Conflicts of Interest Policy Statement

Anti-Money Laundering & Counter-Terrorism Financing Procedures


Internal Dispute Resolution Process


Conflicts of Interest Policy Statement Overview


1. Zar Mortgage Brokers Licensee Obligation

The National Consumer Credit Protection Act 2009 includes a provision that all licensees under the National Consumer Credit Protection Act must:

“have in place adequate arrangements for the management of conflicts of interest that may arise wholly, or partially, in relation to activities undertaken by the licensee or a representative of the licensee in the provision of financial services as part of the financial services business of the licensee or representative.”


1.1 What are conflicts of interest?

ASIC defines conflicts of interest as ‘circumstances where some or all of the interests of people (clients) to whom a licensee and it's representatives provides financial services are inconsistent with, or diverge from, some or all of the interests of the licensee or its representatives. This includes actual, apparent and potential conflicts of interest'.

A conflict of interest generally arises where an individual has a personal interest which may influence how they perform their duties and responsibilities to Zar Mortgage Brokers.

This includes using any information obtained as a representative of Zar Mortgage Brokers, which includes Directors, employees, agents and their employees, which is not available to the general public, for personal gain.

All representatives should avoid taking part in any dealings that place them in a position of conflict with Zar Mortgage Brokers interests.


1.2 ASIC's Policy Statement 181 Licensing: Managing conflicts of interest

PS181 sets out the minimum arrangements licensees (including their representatives) must have had in place to comply with the conflicts management obligation. ASIC states that it expects licensees to control, disclose and, where necessary, avoid conflicts of interest.

As part of managing conflicts, ASIC expects Zar Mortgage Brokers and other licensees to identify, assess and respond to the conflicts of interest that arise in their business.


2. Controlling and avoiding conflicts

In controlling conflicts of interest, ASIC expects that Zar Mortgage Brokers will have arrangements in place to enable us to:

Identify the conflicts of interest relating to our business;

Assess and evaluate those conflicts; and

Decide upon, and implement, an appropriate response to those conflicts.


3. Disclosing conflicts

ASIC requires that Zar Mortgage Brokers ensures that clients are adequately informed about any conflicts of interest that may affect the provision of financial services to them. This means providing clear, concise and effective disclosure so that clients can make an informed decision about how the conflict may affect the relevant service.

The conflicts of interest obligation applies equally to services provided to retail and wholesale clients, although the level of disclosure required may be less detailed for our wholesale clients.



1. Policy on Avoiding Conflicts of Interest

1.1 Honesty & Integrity

All representatives shall act honestly and with integrity in all their dealings with Zar Mortgage Brokers. This includes engaging in and promoting honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

Representatives will not discriminate on the grounds of people's race, religion, gender, marital status or disability.

Representatives will not make promises or commitments that Zar Mortgage Brokers does not intend, or would be unable to honour.

Representatives' conduct, at all times, will be such that their honesty is beyond question.

Representatives will adhere to the truth, and not mislead directly or indirectly nor make false statements, nor mislead by omission.


1.2 Use of Zar Mortgage Brokers Information

Representatives will take all reasonable measures to protect the confidentiality of non-public information obtained or created in conjunction with their activities and to prevent unauthorised disclosure of such information unless required by applicable law or regulation or legal or regulatory process or with the consent of Zar Mortgage Brokers.


Representatives must not:

use Zar Mortgage Brokers name, or any confidential information obtained during their employment or appointment as an authorised representative with Zar Mortgage Brokers (regardless whether this information is available to the general public) for personal gain or for the benefit of others;

directly or indirectly communicate price sensitive information about Zar Mortgage Brokers products to a person who is likely to deal or trade in these products.


1.3 Positions of Conflict of Interest in Zar Mortgage Brokers Matters

Representatives must not:

allow any personal relationships with customers or third parties to interfere with their duties to Zar Mortgage Brokers;

manage any customer relationships where they have an interest or potential to obtain a personal benefit from the relationship; and

knowingly cause or direct Zar Mortgage Brokers to acquire goods or services from vendors or organisations in which they have an interest or under arrangements in which they will obtain a personal benefit or gain.

A representative will only prepare any of Zar Mortgage Brokers security or other legal documents for customers or any other person, if this is in the normal course of their duties.

If a representative becomes aware of any matter which may result in them being in an actual or perceived conflict of interest, they must fully disclose this to their manager, or refer the situation to the ASIC compliance section.

A representative must not use any insider information to gain any professional or personal advantage.

A representative must disclose to their manager or the ASIC compliance section, any material interests they have in Zar Mortgage Brokers customers or Zar Mortgage Brokers contracts, transactions or other commercial arrangements upon becoming aware of the interest.


1.4 Acceptance of Gifts

In the course of their employment with Zar Mortgage Brokers, if a representative receives money (whether as a gift or commission) from outside parties involved in Zar Mortgage Brokers business, they must return this money and immediately report the incident to their manager.

If a representative receives a gift or invitations to entertainment (exceeding $100 in value) in the course of their employment at Zar Mortgage Brokers, they will pass on same to a senior manager who will distribute it to the appropriate personnel at his or her discretion.

A representative will not provide or accept any entertainment which, to a reasonable person, will seem inappropriate or abnormal.


1.5 Non-Work Related Activities

A representative will not:

participate in any business activities; or

enter into any business arrangement; or

accept any employment with another business outside their employment with Zar Mortgage Brokers;

that could:

have an adverse impact on their ability to carry out his/her responsibilities and duties to Zar Mortgage Brokers;

cause a conflict of interest; or

conflict with Zar Mortgage Brokers corporate image or business activities.

A representative will not become or act as an executor, administrator, trustee or attorney for any customer of Zar Mortgage Brokers who is not a member of their immediate family or associated entities without Zar Mortgage Brokers consent.

If a representative is nominating or running for any government office (whether it is local, State or Federal government), they will disclose this to a senior manager.


1.6 Employee Personal Banking

Representatives will ensure that their own accounts (which includes their deposits, loans and other facilities) with Zar Mortgage Brokers are maintained in accordance with Zar Mortgage Brokers policies and procedures, and they will not process their own transactions.

If a representative is about to undertake any Zar Mortgage Brokers financial transaction on their own behalf and is unsure whether a conflict of interest or a breach of policy or risk exists, they will refer the matter to their manager before undertaking the transaction.

A representative will only personally operate on accounts of public bodies, churches, societies, and clubs etc held at Zar Mortgage Brokers only if the account requires joint signatures with other office bearer(s) unless consent has been received from a senior manager.

A representative will not borrow money for him or her self from a Zar Mortgage Brokers customer in any circumstances unless it is from an associated family member.

A representative will not lend money to a Zar Mortgage Brokers customer on their own behalf in any circumstances unless it is to an associated family member.

A representative will not approve or process family member's loans without consent from the Loans Manager.


1.7 Incentive & Remuneration Practices

Zar Mortgage Brokers will ensure that their incentive and remuneration practices for all representatives are consistent with the provision of financial services in a fair, honest and professional manner.

Incentive and remuneration practices that place the interests of the business or its representatives in direct and significant conflict of those of their clients will be avoided (not just disclosed).


2. Strategies to Manage Potential Conflicts

It is Zar Mortgage Brokers policy that all representatives will be forwarded a copy of this policy and a ‘Declaration of Conflict of Interest' form on an annual basis.

Each representative is to review the policy and if the representative believes that any business or personal matter is, or could be, a conflict of interest or potential conflict of interest involving his/her role, they must complete this form providing full details.

The declaration is to be forwarded to the FSRA Compliance area.


3. Conflict of Interest Handling Process

Where a potential conflict of interest is declared or perceived, the FSRA Compliance section will pass on this to the Executive Manager/Director and the Chief Financial Officer who will investigate the matter to identify the nature of the potential conflict and to determine a course of action be taken to manage the matter.

The Managing Director will be informed of the issue and if identified as a potential conflict, then it will be recorded in the ‘Conflicts of Interest Register' to be brought to the attention of the Board of Zar Mortgage Brokers.

Where the conflict involves either the Executive Manager/Director or the Chief Financial Officer then the Managing Director will be notified in the first instance.


4. Potential Conflict of Interest Complaints

All complaints regarding conflict of interest are to be directed to either the Executive Manager/Director or the Chief Financial Officer. They will communicate directly with the individual raising the concern and investigate the matter to determine the nature of the complaint and determine options for appropriate courses of action.

Potential courses of action will be discussed with the complainant to determine if an acceptable resolution can be achieved.

Where a resolution is not reached in a timely manner and the complainant is concerned that the potential conflict of interest still exists, the matter will be referred to the Managing Director/Board of Zar Mortgage Brokers for determination.

Where referral to the Board fails to reach an acceptable resolution to the complainant's satisfaction, the complainant will be informed in writing of Zar Mortgage Brokers position and that they can refer the matter to Zar Mortgage Brokers external dispute resolution scheme, Credit Ombudsmen Scheme Limited (COSL).

All stakeholders involved with the potential conflict of interest complaint will be kept informed in writing of any actions relevant to the complaint.


5. Status of Policy

This policy will be reviewed annually, or more frequently if changes to legal or regulatory requirements dictate.

Each representative is responsible for ensuring that they comply with this policy.


Anti-Money Laundering & Counter-Terrorism Financing Procedures


Zar Mortgage Brokers is subject to, and complies with, applicable Australian laws including the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 (the Act).


Under the Act, Zar Mortgage Brokers has adopted an AML/CTF Program consisting of a set of standards which set out how it identifies, mitigates and manages money laundering and terrorism financing risk.


Background to the Act

The Act received Royal Assent and came into effect on 12 December 2006, and is part of a legislative package that will implement reforms to Australia's AML/CTF regulatory regime. These reforms are designed to bring Australia in line with international AML/CTF standards. The Act is being introduced in phases over a two-year period. The Federal Government's Australian Transaction Reports and Analysis Centre (AUSTRAC) is responsible for overseeing and monitoring compliance of the Act. More information about the AML/CTF Act .

Our Aspirations

Through our AML/CTF Program we look to:

•  articulate, to customers and employees, Zar Mortgage Brokers commitment towards fighting money laundering and terrorism financing

•  protect Zar Mortgage Brokers, our customers and our employees from becoming a victim of, or an accomplice to, illegal activities

•  define how Zar Mortgage Brokers will govern itself under the AML/CTF Act and associated laws

•  promote ethical and professional standards within the Bank and broader financial sector

•  adopt “better practices” that satisfy our regulatory obligations in a sustainable manner.


Money laundering

The primary goal of criminals is to make money. Often criminals use financial institutions to conceal their illegitimate funds with the aim of making ‘dirty money clean' – known as money laundering.


The process of money laundering is generally completed over three stages:


1. Dirty money is ‘placed' into the financial system.

2. A series of transactions provide a ‘layering' effect to hide the origin of the funds.

3. Funds are ‘integrated' back into the economy and appear to be lawful.


Zar Mortgage Brokers will continue to work with AUSTRAC and the broader financial industry to curtail money laundering activity.


Terrorism financing

The financing of terrorism is the financial support, in any form, of terrorism or of those who encourage, plan, or engage in terrorism.


Those who finance terrorism transfer funds in such a way that the ultimate use, which is the support of terrorism, is concealed. The funds may be either legal or illegal in origin.


Business relationships with those who finance terrorism or other closely associated persons or entities could expose Zar Mortgage Brokers to significant reputation, operational and legal risk.



Identification and reporting of suspicious matters


Zar Mortgage Brokers will look to identify customers or employees behaving in a suspicious way. There are many different ways of identifying suspicious matters. Time and again, it's often a number of factors that may raise suspicion. Some situations that may be considered suspicious could include:

•  the unusual nature or circumstances of an interaction with a customer

•  a knowledge of the customer's background

•  the customer's transaction

•  the business of the person involved.

Zar Mortgage Brokers has the relevant policies and procedures in place to ensure any suspicious customer activities or transactions are reported to AUSTRAC.



Outlined in the table below are the key roles and responsibilities for the management and governance of Zar Mortgage Brokers AML/CTF Program -



Board Oversight

Mark Lewis will have ongoing oversight of the AML/CTF.

AML/CTF Compliance Officer

Mark Lewis for Zar Mortgage Brokers has been designated the AML/CTF Compliance Officer for Zar Mortgage Brokers.



Our AML/CTF policy principles

1.Zar Mortgage Brokers operates an AML/CTF Program that:


•  meets the AML/CTF Act and associated laws

•  Is supported by policies and procedures to combat money laundering and terrorism financing

•  is monitored and tested to ensure policies and procedures remain effective and are adhered to

•  supports the achievement of AML/CTF best practices.


2.Zar Mortgage Brokers will identify and report suspicious behaviours by:

•  ensuring authorities receive the necessary information to further investigate any illegal activities

•  educating our employees so they can identify, monitor and report suspicious matters

•  ensuring our employees are aware that suspicious matters are not limited to financial transactions

•  submitting, when appropriate, suspect transaction reports to AUSTRAC.


3.Zar Mortgage Brokers will endeavour to protect itself from being used for illicit activities by:

•  conducting customer identification and verification processes to ensure our customers are who they say they are

•  only dealing with legitimate customers and ensuring our products and services are not being utilised by money launderers, terrorist financers or anybody that chooses to support these types of individuals

•  carrying out ongoing customer due diligence.


4. Zar Mortgage Brokers will manage Employee Due Diligence by screening all prospective and existing employees, contractors and temporary employees.


5. Zar Mortgage Brokers will retain all relevant records for seven years should any investigations related to unlawful activities be conducted.


6. Zar Mortgage Brokers AML/CTF training program will ensure employees receive relevant and ongoing training. The program will provide an awareness of money laundering and terrorist financing, indicate how to identify and report a suspicious matter and inform our employees of our regulatory obligations under the AML/CTF Act.


Privacy Policy


Zar Mortgage Brokers seeks to provide the best possible service to its customers by providing the best possible range of financial products and services.

We understand how important it is to protect your personal information. This document sets out our Privacy Policy commitment in respect of personal information that you may provide to us.

We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy. It is important to us that you are confident that any personal information we collect from you or is received by us will be treated with appropriate respect ensuring protection of your personal information.

Our commitment in respect of personal information is to abide by the National Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.



Zar Mortgage Brokers is an organisation that offers financial products and services within the mortgage industry. We process and assess information in respect of loan applications. We locate funders suitable to provide loans to you. We also market other products.



When we refer to personal information we mean information from which your identity is apparent. This information may include information or an opinion about you, from which your identity can reasonably be ascertained.



We collect and receive personal information from our customers or from other business referrers in order to conduct our business, including assessing and obtaining approval for loans. From time to time we may offer other products and services.

To enable us to maintain a successful business relationship with you, we may disclose your personal information with other organisations that provide products or services used or marketed by us. The types of organisations to which we are likely to disclose information about you include other mortgage intermediaries, lenders, valuers, lenders mortgage insurers, surveyors, accountants, credit reporting agencies, and lawyers. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your loan, or in our business.



Where reasonable and practical we will collect your personal information only directly from you.



Where possible, we will inform you, at or before the time of collecting your personal information, the types of organisations that we intend to disclose your personal information to.

Prior to disclosing any of your personal information to another organisation, we will take all reasonable steps to satisfy ourselves that:

(a) the organisation has a commitment to protecting your personal information at least equal to our commitment; and

(b) you have consented to us doing so.

Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court or Tribunal in response to a request or in response to a subpoena or to the Australian Taxation Office.



From time to time we may use your personal information to provide you with current information about mortgage loans, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with.

If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our offices by telephoning 1800 180 927 or by writing to us at Zar Mortgage Brokers, Privacy Officer, PO Box 6221, Mitchelton 4053 . We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.



It is important to our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.



We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.

To access personal information that we hold about you, use the contact details specified above. We may charge a fee for our costs in retrieving and supplying the information to you.



There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.

An explanation will be provided to you, if we deny you access to your personal information we hold.



In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where, it is lawful and practicable to do so, we will offer you the opportunity of doing business with us, without providing us with personal information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.

Where sensitive information is collected, stored, used or transferred about you, we will only use this information if you have consented or in the exercise or defence of a legal claim. Sensitive information is information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional association or trade unions, sexual preferences, criminal record, or health.



We will take reasonable steps to protect your personal information by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.

We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.



You may request further information about the way we manage your personal information by writing or emailing.



We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

As a consequence we may change this Privacy Policy from time to time or as the need arises.

This Privacy Policy came into existence on 1/7/2010 .


Internal Dispute Resolution Process

1) Contact Mark Andrew Lewis 0405 780 870 or Gary William Lewis 0433 118 284

2) Mark or Gary will attempt to resolve dispute over the telephone.

3) If the dispute is not resolved over the telephone, a written letter or email is required detailing all complaint issues.

Zar Mortgage Brokers

Complaints and Compliments

PO Box 6221

Mitchelton Qld 4053

Email: or

4) A response will be given within 48 hours to confirm receipt and to advise the dispute is under investigation.

5) A written response will be made within 31 days of receipt of the complaint.

6) If resolution is not achieved, referral to COSL on 1800 138 422 or 02 9273 8400.


We are obliged prior to providing credit assistance to ensure the proposed transaction is not
Credit Assistance is given when we:
suggest that a consumer apply for a loan, an increase to a loan, or a lease with a particular credit provider;
suggest that a consumer stay with an existing lender or lessor; or
assist a consumer to apply for a loan, an increase to a loan, or a lease with a particular credit provider.
Unsuitable - to determine whether proposed credit is unsuitable, we must:
make reasonable enquiries about the consumer’s requirements and objectives;
make reasonable enquiries about the consumer’s financial situation; and
take reasonable steps to verify that financial situation.
Credit will be unsuitable if at the time the preliminary assessment is made, it is likely that:
the consumer will be unable to pay or could only pay with substantial hardship; or
the credit will not meet the consumer’s requirements and objectives;
if the consumer enters the credit contract, lease contract, or the principal sum is increased within the time for which the preliminary assessment applies (up to 90 days).
In order to make this assessment, we are required to establish our own credit policy. The key elements of our credit policy are:
the consumer’s requirements and objectives;
loan to value ratio (LVR); and
the consumer’s financial position – enquiries and verification.
Rather than develop our own discrete policy, because the proposed credit also needs to fit within the requirements of our panel of credit providers, our credit policy will comprise a combination of all our panel credit providers’ credit policies.
Each time we approve a new credit provider, or a credit provider changes its credit policy, we will
review that credit provider’s policy and in particular review the four key elements listed above.
We will make our own assessment as to whether each particular policy is appropriate.
When each credit provider’s credit policy is approved, that policy is added to our ‘approved policy list’.
As a consequence, our credit policy is ‘if an application fits the policy of any approved credit
provider, then that credit will comply with our credit policy and the credit should not be unsuitable’.
As a result of each credit provider’s policy being reviewed prudently, the mere fact that a particular application only fits the criteria of one of those credit providers does not mean that that credit is unsuitable.
In addition to what is written in these policies, we need to be alert to the special circumstances of each consumer and each proposal for credit which may make a particular credit unsuitable.
A written record (which may be electronic) will be made of each preliminary credit assessment specifying the period it covers.