Continuous Professional Development Policy

Introduction

The Heron Partnership Pty Limited ( Heron ) recognises the importance of the training and development of our staff so that they excel in their roles and in the services provided to our clients. We believe our employees are fundamental to the success of our firm and we encourage our staff to continue to enhance their skills and abilities.

This CPD Policy applies from 1 January 2019.

All Heron staff authorised to provide personal advice, as authorised by our Australian Financial Services Licence (252538), to our retail clients, are expected to comply with this Policy.

Purpose

This policy embeds a CPD framework and outlines the CPD requirements under Corporations Amendment (Professional Standards of Financial Advisers) Act 2017 (Cth) and Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018, which requires all individuals identified as 'relevant providers' to meet the requirements for CPD set by the FASEA.

This document outlines the overarching CPD policy and provides a summary of the relevant provider requirements.

This CPD policy embeds the following principles:

• CPD maintains currency of technical knowledge
• CPD enhances and extends knowledge and skills
• CPD involves critical reflection and development
• CPD is relevant and flexible
• CPD is integral to ethical and professional practice

Definition

Relevant staff member: a person is a relevant staff member, for the purposes of this Policy, if the person:

1. is an individual; and
2. (b) is:
   1. (i) a financial services licensee; or
   2. (ii) an authorised representative of a financial services licensee; or
   3. (iii) an employee or director of a financial services licensee; or
   4. (iv) an employee or director of a related body corporate of a financial services licensee; and
3. (c) is authorised to provide personal advice to retail clients, as the licensee or on behalf of the licensee, in relation to relevant financial products.

Responsibility

Our Senior Actuary has the responsibility for ensuring the maintenance, regular review and update of this Policy.

Continuous Professional Development (CPD)

CPD Training Platform

Heron will continue to utilise the Kaplan Ontrack platform to assist in managing CPD. This platform enables Heron to add approved training material, track the progress of relevant staff, creates reports and provides necessary evidence of adequate CPD management.

CPD Plans

CPD Plans for each relevant staff member, aligned with the requirements of the FASEA, developed on a pro‐rata bases for the first 18 months to 30 June 2020, and annually thereafter, will be approved by the Heron Board.

CPD Obligations of Relevant Staff Members

The total minimum target is 40 hours of qualifying CPD per CPD year. Qualifying CPD activities must include a minimum in the following areas:

CPD Areas

A CPD activity must relate to one of the following CPD areas:

Maximum Restrictions

In any CPD year, no more than the specified hours in each activity below may be counted as follows:

• 30 hours of formal relevant education
• 4 hours of professional or technical reading

Assessment and Approval of CPD Plans

Heron CPD Policy assessment, approval, management and review details and responsibilities is detailed in the following table.

Qualifying CPD Activities

70% of all CPD activities undertaken by relevant staff members must be assessed and approved by the Senior Actuary. Heron will permit relevant staff members to undertake their CPD Activity through:

• In-house training/workshops by internal and external trainers;
• Via Kaplan Ontrack CPD platform and content provider;
• Attendance at relevant external professional developments days and workshops;
• Formal relevant education (provided by an education provider) including degree equivalent study to meet legislative requirements (such as bridging courses and approved degrees) and any relevant formal qualifications and designations – maximum 30 hours per annum;
• Non-formal education including for the purposes of achieving a relevant professional designation, for the purposes of meeting requirements in specific financial advice provision and for the purposes of accreditation in specific form of financial products relevant to licensing arrangements;
• Completing other professional development activities for example those provided by professional associations, product providers and other financial services industry participants; and
• Professional and technical reading.

Approval of Qualifying CPD Activities

70% of all CPD activities undertaken by relevant staff members must be assessed and approved by the Senior Actuary.

Assessment of qualifying CPD activities

A CPD activity must meet and provide evidence of the following requirements to be approved as a 'qualifying CPD activity':

• Clearly defined aims and learning outcomes;
• Is current, accurate and up-to-date;
• Relates to one of the FASEA CPD areas;
• Is the appropriate learning level and has appropriate technical or practical content;
• Deals primarily with matters related to the provision of financial product advice, financial advice services and financial advice business;
• Is led or conducted by one or more persons with appropriate expertise, academic qualifications and practical experience;
• Enhances advisers' knowledge and skills, and/or contributes to the maintenance of knowledge and skills in areas relevant to the provision of financial product advice and financial advice services;
• Includes one or more of the following: workshop, face-face presentation, multimedia, worked examples, activities, case studies, tips, warnings, and if appropriate, reference to relevant legislation; and
• Hours are allocated on a basis of the estimated time taken to complete all activity components (including presentation, workshop, discussion, video and/or multimedia) plus the completion of any assessment. Every one minute competed will equal one minute CPD.

Evidence requirements

For approval to be granted for a 'qualifying CPD activity' the following evidence is required:

• Name of the activity and the provider;
• Date the activity was undertaken;
• Activity outcomes & training material provided;
• Name of the person/s presenting the activity and bio or CV if appropriate;
• The FASEA CPD areas and knowledge areas to which it relates;
• The duration in minutes/hours of the activity;

Kaplan Ontrack and pre-assessed content from professional associations will automatically receive approval. All remaining CPD activities will require approval from either the Senior Actuary. Activities will be denied if any of the requirements are not met.

Record Keeping

The Kaplan Professional Ontrack platform will be used to record the completion of CPD activities. CPD plans will specify each relevant provider's:

• individual overall CPD target;
• minimum requirements in each CPD area;
• any other specific requirements that must be met;

The platform will monitor individual progress and provide reporting.

For CPD activities undertaken and completed outside the Ontrack platform, each individual relevant staff member is required to upload details into Ontrack and submit evidence for assessment and approval to the Senior Actuary.

It is the relevant staff member's responsibility to maintain complete and accurate records within Ontrack.

Monitoring

Monitoring of the completion of CPD requirements by each relevant staff member will be undertaken using the reporting functionality of Ontrack on a quarterly basis.

Non-compliance

A relevant provider must comply with the CPD obligations specified in this policy.

Failure to meet the specified requirements requires the licensee to notify ASIC of the relevant providers non-compliance with the continuing professional development standard (922HB, Corporations Amendment (Professional Standards of Financial Advisers) Act 2017).

CPD Policy Version March 2019