Learning & Development Policy

MARCH 2022

Purpose

Lorica Partners Pty Limited, AFSL 237314, (the Licensee) is required to develop and adopt a Continuing Professional Development Policy, Pursuant to section 5 of the Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018. This requirement is addressed within this policy.

Lorica Partners (LP) is committed to providing a supportive and rewarding environment for employees and recognises that the behaviours, capabilities, and mindset of employees are inextricably linked to LP's achievement of its mission and strategic goals.

The purpose of the Learning and Development Policy is to encourage and support employees to actively pursue their career development as an integral element of their employment with LP. LP acknowledges that continuing development contributes to personal job satisfaction, workplace productivity, reward and recognition.

This policy applies to all LP employees on fixed term and ongoing appointments and sets out the principles that underpin career development at LP.

Policy Statement

LP will identify organisational goals and priorities. LP will develop and implement a range of strategies and programs to enhance and build the behaviours, capabilities, and mindset of employees to enable them to contribute effectively to LP's mission and strategic goals. LP is committed to providing employees with:

  • The opportunity to develop capabilities that contribute to organisational and team goals.

  • The opportunity to develop a career plan and participate in career development activities that extend and enhance their capabilities and capacity for advancement within LP.

  • Equity of access to development opportunities.

The Managing Director is required to plan and prioritise the development needs of LP employees in alignment with organisational goals. Consideration will ensure equity and access to all staff in planning and determining career development opportunities. Employees are encouraged to take an active role in their own ongoing development and to apply their learning to its most effective use.

Representatives must:

  • develop and maintain a CPD Plan on a continuing basis;

  • complete at least 40 hours of CPD activity in each CPD Year, 70% of which must be approved by the Licensee;

  • maintain a continuous, up-to-date, and accurate record of their CPD activities, including evidence of completion of any CPD activity; and

  • provide those records to the Licensee to allow the Licensee to monitor compliance with the CPD standards.

The Licensee, via the Managing Director, will make appropriate resources and opportunities available to the representative to enable the representative to meet its CPD requirements.

Principles

The principles that underpin the provision of career development at LP comprise:

  • Acknowledging CDP requirements for Representatives, as well as other professional bodies to support and encourage opportunities for continuous learning.

  • Applying the principle of merit or achievement relative to opportunity to determine equity of access to development programs, resources and support.

  • Recognising that responsibility for development is shared between employees and the Managing Director for the planning and undertaking of development relevant to their roles and responsibilities.

  • Ensuring the provision of learning and development that meet the core requirements of LP's and employees' roles and responsibilities and that comply with statutory obligations and LP policies.

  • Ensuring alignment between individual, team, and organisational plans and priorities and identifying individual and team learning and development needs of employees.

  • Evaluating employee participation, learning outcomes and the relevance and quality of development programs on an ongoing basis.

Employees and the Managing Director should consider a range of development activities to enhance organisational and individual development and capabilities. Development programs include orientation, induction, and on-the-job training; career development; participating in internal projects or external committees, networking, coaching and mentoring programs.

The Managing Director will ensure the provision of resources for development including allocation of funding for development.

The development year

The development year, inclusive of the CPD year, is a 12-month period beginning on the day of the year determined by the Licensee.

LP has determined that its CPD year will commence on 1 July.

The Licensee will notify ASIC of the day on which the Licensee’s CPD year begins within 30 business days of the day that the Licensee made the determination.

The Licensee may decide to change the Licensee’s CPD year if it has not previously notified ASIC of its CPD year within the preceding 12 months.

If the Licensee changes its CPD year it will:

  • notify its representatives in writing;

  • notify ASIC of the new day on which the Licensee’s CPD year begins within 30 business days of the day that the Licensee made the determination; and

  • update this Policy.

Procedures

Internal Development Provision

The Managing Director has primary responsibility for the provision of LP wide learning and development programs and activities.

Internal learning and development programs will be informed by LP's strategic goals and priorities.

Individual Development Plans

An important component of LP's performance, planning and development process is the planning and discussion of the employee's career development such as undertaking professional development (short courses or conferences), further studies, undertaking a secondment, on-the-job training, study visit or other Continuing Professional Development activities. It is recommended that each employee develops, in consultation with the Managing Director, an Individual Development Plan, and that the employee, actively implement and summarise progress and outcomes of the plan at least annually.

The Managing Director has the responsibility to ensure the effective planning, support, monitoring and implementation of Individual Development Plans.

Induction

LP provides an induction program for new employees to ensure access to:

  • Information on LP's Vision, Mission and Strategic Plan; compliance, statutory and policy framework; organisational structure; Code of Conduct and Ethics and core values; and conditions of employment; and

  • Support, development and training in core skills or capabilities required for the carrying out of duties related to the position.

Continuing Professional Development

Continuing Professional Development (CPD) facilitates the recognition of employees as a professional group.

A representative will prepare a CPD plan prior to the start of each CPD year and lodge the plan with the Licensee. The Licensee may assist the representative to prepare the CPD plan.

The CPD plan may be amended at any time, subject to the Licensee’s approval of any amendments.

The CPD plan will:

  • assess the representative’s training needs, having regard to the specific financial services and products that are relevant, particularly if the representative’s functions change;

  • identify areas for improvement, including any training gaps or weaknesses in the preceding year, in the representative’s competence, knowledge and skills;

  • set objectives to be met (being, the desired changes in the adviser’s knowledge, skills and/or performance at the end of the training year); and

  • describe the CPD activities the provider will complete during the CPD year to achieve those improvements and objectives.

If a representative has not been practising or authorised as a representative for a continuous period greater than two years, the Licensee must not approve a CPD plan unless it is satisfied that it is appropriate to address gaps in the adviser competence, knowledge and skills arising from the provider’s absence from practice. The representative will not be permitted to provide financial product advice on behalf of the Licensee until the CPD plan has been approved by the Licensee.

If a representative is appointed after the start of the Licensee’s CPD year, the representative’s CPD plan must be prepared no later than 3 months after the date that the representative is authorised.

  1. Minimum number of hours

Representatives must complete a minimum of 40 hours of qualifying CPD activities during a CPD year. At least 70% of a representative’s minimum CPD hours must be approved in writing by the Licensee in accordance with FASEA requirements.

In special circumstances, part-time representatives may reduce their CPD requirement to a minimum of 40 hours of qualifying CPD activities with the Licensee’s prior written consent.

A minimum of 24 hours of CPD during the CPD year will be allocated to the following five qualifying CPD activities in accordance with FASEA requirements:

Qualifying CPD Activities Minimum Hours

Technical Competence  5 hours

Client Care and Practice  5 hours

Regulatory Compliance and Consumer Protection  5 hours

Professionalism and Ethics  9 hours

The balance of CPD hours must consist of qualifying CPD activities covering the activities listed in FASEA’s CPD Legislative Instrument.

If the Licensee’s first CPD year starts on a date after 1 January 2019, the minimum number of CPD hours to be completed between 1 January 2019 and the end of the Licensee’s first CPD year is increased on a proportionate basis.

For example, where the Licensee’s first CPD year commences on 1 July 2019, the representative will be required to complete 60 hours of CPD between 1 January 2019 and 30 June 2020.

2. Approval of Qualifying CPD Activities

The Licensee will either:

  • provide in-house CPD approved by the Licensee; or

  • select qualifying CPD activities provided by external providers approved by the Licensee.

A representative may request the Licensee’s approval for a qualifying CPD activity.

The Licensee will approve a minimum of 70% of the representative’s minimum CPD requirement (i.e. 28 hours of a full time representative’s CPD activities and 26 hours of a part time representative’s CPD activities) per CPD year.

3. Criteria for approval

The Licensee may approve a proposed CPD activity if it is satisfied that the proposed CPD activity meets the following criteria, in accordance with FASEA’s CPD Legislative Instrument:

  • the activity covers one of the areas listed in section 6;

  • the activity consists of one of the types of CPD listed in section 7;

  • the activity (other than technical or professional reading) is conducted or lead by persons who have sufficient standing, expertise, academic qualifications and practical experience;

  • the content of the activity is of sufficient intellectual and/or practical content;

  • the activity primarily addresses matters related to the provision of financial product advice; and

  • the activity is designed to enhance the representative’s knowledge and skills in areas relevant to the Licensee’s authorisations to provide financial product advice.

The Licensee must also consider FASEA’s guidelines on CPD when approving a proposed CPD activity.

4. New representatives

A new representative may not be authorised to provide financial product advice on behalf of the Licensee until the Licensee has approved the representative’s CPD plan for the first CPD year after the representative’s appointment.

The Licensee will also require a new representative to produce CPD records prior to appointing the representative to provide financial product advice on behalf of the Licensee.

In addition to the criteria above, if the representative has not practised as a financial adviser for a continuous period of 2 or more years prior to its appointment, the Licensee may only approve the representative’s CPD plan if the Licensee has satisfied itself that the CPD plan appropriately addresses gaps in the representative’s competence, knowledge and skills.

Please also refer to the Appointing, Supervising and Monitoring Representatives Policy.

5. Qualifying CPD activities

CPD in the following areas will be counted towards a representatives’ CPD requirements:

  • technical competence – improving the representative’s technical ability to develop and provide advice strategies appropriate to retail clients’ objectives, financial situation and needs;

  • client care and practice – covering the representative’s ability to act as a client-centric financial adviser;

  • regulatory compliance and consumer protection – improving the representative’s understanding of its legal obligations and how it complies with those obligations;

  • professionalism and ethics – acting as an ethical professional; and

  • general – covering activities designed to maintain and extend professional capacity, knowledge and skill not otherwise covered by the specific CPD areas listed above.

If a CPD activity covers more than one of the above areas, the CPD activity may be counted towards all the areas covered. However, the representative may not “double count” the CPD hours for the purposes of total CPD hours.

6. Types of CPD

a) CPD sessions

Sessions and workshops at conferences and Professional Development days may be counted towards the representative’s CPD requirements.

b) Professional or technical reading

A representative may count professional or technical reading towards meeting the CPD requirement, to a maximum of 4 CPD hours per CPD year.

c) Formal education

Formal relevant education towards qualifications and designations relevant to the financial services the representative is authorised to provide may be counted towards the representative’s CPD requirement, to a maximum of 30 CPD hours per year.

Formal relevant education can include study undertaken by the representative to meet statutory education requirements, such as a degree in a relevant discipline or bridging courses. 

d) Non-formal education

The representative may count hours spent in education that the representative has undertaken to:

  • achieve a relevant professional designation (e.g. Certified Financial Planner, Fellow Chartered Financial Practitioner);

  • meet requirements in specific financial advice provisions; and

  • achieve accreditation in a specific financial product that the Licensee is authorised.

e) Leading or conducting a qualifying CPD activity

A representative may count hours spent leading or conducting a qualifying CPD activity.

Short Courses and Conferences

An employee may attend a short course or conference that is directly relevant to the employee's work, CPD requirements or development with the support of the Managing Director. Support will be in the form of granting work time to attend the short course or conference and/or a contribution towards the registration fee and travel costs.

Where an employee is required and directed by LP to undertake a course essential for carrying out their current duties, the cost of participation will be covered by LP. Where the employee initiates a request to attend a course or conference that is relevant to the employee's work, the Managing Director may approve a contribution towards the total cost of participation.

Employees seeking to attend a short course or conference should discuss this with the Managing Director outlining:

  • Description of the course or conference.

  • Expected outcomes from participating in the course or conference.

  • Costs and financial assistance applied for to attend the course or conference.

  • Recommendation and support for participating in the course or conference by the line supervisor.

Internal Secondment

A secondment provides an eligible employee with a career development opportunity to extend their skills, knowledge or experience in another position usually in another area of LP. Where a vacancy is advertised internally for a specified period of time and an employee applies and is recommended by as the preferred applicant, the employee may request a secondment to the position.

External Secondment or External Exchange

An external secondment is an arrangement made with the mutual consent of LP and an employee where LP agrees that the employee can work with another employer (host organisation) for a specified period of time and under specific agreed conditions. The opportunity for a secondment or exchange or other forms of career development should be discussed by the employee with their supervisor at the time of the annual performance, planning and development meeting and form part of the employee's Individual Development Plan.

An external exchange is a placement of a LP employee with another LP or organisation either in Australia or overseas. External exchanges normally involve a reciprocal visit by a staff member from the other organisation or LP. The conditions of an external exchange must be negotiated and agreed by both organisations including details of functional placement, cost responsibilities and insurances.

All full-time or part-time employees who have completed a minimum of the equivalent of 12 months' full-time continuous service and who have satisfactorily met performance expectations may apply for a secondment or exchange.

Study Visit

An employee may be eligible to undertake a study visit to another similar organisations nationally or internationally. A study visit is usually of short duration from a few days to two weeks where an employee undertakes a study visit to a similar organisation. The purpose of a study visit is to further the employee's learning ad development and study other business practices, processes or systems to support the implementation of improvements or organisational change initiatives at LP.

All full-time or part-time employees who have completed a minimum of the equivalent of 12 months' full-time continuous service and who have satisfactorily met performance expectations may apply for a secondment or exchange.

Education Support

An employee undertaking an approved formal award course may be eligible for education support in the form of paid study leave, exam leave and/or an education support allowance. Education support is available to full-time or part-time employees who have completed a minimum of the equivalent of 12 months' full-time continuous service and who have satisfactorily met performance expectations. The approved study and relevance of the course to the employee's career development should be discussed with and agreed to by the Managing Director.

Study Leave

An employee may apply for paid study leave to undertake an approved formal award course.

The maximum study leave entitlement is 15 hours per annum. If the time needed exceeds this amount, the balance should be taken from other forms of leave such as annual leave.

Exam Leave

Employees enrolled in an approved formal award course will be granted paid leave to undertake an examination. Exam leave is additional to any study leave granted and must be requested.

Education Support Allowance

LP will provide support to employees enrolled in an approved formal award course through payment of an Education Support Allowance. The Education Support Allowance may be used to assist with course fees, purchase of textbooks or course materials.

The Education Support Allowance is to be approved by the Managing Director.

The Education Support Allowance will be paid via the payroll as a taxable allowance and will be paid after the census date for the semester the employee is enrolled in. The employee must provide the original receipt of fees paid.

Records

A representative must maintain records of:

  • the qualifying CPD activities the representative undertakes;

  • when the qualifying CPD activities were undertaken;

  • how many hours were spent on each qualifying CPD activity;

  • evidence of completion of and outcome of each qualifying CPD activity; and

  • the progress of implementation of the representative’s CPD plan.

The representative must make those records available to the Licensee at the Licensee’s request.

The Licensee will maintain a record of training, including qualifying CPD activities, that each of its representatives has undertaken after that person became a representative, and any training undertaken before that person became a representative to the extent that the Licensee can obtain that information after reasonable inquiry.

To demonstrate compliance with the CPD standards, the Licensee will:

  • keep written records of each representative’s CPD plan. The CPD plan must be updated at least annually and address the elements contained in section 3 of this Policy;

  • keep evidence of their representatives’ CPD activities, including Certificates of Completion, receipts, enrolment records, attendance lists, detailed diary notes; and

  • maintain the Licensee’s Training Register.

All written records will be kept for a period at least 7 years after the representative ceases to provide financial services on behalf of the Licensee.

Monitoring compliance

It is the responsibility of the representative to ensure that it satisfies its CPD obligations.

The Licensee will periodically review the representatives’ ongoing CPD status.

Depending on the location of the representative, this may be performed by a meeting or telephone conversation between the representative and Compliance Officer. The Licensee may require the representative to produce documents and records in support of its CPD performance.

The Licensee will:

  • assess whether the representative is meeting the objectives of the CPD plan; and

  • provide feedback sessions with the representative about their performance.

The Licensee will also undertake an annual review immediately following the end of the CPD year to assess whether the representative has complied with its CPD plan and determine whether the representative has complied with the CPD standard during the CPD year.

If a representative fails to comply with its CPD plan or meet the minimum number of CPD hours, the Compliance Officer must report such failure to the Responsible Managers. This report should include any rectification plan that will remedy the failure.

Reporting non-compliance to ASIC

If, at the end of the Licensee’s CPD year, the Licensee determines that a representative has not complied with the CPD standard during the Licensee’s CPD year, the Licensee must lodge a report with ASIC within 30 business days of the last day of the Licensee’s CPD year.

Definitions

For the purpose of this policy:

  • Lorica Partners Pty Limited, (the Licensee) is referred to as the LP.

  • Learning and Development includes the provision of learning and development opportunities and activities to extend and broaden the scope of capabilities of employees in relation to their role and reLPonsibilities. Development activities build on the collective knowledge and experience of employees and provide employees with opportunities to acquire, practice and adopt new knowledge, thereby enhancing individual, team and organisational learning and capabilities. Within this context:

    • Capabilities refer to the combination of attributes, qualities, skills, knowledge and understanding of ethical principles that underpin the professional practices of employees and that enable a person to perform to a high standard in a given context and role.

    • Development refers to the process of enabling employees to plan their careers and engage in career development activities that will improve their career proLPects and job progression or promotion.

    • Career Management refers to the process of actively planning, managing, developing and evaluating one's career.

    • Continuing Professional Development (CPD) facilitates recognition of employees as a professional group and reflects a commitment to demonstrating high professional standards, building professional capabilities, continuous quality improvement in work practices, and optimising career opportunities.

  • The primary professional group, Representatives, means the:

    • employees and directors who provide financial services on behalf of the Licensee;

    • Responsible Managers; and

    • Authorised Representatives.

  • Approved formal award courses are courses that lead to a national qualification issued in the higher education sector and that are recognised under the Australian Qualifications Framework (AQF). Approved formal award courses must be relevant to the employee's current position or career and have significant value to both the individual and to LP.

  • Short Courses are courses of short duration that are normally from half a day to five days in length, run on consecutive days or over a period of time, offered by an external provider and which would not normally lead to a qualification under the AQF.