Our Policy

1. PURPOSE

• As part of Australian Loans & Mortgage’s (the Business) process to ensure that it continues to maintain the highest levels of best practice standards, professional integrity and ethical conduct, the Business has adopted this Environmental (E), Social (S) and Governance (G) (together, making ESG) Policy (Policy) to manage their acknowledgement of, compliance with, and commitment to, ESG principles in an open and transparent manner.
• ESG refers to three important criteria that, when considered holistically in a comprehensive manner, can have a material impact on the Business’ long term decision-making process, corporate strategy and growth, and ultimately, benefits society. When taken into account and implemented correctly, these factors can lead to measurable actions that could collectively contribute to making a positive impact on the world.
• The enactment of ESG’s principles also allows the Business the opportunity to be a role model for others and a good corporate citizen. This results in our Business intertwining itself in the fabric of our society’s matrix, thereby adding to the rich tapestry of the big wide world. These values are at the heart of our Business and what we stand for.

2. BACKGROUND

• Each letter of the ESG acronym encompasses a different approach or strategy that should be taken into consideration by, and incorporated into, the Business’ day to day operations.
• The below lists are non-exhaustive examples of what could be classified and captured within each part of the framework. These factors are numerous and ever-shifting, often dependent on, and specific to, the Business.
• (a) E = EnvironmentalThe ‘Environmental’ aspect examines how the Business interacts with, and affects their, natural surrounding environment and ecosystem. This includes, but is not limited to:
  • climate change;
  • energy and natural resources;
  • resource depletion vs preservation;
  • circular economy / waste;
  • pollution;
  • land use;
  • agriculture, forestry and fisheries and/or
  • biodiversity.
• (b) S = SocialThe ‘Social’ aspect analyses how the Business manages their relationships with its employees, customers, their immediate suburb/community where they operate, supply chain, as well as broader community such as where the Business fits in within their city, state/territory, country and region. This includes, but is not limited to:
  • human rights;
  • health and safety;
  • privacy and data protection;
  • modern slavery;
  • supply chain management;
  • responsible lending;
  • working conditions, labour relations, child labour;
  • employee relations and their wellbeing;
  • community engagement; and/or
  • diversity, equity and inclusion.
• (c) G = GovernanceThe ‘Governance’ aspect deals with the actual day-to-day structure of the corporation, their mission statement and their values/objectives, including the interactions with, and between, its hierarchy, stakeholders, shareholders, audit and controls. This includes, but is not limited to:
  • leadership, corporate governance and oversight;
  • risk and compliance management;
  • conflicts of interest;
  • tax strategy;
  • ethics and culture;
  • transparency (including financial and operational reporting);
  • fraud, anti-bribery, sanctions, anti-corruption and whistle-blowing;
  • executive remuneration;
  • board diversity and structure; and/or
  • political lobbying and donations.
• Key ESG drivers in the Business model include:
  • investors;
  • laws;
  • regulators;
  • local communities and the broader society; and/or
  • other businesses and organisations.
• The key drivers of the Business place a high importance on ESG principles and their role in undertaking and participating in social activism. These drivers help ensure that our Business maintains its reputation as an ESG leader.
• We want everyone involved with our Business from our customers to our investors to our staff, to be proud to be involved with our Business. Part of that pride is understanding how our Business makes a positive contribution to the world.
• Our Business does not operate in a vacuum of isolation. Value is created through collaboration with our partnerships. As each element of the value chain is interconnected, when one link is inconsistent with ESG’s principles, then the whole chain is impacted. It is about understanding the risks associated with each stage and making concerted efforts to reduce those risks.

3. APPLICABLE STANDARDS

International ESG Standards

• The provisions of this Policy will assist the Business in complying with the voluntary and aspirational requirements of the United Nation’s Principles for Responsible Investment (UN PRI).There are 6 principles comprising the UN’s PRI. These are:
  1. We will incorporate ESG issues into investment analysis and decision-making processes.
  2. We will be active owners and incorporate ESG issues into our own ownership policies and practices.
  3. We will seek appropriate disclosure on ESG issues by the entities in which we invest.
  4. We will promote acceptance and implementation of the UN PRI within the investment industry.
  5. We will work together to enhance our effectiveness in implementing the UN PRI.
  6. We will each report on our activities and progress towards implementing the UN PRI.

Australian ESG Standards

• In Australia, there is not one unifying ESG legislative act that sets out what is ESG and how it applies to Businesses. However, there are separate laws and regimes which are relevant to certain ESG factors, which assist in creating different legal ESG obligations.
• Relevant legislative instruments regarding Australia’s ESG obligations, their application and implementation would be derived from, including but not limited to, the following sources:
  • Governance principles, financial, disclosure, and whistle-blower, reporting requirements of the Corporations Act 2001(Cth);
  • Anti-bribery and corruption laws;
  • ASIC’s regulatory guidance;
  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006(Cth)
  • Modern Slavery Act 2018(Cth);
  • Fair Work Act 2009(Cth);
  • Work Health and Safety Act 2011(Cth);
  • Workplace Gender Equality Act 2012(Cth);
  • Environment Protection and Biodiversity Conservation Act 1999(Cth);
  • National Greenhouse and Energy Reporting Act 2007(Cth); and/or
  • Native Title Act 1993(Cth).
• These legislative provisions work together with and complement the Business’ existing frameworks and ongoing obligations (i.e. its own Modern Slavery Statement or its Anti-Bribery and Corruption Statement).

4. WHO DOES THIS POLICY APPLY TO AND WHAT ARE THEIR RESPONSIBILITIES?

• This Policy always applies to all representatives and employees of the Business and the requirements remain in force and are updated on an ongoing basis. Active participation and engagement at all levels of the Business is of great importance to ensure the collective ownership of ESG by all.
• Each role and their responsibility are outlined below. RoleResponsibility Director
  • sets the expectations for the ESG culture as an integral part of the Business;
  • leads and drives culture;
  • translates and communicates Board expectations;
  • resourcing, including training and skills development.
  Executive team
  • implement procedures and processes;
  • supervision of direct care employees;
  • education lind coaching on employees to support processes; identifying individual training needs;
  • identifying, reporting and responding to incidents and assist to identify root causes and corrective actions;
  • reporting and escalation of abuse or misconduct;
  • identifying risks and escalating;
  • monitor the control environment for risks;
  • documenting and reviewing policies, procedures and supporting documents to ensure they align with best practices.
  Risk & Compliance team
  • responsible for the management of aspects of the Regulatory Compliance Framework and Enterprise Risk Management Policy, Framework and Procedure;
  • monitor the internal and external environment for risks;
  • asliistance with identifying compliance and risk training;
  • completing independent control testing.
  Employees
  • recognising ESG factors;
  • following policies and procedures.
  • Responsible for reporting any ESG related risks to the risk and compliance team

5. POLICY SCOPE AND PRINCIPLES

• The Business has adopted the following principles to guide its ESG framework, thereby aligning our operations and controls with our Business’ values:
• Environmental Principles:
  • We aim to drive down our energy and carbon impacts, by committing to environmentally sustainable initiatives that deliver near-term efficiency and value for our business and the wider community. This includes, but is not limited to:
    • Reducing use of paper by keeping all client files digital
    • Emailing correspondence and customer related documents
    • Reducing our carbon footprint by minimising the required physical space to operate The Business in an efficient manner
    • Promote energy saving exercises in all locations where possible
  • We encourage our customers to reduce their impact on the environment by recommending more sustainable alternatives and options where applicable.
  • We aim to comply with current environmental legislation.

• Social Principles:
  • Our focus is to deepen relationships with our key stakeholders by investing in our employees and partnering with our customers, communities, investors and suppliers. We are committed to engage with our employees to provide an inclusive and diverse work environment that supports their professional development, as well as promoting a good work-life balance that prioritises their overall health and wellness.
  • We are committed to upholding a high standard of Responsible Lending
  • Attempting to provide our employees with a strong work life balance through the option to work from home
  • We will support initiatives that benefit the environment, human welfare and education, including skills training.
  • Offering regular training and personal development opportunities with aligned partners
  • We will preserve and promote the protection of human rights and welfare within our own business activities in compliance with our own policies and procedures.
• Governance Principles:
  • Our focus is to promote high ethical standards including adequate oversight, transparency and risk management, both within our organisation and with our stakeholders.
  • We will maintain high corporate governance practices and standards in relation to ESG by setting goals and establishing accountability frameworks.
  • We will mitigate the business’ risk exposure through our corporate governance structure.
  • Environmental– Ensure that finance providers we utilise hold and maintain their own ESG policies and principles to ensure a greater focus on reducing use of pollutants, chemicals and renewable energy sources
  • Put focus towards the issue of reducing greenhouse gas emissions by occupying office spaces which meet regional, national or internationally recognised standards or certifications for environmental performance
  • Social– Clients – We continually look to enahce the ways clients can access credit assistance through by improving documentation and introducing new technologies which promote greater accessibility
  • Staff– As an employer across several Australian states, we pride ourselves in welcoming inclusion of all and diversity
  • Privacy and Data Protection– Australian Loans & Mortgages realises the importance of privacy and data protection of both their customers and related businesses and stakeholders. Our Privacy Policy sets out our commitment in respect of personal information we hold about clients and what we do with that information. Any personal information we collect will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that our clients are confident that any personal information we hold about them will be treated in a way which ensures protection of their personal information.
  • Risk & Compliance Strategy– In an ever-changing industry and business environment, Australian Loans & Mortgages continually reviews and adjusts its risk appetite and the compliance involved to maintain adherence to legislation, legal obligations industry standards.
  • Responsible Lending– As a Mortgage Manager, AL&M maintains the adherence to credit policies produced by our accredited White Label product funders. AL&M will also follow strict responsible lending guidelines and where applicable, the application of local consumer lending regulations. The credit assessment process will typically encompass reasonable inquiries about the consumer’s financial situation, their requirements and objectives; take appropriate steps to verify the consumer financial situation; and make an assessment about whether the lending product is suitable for the applicant.
• The Business’ Group Operations Manager must ensure that the proper controls, systems, trainings and frameworks are in place for the Policy to be adhered to, and complied with, during the day-to-day running of the Business.
• The Business must strive to work as one team when fostering its ESG goals in an open, transparent and sustainable manner. It shows our Business’ intention and commitment to being alert and responsive to the challenges and opportunities it faces in the financial economy.

6. CONFLICTS OF INTEREST AND POLICY BREACHES

• The Business has a Conflicts Of Interest Policywhich describes the process for identifying and managing conflicts of interests. This Policy should be read in conjunction with the Conflicts of Interest Policy].
• Breaches of this Policy may lead to disciplinary action being taken against the relevant party, including dismissal in serious cases and may also result in prosecution under the law where that act is illegal. This may include re-assessment of bonus qualification, termination of employment and/or fines.
• Staff are trained internally on compliance in accordance with their regulatory obligation to the Business. They are encouraged to respond appropriately to, and report, all breaches of the law and other incidents of non-compliance, including the Business’ policies, and they should seek guidance if they are unsure. The aim of this training is to proactively prevent and mitigate circumstances of non-compliance with this Policy.
• Staff must report breaches of this Policy directly to the Group Operations Manager.

7. POLICY APPROVAL AND REVIEW PROCESS

• The Business’ ESG Policy will be reviewed on at least an annual basis by the Group Operations Manager, having regard to the changing circumstances of the Business.
• Changing circumstances occur when/if the Business becomes aware of:
  • any legislative changes or regulatory requirements to review the Policy;
  • any provision of the Policy that is no longer considered to be appropriate; or
  • it becomes reasonable to believe that this Policy has failed or may fail, to support the Business’ obligations.

8. EFFECTIVE DATE

• This policy is effective from the review date above, and will be reviewed annually or as deemed necessary.

9. SUPERSEDES

• This document supersedes all previous documents, practices and policies relevant to ESG.

10. GLOSSARY