikuwai
Te KΔhui MΔngai Ministry of Maori Development tkm.govt.nz/ Te Kahui Mangai is a useful tool for anyone to find out basic information about iwi, hapu and marae
Xero Assistance Program β https://www.xero.com/nz/about/social-and-environmental-impact/business-support/ If you are a user of the accounting software Xero, they offer a free and confidential well-being support through Benestar.
Talk to someone
Your GP, doctor or hauora service can help you access counselling and can talk to you about treatment options if youβre experiencing stress or anxiety.
Need to talk? Free call or text 1737 to talk to a trained counsellor, anytime.
Lifeline 0800 111 757 for counselling and support. Text βHelpβ to 4357
Depression Helpline 0800 111 757 or Text 4202.
Samaritans Aotearoa 0800 726 666 for confidential, non-judgemental & non-religious support. 24 hours a day, 365 days a year.
Training & Development
Policy
Maurice Trapp Group will give employees adequate training to do their job safely and competently. Our business believes training is a two-way process. We encourage employees to participate and to highlight any gaps in their own skills or knowledge they believe they have.
Training includes internal on-the-job training, written instructions such as standard operating procedures, coaching, and courses.
Maurice Trapp Group encourages learning and development in our employees, including regular webinars and support for additional qualifications (for example, Certificate in Financial Services Level 5 papers).
Contract Advisers are required to complete learning and development, provider accreditations, and required qualifications to give advice. They must complete 40 Continued Professional Development Points per annum.
Health, Safety and Wellbeing Policy
1. Purpose and Scope
This policy applies to all Maurice Trapp Group (MTG) staff, contractors, and visitorsβwhether at an MTG office, offsite, or working remotely from home. MTG is committed to providing and maintaining a safe and healthy workplace, free from preventable harm and risk to physical and mental wellbeing.
2. Our Commitments
MTG is committed to:
Complying with all relevant health and safety laws and standards.
Eliminating or minimising risks to health and safety, including physical and psychological hazards.
Providing adequate facilities such as first aid, toilets, drinking water, and clean workspaces.
Ensuring all staff receive necessary training, supervision, and access to information to work safely.
Involving staff in health and safety decision-making and improvements.
Monitoring workplace risks and maintaining clear incident reporting procedures.
3. Staff Responsibilities
All employees, contractors, and visitors are expected to:
Take reasonable care for their own and othersβ safety.
Follow all health and safety procedures and use protective equipment as required.
Report any hazards, incidents, near misses, injuries, or unsafe behaviours immediately.
Attend health and safety training when required.
Comply with the requirements of this policy and the policies of offsite locations.
Notify their manager if they are taking medication or have a condition that may affect their ability to work safely (medical details are not required).
4. Hazard and Risk Management
All staff and visitors are responsible for:
Identifying and reporting hazards or risks in the workplace.
Eliminating or minimising risks where possible.
Recording hazards in the Hazard Register, which will be assessed to determine whether the risk is significant.
Following the Hazard Escalation Process where a risk cannot be addressed immediately.
Ensuring resolution steps (temporary or permanent) are implemented and documented.
If a serious or unavoidable hazard is identified, MTG may suspend standard work duties and assign temporary alternatives.
5. Incident and Injury Reporting
If an injury, accident, or near miss occurs:
Seek first aid or call 111 in the case of serious injury.
Report the incident to your manager and complete an Incident/Accident Report Form.
For injuries requiring medical treatment or time off, complete an ACC Claim Form.
The incident must be recorded in the Register of Injuries, Incidents, and Near Misses.
Serious injuries must be reported to WorkSafe immediately (0800 030 040). The accident scene must not be disturbed unless cleared by a safety inspector.
6. First Aid
First Aid Kits are located at:
Auckland: Kitchen wall, far end of bench
Tauranga: Under-sink cupboard in kitchen
Hamilton: Kitchen drawers under sink
Napier: Drawer under desk
7. Specific Workplace Hazards and Prevention
7.1 Slips, Trips, and Falls
Hazards: Wet floors, loose cables, poor lighting, obstructed walkways
Prevention: Keep areas tidy, use warning signage, assist when carrying large items
7.2 Lifting and Carrying
Hazards: Heavy or awkward loads, bending or twisting
Prevention: Store items at safe heights, use safe lifting techniques, avoid repetitive tasks
7.3 Germs and Infections
Hazards: Illness spread via air, surfaces, or contact
Prevention: Wash hands regularly, disinfect shared surfaces, stay home when unwell
7.4 Working Posture and Ergonomics
Hazards: Poor desk setup, prolonged sitting or standing
Prevention: Use ergonomic furniture, maintain correct posture, take regular movement breaks
8. Drugs, Alcohol and Medication
No staff member may perform work duties under the influence of alcohol or drugs.
No person may drive a company or private vehicle for work purposes while impaired.
Prescription and non-prescription medication that may impair safe performance must be disclosed to your manager (only the effect, not the condition).
Substance abuse (including sale or possession of illegal substances at work) may result in disciplinary action. MTG may provide referral support for staff seeking help.
9. Smoke-Free Environment
MTG is a smoke-free workplace:
Smoking is permitted only during breaks and only outside buildings.
No smoking is allowed indoors or during work duties.
10. Inappropriate Behaviour
Harassment, bullying, or discrimination are prohibited and may cause psychological harm.
If you experience or witness inappropriate behaviour:
Address it directly if comfortable
Speak to your manager or a trusted senior staff member
Make a formal report
Such behaviour may lead to disciplinary action, including dismissal.
11. Our Safety Culture
Everyone at MTG has a role in creating a safe workplace.
We will:
All Team Members Will:
Report hazards, incidents, or pain/discomfort
Comply with safety procedures and training
Participate in H&S discussions and initiatives
Communicate any allergies or health conditions relevant to workplace safety
Management Will:
Engage with staff and contractors on health and safety issues
Ensure all incidents and near misses are recorded and investigated
Regularly review health and safety systems and goals
Support return-to-work plans for injured employees
Ensure safe practices for all contractors and sub-contractors
12. Workersβ Compensation
All staff may be eligible for ACC compensation for work-related injuries. MTG will support the claim process and return-to-work arrangements.
13. Emergency Contacts
In any emergency: Dial 111
Notify the Office Manager or, if unavailable, a Director immediately.
Health & Safety A & E Clinics
Closest A&E Clinics
Auckland
Auckland City A&E
2 Park Road, Grafton, Auckland
Ph. 09 367 0000
Hours β open 24 hours
Hamilton
Anglesea A&E
Gate 1 Cnr Thackeray & Anglesea Streets, Hamilton
Ph. 07 858 0800
Hours β open 24 hours
Cambridge
Cambridge Medical Ctr
Alpha Street, Cambridge
Ph: 07 827 7184
Hours β Monday to Friday β 8.30am to 5pm
Tauranga
Tauranga Hospital
829 Cameron Road Tauranga
Ph. 07 5798000
Hours β open 24 hours
Napier
City Medical 24/7
76 Wellesley Road Napier South
Ph. 06 8354999
Hours β open 24 hours
Whanganui
Whanganui Hospital
100 Heads Road, Gonville, Whanganui
Ph: 06 348 1234
Hours β open 24 hours
Christchurch
Moorhouse Med Ctr
3 Pilgrim Place Christchurch
Ph 03 365 7900
Hours 8am to 8pm
Please record any accidents or near misses to Sian in Auckland, Janeen in Tauranga, Sandra in Hamilton, Karyn in Cambridge, Tim in Napier and Sharon in Christchurch.
Equal Employment Opportunity (EEO) & Anti-Bullying
Policy
This policy applies to all staff including contractors and covers all work-related functions and activities including external training courses sponsored by Maurice Trapp Group Companies.
It also applies for all recruitment, selection and promotion decisions.
The objective of Maurice Trapp Groupβs Equal Opportunity Policy is to improve business success by:
attracting and retaining the best possible employees
providing a safe, respectful and flexible work environment
delivering our services in a safe, respectful and reasonably flexible way
Discrimination, Sexual Harassment and Bullying
Maurice Trapp Group is committed to providing a workplace free from discrimination, sexual harassment and bullying. Behaviour that constitutes discrimination, sexual harassment or bullying will not be tolerated and will lead to action being taken, which may include dismissal.
For the purposes of this policy, the following definitions apply:
Discrimination:
Direct discrimination occurs when someone is treated unfavourably because of a personal characteristic.
Indirect discrimination occurs when a rule seems neutral, but has a discriminatory impact on certain people. For example a minimum height requirement of 1.8m for a particular job might be applied equally to men and women, but would indirectly discriminate on the basis of sex, as women tend to be shorter than men.
Sexual harassment includes unwelcome conduct of a sexual nature in circumstances in which it could reasonably be expected to make a person feel offended, humiliated or intimidated or where a reasonable person, having regard to all the circumstances, would have anticipated that the person harassed would be offended, humiliated or intimidated.
Workplace bullying may include behaviour that is directed toward an employee or group of employees, that creates a risk to health (mental and physical) and safety e.g. physical and/or verbal abuse, excluding or isolating individuals; or giving impossible tasks. This also includes passive/aggressive behaviour.
Maurice Trapp Group provides equal opportunity in employment to people without discrimination based on a personal characteristic protected under equal opportunity legislation.
Under NZ legislation they include:
age
race or colour
ethnicity or national origins
sex or gender identity
sexual orientation
disability
industrial activity
religious or ethical belief
marital status
employment status
political opinion
Any employee found to have contravened this policy will be subject to disciplinary action, which may include dismissal as outlined in the complaint procedure below.
Employees must report any behaviour that constitutes sexual harassment, bullying or discrimination to their manager.
Employees will not be victimised or treated unfairly for raising an issue or making a complaint.
Investigation and Possible outcomes
If after investigation management finds the complaint is justified, management will discuss with the complainant the appropriate outcomes which may include:
disciplinary action to be taken against the perpetrator (counselling, warning or dismissal)
staff training
additional training for the perpetrator or all staff, as appropriate
counselling for the complainant
an apology (the particulars of such an apology to be agreed between all involved)
Leave
General Leave Policy
Unless specified otherwise, employees referred to in this policy mean permanent full-time or part-time salaried/ wage employees.
All employees are entitled to leave in accordance with the relevant awards or agreements and statutory provisions. Where the entitlements or practices in this document conflict, the applicable award, workplace agreement, employment contract or employment law takes precedence.
All planned leave has to be mutually agreed, and take into account workloads and the employeeβs needs. Leave must be approved in advance, except when the employee canβt anticipate the absence. Any documents regarding leave will be kept on the employeeβs personnel file.
Annual Leave Policy
Each employee is entitled to a minimum of 20 days (4 weeks) of annual leave per year (pro-rated for part-time employees), unless negotiated otherwise. Leave entitlements are calculated from the date you commenced employment and accrue in accordance with workplace relations legislation.
Minimum Time Off Requirement
To support employee wellbeing and ensure adequate rest, all employees must take a minimum of 15 days (3 weeks) of their annual leave each year as actual time off work.
Employees may request to cash out up to 5 days (1 week) of annual leave per year, provided they retain and use at least 3 weeks for time away from work.
Employees with more than 4 weeksβ annual leave entitlement (e.g. 25 days) may request to cash out up to 10 days (2 weeks) but must still take a minimum of 15 days (3 weeks) as leave.
Cashing out annual leave is only permitted where agreed by Maurice Trapp Group and in accordance with workplace relations legislation. Any request to cash out leave will be assessed on a case-by-case basis.
Annual Leave Applications
Applications for annual leave should be submitted to your direct manager and must be lodged at least 4 weeks in advance, where possible. Approval is subject to business needs.
Employees are expected to use accrued annual leave during business close-down periods. Where an employee has insufficient leave accrued, unpaid leave may be directed.
In some circumstances, leave in advance of accrual may be approved, subject to:
The employee agreeing to repayment via deduction upon termination, or
Acceptance of the time off as unpaid leave.
Personal (Sick) Leave Policy
For full time salaried employees, there is provision of ten daysβ paid sick leave a year.
Sick leave can be used when an employee is sick or injured, or when the employeeβs spouse or partner or a person who depends on the employee for care (such as a child or elderly parent) is sick or injured.
At any time when the employee does not have a sick leave entitlement, the employer and employee can agree to the employee anticipating the sick leave entitlement. In this case, any sick leave taken can be deducted from the next entitlement that arises.
In certain circumstances and at the discretion of management, additional paid sick leave may be approved.
Please notify your direct line Manager as soon as possible if you are unable to attend work due to illness or injury. The preferred method for notification is by telephone rather than text. Management, at its discretion, may request evidence such as a medical certificate showing that the employee was entitled to take personal leave during the relevant period. If the employer asks for proof after the first three days of the sick leave, the employer is responsible for any costs the employee might incur to gain this proof.
Bereavement Leave Policy
Our general policy is, employees are entitled to paid Bereavement leave. Bereavement Leave can be made available from employment inception under certain circumstances whereby a Bereavement occurs of a close family member. Bereavement leave is paid leave taken by an employee after the death of a family member.
You are entitled to a period of three days paid Bereavement leave where a family member (spouse, parent, child, brother/sister, grandparent, grandchild or spouseβs parent) has died, or if you need to spend time with a seriously ill family member. At the discretion of Management, additional paid or unpaid Bereavement Leave may be approved.
One day of paid bereavement leave on the death of any other person if the employer accepts that you have suffered bereavement as a result of death of a close associate or more distant relative.
Public Holidays
You are entitled to the Public Holidays specified in the (current) Holidays Act and its amendments.
Parental Leave Policy
Please check the latest governmental entitlements here.
Leave Without Pay
Management has the discretion to approve leave without pay that you as an employee are not otherwise entitled to.
Jury Service Policy
An employee on jury service should supply the official request to attend, the details of attendance and the amount the court will pay them. Maurice Trapp Group may consider reimbursing the employee the difference between this amount and their base salary.
Abandonment of Employment
Where you absent yourself from work for a continuous period exceeding 3 days without notifying or obtaining the consent of the Company, the Company will take all reasonable steps to ascertain why. If you cannot be contacted or no satisfactory reasons can be provided, you shall be deemed to have terminated your employment. If you are unable to notify the Company of absence because of unforeseen hospitalisation or similar cause, you shall be entitled to reinstatement without loss.
Local Purchase Policy
Why buy local?
Where possible and when economically viable, we prefer to purchase locally.
1. Buy Local β Support Yourself: Several studies have shown that when you buy from an independent, locally owned business, rather than nationally owned businesses, significantly more of your money is used to make purchases from other local businesses, service providers and farms β continuing to strengthen the economic base of the community.
2. Support community groups: Non-profit organisations receive an average 250% more support from smaller business owners than they do from large businesses.
3. Keep our community unique: Where we shop, where we eat and have fun β all of it makes our community home. Our one-of-a-kind businesses are an integral part of the distinctive character of this place. Our tourism businesses also benefit. βWhen people go on vacation they generally seek out destinations that offer them the sense of being someplace, not just anyplace.β ~ Richard Moe, President, National Historic Preservation Trust
4. Reduce environmental impact: Locally owned businesses can make more local purchases requiring less transportation and generally set up shop in town or city centres as opposed to developing on the fringe. This generally means contributing less to sprawl, congestion, habitat loss and pollution.
5. Create more good jobs: Small local businesses are the largest employer nationally and in our community, provide the most jobs to residents.
6. Get better service: Local businesses often hire people with a better understanding of the products they are selling and take more time to get to know customers.
7. Invest in community: Local businesses are owned by people who live in this community, are less likely to leave, and are more invested in the communityβs future.
8. Put your taxes to good use: Local businesses in town centres require comparatively little infrastructure investment and make more efficient use of public services as compared to nationally owned stores entering the community.
9. Buy what you want, not what someone wants you to buy: A marketplace of tens of thousands of small businesses is the best way to ensure innovation and low prices over the long-term. A multitude of small businesses, each selecting products based not on a national sales plan but on their own interests and the needs of their local customers, guarantees a much broader range of product choices.
10. Encourage local prosperity: A growing body of economic research shows that in an increasingly homogenised world, entrepreneurs and skilled workers are more likely to invest and settle in communities that preserve their one-of-a-kind businesses and distinctive character.
Performance Expectations
Policy
As a member of our Maurice Trapp Group Team, we have set detailed below the expectation we have of you as an individual, and as a team member. In addition we have provided details of what you can expect from MTG as your employer.
MTG Individual Employee Performance Expectations
Display a positive and respectful attitude.
Work with honesty and integrity.
Represent the organization in a responsible manner when dealing with Providers and Clients.
Perform your role efficiently, effectively, with time sensitivity and attention to detail front of mind.
Maintain good attendance.
Conduct yourself in a professional manner.
Follow set policies and procedures when dealing with problems or issues.
Be self-motivated and reliable.
MTG Contract Adviser Performance Expectations
Maintain appropriate qualifications for the provision of advice and complete required CPD hours.
Respond to client queries and requests in a timely manner.
Display a positive and respectful attitude.
Work with honesty and integrity.
Represent the organisation in a responsible manner when dealing with external parties.
Conduct yourself in a professional manner at all times.
Follow FAP policies and procedures, including record keeping, complaints and breaches.
Work in accordance of the Code of Professional Conduct.
MTG Team Expectations
Respect each other, and be courteous and sensitive to everyoneβs needs and concerns.
Be accountable for your work.
Be flexible about job and task assignments.
Be willing to help each other instead of displaying an βitβs not my jobβ attitude.
Ask for help when needed.
Work safely together.
Be open to constructive feedback without being defensive or negative.
Be self-motivated and reliable.
Share ideas for improvement.
Be cheerful, positive and encouraging to other team members.
In response to this MTG will provide:
Proper training, support and leadership from management.
Timely and accurate payment of wages.
Safe and healthy working environments.
Full disclosure and explanation of the job responsibilities, company policies and procedures.
Regular feedback on performance from supervisors or managers.
Access to the resources needed to perform your work tasks efficiently and properly.
Fair and consistent communication and application of policies (e.g., performance, discipline, conduct) across the team.
Credit and acknowledgement for work achievements.
Performance Management
Policy
The purpose of performance management is to improve performance. It is an ongoing process. It should include informal and formal review. We encourage a two-way process, that is, employees can also give management feedback on performance.
Performance Improvement
Policy
Where warranted Maurice Trapp Group will use improvement processes to improve performance. Should such improvement processes be unsuccessful in improving an employeeβs performance, Maurice Trapp Group may decide to end an employeeβs employment. Depending on the circumstances, performance improvement action may include verbal or written warnings, counselling or retraining.
Maurice Trapp Group requires a minimum standard of conduct and performance which will be made clear to employees in management appraisals. If an employee does not meet this standard, Maurice Trapp Group will take appropriate corrective action, such as training. Formal performance improvement procedures will generally only start when other corrective action fails.
If an employee deliberately breaches business policy or procedure, repeated fails to follow process, or engages in misconduct, Maurice Trapp Group may start improvement procedures, or, in cases of serious misconduct or breach of policy, may dismiss an employee.
Each employee must understand their responsibilities, be counselled and given the opportunity to reach the standards expected of them. Maurice Trapp Group will give an employee the opportunity to defend themselves before management takes further action.
Gross or serious misconduct policy
Summary (instant) dismissal for gross, negligent or serious misconduct is possible (depending on the facts involved). Management will seek advice before taking this step.
Whilst MTG encourages informal discussions between employees and their managers wherever possible, there may be times when it is appropriate to instigate a formal disciplinary process. This may be the case where MTG is concerned that an employee or Contractor has committed serious misconduct. Serious misconduct includes (but is not limited to):
Any act of discrimination, victimisation, bullying or harassment
Acting in conflict with MTGβs best interest
A breach of any health or safety requirement or obligation
Wilful damage or MTGβs property
Misappropriate or theft of an individualβs property
Wilful neglect in the performance of an employeeβs duties
Imprisonment or conviction by a Court of any offence, which MTG considers as potentially damaging to its reputation or image
Any failure by an employee to inform MTG of any criminal charge taken against an employee
Serious negligence or dishonesty
Incapacity at work caused by alcohol or drugs
Any breach of MTGβs Drug and Alcohol policies
Breaching any of MTGβs information system policies
Actual or attempted defrauding of MTG
Misuse of MTGβs funds and / or corporate cards
Conduct that causes risk to the health or safety of a person or the reputation, viability or profitability of MTGβs business
Refusal to carry out MTGβs reasonable and lawful instructions
Fighting or disorderly conduct
An employee engaging in conduct that constitutes direct or indirect discrimination under MTGβs policies
Any employee victimising another
An employee engaging in behaviour that constitutes sexual harassment
Any employee maliciously or falsely raising an allegation of discrimination, bullying, victimisation, harassment or sexual harassment under MTGβs policies
Any breach of MTGβs Health and Safety policies, including any failure by an employee to report stress
Unauthorised disclosure of confidential information
Falsification of reports or records or deliberate failure to accurately complete reports or records
Using abusive or discriminatory language during work hours
A breach of any term of an employeeβs employment agreement
Any breach of MTGβs Social Media policies
Viewing or distributing pornographic material or distributing offensive or illegal material
Any other action which MTG considers constitutes serious misconduct after it has considered all of the circumstances of an allegation
MTG will arrange a meeting time with the employee to discuss their concerns. Before the meeting occurs the employee will be advised of:
The nature of the meeting
His or her right to be accompanied by a support person / representative at that meeting and
The possible outcome of that meeting
The above will usually be confirmed in writing by MTG.
Grievance Complaints
Policy
Maurice Trapp Group supports the right of every employee to lodge a grievance with their manager if they believe a decision, behaviour or action affecting their employment is unfair. An employee may raise a grievance about any performance improvement action taken against them.
We aim to resolve problems and grievances promptly and as close to the source as possible. When necessary, Maurice Trapp Group will escalate a grievance to the next higher level of authority for more discussion and resolution, and continue escalating it to the level above until it is resolved.
Managers will do their utmost to action grievances objectively, discreetly and promptly. Be aware that grievances that are misconceived, vexatious, and lacking substance may result in disciplinary action being taken against the employee lodging the grievance.
Procedure
The employee should try to resolve the grievance as close to the source as possible. This can be informal and At this stage, every possible effort should be made to settle a grievance before the formal grievance process starts. If the matter still canβt be resolved, the process continues and becomes formal.
To start the formal grievance the complainants must fully describe their grievance in writing, with dates and locations wherever possible and how they have already tried to settle the grievance.
The person(s) against whom the grievance/complaint is made should be given the full details of the allegation(s) against They should have the opportunity and a reasonable time to respond before the process continues.
If the grievance still canβt be resolved, the matter will be referred to the most senior manager for consideration and a final A grievance taken to this level must be in writing from the employee.
Domestic Violence
Policy
MTG is committed to doing all we reasonably can to support staff who are victims of family violence. All requests for family violence leave or short-term safety measures at work will be considered urgently. We define family violence as physical abuse, sexual assault, emotional abuse, verbal abuse, neglect, financial abuse, restraint, stalking or image-based abuse.
Should you be experience domestic violence you will be entitled to take leave subject to allowable days. You can also take this kind of leave to support a child who has experience domestic violence, if they live with you some of the time.
Procedure
In the first instance staff who are affected by Domestic Violence are encouraged to talk confidentially with their manager or the business owner. There may be support services available for you. Your manager has been trained to ensure they provide you with sufficient support and assistance.
In New Zealand there are many support services available to you and your manager will assist you in identifying external support, if you feel you are ready. We have listed a few below for ease of reference.
If you wish to take domestic leave you must notify your manager as early as possible. In some circumstances MTG may, in good faith, ask staff to supply proof of the domestic violence. Examples of proof may include:
letter or email about whatβs going on and how it affects the employee from either a support organisation β for example, a domestic violence support service or Oranga Tamariki.
report from a school.
a declaration β a letter of evidence witnessed by an authorised person like a justice of the peace.
any court or police documents about the domestic violence.
Doctor or nurse.
Staff support
You can take at least 10 days paid domestic violence leave. This is separate from annual leave, sick leave and bereavement leave. You may ask for short-term flexible working arrangements. This can be for up to 2 months. You must not be treated adversely in the workplace because you might have experience domestic violence. This is discrimination. If any staff member experiences discrimination
within the workplace as a result of the domestic violence, they must report this to their manager. If the manager is the source of discrimination β they must report this to the CEO.
Domestic Violence Support Services
Family Violence Information Line areyouok.org.nz 0800 456 450
Womenβs Refuge womensrefuge.org.nz 0800 743 833
SHINE 2shine.org.nz 0508 744 633
Safe-to-talk 0800 044 344
Whistleblower Policy
Policy
The purpose of this Policy is to set out the processes by which suspected serious wrongdoing can be reported, within the framework of protection provided by the Protected Disclosures Act 2000 (the Act).
Reporting serious wrongdoing assists with managing risk (including health and safety risk), promotes openness and transparency and protects MTGβs reputation
MTG encourages our staff to utilise the whistle-blower process when they suspect serious wrongdoing. MTG acknowledges that whistle-blowers or staff making internal disclosures may be concerned about reprisals, discriminations, harassment or retribution in making an internal disclosure. MTG is committed to minimising those possibilities with the following:
Protection of the identity of the person making the internal disclosure.
Protection from personal disadvantage for having made the disclosure where the discloser has acted in good faith and has not engaged in misconduct or illegal activities or made a malicious disclosure.
Protection from victimisation for having made the disclosure MTG intends to investigate thoroughly any report, concern or complaint made in good faith that it receives relating to a suspected Everyone will be required to cooperate in internal investigations of misconduct or unethical behaviour.
For the purposes of making a report under this Policy, matters may include, but are not limited to, any actual or suspected:
conduct or practices which are dishonest, illegal or breach any law;
breach of any of MTGβs policies including the Companyβs Code of Conduct and Ethics;
sexual harassment;
inappropriate accounting, internal accounting controls or auditing matters;
corrupt activities;
theft, fraud or misappropriation of assets;
significant mismanagement or waste of funds or resources;
abuse of authority; or
unsafe work practice or environment.
MTG considers and will take such allegations seriously. It equally expects and assumes that allegations are made in good faith, are truthful and can be substantiated.
Procedure
When an employee suspects serious wrongdoing and is looking to make an anonymous report, they can do so by going directly to the CEO or the Compliance Manager. If it is felt that reporting to the CEO will cause ill feeling or be conflicted staff have the option to contact::
MTGβs disputes resolution provider,
Compliance partner
The FMA
All information will be kept confidential.
Conflict of Interest
Policy
Conflict of interest arises whenever the personal, professional or business interests of an employee are potentially at odds with the best interests of Maurice Trapp Group Companies.
All employees are required to act in good faith towards Maurice Trapp Group. Employees need to be aware of the potential for a conflict of interest to arise and should always act in the best interests of Maurice Trapp Group.
As individuals, employees may have private interests that from time to time conflict, or appear to conflict, with their employment with Maurice Trapp Group. Employees should aim to avoid being put in a situation where there may be a conflict between the interests of Maurice Trapp Group and their own personal or professional interests, or those of relatives or friends. Where such a conflict occurs (or is perceived to occur), the interests of Maurice Trapp Group will be balanced against the interests of the staff member and, unless exceptional circumstances exist, resolved in favour of Maurice Trapp Group.
It is impossible to define all potential areas of conflict of interest. If an employee is in doubt if a conflict exists, they should raise the matter with their manager.
Secondary Employment Policy
Secondary employment is any additional work an employee undertakes, or is planning to undertake, for another employer or work they may undertake as a self-employed person or as the partner of a self-employed person. Employees and contractors must advice Maurice Trapp Group of their secondary employment.
Maurice Trapp Group will permit employees to undertake additional work providing Management is satisfied that this does not conflict with the following:
The interests of the Organisation;
The performance of the employeeβs normal duties;
Permission to undertake secondary employment will not be refused without good reason. However, if it is deemed that the secondary employment is against the interests of Maurice Trapp Group, then agreement is likely to be refused.
Procedure
Employees must:
declare any potential, actual or perceived conflicts of interest that exist on becoming employed by Maurice Trapp Group to management
declare any potential, actual or perceived conflicts of interest that arise or are likely to arise during employment by Maurice Trapp Group to management
avoid being placed in a situation where there is potential, actual or perceived conflict of interest if at all possible
If an employee declares such an interest, Maurice Trapp Group management will review the potential areas of conflict with the employee and mutually agree on practical arrangements to resolve the situation.
Employees must disclose any other employment that might cause a conflict of interest with Maurice Trapp Group to their manager. Where there are external involvements that do not represent a conflict of interest, these must not affect performance or attendance whilst working at Maurice Trapp Group. If such involvement does affect performance or attendance it will be considered a conflict of interest.
Employees must not set up or engage in private business or undertake other employment in direct or indirect competition with Maurice Trapp Group using knowledge and/or materials gained during the course of employment with Maurice Trapp Group.
Engaging in other business interests during work hours will result in strong performance improvement action.
Failure to declare a potential, actual or perceived conflict of interest or to take remedial action agreed with Maurice Trapp Group, in a timely manner, may result in performance improvement proceedings including dismissal.
Intellectual Property & Security
All intellectual property developed by employees during their employment with Maurice Trapp Group, including discoveries or inventions made in the performance of their duties related in any way to the business of Maurice Trapp Group, will remain the property of Maurice Trapp Group.
Employees may be given access to confidential information, data, business property, keys to premises or any other business related property/information in the performance of their duties. This must be protected and used only in the interests of Maurice Trapp Group.
Employees must not:
disclose or use any part of any confidential information outside of the performance of their duties and in the interests of Maurice Trapp Group; or
authorise or be involved in the improper use or disclosure of confidential information; during or after their employment without the Employerβs written consent, other than as required by law.
βConfidential informationβ includes any information in any form relating to Maurice Trapp Group and related bodies, clients or businesses, which is not in the public domain.
Employees must act in good faith towards Maurice Trapp Group and must prevent (or if impractical, report) the unauthorised disclosure of any confidential information. Failure to comply with this policy may result in performance improvement proceedings including dismissal, and Maurice Trapp Group may also pursue monetary damages or other remedies.
Good Faith
Good faith includes the following three elements:
Parties must not act in a misleading or deceptive way.
Parties must be responsive and communicative.
Before making a decision, which may result in employees losing their job, the employer must give the affected employees sufficient information to be able to understand the proposal and then give them a proper opportunity to comment.
Good faith is also wider than this. It is more than just following the letter of the law. It involves treating others fairly using common sense. Broadly, good faith requires employers, employees and unions to:
act honestly, openly, and without hidden motives,
raise issues in a fair and timely way,
work constructively and positively together,
give each other relevant information ahead of when it is needed and as soon as possible, all information given should be carefully considered,
be fully honest with each other,
raise concerns or issues as soon as possible and respond to these quickly;
keep an open mind, listen to each other and be prepared to change opinion about a particular situation or behaviour, and
treat each other with respect.
These changes do not affect an employerβs obligations under the Official Information Act 1982 or the Privacy Act 2020.
Responsible Disposal of E-Waste Policy
It is important that e-waste is not put in with the standard rubbish.
MTG suggests that all staff and Advisers use TechCollect to remove their electronic items β https://techcollect.nz.
Note: There are many other e-waste collectors and you are free to use them. We have suggested TechCollect as they have a nationwide collection service through Office Max.
What Tech Collect take
We accept and recycle the following items:
Personal and laptop computers and all cables
Tablets, notebooks and palmtops
Computer monitors and parts (e.g. internal hard drives and CD drives)
Computer peripherals and accessories (e.g. mice, keyboards, web cameras, USBs and modems)
Printers, faxes, scanners and multi-functional devices
Cameras and video cameras
Locations
Locations for TechCollect are here.
Gift Policy
This policy applies to all staff, contractors, authorised bodies and financial advisers
MTGβs gift policy provides guidance to our team members about what is and isnβt appropriate to accept as a present, offering or token of appreciation from a client, vendor or supplier. It is important that we are seen by our clients to be ethical in the way we conduct our business and that we are avoiding the potential for a conflict of interest, no matter how well-meaning or intentioned a gift or offer of hospitality may be.
Policy
MTG must be seen to act with integrity by our clients, this is paramount and adherence to this policy is an essential part in confirming this requirement. We do not accept or solicit gifts, rewards or benefits from our clients, vendors or suppliers which might place us under an obligation to a third party.
We keep a register for all gifts received with a value of $200.00 or more.
We do not accept gift that may cause a conflict of interest, real or perceived.
Procedure
When MTG team members are presented with a gift they must notify their direct manager or the Compliance office. The following must be taken into consideration:
The possibility of reputational risk
Who is providing the gift or benefit and what is their relationship to you?
The reasons for the gift being offered
Are they seeking to influence a decision or action?
Are they seeking a favour in return for the gift or benefit?
Would accepting the gift diminish trust?
The value of the gift and the benefit to the team member
Will the gift cause a conflict of interest?
In the interest of transparency and accountability, and to demonstrate how this policy has been applied, offers of gifts, discounts or hospitality must also be formally recorded in the Gifts Register and the Compliance Office advised.
Any inappropriate gift or incentives are addressed with the person and the gift returned.
Breastfeeding Policy
Policy Brief & Purpose
Our workplace breastfeeding policy refers to our provisions for breastfeeding employees or contracted Advisers. We recognize that breastfeeding has many benefits for new mothers and their children. Our company wants to support our employees and Advisers whenever they need it. For clarity, we will refer to contracted Advisers and employees as employees hereafter.
Why do we have a workplace breastfeeding policy?
Our breastfeeding policy is part of our program for supporting mothers in completing their parental duties and bonding with their babies.
Scope
This policy applies to all new mothers in our company regardless of rank, status and position. The provision is meant to apply to employees of The Mortgage Lab working from their home premises.
Policy elements
New mothers can pump/express milk or breastfeed their babies during work time. They can take reasonable unpaid breaks whenever thereβs need. A general provision for these breaks is 15 minutes. But, employees are allowed to take as much additional time as they need.
We recommend planning a lactation room at your place of work. This room should be:
Separate from bathrooms and meeting rooms
Shielded from view by the public and coworkers
Equipped with comfortable chairs, electric plugs, a table and a sink
Cleaned and sanitized regularly
The room may also house a fridge where employees can store their milk.
Unless the law provisions differ, lactation breaks are generally unpaid. If employees would like to receive their usual compensation, they can choose to extend their working time (daily or weekly) to cover time spent in the lactation room. To do this, they have to receive approval from their supervisor and HR.
We should note that employees will be compensated as usual if they are summoned for an emergency or occupied with urgent job-related issues during their lactation breaks. However, we encourage employees to use these breaks as expected.
General rules
Employees can use this policyβs provisions for one year after their childβs birth.
Breastfeeding employees should not be disturbed with work issues when using the lactation room. They are not expected to be available on any messaging platform the company uses (Slack etc).
If employees use their paid breaks to pump/express milk, they will be compensated as usual. Employees can use their lunch breaks for this purpose too.
Employees should inform their supervisors when they want to use the lactation room to avoid confusion.
Supervisors arenβt allowed to prohibit employees from using break time for breastfeeding and pumping/expressing milk. Doing so could result in disciplinary action.
Employees should not take break time when itβs not needed or be consistently late to return. Doing so might violate our attendance policy.
Supervisors and the HR department are obliged to communicate this policy to employees.
At a time when infants are very young and breastfeeding is frequent, itβd be best for new mothers to use their maternity leave.
All employees should support new mothers. We will not tolerate comments, disturbance or victimization of our employees.
Procedure
Employees who have complaints about the process, the room or their coworkersβ behavior can use our grievance procedure to let us know. All legitimate complaints will be investigated and resolved.
Policies - Advice Related
Advice Process
OUR ADVICE PROCESS
Our 6 Step Advice process is described in detail on the Intranet.
For Risk and Investment Advisers
CONTROLS
Client File Reviews
Client file reviews completed to check the process is being followed and to identify any areas of concern or failures in this process.
Responsibility: QA Administrator
Frequency: Monthly
Training
Training provided at induction and annually on policies, processes, controls, and the process
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
Frequency: Induction and Annually
Replacement Business Policy (Risk)
π CPD Point Available For This Section π
INTRODUCTION
Replacement business represents conduct and client risks for MTG that needs to be managed effectively.
For Risk Advisers this policy must be read in conjunction with MTGβs βRisk Replacement Advice Practice Standardsβ
Potential harms for clients could include:
Clients being over/under insured.
Clients have claims denied that might have been accepted under original policies.
Clients lose benefits they might have otherwise received under original policies.
Replacing policies purchased at a younger age may result in more expensive premium or limited benefits.
Increased likelihood of exclusions or limitations associated with changes in health, lifestyle or occupation that have occurred since the original policy has been taken out.
Inadvertent non-disclosure which reduces or annuls cover.
Potential to reset any waiting periods for benefits.
Policy benefits could attract a loading on a new policy that werenβt subject to a loading on an existing policy, raising the long-term cost of the new policy.
POLICY STATEMENT
When we are actively engaged with a client in relation to replacement business, we expect advisers to actively identify areas of potential client harm and use the business processes (outlined below) to mitigate the risks.
Doing so will enable us to meet our obligations under the Code of Professional Conduct and ensure that our clientβs best interests are put ahead of our own.
We will ensure full disclosure is provided at all stages of the replacement business process;
We will ensure we consider any conflicts of interest and manage in accordance with MTGβs conflict of interest policy and practice standards;
We are aware of and adhere to FMAβs view of conduct;
We will use competence, knowledge and skill, this includes keeping good records of our advice and recording client communications, for the clientβs benefit, and providing these to the client to help them with their decision-making;
We will only proceed in replacing a product if it is in the clientβs best interest and the client is in full agreement and has been made fully aware of any risks, detrimental effects, or potential consequences.
KEY PROCESSES
We must conduct a comprehensive comparison between the original and proposed product (e.g. policy), identify features, benefits and risks related to replacing the product. The financial advice should be presented to the client in a format that the client can easily understand. In particular the risks of switching providers or cancelling a product should be highlighted.
The types of comparisons could include: benefit periods; wait periods; sums assured; premium structures; differences in covered medical conditions, existing or new exclusions and/or loadings, and any costs to change products or providers.
The financial advice must not be driven by any conflicts of interest such as incentives, bonuses or soft dollar commissions. Where a conflict arises, we have a duty to act in the best interests of the client.
REFERENCES
Code of Professional Conduct
β Part 1 of the Code of Conduct sets out the minimum standards of ethical behaviour, conduct and client care.
β Part 2 of the Code of Conduct sets out the minimum standards of competence, knowledge and skill.
431J Duty to ensure client understands nature and scope of advice
431K Duty to give priority to clientβs interests
431L Duty to exercise care, diligence, and skill
431M Duty to comply with code of conduct
CONTROLS
File Checks
How implemented: Systemised client file QA checks completed and diary notes & SOAβs checked to confirm a comprehensive comparison between the original and proposed product has been performed
Responsibility: QA Administrator
Regulatory Returns
We monitor replacement business activity bi-monthly through the SMT and report annually to the FMA the volume of insurance replacement and KiwiSaver switching activity
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
MTG Risk Replacement Advice Practice Standards
How implemented: All advisers receive training on the policy and MTGβs Risk Replacement Advice Practice Standards
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
Frequency: Annually
See related policies
Conflicts of Interest Policy
Record keeping
REFERENCES
Code of Professional Conduct
β Part 1 of the Code of Conduct sets out the minimum standards of ethical behaviour, conduct and client care.
β Part 2 of the Code of Conduct sets out the minimum standards of competence, knowledge and skill.
431J Duty to ensure client understands nature and scope of advice
431K Duty to give priority to clientβs interests
431L Duty to exercise care, diligence, and skill
431M Duty to comply with code of conduct
Replacement Business Policy (KiwiSaver)
π CPD Point Available For This Section π
INTRODUCTION
Replacement business represents conduct and client risks for MTG/Mortgage Lab that needs to be managed effectively. Every year we are required to formally report to the FMA the level of KiwiSaver switching activity that takes place across our business as part of our regulatory return.
The Financial Markets Authority (FMA) has highlighted several potential harms associated with replacing a KiwiSaver provider or product. These potential harms can impact both the investor and their long-term financial well-being.
Inappropriate Investment Choices
Switching KiwiSaver providers or products can lead to an investment that may not align with the investorβs risk profile, investment goals, or time horizon. For example, moving from a conservative to a growth fund (or vice versa) without fully understanding the implications could expose the investor to either unnecessary risk or insufficient growth potential.
Loss of Accumulated Benefits
Some KiwiSaver providers offer unique benefits, such as lower fees, insurance coverage, or financial advice, which may not be available with a new provider. Replacing a KiwiSaver product could mean losing these benefits, which may not be immediately apparent but could have a long-term impact on the investorβs savings.
Disruption of Contributions
Transferring KiwiSaver funds from one provider to another can cause temporary delays or disruptions in contributions. This could affect both employee and employer contributions, as well as government contributions, potentially impacting the investorβs savings trajectory.
Increased Fees or Unfavourable Fee Structures
The new KiwiSaver product may have different fee structures, including entry, exit, or management fees, which may be higher than those of the current product. Higher fees can erode savings over time, reducing the overall return on investment.
Impact on Fund Performance
KiwiSaver products vary significantly in terms of fund performance. Switching to a product with lower historical returns or a different investment strategy could result in lower earnings. Since past performance is not a guarantee of future results, this switch could potentially harm long-term savings.
Tax Implications
Depending on the structure of the new KiwiSaver product, there may be differences in tax treatment, which could impact the net return. Without proper understanding, an investor might end up in a product that is less tax-efficient for their situation.
Short-Term Focus on Market Timing
Some investors switch KiwiSaver products to capitalize on short-term market conditions, which can lead to poor timing decisions. Attempting to time the market by switching funds can lead to crystallizing losses or missing out on potential future gains.
Uninformed or Inadequate Advice
If the decision to switch is made based on inadequate or inappropriate advice, this could lead to suboptimal choices. For example, an investor may not fully understand the new product or may be swayed by incentives offered by the new provider rather than focusing on long-term benefits.
Potential for Conflict of Interest
There is a risk of receiving advice that may not be in the best interest of the investor if the advisor has a financial incentive for recommending a particular product. This could lead to switching to a product that is less suitable for the investorβs needs.
POLICY STATEMENT
When we are actively engaged with a client in relation to replacement business, we expect advisers to actively identify areas of potential client harm and use the business processes (outlined below) to mitigate the risks.
Doing so will enable us to meet our obligations under the Code of Professional Conduct and ensure that our clientβs best interests are put ahead of our own.
We will ensure full disclosure is provided at all stages of the replacement business process;
We will ensure we consider any conflicts of interest and manage in accordance with MTGβs conflict of interest policy and practice standards;
We are aware of and adhere to FMAβs view of conduct;
We will use competence, knowledge and skill, this includes keeping good records of our advice and recording client communications, for the clientβs benefit, and providing these to the client to help them with their decision-making;
We will only proceed in replacing a product if it is in the clientβs best interest and the client is in full agreement and has been made fully aware of any risks, detrimental effects, or potential consequences.
KEY PROCESSES
Any recommendation to switch providers must be supported by an advice document considering the clients risk profile, consideration for how the investment strategy is based on the clients risk tolerance, investment horizon (short, medium, long term) and supporting evidence for why you have recommended a switch in provider (rather than a change of fund with the existing provider). Supporting evidence for the justification of the switch of manager must be provided
REFERENCES
Code of Professional Conduct
β Part 1 of the Code of Conduct sets out the minimum standards of ethical behaviour, conduct and client care.
β Part 2 of the Code of Conduct sets out the minimum standards of competence, knowledge and skill.
431J Duty to ensure client understands nature and scope of advice
431K Duty to give priority to clientβs interests
431L Duty to exercise care, diligence, and skill
431M Duty to comply with code of conduct
CONTROLS
File Checks
How implemented: Systemised client file QA checks completed and diary notes & SOAβs checked to confirm a comprehensive comparison between the original and proposed product has been performed
Responsibility: QA Administrator
Regulatory Returns
We monitor replacement business activity bi-monthly through the SMT and report annually to the FMA the volume of insurance replacement and KiwiSaver switching activity
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
See related policies
Conflicts of Interest Policy
Record keeping
REFERENCES
Code of Professional Conduct
β Part 1 of the Code of Conduct sets out the minimum standards of ethical behaviour, conduct and client care.
β Part 2 of the Code of Conduct sets out the minimum standards of competence, knowledge and skill.
431J Duty to ensure client understands nature and scope of advice
431K Duty to give priority to clientβs interests
431L Duty to exercise care, diligence, and skill
431M Duty to comply with code of conduct
Disclosure Policy
π CPD Point Available For This Section π
INTRODUCTION
Disclosure is the act of making something known, such as any relevant risks, fees, commissions or information about an adviserβs experience and qualifications. The principle behind disclosure is to provide the essential information that our clients need to make informed decisions.
When providing regulated financial advice, financial advice provider licensees and their financial advisers must make ongoing disclosure throughout the advice process. We must provide disclosure when we give product or service information to our retail clients. If we provide a service to a client, we must disclose certain information.
The information we provide must always be presented in a clear, concise, and effective manner.
POLICY STATEMENT
Disclosure will be made as it becomes relevant to the client at certain points in the advice process. This will allow our clients to receive the information that they need when they need it. We have the flexibility to develop disclosures that fit within our processes.
There are four key stages when disclosure information must made available to the client:
Public disclosure: we will disclose general information on our website or upon request. This information is to help the public with choosing a financial advice provider that will meet their needs. The information we disclose includes information about our licence, the types of products we can advise on, the fees that may be payable and commissions or conflicts of interest that may apply.
When the nature and scope of the advice is known: our Financial Advisers will disclose information about themselves, the types of financial advice products the advice will be given about, the key product providers, any material limitations of the advice, any adverse history of the Financial Adviser, how the adviser gets paid and how any conflicts of interest will be managed. This information is disclosed to help clients decide whether to seek, obtain or act on advice from a particular
When the advice is given: this will be followed by more detailed information that relates specifically to the client when making a recommendation. This includes details of fees and any relevant commissions that will apply, specific conflicts of interest and the duties that the adviser must adhere to. This information is disclosed to help clients decide whether to act on the advice given.
When a complaint is made: when they receive a complaint, our advisers will inform clients of their ability to access redress via the relevant approved dispute resolution scheme.
This policy applies to all MTG contractors and staff involved with providing financial advice to our retail clients.
KEY DISCLOSURE PROCESSES
Licensing information
(On our website) A summary of our licensing status as a financial advice provider and a brief summary of any conditions on the licence that may limit or restrict the advice that can be given
Nature and scope of the financial advice service
(On our website) Information relating to the types of advice we give, the financial advice products that can be advised on, and whether there are any limitations (including on the product providers whose products can be advised on).
Fees or expenses
On our website: an explanation of any fees that might be charged for financial advice, including the circumstances in which they may be payable.
When nature of advice is known: information regarding any fees or expenses that may need to be paid in relation to the giving of financial advice, including the circumstances when they are payable and the amount of any fees (if known) or an estimate (if practicable).
When financial advice is given: if not previously disclosed, information regarding any fees or expenses that may need to be paid in relation to the giving of financial advice, or following the advice, including the circumstances when they are payable and, the amount of any fees (if known) or an estimate (if practicable).
Conflicts of Interest and incentives
On our website: a description of any conflicts of interests, an explanation of the circumstances in which commissions, renewal commissions or other incentives will be received and a brief explanation of how any conflicts will be managed.
Reliability history
When nature of advice is known: information regarding any recent instances of being publicly disciplined, relevant convictions or civil proceedings and, in the case of our financial advisers, any recent bankruptcies or insolvencies.
Identifying information
When nature of advice is known: information to help identify the financial advice provider, financial adviser or nominated representative.
Availability of information
On our website: we provide a statement to the effect that the client is able to request the information to be provided in a hard copy or an electronic copy.
Complaints handling and dispute resolution
On our website: information regarding the internal complaintβs procedure and external dispute resolution process.
Duties Information
On our website: a description of the duties in the FMC Act that the person is required to meet.
CONTROLS
Review client files for disclosure
How implemented:
β Advisers have completed disclosure requirements at all times.
β A systematic audit process regularly checks on prepared disclosures.
β Disclosure is built into the advice process in Trail
Responsibility: QA Administrator
Frequency: Monthly
Complaints
How implemented: Complaint handling procedures and DRS disclosed
Responsibility: QA Administrator
Frequency: Monthly
Website Review
How implemented: Website and or marketing material (if no website) to be reviewed at induction to ensure publicly available information is available and compliant as outlined in the disclosure requirements
Responsibility: Rupert Gough
Frequency: Annually
REFERENCES
FMC (Regulated Financial Advice Disclosure) Amendment Regulations 2020
New regulations setting out the requirements.
www.legislation.govt.nz/regulation/public/2020/0132/latest/ LMS177125.html
Ministry of Business, Innovation and Education (MBIE) Guidance Published June 2020
Summary of Disclosure Requirements in the New Financial Advice Regime
www.mbie.govt.nz/dmsdocument/11508-regulations-setting-out- disclosure-requirements-in-the-new-financial-advice-regime-overview
Dispute Resolution Scheme Rules
Read the rules for FSCL here: https://fscl.org.nz/publications/fscl-terms-of-reference/
The guide to handling complaints can be found here: Guide to handling complaints β advisers
Research and Product Selection Policy
π CPD Point Available For This Section π
PRODUCT SELECTION
We select and recommend to our clientβs quality, reliable and defendable product solutions.
We ensure that the clientβs needs are acknowledged and that we fully understand the type of advice that the client is looking for. We complete a Statement of Advice to evaluate the clientβs position and needs for short, medium and long term.
We prioritise our clientsβ interests ahead of our own if any potential conflicts arise we will only make a recommendation based on our research.
If our client has an existing product in place, we compare products to confirm that there would be no loss of benefits or cover by any potential change and explain why we may be recommending to confirm if there are any impacts to benefits or cover by any potential change and what the advantages and benefits are.
Refer to our Replacement Business Policy.
POLICY STATEMENT
MTG/Mortgage Lab follows a process of due diligence when selecting product providers. When considering a product provider we consider a range of factors which include:
Is the company licenced to provide financial products in NZ
Do we hold a suitable and signed distribution agreement
Advisers are required to complete accreditation training
Company reputation
Service
Claims paying
Technology
Price
Product design and how it would protect the client at time of claim e. the detail within the policy wording
Underwriting processes, rules and relationships, flexibility and adjustability
For Mortgages, we only recommend product providers that are on our Approved Product Provider Register (access via company intranet).
KEY PROCESSES
We document our rationale for selecting a product provider
We only provide advice on products and areas where we are competent to do so
We undergo continuous training to understand the products and services we provide advice
We provide enough information about the financial product being recommended to enable a client to make an informed decision.
Inability to offer approved product or service
In the event that a suitable product solution cannot be provided or we cannot offer further advice, the client will be informed in writing.
On the occasions where we do not have the necessary expertise or capacity to advise a client, we will refer them to an appropriate specialist. Whether we are able to refer a suitable specialist or not, we will give the client clear written advice that we are NOT able to advise them in the particular area, and who they should contact if they wish to receive such advice.
CONTROLS
Statement of Advice
How implemented: Advisers Statement of Advice are checked to confirm that they are selecting products only approved by MTG
Responsibility: QA Administrator
Training Register
How implemented: Training register to be checked for product accreditation
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
Product Providers
Due diligence is required to be followed and documented whenever a new provider is added to our supplier options
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
See related policies
Conflicts of Interest Policy
REFERENCES
FMA
Licensing requirement
FMC Act 2013
431K Duty to give priority to clientβs interests
Code of Professional Conduct for Financial Advice Services
Code Standard 3. GIVE FINANCIAL ADVICE THAT IS SUITABLE
A person who gives financial advice must ensure that the financial advice is suitable for the client, having regard to the nature and scope of the financial advice.
If the financial advice includes a comparison between two or more financial advice products, the financial advice should be based on an assessment of each product.
Client Servicing Policy
INTRODUCTION
We are an Advice-based business. Our approach involves a carefully designed process that fosters strong, positive relationships between our clients and our team, starting with the initial onboarding phase which sets the foundation for a long-term collaboration.
We recognise that our clients financial needs may change many times through their life journey, and servicing is an important component of a clientβs interaction with MTG. Regular contact plays a crucial part in customer satisfaction and enables us to ensure that our advice remains relevant and our clients receive the necessary information and assistance they require.
POLICY STATEMENT
We will proactively initiate contact with our clients through a diverse range of channels and methods including calls, emails, newsletters, online or face to face meetings. The frequency of a review will relate to the nature of the products they hold with us, and the clients preference.
We will endeavour to engage with the client personally at least once a year by either phone or email. Vulnerable clients will be identified and offered more frequent reviews when it is deemed necessary.
KEY PROCESSES
As part of our onboarding process, we discuss our client servicing commitment with the customer and confirm with them their preference, nature and frequency of the servicing timeframe.
To ensure comprehensive support, all clients will be systematically offered an annual review of their products with their financial adviser. This process is facilitated through an automated email, which guarantees that our clients receive at least one review per year.
In addition to the annual reviews, we also provide our clients with continuous phone and email access to a dedicated team of specialists for policy servicing and claims.
CONTROLS
File reviews
How implemented: Review of client files to ensure adequate documentation of reviews and alterations
Responsibility: Business Risk Manager
Servicing Team
How implemented: Specialist team dedicated to all servicing processes including claims for all MTG clients
Responsibility: National Relationship Manager
REFERENCES
Code of Professional Conduct for Financial Advice Services
Part1: Ethical Behaviour, Conduct and Client Care
FMCA 2013
431M β Duty to comply with the code of conduct
Client Onboarding Policy
π CPD Point Available For This Section π
INTRODUCTION
Our on boarding process is the way we introduce and welcome new clients to the MTG/Mortgage Lab way of doing business. The purpose of this Client Onboarding Policy is to outline the process by which new clients are engaged, assessed, and onboarded. This policy ensures compliance with all relevant legislation, including the Financial Markets Conduct Act 2013 and the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act 2009.
Onboarding is the way we ensure that the client gets enough information to make informed decisions about using our services, and we get enough information from them to meet our obligations.
POLICY STATEMENT
Our procedures for bringing new clients on board must ensure that they get enough information to make informed decisions about the financial services we offer.
This includes information about the business and our services, and ideally should include a discussion about our Vision and Purpose.
KEY PROCESSES
6 Step Advice Process
Our 6 Step Advice process is described in detail on the Intranet.
For Risk and Investment Advisers
Onboarding Processes to MoCRM & GetTrail
Our CRM onboarding processes are described in detail on the Intranet
Application Process
Submission of Applications
Assist the client in completing life insurance or mortgage applications, ensuring all necessary documentation is accurate and complete.
Submit the application to the chosen insurance provider or mortgage lender on behalf of the client.
Monitoring and Follow-up
Monitor the progress of the application and provide the client with regular updates.
Liaise with insurers or mortgage providers to address any additional requirements or questions.
Compliance and Record Keeping
AML/CFT Compliance
Comply with New Zealandβs AML/CFT obligations by maintaining accurate records of identification, risk assessments, and transactions.
Ensure that ongoing due diligence is performed on clients, particularly those deemed high-risk.
Privacy and Data Protection
Handle all client information in accordance with the Privacy Act 2020, ensuring confidentiality and security of personal data.
Use secure systems to store client data and restrict access to authorized personnel only.
Onboarding Completion
Set up periodic reviews (e.g., annual reviews) to ensure that the clientβs life insurance and mortgage arrangements remain aligned with their changing circumstances.
Ongoing Client Support
Offer ongoing client support by providing updates on market conditions, product changes, and opportunities for financial reviews.
Ensure that the client is informed of any regulatory or legislative changes that may impact their financial arrangements.
Complaints Handling
Clients are informed about the complaints process during onboarding. Any complaints are addressed promptly in accordance with our Complaints Handling Policy, ensuring fair and efficient resolution.
CONTROLS
6 Step Advice Process
How Implemented: All advice steps completed and docs stored in Mo/Trail
Responsibility: QA Assessor
Training
How implemented: All advisers and staff receive training on this policy
Responsibility: Head of Risk & KiwiSaver/Head of Mortgages
See related policies
Disclosure Policy
Complaints Policy
Vulnerable clients Policy
REFERENCES:
Code of Professional Conduct for Financial Advice Services
Part 1, Ethical Behaviour, Conduct and Clients Care (All code standards under part 1 apply)
FMC Act 2013
Part 2 β Fair Dealing
FMC Act 2013
431J β Duty to ensure client understands the nature and scope of advice
Adviser Training & Competency Policy
INTRODUCTION
This policy ensures the employed and contract advisers providing advice under our licence meet the competence, knowledge and skill requirements of the Code of Professional Conduct as well as describing our framework for maintaining competency and ongoing professional development.
POLICY STATEMENT
Training and upskilling are critically important for our staff/contract advisers, our clients and for the business. We aim to ensure our team are appropriately trained and have the necessary competence, knowledge and skill to perform their roles effectively and professionally. This will help both them and the business to perform well, protect our customers and to meet our regulatory and conduct obligations.
KEY PROCESSES
General Competence, Knowledge and Skill
All new and existing MTG advisers (either contract or employed) are required to hold the NZCFS (Level 5) or alternative (independently verified by NZQA) as described in the Code of Professional Conduct before providing advice to MTG clients. This includes the relevant core and specialist strands for their relevant area of advice/expertise.
Keeping Competence, Knowledge & Skill up to date.
All MTG Advisers (staff or contract) will be required to complete a Professional Development plan annually. The learning activities described in the plan should ensure that advisers maintain competence, knowledge and skill for the advice they provide: Our Professional Development approach requires advisers to attain a minimum of 40 hours relevant structured CPD every year and MTG will also β
Identify, create, and provide opportunities for professional development and training to enhance and build the capability, skills, excellence, and professionalism of staff/contractors
Set aside regular time for reviewing of regulator and product Throughout the CPD period (one year) advisers who attend 80% of our weekly sales team video conference calls for business and supplier updates will receive 20 structured CPD hours if this attendance rate is achieved.
Monitor attendance of seminars and related relevant training to gather required CPD hours
Advisers will be required to complete online modules and quizzes to test knowledge, and maintain MTG and Product Provider Accreditation requirements. Relevant CPD hours will be allocated for
We will maintain and keep current an annual professional development plan for every adviser
MENTORING PROCESS β HOME LOANS
New advisers to Mortgage Lab are mentored according to the mentoring process as outlined in Guru. This process includes details on access to knowledgebase, onboarding, knowledge testing and mentoring with Home Loans L&D manager (Brett).
CONTROLS
Teamsplus/Training register
How implemented: Teamsplus and/or training register updated after any training carried out, including number of CPD hours gained for the relevant period
Responsibility: L&D Co-Ordinator β Ongoing
PDP
How implemented: All advisers are required to complete an Annual PDP
Responsibility: L&D Co-Ordinator (before end February annually for calendar year)
REFERENCES:
Code of Professional Conduct
Part 2: Competence, Knowledge and Skill (Code standards for part 2 apply)
FMC Act 2013
431L β Duty to exercise care, diligence, and skill
431I β Duty to meet standards of competence, knowledge, and skill
ADDITIONAL INFO:
Where do you start?
You should set your plan each calendar year by identifying any gaps in your knowledge that you should consider enhancing.
Ensure that you allow sufficient time each week to participate in regular learning opportunities, such as our KAN webinars (mortgage advisers), conferences, etc.
Over the course of the year you should complete relevant training to upskill yourself and your team with specific knowledge that is relevant to the area of financial advice that you provide (mortgages, insurance, investments).
Product knowledge also forms part of this requirement so keep reading the updates from your providers.
What areas of competency should you aim for?
Mortgage (structures/ownership/tax implications)
Insurance (personal risk/business risk/general risk/tax implications)
Investment (portfolio construction/risk profiling clients/structures)
KiwiSaver (for deposit first home/retirement planning)
CRM
Regulations and legislation
FMCA/FSLAA new obligations for Financial Advice Providers
The Code of Professional Conduct for Financial Advice Services
Disclosure requirements
Privacy Officer training (Privacy Act 2020)
AML/CFT β customer due diligence
CCCFA 2003
Professional Ethics
Compliance officer training
The Advice Process
Personal Development (software/Xero/planning/Leadership)
Business Development (strategic planning for growth/succession planning)
Estate planning basics
Taxation basics
Directors responsibilities
Governance
Complaints handling training
Record keeping
Business continuity planning
Health and safety
Good Conduct
Desired outcomes
You meet your obligations for the Code regarding competence, knowledge and skill and have a recorded log of your training in your register to evidence what you have completed.
You can demonstrate up-to-date knowledge relevant to your area of advice if challenged about your advice by a client or a third party (FMA, Disputes Scheme Provider, KAN).
You learn something helpful and grow your knowledge and skills.
You spend time working on your business strategy and achieve great results.
How else can you meet the requirements?
Complete a NZ Certificate in Financial Services (Level 5) Version 2 course.
Hold the relevant specialist strand for the advice you provide (e.g. RPL, LD&H, Investment).
Undertake specific training on the new regulatory requirements by attending webinars and training courses.
Keep up to date with your product providers requirements and policies.
Be across any changes as they occur in the industry by subscribing to communications from FMA and other industry or Government bodies (Financial Advice New Zealand, Commissioner for Privacy, MBIE).
Privacy Policy
π CPD Point Available For This Section π
1. Introduction
When a client uses our services, they are trusting us with their personal and financial information. We understand that this is a significant responsibility, and we work diligently to protect their information in accordance with the Privacy Act 2020 (the βActβ).
This policy outlines how we collect, use, store, and disclose personal information relating to clients, staff, contractors, and third parties. It also provides operational guidance to staff for handling privacy-related issues in day-to-day work.
2. Scope
This policy applies to:
Personal information about clients, prospective clients, and claimants
Personal information about staff, job applicants, and contractors
Any situation where personal information is collected, stored, accessed, or disclosed by Maurice Trapp Group or its subsidiaries
3. Our Commitment
We are committed to:
Handling personal information lawfully, fairly, and transparently
Complying with the 13 Privacy Principles under the Act
Ensuring all staff are trained and aware of privacy obligations
Responding promptly to privacy breaches and complaints
Assessing third-party providers (including overseas vendors) for privacy compliance
4. Collecting Personal Information
We collect personal information through:
Direct contact with clients, including online forms, email, telephone, or in person
Authorised third parties, such as insurers, lenders, employers, and medical providers
Publicly available sources
We only collect information necessary to carry out our business functions and provide services lawfully.
5. Employee and Contractor Privacy
We also collect and manage personal information about staff and contractors. This may include contact details, employment history, payroll and tax records, performance data, training history, and compliance requirements.
All staff information is treated with the same level of care and security as client data and is only accessible to authorised staff with a genuine business need.
6. Using and Disclosing Personal Information
We may use or disclose personal information for the following purposes:
To provide advice, arrange insurance or lending, and manage claims or applications
To verify identity and prevent fraud
To meet legal, regulatory, or licensing requirements (e.g. FMA, DIA)
For internal training, compliance, and auditing
With service providers, such as IT vendors, cloud storage, legal advisers, and compliance consultants
With co-insureds or co-applicants named on the same product
We will not use or disclose personal information for any other purpose unless:
The individual has consented
It is required or authorised by law
It is necessary to prevent or lessen a serious threat to life or health
It is being shared in a de-identified or aggregated format
7. Overseas Disclosure and Cloud Services
If we engage an overseas-based service provider (e.g. cloud storage), we must first assess whether they offer comparable privacy safeguards to New Zealand law. This includes:
Reviewing contractual terms
Checking data encryption and access controls
Ensuring data is only stored or accessed in permitted jurisdictions
We will not proceed with vendors who cannot meet these standards.
8. Security and Retention
We take reasonable steps to ensure personal information is:
Protected from unauthorised access, loss, misuse, or disclosure
Accessed only by staff with legitimate business reasons
Backed up and recoverable in case of data loss
Securely disposed of when no longer required
Client records are generally retained for at least seven years, in line with legal obligations.
9. Access and Correction Requests
Clients and staff have the right to request access to their personal information and to request corrections if the information is inaccurate. These requests must be:
Acknowledged promptly
Verified (identity confirmed)
Actioned within a reasonable timeframe
If we decline a correction request, we must allow the individual to add a statement of correction to the record.
10. Privacy Principles (Summary)
We comply with the 13 principles of the Privacy Act 2020:
1 Purpose β Collect only whatβs necessary for a lawful, business-related purpose
2 Source β Collect directly from the person where possible
3 Transparency β Inform individuals about why and how we collect their information
4 Manner β Do not collect information unfairly or intrusively
5 Storage β Keep personal information secure
6 Access β People can request to see and correct their personal information
7 Accuracy β Ensure information is correct before using it
8 Retention β Donβt keep personal information longer than needed
9 Use β Use only for the purpose it was collected
10 Disclosure β Disclose only when legally justified or with consent
11 Overseas Disclosure β Ensure offshore providers meet NZ privacy standards
12 Unique Identifiers β Avoid using othersβ unique identifiers unless permitted
13 Information Sharing β Manage information sharing lawfully and carefully
11. Privacy Breaches
A privacy breach occurs when there is unauthorised access, disclosure, loss, or misuse of personal information. Serious breaches must be reported to the Office of the Privacy Commissioner and affected individuals.
Breach Process:
Contain β Stop the breach and prevent further risk
Assess β Understand the scope and risk
Notify β Inform the Privacy Officer, MD, and Commissioner (if serious)
Prevent β Implement corrective actions to avoid recurrence
All breaches and near misses must be recorded in the Breach Register.
12. Key Controls and Responsibilities
ControlImplementationResponsibleClient record security checksRegular audits of file storage and access controlsHead of OperationsStaff training on the Privacy ActAnnual training via MoProHead of Ops / Head of Insurance & KiwiSaver / Head of MortgagesBreach RegisterAll incidents logged and reviewed regularlyHead of OperationsPrivacy statementsIncluded in all client documents and reviewed regularlyHead of Operations
13. Safe Work Practices (Reminders)
Double-check email recipients before sending client files
Confirm identity on all inbound calls before disclosing details
Lock devices when unattended, especially in public spaces
Do not discuss client information in shared environments (cafes, public transport)
Use MFA and strong passwords for systems access
14. Privacy Officer and Escalation
The designated Privacy Officer is responsible for overseeing privacy compliance, breach response, and managing complaints or requests. Breaches should be escalated first to the Privacy Officer, and where serious, to the MD and Privacy Commissioner.
Related Policies
IT Systems and Security Policy
REFERENCES
Privacy Act 2020
www.legislation.govt.nz/act/public/2020/0031/latest/LMS23223.html
Office of the Privacy Commissioner
www.privacy.org.nz
Code of Professional Conduct β Standard 5
Protect Client Information
Code of Conduct & Ethics Policy
Our purpose at Maurice Trapp Group is to help our clients have βA Certain Futureβ. What this means to individuals will differ, dependent on their ages, their income, their expectations, their health and other circumstances. However, what should never differ is the way that we, as members of MTG, conduct ourselves on all occasions, with integrity in an open honest and fair way. By holding to our values of Care, Share and Dare, we achieve that ambition of our purpose, and allows us to be proud to work with the team of MTG.
This Code of Ethics has been authorised by the MTG Board and sets out the standards that we set ourselves and expect from all who come to work in our environment. We know that by living to these behaviours, we will build trust and create a business that is fun and rewarding to work in. The outcome of maintaining these standards is knowing that we are doing the right thing by our customers, our suppliers, our shareholders and other stakeholders.
Two adages that are relevant to our Code of Ethics, and that I hope will resonate with you, are:
βHow would I like to be treated, if I was in this situation?β
βIf it is to be, then itβs up to me!β
Please read this Code of Ethics and refer to it frequently. Every one of us at MTG is responsible for safeguarding these standards. Together, as a team with a strong and positive culture, we can make a difference to New Zealand.
- Maurice Trapp Chairman, June 2023
INTRODUCTION
This Code provides us with a framework for working within the Maurice Trapp Group and its related businesses; by being consistent with our values, principles and culture. It provides a guideline on decision-making and handling areas of risk. It does not provide a complete list of potential incidents or risks, because we rely on every MTG team member to employ their own good judgement in considering what the right thing to do is.
All at MTG, including contractors, employees and directors, are expected to uphold and follow this Code, as well as other MTG policies and guidelines.
If you are unsure about anything or have concerns, please speak with your immediate leader or to senior management. It is important that we expect the same standards of behaviour from each other and, that we hold each other accountable for following and upholding this code. This should not be onerous, but rather, an expectation that this is how I would like to be treated.
THE RIGHT WAY
At MTG, we require each other to act professionally, ethically and responsibly, at all times. We respect the needs and requirements of others, and aim to provide a customer outcome that exceeds their expectation.
Our roles and duties at MTG include:
Applying MTGβs Values and Behaviours
Valuing diversity and inclusion, and treating all people with dignity and respect
Considering the environment impacts of our decisions and minimising, when we are able, MTGβs environmental impact
Operating efficiently, communicating effectively and applying robust risk management practices
Maintaining the highest standards of service and delivery of quality products that achieve appropriate results for our clients
Conducting ourselves in a way that demonstrates our honesty and integrity on all occasions
Always acting in the best interests of MTG, while taking into account its shareholders and other stakeholders
Valuing individualsβ differences of opinion and treating all people with respect
Dealing fairly and honestly with all people and organisations
Helping someone develop skills and learnings
Not entering into transactions or making promises on MTGβs behalf that MTG is not able to or does not intend to honour
Not using MTGβs property, (including MTGβs name), information or position for personal
Not taking any opportunity discovered through the use of MTG property, information or position for our own personal advantage.
OUR VALUES
| Care | |
|---|---|
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For our clients: Exceed customer expectations For each other: Work as a team and treat each other with respect and courtesy For the business: Participate and contribute For ourselves and our families: By recognising when step back, slow down and seek advice or help |
|
| Share | |
| Our Knowledge and Experience | Our Integrity |
| Our Attitudes: Lead by example | Our Reliability: Pursue excellence |
| Our Respect: Listen and communicate | Our Wins |
| Our Trust | |
| Dare | |
| To Lead | To be Courageous |
| To Challenge | To back Ourselves and Each other β Have fun |
| To Question | |
The MTG Board signs off every year on a Board Charter and Principles. Ultimately, the directors are the leaders of the Company, but we have always had the intent that we would encourage and build leadership throughout our whole team.
Within that Board Charter document, we state the following:
βWe ask all our stakeholders to comprehend and acknowledge our values of Care, Share and Dare.β
Care is epitomised by succession, (for families and businesses, for health and wealth), and through taking the long-term view.
Our founding shareholders have been willing to relinquish short-term gain, to achieve enduring returns and business growth. We built the business so that all our stakeholders have a better world to live in; for themselves today and future generations.
Sharing is an understanding that all our actions and accomplishments are integrated and inter- connected. We aim to achieve win-win situations with all our transactions.
Our ideal is for all our stakeholders to hold an ownership mentality with MTG. Within the business we take responsibility to create an inclusive and better future for all stakeholders. The catch phrase, βIf it is to be, itβs up to meβ is shared with our team throughout the business.
And Dare is about building resourceful resilience. In this rapidly changing world, (think Covid, recession and advancements in technology), our Purpose doesnβt alter. Providing a Certain Future for our clients, our team, our shareholders and all other stakeholders, is a much higher goal than simply maximising shareholder value.
OUR BEHAVIOURS
Inspire
Letβs inspire our customers by performing inspirational acts for them. Letβs also be inspired by them; look for the wonderful things that theyβve achieved. Remember that they are the reason that we are in business. If ever in doubt, ask yourself β βis this the right thing to do for our customer?β
Have Pride
Be proud of being part of the MTG Team. This is our business; it generates all of our livelihoods. Take the time to understand the various parts of the Company and what your fellow team members do. Advocate for the Company and remember to tell empowering stories.
Be Responsible
We are all part of the MTG Team, so treating each other respectfully and with care and concern will make MTG a great work-place. Good business will always be about relationships and building trust.
Be Safe
Take all reasonable precautions while at work, at home and to and from; to ensure your own safety, and the safety of your colleagues, friends and the public. If there is a single lesson to take from Covid-19, itβs not to take anyone, (or anything), for granted.
DECISION MAKING
When we ask our clients to make decisions that involve commitments to external parties, for example, signing personal statements, paying premiums, making claims; itβs imperative to follow the FMA guidelines around advice.
Only provide advice in areas of your own expertise and qualification
Seek advice if uncertain
Be open, honest and transparent with all clients and all stakeholders
Hold ourselves accountable for assessing best practice and providing our
Demonstrate care, diligence and skill
MAKING THE RIGHT CALL
Often, we need to make choices on matters that rely on exercising good judgement, for example, choosing which provider to place a particular client with, the level of cover required, what cover the client may miss out on due to premium restrictions.
As we make these daily decisions, itβs appropriate to ask ourselves:
Is this legal?
Is it the right thing to do?
Is it consistent with this Code, and MTGβs values?
Does it make me feel uneasy?
How would I feel if my peers or other MTG people are aware of what Iβm Would I feel comfortable reading about it if it was published on-line? Could it harm me, my colleagues or customers or others, directly or indirectly?
Would I be comfortable explaining what Iβm doing to members of my family?
Could I be compromising my objectivity and/or my integrity?
PLAYING THE FAIR AND ACTING THE MTG WAY
Part of our role within Financial Services is around education for our clients. Insurance especially, has its own βlanguageβ, and we and insurance companies use terminology that is not common to the general public. We use words and phrases like βindemnityβ, βacceleratedβ, βagreed valueβ, βbuy-backβ, βtpdβ, own occupationβ,
etc. which are typically meaningless to our clients. Playing fair involves us with making sure that our clients understand these terminologies, and we remind them on the occasions that we do reviews.
The MTG way encompasses education and a method of presenting to and meeting with our clients. While we may have our own agenda for a particular meeting, we offer our client the opportunity to provide his/her agenda. The client comes first. Be sure to ask them what issues they might have, and wish to talk about.
If they donβt include what we wanted to raise, then we simply ask if we can add it to their agenda. When we ask permission to do things, we differentiate ourselves and develop a trusting relationship.
When we meet with clients for the first time, there will naturally be a focus on the present. We review their existing covers, their situation and their needs; and we make recommendations accordingly. But strategically, we need to be thinking long term. What will their situation be in twenty yearsβ time? Have we built a strategy that will allow our clients to be rid of unnecessary insurance costs, because now they have assets and have de-risked their situation? If we can help our clients in the short term and the long term, we are truly playing fair.
Our industry receives condemning publicity when βchurningβ is brought to the publicβs attention. And rightly so. There will always be exemplary arguments and reasoning why an existing insurance portfolio is
inadequate, out of date or second best. However, the MTG way is not to make a practice or habit of changing an existing portfolio, but rather to consider how it might be tailored. Changing a clientβs policies to another company, is not in itself churning, but doing so with little or no regard for the clientβs best interests, certainly is.
All our insurance companies here in New Zealand support us in many ways, and they all provide excellent products that pay out many millions of dollars of claims each year. One of the best ways that we can demonstrate our support back to them is to avoid any semblance of churning their business.
Competition is a matter of fact. There will be many occasions when we meet competition and we lose out. There will hopefully be just as many times when we face competition and we win. Learn to live with and embrace competition, so that it brings out the best of you.
|
There are some common-sense rules around dealing with competition, and if we abide by them, we will be putting the clientβs best interests first. These rules demonstrate the MTG way. |
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What we add as our own βextrasβ
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BRIBES, KICKBACKS, GIFTS, HOSPITALITY
While chocolates and wine are usually acceptable and a great way to say thank you to underwriters, clients, claims managers and others who have given great service or help, donβt be extreme.
Bribery and kickbacks imply offering money or other valued benefit in order to influence a result. MTG does not permit bribery, corruption or kickbacks of any form. They are considered unethical and are strictly forbidden.
Giving and receiving gifts, like chocolates or a bottle of wine, can be normal business practice. However, this can also create a grey area where it could be seen as influencing a decision.
At MTG, we are all expected to abide by the MTG Gift Policy. We donβt accept gifts or personal benefits where this could, (or could be seen to), compromise or influence a decision that you make with a client or provider.
Similarly, we donβt give gifts or personal benefits if it might be considered that this could influence or compromise a decision by a client, supplier or other stakeholder.
CONFIDENTIALITY
Confidentiality of information relating to our clients and our business is extremely important. We commit to protecting the confidentiality of all non-public information concerning MTG. Confidential information must not be divulged except where authorised by the Directors or Senior Management of the business or as required by any law or regulation.
Confidential information includes non-public information (news or information that has not been made public) about the business, and our past, present and potential clients and product holders.
CONTROLS
Board signs off on Board Charter and Principles
How implemented: Board to review and agree Charter and Principles at first board meeting for financial year.
Frequency: Annually
Staff/adviser contractor written acknowledgement of receipt and understanding of Code.
How implemented: Each member of Staff and all contract advisers will be provided with a copy of the MTG Code of Conduct and must affirm in writing (which may be by electronic means) that they have received, read, and understood the Code of Conduct.
Frequency: Annually. Attestation fulfilled via email or LMS (TeamsPlus)
See related policies
Whistle Blower Policy
Health & Safety
Conflicts of Interest
REFERENCES
Employment New Zealand
https://www.employment.govt.nz
Code of Professional Conduct for Financial Advice Services
Part 1: Ethical Behaviour, Conduct and Clients Care
Part 2: competence, knowledge and skill.
(All code standards under Part 1 and 2 apply)
Financial Markets Conduct Act
431M: Duty to comply with code of conduct
FMCA 2013
431Z: Application of conduct obligations
Complaints Policy
π CPD Point Available For This Section π
POLICY BRIEF AND PURPOSE
.Policy Intention:
Maurice Trapp Groupβs Complaints Policy aims to address the issue of client dissatisfaction, and provide a framework with which Maurice Trapp Group team members can connect with clients and respond to any issues or concerns that have arisen, creating resolutions that clients are satisfied with and consequently stronger client relationships.
Client complaints can help us identify areas in the business where repetitive behaviour within our team or with our processes and procedures is having negative consequence thereby opening up opportunities for us to make necessary changes to that behaviour, provide further training, or update our product delivery or procedures.
Who this policy applies to:
This complaints policy applies to all representatives of Maurice Trapp Group Ltd and associated Authorised Representatives. This includes employed staff and contractors in all areas of the business.
Why do we have a complaints policy?
Complaints are feedback on our process or conduct and creates the opportunity to improve, as well as strengthen the connection we have with the client as we work through to a resolution that is satisfactory to them. Maurice Trapp Groupβs vision statement is for high quality client outcomes and robust support and advice. Client complaints can identify areas where Maurice Trapp Group Limited can improve and are an important facet of the business.
WHAT IS A CLIENT COMPLAINT
A complaint is an expression of dissatisfaction communicated by:
A customer who has received financial advice from us;
About a product, advice or service that they obtained through us; and
There is a request to remedy the situation
Complaints can come in many forms β particularly:
advice processes
a team member
administration processes and procedures
products and provider services
client and policy servicing
actions taken (or not taken) by our staff
claims and underwriting outcomes
communication
These can occur as either a verbal, (in person or by phone) or written format (letter, email, or through our website). No matter what format a complaint is received, it is to be treated with the same level of care. All team members have a critical role to play in providing positive outcomes for our clients. They are to be actioned in a timely manner with thorough investigation and due respect for the complainant.
Complaints can come from:
Current and former clients
Parties associated with client policies
Prospective clients contacted by telemarketers contracted to Maurice Trapp Group Ltd
COMPLAINTS POLICY STATEMENT
Maurice Trapp Group Limited recognises good customer care is fundamental to the success of our business. We aim to provide clients, partners and suppliers (our stakeholders) with excellent customer service. We will listen to the needs of our stakeholders and respond to complaints seriously, and with sensitivity, allowing redress where appropriate.
All complaints will be entered into our Complaints Registers (for Home Loans the register is in Trail) so that we can monitor emerging trends and issues. All Maurice Trapp Group advisers and staff are to keep thorough written records in the relevant Client File of all information relating to a complaint. These are to be documented chronologically.
Maurice Trapp Groupβs Complaint Process
Complaints may be received at any level of the business and the MTG Team have a critical role to play in the proper functioning of our complaints handling procedure. Complaints received in writing are to be referred to either the Business Risk Manager (BRM) or National Relationship Manager as soon as practicable.
The complaint should be acknowledged within twenty-four (24) hours and recorded in the Complaints Register. In the event of receiving a verbal complaint, where the complaint is easily remedied, attempts should be made to reach agreement as to the steps that will be taken to remedy the complaint. All information is to be recorded on our Complaint Registration Summary Form (for home loans the register is in Trail CRM) and then provided to the BRM and/or NRM without delay.
The BRM and NRM both have critical roles to play in the proper functioning of the Complaints Handling Procedure as all complaints that cannot be resolved by advisors and/or administration team, will be escalated to investigate, monitor, resolve and close.
The BRM will report on open complaints, DRS status and complaint trends to the Senior Management Team bi-monthly.
STEP 1: ACKNOWLEDGE
Acknowledge receipt of the complaint within 24 hours of receipt and inform your client of next steps ensuring realistic timeframes are communicated to them. Let them know who you are and provide them with relevant information on how to contact you (phone / email).
If you receive a verbal complaint, ascertain whether it can be resolved immediately.
Ensure you clearly understand the clientβs expected resolution, and if it is not clear, request further information. For matters that are not straightforward, the BRM will send the following for the client to complete and return to us.
Explain to them that we have a Complaints Handling Process, that we belong to a Disputes Resolution Scheme and how the process works (see 1 to 5 above).
Once the above document is received or once we have all the information we need, the following Acknowledgement Letter should be sent to the client. The text of this letter can also be sent by email.
If the complaint is about you, refer it to your direct manager.
STEP 2: INVESTIGATE / RESOLVE
We aim to resolve the complaint in a timely fashion (between 1 and 5 business days depending on complexities). We should remain open-minded and consider as many options as possible to reach a resolution. Record all correspondence, file notes, investigations, recommendations, decisions, reasons and actions taken.
Once we have completed our investigation and have come to a resolution that we believe the client will find satisfactory, provide an explanation to the client on how this issue occurred and what has been done to rectify the situation. Include updates on review to policies and procedures, training. Our explanation must be clear and must avoid industry jargon. Explain what will happen next.
If the client is not satisfied with our initial explanation investigate further, involve Management (if we havenβt already done so) and together, formulate an alternative resolution and complete the following template and send to the client.
STEP 3: ESCALATION
If the client still does not accept our explanation and resolution, refer them to our dispute resolution scheme β Financial Services Complaints Limited and the timeframe within which this needs to be done (2 months from the date of this Escalation interaction with the client).
This will be provided in letter format to the client.
FSCL will gather relevant information from both parties and investigate accordingly. On conclusion of their investigation they will recommend a settlement. If the client does not accept the decision FSCL makes, then FSCL will impose a final decision which is binding if accepted. If this too is not accepted by the client, the next step is for the client to resolve through a disputes tribunal of the Courts.
KEEP RECORDS
Once FSCL has completed their investigation and a satisfactory resolution has been reached, the file can be closed. We must ensure ALL information that relates to this complaint is recorded chronologically for future reference.
It is imperative that client confidentiality obligations be fulfilled, we will need the complainantsβ written permission before disclosing information to a party outside of Maurice Trapp Group Limited or Authorised Representatives.
It is recommended to exercise caution and refrain from accepting liability if you are unsure about the circumstances.
ESCALATION
The Code of Rights outlines the rights of people using a health or disability service in New Zealand. The Code calls these people βconsumersβ. The Code also sets out the duties of people and organisations providing health and disability services. These people are called βProvidersβ.
The Code of Rights applies to both public and private facilities and to both paid and unpaid services. It stipulates that consumers be given:
The right to be treated with respect
The right to freedom from discrimination, coercion, harassment and exploitation
The right to dignity and independence
The right to services of an appropriate standard
The right to effective communication
The right to be fully informed
The right to make an informed choice and give informed consent
The right to support
Rights in respect to research
The right to
The client must use Maurice Trapp Group Limitedβs internal complaints process first as many problems are of a minor nature that can be easily solved. Maurice Trapp Group Limited have a maximum timeline of 3 months to fully resolve a client complaint. Timely action in regards to complaints further demonstrates to the client that their business is important to us.
ADVISER RESPONSIBILITY
Confidentiality of information relating to our clients and our business is extremely important. We commit to protecting the confidentiality of all non-public information concerning MTG. Confidential information must not be divulged except where authorised by the Directors or Senior Management of the business or as required by any law or regulation.
Confidential information includes non-public information (news or information that has not been made public) about the business, and our past, present and potential clients and product holders.
BUSINESS RISK MANAGER RESPONSIBILITY
The role of the Business Risk Manager is to ensure that we (as a wider Company) are conducting our business in full compliance with all national laws and regulations that pertain to our industry as well as professional standards, accepted business practices and internal standards. There is both an ethical
component and a pragmatic component to compliance β a role that is crucial in helping us manage risk, maintain a positive reputation and avoid litigation.
The complaint will be acknowledged to the client within 24 hours of receipt and recorded in the Complaints Register.
Within 5 working days the client must be advised of the decision being made or an interim response advising that investigations are underway.
The Complaints Register must be updated at each stage therefore it is integral that clear lines of communications are in effect during this process in order that communications are captured correctly.
In the letter to the client advising of the decision being made, reference must also be made to the complainantβs right to have the matter reviewed by our Disputes Resolution scheme. The Business Risk Manager will consider whether a notification is required to the FMA and advise the COO & MD accordingly. If not resolved the Business Risk Manager will adopt the escalation process.
FINANCIAL DISPUTES RESOLUTION SERVICE
Maurice Trapp Group and Authorised Representatives have appointed Financial Services Complaints Limited as our independent disputes resolution scheme.
Post: Financial Services Complaints Ltd P O Box 5967 Wellington 6011
Freephone: 0800 347 257
Phone: 04 472 3725
Email: complaints@fscl.org.nz
Any complaint unresolved through our internal complaint handling process will be referred to FSCL.
CONTROLS
| Control | Control management | Responsibility | Check frequency |
|---|---|---|---|
| Adviser and Administration training | All staff are provided with training on how to manage complaints. This is at time of induction and an annual refresher. | L&D Co-ordinator | Annually |
| Complaint Register | Receipt of complaint to be recorded in Complaints Registers by BRM & NRM. Both manage the registers at each step in the process until the complaint is resolved. | Business Risk Manager & Nat Relationship Manager | Ongoing |
| Complaint Analysis | The Complaint Registers should be analysed to identify any potential trends or systemic issues and to identify control weaknesses that require remediation. | Business Risk Manager | Bi-Monthly |
| Complaint Reporting | Complaint Registers are reviewed bi-monthly and a report provided to the RCC. | Business Risk Manager | Bi-Monthly |
Record Keeping Policy
π CPD Point Available For This Section π
Purpose
This Record Keeping Policy outlines the standards and procedures for maintaining accurate, reliable, and secure records of all business activities, particularly those related to financial advice provided to clients. The policy ensures compliance with applicable laws and regulations, including the Financial Markets Conduct Act 2013 (FMC Act), the Financial Services Legislation Amendment Act 2019 (FSLAA), and the Financial Markets Authority (FMA) guidance for financial advice providers in New Zealand.
Scope
This policy applies to all employees, contractors, and representatives of MTG/Mortgage Lab who are involved in the provision of financial advice, support, or related services. It covers all client records, financial documentation, and other business-related information generated or received during the course of business.
Legal and Regulatory Framework
The policy is governed by the following legal and regulatory frameworks:
Financial Markets Conduct Act 2013 (FMC Act)
Financial Services Legislation Amendment Act 2019 (FSLAA)
Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act)
Privacy Act 2020
Financial Advice Code of Professional Conduct
Financial Markets Authority (FMA) Guidelines
Principles of Record Keeping
MTG/Mortgage Lab will adhere to the following key principles in maintaining records:
Accuracy: Records will be accurate, complete, and up-to-date.
Retention: Records will be retained for a period of at least 7 years from the later of:
the date the record is made; or
the date the financial advice to which the record relates is given; or
the date any later record is made that refers to or relies upon information in the record; or
the date of the conclusion of the life of the financial advice product that the financial advice relates
Security: Records will be protected from unauthorized access, loss, damage, or alteration.
Accessibility: Records will be accessible to authorized personnel, clients (as appropriate), and regulators upon request.
Confidentiality: Records will be treated with strict confidentiality, in line with privacy laws and best practices.
Types of Records to be Kept
The following records must be maintained:
Client Records: Includes personal details, financial circumstances, needs analysis, risk tolerance, and any other information used to provide advice.
Advice Documents: Includes all advice provided, Statements of Advice (SOA), fact finds, product recommendations, and any documentation related to financial advice.
Correspondence: Includes emails, meeting notes, phone call logs, and any communication between the financial adviser and the client.
Transactional Records: Includes all financial transactions related to the advice provided, fees, commissions, and any product-specific records.
Compliance and Risk Management Records: Includes AML/CFT documentation, conflict of interest disclosures, complaints, and other compliance-related documents.
Storage of Records
Digital Records: For L&H and KiwiSaver all digital records will be stored in Mo, a secure cloud-based system or on encrypted servers with regular backups. For mortgages we keep complete records within the Get Trail software.
Physical Records: Physical records will be stored in locked, secure facilities. Only authorized personnel will have access to these records.
Backup and Recovery: A regular backup and disaster recovery system will be maintained for all digital records.
Access and Confidentiality
Access: Only authorized employees or representatives of MTG/Mortgage Lab may access client and business records. Clients have the right to request access to their personal records in accordance with the Privacy Act 2020.
Confidentiality: Personal and financial information of clients will be handled confidentially, and measures will be taken to prevent unauthorized disclosure.
Record Keeping Procedures
A list of key Mo CRM Record Keeping processes can be found on the Intranet
Destruction of Records
Records that are no longer required to be kept under this policy will be securely destroyed. For digital records, this means using methods such as encryption and deletion. For physical records, shredding or incineration will be used to ensure complete destruction.
Responsibilities
Head Of Operations: Ensuring that all staff are aware of and adhere to the Record Keeping Policy and relevant legislation.
Staff and Advisers: Ensuring all client records, advice documentation, and other business-related documents are accurately maintained and securely stored.
QA Assessor: Conducting regular audits to ensure compliance with the Record Keeping Policy and reporting any breaches or issues.
Review and Audit
This policy will be reviewed at least annually, or more frequently if required by changes in legislation or business practices. Regular audits will be conducted to ensure compliance with the policy.
Breach of Policy
Any breach of this Record Keeping Policy may result in disciplinary action and could be subject to regulatory penalties. Serious breaches, such as the unauthorised disclosure of client information, may result in termination of employment or contract, and be reported to the relevant authorities.
CONTROLS
Review of the record keeping procedure
How implemented: Record keeping procedure to be reviewed and confirmed as satisfactory, including destroying records no longer required.
Responsibility & Frequency: Head of Operations β Annually
Check of records and security
How implemented: Periodic review to confirm that records are safe, secure, and complete.
Responsibility & Frequency: QA Assessor β Ongoing
Check of Cyber Security
Refer IT Systems and Security Policy
See related policies
Privacy Policy
Information Technology & Security Policy
Conflicts of Interests & Gifts Policy
π CPD Point Available For This Section π
The purpose of this policy is to ensure that any actual or potential conflicts of interest are identified, managed and disclosed.
The desired outcome is to prevent client harm, balance clientβs interests with business interests and provide staff with clarity on how to act if conflicts of interest arise.
This policy applies to all directors, employees, and contractors.
WHAT IS A CONFLICT OF INTEREST?
A conflict of interest may arise, in any area of a FAPβs business, where a FAP:
Is likely to make a financial gain (or avoid a loss) to the detriment of its clients.
Receives money, goods, or services from a third party in relation to services provided to clients other than standard fees or commissions.
Has a financial or other incentive to favour the interests of one client over another.
INTRODUCTION
The meaning of conflict of interest as stated in schedule 21A of the Financial Markets Conduct Regulations 2014 which defines a conflict of interest as where βa reasonable client would expect [it] to, or to be likely to, materially influence the advice given by the adviser
This clause defines what is meant by a conflict of interest and a commission or other incentive in relation to advice given by a person (A) to a client of a financial advice provider (P).
A conflict of interest, in relation to advice, means any interest of A, P, or another person connected with the giving of the advice that a reasonable client would expect to, or to be likely to, materially influence the advice given by A.
A commission or other incentive is a commission, benefit, or other incentive (whether monetary or non-monetary and whether direct or indirect)β
that is given to A, P, or another person connected with the giving of the advice as a consequence of A giving the advice or the client acting on the advice (for example, by acquiring a financial advice product); and
that a reasonable client would expect to, or to be likely to, materially influence the advice given by A.
A conflict of interest (COI) is a situation in which a person is able to derive personal benefit from actions or decisions made in their official capacity. A conflict of interest also arises in the workplace when we have competing interests or loyalties, which either are or potentially can be, at odds with each other.
Conflicts of Interest can be separated into financial conflicts and non-financial conflicts. Here are several examples for risk and home loans advisers.
Commission-based remuneration: we earn commissions based on the risk products or loans we facilitate. This creates a potential conflict of interest, if advisers recommend risk products or loans that offer higher commissions rather than those that are the best fit for the client. Of particular concern is instances where financial products are being replaced (refer our Replacement Business Policy and Practice Standards for more information)
Incentives from insurance providers or lenders: in circumstances where we may receive incentives or bonuses from insurers or lenders for directing business their way thereby influencing an adviser to favour suppliers, even if those suppliers do not necessarily provide the most favourable terms for the borrower.
Volume-Based Bonuses: we may receive bonuses based on the volume of risk products we issue or loans we originate. This may encourage advisers to prioritize quantity over quality, potentially leading to recommendations that are not in the best interest of the client.
Affiliated relationships: we may have affiliations or partnerships with specific insurers or lenders. In such cases, there may be a conflict of interest if we promote their products without considering other options that might be more suitable for the borrower.
Secondary businesses: if we are involved in other financial services or have affiliations with companies that provide related services (such as home appraisal services), there could be a conflict of interest if the adviser directs clients to those services without considering alternatives.
Conflicted Roles: for home lending we are required to ensure that advisers are not also acting as real estate agents, accountants or solicitors.
Referral arrangements: advisers may have referral agreements with other professionals, such as attorneys or accountants. Conflicts of interest can arise if these referrals are based on financial arrangements rather than the clientβs best interests.
POLICY STATEMENT
Where there is a conflict of interest, priority must be given to the clientβs interests by taking all reasonable steps to ensure that the advice/product/service is not materially influenced by any other interests.
We are required to identify and manage conflicts of interest and be transparent with clients when or if conflicts could arise. Wherever possible, conflicts of interest should be avoided or managed.
KEY PROCESSES
Conflicts of interest are likely to arise from time to time, so we have ongoing processes for managing them.
| Identify |
|
|---|---|
| Manage |
|
| Avoid |
|
| Communicate |
|
| Record and Review |
|
CONTROLS
COI Register
How implemented: We note any COI in the COI register
Responsibility: Head of Ins & KiwiSaver/Head of Mortgages
COI Training
How implemented: Induction and Ongoing
Responsibility: Head of Ins & KiwiSaver/Head of Mortgages
Gift Register
How implemented: Review the register to ensure all gifts are recorded. This may include hospitality or discounts offered. The Gift Register is here.
Responsibility & Frequency: Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
REFERENCES:
Financial Markets Conduct Act 2013
431K Duty to give priority to clientβs interests
Code of Professional Conduct for Financial Advice Services
Part 1, Ethical Behaviour, Conduct and Client Care
Code Standard 2 β Act with Integrity
Vulnerable Customers Policy
π CPD Point Available For This Section π
INTRODUCTION
MTG has a duty of care to ensure that we have a clear, transparent, and consistent process for addressing the risks associated with selling products to vulnerable people.
A vulnerable person is defined as βsomeone who, due to their personal circumstances, is especially susceptible to harm, particularly when an organisation or business is not acting with appropriate levels of careβ.
Examples of vulnerable clients are:
Persons with mental health problems g depression;
Persons with difficult financial circumstances g. recent unemployment;
Persons with physical health issues g. hearing or sight impairment;
Persons experiencing age-related impairment, cognitive impairment, elder abuse;
Persons with communication issues g. English is not their first language; and
Persons in a stressful or unfamiliar situation g. recent death of a spouse or loved one, recent immigrant
In certain circumstances, anyone could be classified as a vulnerable customer. Having alternate approaches, prompts and techniques will help all types of customers understand your advice
Whilst vulnerable clients are typically identified as specific groups of people, for example those with health issues or low literacy skills or without any significant financial buffer against unexpected events, anyone can potentially become vulnerable at some point in their lives.
As such a robust approach to vulnerability is more than a process designed to βtreat clients fairlyβ. Vulnerable clients are those that need some additional assistance at some point to avoid harm (financial or psychological), either throughout the lifecycle of a product/service or in response to certain events that may occur.
POLICY STATEMENT
When we approach a client, we will use the 3Cβs approach to help identify all types of vulnerability. By understanding these different groups is an effective method of identifying the various forms of vulnerability before establishing βbestβ practices in terms of how we should be approaching them.
We ensure that vulnerable clients have access to practical, jargon-free information and help in respect of our products.
Channels and Accesse.g. hearing, sight, language barriers and physical disability |
Comprehensione.g. Mental capacity, low financial understanding and issues relating to old age, such as dementia |
Circumstancee.g. bereavement, family breakdown or illness |
KEY PROCESSESS
We are trained to recognise vulnerable clients and then implement an advice solution that is appropriate for these clients. Once we have identified a vulnerable client, we will note it in our CRM so we are all aware of it and can take the appropriate steps when working with the client. This will normally involve a modification to the advice process and can include one or more of the following actions:
Visual Impairment
Our approach varies depending upon severity:
- We use larger font in our advice documents
- We read out key points
- We may ask for a support person to be present in the meeting
- We may send copies of documents to the support person
Auditory Impairment
Our approach varies depending upon severity:
- In an interview, we sit on the side where the client has better hearing
- If the client needs to lip-read, we sit opposite them and speak clearly
- We put more detail into our advice documents so the client can read rather than rely on verbal explanations
Age-Related Issues
Our approach varies depending upon severity:
- Talk slower
- Hold more interviews of shorter duration
- Repeat key points
- Schedule meetings for when the client is most alert (normally 09:30β12:30)
- Request a support person to be present
- Send copies of documents to the support person or a trusted third party
Clients Where English Is Not Their First Language
Our approach varies depending upon severity:
- May engage a translator
- Provide key documents in dual languages
- Explain key concepts and recommendations several times
- Include more supporting information in writing so a trusted friend can translate
- Speak slower
- Use simple verbal and written language
Clients in Stressful Situations
Our approach varies depending upon severity:
- Spend more time with the client
- Give clients longer to make a decision
- Ask if they would like a copy of recommendations and rationale sent to a trusted third party
- Recommend a support person attends all meetings
Other Vulnerabilities
(Consider any additional factors that might affect the clientβs ability to engage.)
CONTROLS
Training Register
How implemented: Training provided on how to manage and identify vulnerable clients at induction and ongoing.
Responsibility: Head of Insurance & KiwiSaver/Head of Mortgages
Client File Reviews
How implemented: QA checks of client files include review of any vulnerable clients identified and whether suitable consideration was factored into advice and documented
Responsibility: QA Co-Ordinator
Vulnerable Clients recorded in MO CRM and reported to SMT
How implemented: Vulnerable clients identified in MO CRM
Responsibility: Underwriting Administrators β Ongoing
The CRM includes functionality to identify vulnerable clients through a visual indicator, which actives a red switch to alert staff. As part of the process, a detailed note is required to be added to the client group profile page specifying the reason for their vulnerable status and providing instructions on their particular needs e.g. 1. deaf client requires communication via text or mail only, 2. terminally ill client.
Vulnerable clients list produced bi-monthly and considered via SMT
Vulnerable Clients recorded in Trail CRM and reported to SMT
How implemented: Vulnerable clients identified in Trail CRM
Responsibility: Mortgage Adviser β Ongoing
The CRM includes functionality to identify vulnerable clients through a visual indicator. As part of the process, a detailed note is required to be added to the client group profile page specifying the reason for their vulnerable status and providing instructions on their particular needs e.g. 1. deaf client requires communication via text or mail only, 2. terminally ill client.
Vulnerable clients list produced bi-monthly and considered via SMT
See related policies
Code of Conduct and Ethics
REFERENCES
Code of Professional Conduct
Part 1, Std 4 A person who gives financial advice must take reasonable steps to ensure that the client understands the financial advice
FMCA 2013
431J β Duty to ensure client understands nature and scope of advice
431K β Duty to give priority to clientsβ interests
431L β Duty to exercise care diligence and skill
431M β Duty to comply with the code of conduct
Responsible Lending Code
P17. 4.6c. If the client is a vulnerable borrower.
P19. 5.122. Enquiries into substantial hardship.
P23. 6. If the guarantor is a vulnerable guarantor.
Further Guidance on page 27 and page 58 section 15.
Adviser Attestation
Advisers are to complete this attestation every 6 months - every April and October.
Gift Register
Use this form to register any gifts received.
Emergency Response Plans
Last updated: 13/7/2025
In the Event of an Emergency
Remain calm
Dial 111 to notify emergency services
Follow instructions from Building Wardens and Civil Defence
Take action to keep employees, clients, visitors and contractors safe
Notify your Business Continuity Coordinator
Refer all media enquiries to the Leadership Team
Crisis Management Team (CMT)
The CMT is a centralised leadership group responsible for managing disruptions across all MTG offices.
The primary purpose of the CMT is the preservation of life and property.
CMT Priorities
Gather accurate information about the incident
Invoke the appropriate response plan
Ensure welfare of all staff and clients
Provide strong leadership and decision-making
Maintain clear communication
Engage external specialists (e.g., IT, landlords, property, etc.) as needed
Emergency Call Tree
CMT Checklist
Incident Management
Assess size/severity of incident
Activate Business Continuity Plan (BCP) via text, phone or email
Assign CMT roles
Complete Event Response Form
People
Confirm staff safety
Understand immediate staff needs
Check for clients/visitors on-site
Establish staff communication channels
Decide if office closure is required
Premises
Prioritise staff safety
Assess damage to premises
Secure site if needed
Confirm premises are safe before return
Request engineering reports if required
Communicate premises status to staff/clients
Business Continuity β IT & DR
Check status of IT systems
Enable phone diversion as needed
Set up remote access
Identify and prioritise critical business functions
Activate Disaster Recovery Plan if needed
Business Continuity β Client Servicing
Confirm client safety (if onsite)
Enable alternate communication channels for clients
Maintain servicing continuity
Activate BCP if needed
Business Continuity β Premises
Control or revoke access as needed
Liaise with landlords/building managers
Notify security monitoring
Coordinate inspections or repairs
Activate BCP or Disaster Recovery Plan
Crisis Management Teams
| Role Name | Staff Name | Phone Number |
|---|---|---|
| Head Office β Auckland | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | Sian Johnson | 021 297 7360 |
| Operations & Business Recovery Manager | Sian Johnson | 021 297 7360 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sian Johnson | 021 297 7360 |
| IT & Systems Lead | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |
| Company Insurances | Ashley Greer | 021 333 712 |
| Company Insurances | Kelly OβConnor | 021 870 944 |
| Tauranga | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | Sian Johnson | 021 297 7360 |
| Operations & Business Recovery Manager | Sian Johnson | 021 297 7360 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Health, Safety & Environment Lead | Janeen Flower | 021 448 228 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sian Johnson | 021 297 7360 |
| IT & Systems Lead | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |
| Hamilton | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | Sandra Sutton | 021 274 7114 |
| Operations & Business Recovery Manager | Sian Johnson | 021 297 7360 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Health, Safety & Environment Lead | Sandra Sutton | 021 274 7114 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sandra Sutton | 021 274 7114 |
| IT & Systems Lead | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |
| Cambridge | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | David Cooney | 021 972 721 |
| Operations & Business Recovery Manager | Sandra Sutton | 021 274 7114 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Health, Safety & Environment Lead | Sian Johnson | 021 297 7360 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sandra Sutton | 021 274 7114 |
| IT & Systems Lead | David Cooney | 021 972 721 |
| Assist | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |
| Napier (Employee Lab β Lewis Ltd) | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | Tim Jones | 021 660 834 |
| Operations & Business Recovery Manager | Sarah Jones | 021 649 913 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Health, Safety & Environment Lead | Gretchyn McLean | 021 047 0732 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sarah Jones | 021 649 913 |
| IT & Systems Lead | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |
| Christchurch | ||
| Crisis Team Leader | Brent Wright | 021 270 0088 |
| Command Centre Manager | Jack Radford | 021 627 049 |
| Operations & Business Recovery Manager | Sharon Empson | 021 109 3165 |
| HR & Administrative Support Lead | Sian Johnson | 021 297 7360 |
| Health, Safety & Environment Lead | Sharon Empson | 021 109 3165 |
| Legal Specialist | Nick Hodson | 021 654 530 |
| Business Continuity Coordinator | Sian Johnson | 021 297 7360 |
| IT & Systems Lead | Sharon Empson | 021 109 3165 |
| Assist | Rupert Gough | 021 438 043 |
| Assist | Gavin Christie (ATeamIT) | 021 854 854 |
| Finance | Brent Wright | 021 270 0088 |