Professional Documents
Culture Documents
ASSESSMENT PACK – OD
Mode | Online Delivery
Assessment Tasks
The following summative assessments are planned for these units;
# Assessment Task/Activity Type Assessment Method
Part A: Develop a Compliance Management Procedure Individual Written
1
Part B: Project: Monitor and Report Breaches in Compliance Team Written and Observation
Essay: Learning a Lesson from Corporate Failures: The Need for a
2 Individual Written
Value-Based Compliance Management System
3 Knowledge Test Individual Written Test
Task Instructions:
For a given business scenario, you will be required to develop a policy document on compliance
management procedure and then create report on breaches in compliance.
Brief description:
Organisation compliance policies and procedures, in particular in a regulated industry or sector such as
Financial Services Sector in Australia, is essentially linked to regulatory compliance, and how organisations take
steps to comply with relevant laws, policies, regulations, and codes of conduct, such as;
• Laws and regulations
• Internal policies and procedures
• Contractual arrangements
• Risk treatment (continuous improvement) initiatives
• Professional standards
An effective compliance procedure can help all staff in an organisation understand their obligations and
reduce the risk of breaching their obligations.
An effective compliance management system incorporates risk management and compliance management
procedures to ensure that organisations continue to comply with both internal and external regulatory,
professional conduct, and best practice requirements. The organisations have an obligation to monitor
adherence to the compliance requirements and standards, implement a risk management program, and an
effective process for identifying, reporting, and managing breaches.
Task details:
In this task, you will be required to develop a compliance management procedure, in form of a policy
document. As a guideline document, you will be using AS-3806:2006 Compliance Program Standard (Principles
1-5) in developing your compliance procedure. A copy will be provided by your trainer. You may also use any
other sample organisation in consultation with your trainer.
Given the nature of the task, you will play the role of a “Audit and Compliance Officer” working in the sample
organisation as follows:
Business scenario:
Mortgage Choice was established in 1992 by co-founders Rod Higgins and Peter Higgins who had a vision of
building a national network of ethical, credible and professional mortgage brokers who local communities
could trust (Mortgage Choice: Profile, 2019).
Since then, it has evolved into a fully-fledged financial services provider. The company’s goal is to help
Australians make better decisions with their finances.
The company has a national network of professional mortgage brokers and financial advisers. Brokers offer
customers a wide choice of home loan products via an extensive panel of leading lenders. They also assist with
personal loans, commercial loans, asset finance, deposit bonds, and risk and general insurances. Mortgage
Choice has no balance sheet or funding risk, and consistently delivers strong profits and attractive yields. The
company has been listed on the ASX since 2004 and is a member of the Mortgage & Finance Association of
Australia (MFAA).
Regulatory Context
Credit licensees have general conduct obligations under s47(1) of the National Credit Act. Credit licensees
must comply with general conduct obligations under RG 205.1. Licence applicants must also be able to
demonstrate that they can comply with these general conduct obligations as per RG 205.3–RG 205.7. As a
credit licensee companies are responsible for deciding how to comply with the general conduct obligations:
Ref: RG 205.8–RG 205.10. An effective compliance program/procedure is one of the General Conduct
Obligations for Australian Credit Licence holders, under the NCCP Act.
The regulatory information can be found here; https://download.asic.gov.au/media/1241300/rg205a.pdf
Task – Part A
Within the given roleplay, assume that you have been given a task to research and develop a compliance
management procedure for the company. Under the regulations, a Credit Licensee needs to demonstrate it:
▪ Has all the appropriate policies;
▪ Has a documented schedule (quarterly) to test itself against the policies;
▪ Documents the testing results; and
▪ Takes any necessary actions arising out of the results.
Your compliance procedure must cover the above aspects with appropriate references to the regulatory
requirements and best practice (aligned with AS 3806-2006 as a best practice model within the sector).
Develop a comprehensive policy document that sets the framework for compliance and the relevant
procedure for ensuring and meeting all the compliance obligations. Your compliance document will cover:
▪ Purpose of the Policy and Procedure
▪ Scope
▪ Applicable Legislations and Codes (relevant to company’s operations – detailed description)
▪ Compliance Obligations
▪ Areas of Compliance (at least two different areas – e.g. credit, advice, insurance, loans, privacy, etc.)
▪ Policy Statement
▪ Potential Compliance Risks and Risk Management (Ref: AS-4360:2004) – with examples of
instances/situations where breaches can occur
▪ Procedure for identifying and classifying breaches
▪ Monitoring schedule and investigation (testing practice/operations)
▪ Procedure for rectifying and reporting breaches
Your policy document must outline regulatory requirements and compliance obligations in detail, pertaining to
each area of compliance. Refer to and provide reference to the principles of AS 3806-2006 relevant to
commitment.
The policy document must be developed as a formal organisational compliance reference document with
appropriate formatting, structure and writing. You will also need to attach copies of the relevant codes,
guidelines, and standards used/referred as appendices.
Task – Part B
Using the same busines scenario in Part A, you will form teams with your classmates to play the role of an
“Internal Audit” team (for compliance monitoring and reporting purpose). You will use one of the compliance
procedures developed in the previous task. Your trainer will guide you as the “Compliance Manager”.
The report should be approximately 2500 words long excluding any attachments/reference documents. It is
expected that each of the above sections will be described in detail to cover the required information and
assessment criteria. Use AS-3806:2006 as the underlying compliance management standard for reference. The
report should be prepared and submitted as a formal report and saved for safe storage as instructed.
Submission Guidelines:
Part A:
▪ Soft copy of word-processed policy/compliance document developed by you
▪ Copies of reference documents as attachments
Part B:
▪ Written report in a word-processed soft copy
▪ Copies of reference documents
▪ Copies of stakeholder presentation
▪ Signed team statement outlining the team process and member contributions (as part of the report)
Student should upload completed task on the MEGA Student Portal as per trainer instructions.
Essay: Learning a Lesson from Corporate Failures: The Need for a Value-
Based Compliance Management System
Task Instructions:
You are required to write an expository essay on the given topic.
Brief description:
In March 2017, The Australian Securities and Investments Commission (ASIC) said it had started civil
proceedings against the Westpac Banking Corp, a $113 billion bank, for "a number" of contraventions of
responsible lending provisions contained in consumer protection laws. In 2009, the US Department of Justice
won a $150m settlement from Deloitte, the world’s biggest professional services firm, over its alleged failure to
detect a long-running fraud at a former mortgage broker.
In one of the major financial irregularity cases in Australia, The Commonwealth Bank forced Storm Financial
into administration on 9 Jan 2009 when the bank called up its lending facilities to Storm citing a default on
Storms own margin lending facility with the bank.
Despite numerous legislations, standards, and protocols, we continue to see mismanagement, unethical
practices (landing, credit etc.) and corporate collapses in Australia and around the world.
In this concise expository essay (maximum 1200 words), research and discuss the concept of organisational
compliance within the Australian financial services sector context from a holistic viewpoint. Explain how
“values” can be used for implementing best and ethical practice in addition to the legislative and professional
practice frameworks.
In effect, you will be focussing on theories such as value-based-management and management by principles
while keeping the compliance and regulatory principles as the outcomes. Justify and argue why, in your view, a
value-based compliance management system could or could not be viable in the sector. Ensure that you cover
in your essay;
• An overview of the Financial Services Sector in Australia
• Summary of the regulator and compliance framework for financial services organisations
• Examples of major corporate collapses (where compliance and management practice were issues) –
examples of breaches
• Components of a typical compliance management system
• An overview of value-based management concepts (examples)
• Role of values as part of the compliance management system (e.g. ethics, principles, leadership etc.)
The essay must be written in your own words and appropriate referencing and citation must be used in all
external references (preferred: Harvard referencing system: The essay should be concise, succinct, and
focussed on key points.
Submission Guidelines
▪ Word-processed soft copy of the essay
Student should upload completed task on the MEGA Student Portal as per trainer instructions.
Knowledge Test
Task Instructions:
Research the learning and online resources and answer the following questions
Q1. Describe the concept of a “Compliance Management System” within the context of a financial services
institution (e.g. bank) in your own words.
Q2. What can be the key components of an effective Compliance Management System?
Q3. List and briefly describe key compliance documentation required to maintain compliance.
Q4. Describe the key responsibilities of the senior management (e.g. the Boards, CEO, Directors etc.) in
maintaining effective compliance and compliance culture within the organisation.
Q5. List internal and external job roles (at least five) that focus on managing compliance within an
organisations/institute.
Q6. Explain how a compliance culture can be supported within an organisation in your own understanding
Q7. Outline a typical compliance planning processes of the organisation in your own words.
Q8. Explain reporting processes on compliance management including reports on breaches and rectifications
in your own words.
Q9. Provide examples of some of the measures to assess compliance performance (at least five).
Q10. Briefly describe standards for quantitative and qualitative data analysis techniques relevant to
compliance related evaluation in your own words.
End Test
Submission Guidelines
▪ Completed answers in word document
Student should upload completed task on the MEGA Student Portal as per trainer instructions.
Assessment Criteria:
The following assessment criteria will be used for marking this assessment task. Ensure that you have
addressed all of the criteria in your work.
Task 1-A:
▪ Completed the task as instructed within the given roleplay
▪ Used an appropriate organisational context and profile to cover the required compliance areas for the
purpose of this task
▪ The policy/compliance document demonstrates a satisfactory extend of research into the relevant
legislation, code, and standards
▪ Was able to understand and refer to AS 3806-2006 (1-6) as the fundamental commitment principles in
drafting the document
▪ Was able to provide a cohesive description of compliance requirements, obligations, and the underpinning
legislations, code, and standards – in a logical flow (summarised and structured for policy purpose)
▪ Was able to outline compliance obligations in view of organisation’s operations and services
▪ Identified and described specific compliance requirements and obligations for two compliance areas
▪ Identified and articulated compliance risks in the potential areas
▪ Used AS-4360:2004 as a guide towards risk management and suggested strategies for mitigating the risk
▪ Provided an overview of potential breaches that could occur in the operational areas
▪ Developed a policy to set a framework of compliance in view of legislative and best practice requirements
and guidelines
▪ Outlined procedures for identifying and classifying breaches
▪ Outlined procedures for monitoring compliances and investigating breaches in compliance
▪ Provided step-by-step processes to outline all the key procedures
▪ Procedures are consistent with the set policy statements and in compliance with the requirements
▪ Formatted and structured a formal policy document encompassing all the above requirements
▪ Demonstrated knowledge of organisational compliance within the operational areas and strategies for
dealing with potential breaches
Task 1-B:
Teamwork:
▪ Successfully formed the group and defined and discussed roles and responsibilities of each group member
▪ Reviewed the given reference documents and made notes as required
▪ Identified and itemised the required tasks based on the work required
▪ Delegated tasks to group members based on their skill and knowledge
▪ Maintained a group folder with records of group work
▪ Maintained effective communication and group cohesion throughout the task
▪ Maintained communication with the trainer/assessor within the roleplay
▪ Effectively maintained the given roleplay and demonstrated commitment as a group
▪ Successfully completed the project tasks as required
Individual:
▪ Participated in group formation process and joined a project group
▪ Communicated effectively with the group members and clarified own roles and responsibilities
▪ Attended the required team sessions/meetings
▪ Actively participated and contributed in team discussions
▪ Developed own work or action plans
▪ Maintained a professions approach and focus within the give role play
▪ Completed own tasks as delegated by the group
Report:
▪ The report is appropriately structured and presented as a formal business document reflecting a real-life
practice (sample plans as benchmarks)
▪ Appropriate headings and sub-headings are used to structure the contents
▪ The content flow covers all the required elements of the plan and contains a logical sequence of the topics
▪ An Executive Summary is included and provides key findings and recommendations of the report