Page 62 - Phil Reddin Financial Services Ltd DRAFT V1

We cultivate a culture of accountability and in keeping with our Company Standards, it is expected
that each of us demonstrates a sense of personal and collective responsibility for our actions.

Our individual responsibilities include:

• We must always meet legal requirements and regulatory obligations, and adhere to operating
procedures
• We are alert to indications of fraud, money laundering and other financial crime
• We report concerns or suspicions and act promptly using the procedures established by our
business unit
• We comply with the physical security and health and safety rules applying to our business unit
We ensure all work-related data and information is used appropriately and stored or
communicated securely
• We do not discuss our Company with the media without specific authorisation from Phil Reddin.
7.2 OUR BUSINESS: SOME EXAMPLE OF OUR BUSINESS STANDARDS

7.2.1 Operating controls and procedures
We always comply with operating and control procedures. Should there be a legitimate reason to
deviate from these procedures, we must have prior permission from the appropriate senior
management. Deviations which do not conform to our legal and regulatory obligations are never
permitted.

If we identify a weakness in controls or procedures, we must bring this to the attention of our line
manager who is responsible to escalate this to the appropriate level.

We must also report any breach of controls, procedures or processes that come to our attention. This
can be done through your branch manager or by approaching Phil Reddin.

7.2.2 Preventing fraud, money laundering and other financial crimes
We must always be alert to indications of internal and external fraudulent activity, to potential money
laundering and to terrorist financing, and must report any concerns or suspicions promptly.
Completion of annual training on anti-money laundering procedures by all staff is mandatory.
Key requirements include the identification of the customer and/or beneficial owner and retention of
documentary evidence. In addition we must obtain information on the nature of the business
relationship with the customer as well as conduct on-going monitoring of that relationship and
transactions for any suspicious activity.

7.2.3 Physical security, health and safety
Those of us working in sensitive areas of the Company, such as branches, cash centres and data
centres, should familiarise ourselves with and comply with the specific rules applying to our location.
Strict rules apply for identification and access for all staff and visitors to all Company locations, which
must be adhered to.

Concerns about security threats should be escalated to your branch manager or to Phil Reddin.

7.2.4 Information Management
The relevant Data Protection provisions, including those related to usage, storage and access, must be
complied with at all times when managing company information, whether that is business, customer

Page 61 of 83