Objective

The objective is to ensure that persons who have concerns about SERVICE ONE Members Banking's (SERVICE ONE's) non-compliance with legal, regulatory or ethical standards can raise their concerns freely either internally or externally and to ensure that such persons are not victmised for raising these concerns.

Definitions

The following definitions apply for the purposes of this Policy.

Whistleblowing
Means the deliberate and voluntary disclosure of information about the improper conduct of any SERVICE ONE director, senior manager, employee, auditor or professional service provider to SERVICE ONE, relating to an actual, suspected or anticipated wrongdoing within or by SERVICE ONE that is within SERVICE ONE's ability to control.

Whistleblower
Means any person who makes or attempts to make a disclosure about improper conduct.

Improper conduct
Means:

1. Corrupt conduct
2. Fraudulent activity
3. Conduct relating to the fitness and propriety of a SERVICE ONE Director, Senior Manager or Auditor
4. A substantial mismanagement of SERVICE ONE resources
5. Misleading or deceptive conduct in advertising or selling of any SERVICE ONE product or service
6. Conduct involving substantial risk to public health or safety, or
7. Conduct involving substantial risk to the environment.

In addition, any of the above conduct, if proven, must amount or lead to:
a) A criminal offence
b) Breach of a prudential, financial reporting or other regulatory obligation of SERVICE ONE
c) Reasonable grounds for dismissing the person who engaged in the conduct. who was, or is, engaged in the improper conduct, or
d) Reasonable grounds for disciplinary action.

Protected disclosure
Means any good faith communication based on reasonable grounds that discloses or demonstrates an intention to disclose information that may evidence improper conduct.

SERVICE ONE personnel
Means:

1. Any SERVICE ONE Director
2. Any SERVICE ONE Senior Manager
3. Any SERVICE ONE Employee
4. Any SERVICE ONE Auditor, and
5. Any professional service provider for SERVICE ONE.

How Do You Make a Disclosure?

If a SERVICE ONE Member or a member of the public considers that any SERVICE ONE personnel is involved in improper conduct, they must follow this procedure.

1. In the first instance, they must make a report to the CEO.
2. If they consider the CEO is involved in the improper conduct, they must make a report to the Chair of the Audit and Compliance Committee.
3. If they consider the Chair of the Board or any Director is involved in improper conduct, they must make a report to the Internal Auditor. The Internal Auditor has been retained as an Independent Whistleblower Service Provider to SERVICE ONE.
4. If they consider either a SERVUCE ONE auditor or their officers are involved in improper conduct, they must make a report to APRA.

The contact details of the above are provided at the end of this Policy.

If any person is in doubt whether they can make a disclosure, it is recommended that they first discuss the matter informally with the person to whom they are required to make a report under this Policy. That person will be able to advise them on whether the matter is within the scope of this Policy or whether the matter ordinarily would be viewed as one of normal commercial business judgment or opinion (and therefore not a matter of a breach of SOMB's compliance or ethics policies).

Can I make a disclosure anonymously?

Yes, you can. However, it is recommended that the whistleblower reveal their identity when making a disclosure. It is easier for SERVICE ONE to protect the whistleblower and carry out any necessary investigation more effectively.

What evidence do I require for my disclosure?

Documentary evidence of the whistleblower's concern is desirable to enable an investigation to start. At the least, the whistleblower will need to be able to tell the person receiving the disclosure, the person who is suspected to be involved in the improper conduct, when it occurred and who was affected.

The more evidence the whistleblower is able to provide, the more effective the investigation of their concern is likely to be.

What follows after a disclosure is made?

A disclosure will be investigated as soon as practicable. The investigator will take all reasonable steps to ensure that investigations into disclosures are fair and unbiased. This means that:

1. Any person who may be affected by the investigation will be given the opportunity to put their case and to be aware of the allegations and evidence against them
2. If necessary, the investigator will obtain specialist, independent advice on matters outside their knowledge or expertise, and
3. Investigations will be carried out as fast as reasonably practicable and with a degree of confidentiality consistent with the seriousness of the allegations raised.

The investigator will keep detailed records of all interviews conducted and all records reviewed during the investigation.

At the end of the investigation, the investigator will submit a report to the Audit and Compliance Committee. This report will summarise the conduct of the investigation and the evidence collected, draw conclusions about the extent of any non-compliance, and recommend action to remedy the non-compliance and ensure that it does not recur.

Protection for the Whistleblower

This Policy forbids any SERVICE ONE personnel from acting in a way that penalises, victimises or that can be reasonably construed as penalising any person who has made a disclosure or intends to make a protected disclosure under this Policy.

Any person who receives a disclosure will do everything reasonably possible to ensure that the identity of the whistleblower is kept secret during the course of any investigation and until the outcome is made public.

However, such protection cannot be guaranteed in the following circumstances, for example:

1. If the whistleblower has informed other persons of the fact they have made a disclosure or their intention to make a disclosure
2. Where the investigation leads to charges being made in court, or
3. Where the nature of the allegations is such that the identity of the whistleblower can be deduced from the disclosure made.

As soon as possible after the first disclosure the person who receives the disclosure will discuss the issue of confidentiality with the whistleblower and the degree of risk that their identity will become known.

Any person who receives a disclosure will advise the whistleblower promptly if matters change in a way that affects SERVICE ONE's ability to protect the whistleblower's identity and will give the whistleblower as much warning as reasonably possible if it appears likely to the person who receives the disclosure that the whistleblower's identity will become known.

Can I Make a disclosure to a regulator directly?

If for any reason a SERVICE ONE Member or member of the public feels they cannot make a disclosure in accordance with the procedure outlined above, they may make a disclosure directly to a regulator including the Australian Prudential Regulation Authority (APRA), the Australian Securities and Investments Commission (ASIC), the Australian Competition and Consumer Commission (ACCC) or the Privacy Commissioner

Contacts
Mark your disclosure "PRIVATE AND CONFIDENTIAL"

Peter Carlin
SERVICE ONE CEO
SERVICE ONE Members Banking
75 Denison Street, Locked Bag 1
DEAKIN, ACT 2600
Ph: (02) 6215 7140
Fax: (02) 6215 7171
Email: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

John Clarke
Chair, Board of Directors
SERVICE ONE Members Banking
75 Denison Street, Locked Bag 1
DEAKIN, ACT 2600
Ph: (02) 6215 7140
Fax: (02) 6215 7171
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Erik Adriaanse
Chair, Audit & Compliance Committee
Service One Members Banking Ltd
75 Denison Street, Locked Bag 1
DEAKIN, ACT 2600
Ph: (02) 6281 1170
Fax: (02) 6215 7171
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Steve Baker, WalterTurnbull
Internal Auditor - Independent Whistleblowing Services Provider
44 Sydney Avenue
BARTON, ACT 2601
Ph: (02) 6247 6200
Fax: (02) 6257 6655
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The Secretary
Australian Prudential Regulation Authority
Level 26, 400 George Street
SYDNEY, NSW 2000 or
PO Box 9836
SYDNEY, NSW 2001
Fax: 612 9210 343

ASIC Complaints
Australian Securities & Investments Commission
PO Box 9149
TRARALGON, VIC 3844
Fax: (03) 5177 3749

Freedom of Information Officer
Australian Competition and Consumer Commission
DICKSON, ACT 2602
Ph: (02) 6243 1244
Fax: (02) 6243 1210
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The Privacy Commissioner
GPO Box 5218
SYDNEY, NSW 2001
Ph: 1300 363 992
TTY: 1800 620 241
Fax: (02) 9284 9666
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