1.1 Other compliance personnel
(a) Responsible Managers
• ZM’s ACL Responsible Manager is Leonie Chapman
• ZI’s AFSL Responsible Managers are Nicola Henderson, Alan Greenstein and Anthony Kalaf
(b) Responsible persons
Key managers have the primary responsibility for effecting compliance with this Compliance Plan and are referred to in this Compliance Plan as “Responsible Persons”.
Responsible Persons must:
• understand, and act in accordance with Zagga’s obligations;
• understand, and assume responsibility for, their obligations under the Compliance Plan and for rectifying any breaches;
• identify, with the assistance of Zagga’s Legal and Compliance, compliance obligations and ensure that these compliance obligations are embedded into the relevant business systems and administrative procedures;
• report and …show more content…
Risks are identified through consultation with key business resources.
(b) Step 2 – Identification of risks – likelihood and impact assessment
The likelihood and impact of the risk is assessed from a stakeholder (primarily client) perspective.
(c) Step 3 – Identification of risks – treat risk based on assessment
The results of step 2 enable appropriate risk management strategies to be developed and prioritised. Once identified and assessed, risks are treated appropriately:
• Accepted – Zagga is aware of the risk and has controls in place to monitor the risk.
• Rejected – The risk is considered too high so Zagga will avoid the risk by not engaging in the relevant activity.
• Transferred – The risk can be transferred to another party, for example through insurance cover.
• Reduced – The risk is identified and Zagga has implemented controls to reduce the risk. For example, through the segregation of duties to reduce possibility of internal fraud or disclosure in the event of conflict of interest.
(d) Step 4 –
(a) Responsible Managers
• ZM’s ACL Responsible Manager is Leonie Chapman
• ZI’s AFSL Responsible Managers are Nicola Henderson, Alan Greenstein and Anthony Kalaf
(b) Responsible persons
Key managers have the primary responsibility for effecting compliance with this Compliance Plan and are referred to in this Compliance Plan as “Responsible Persons”.
Responsible Persons must:
• understand, and act in accordance with Zagga’s obligations;
• understand, and assume responsibility for, their obligations under the Compliance Plan and for rectifying any breaches;
• identify, with the assistance of Zagga’s Legal and Compliance, compliance obligations and ensure that these compliance obligations are embedded into the relevant business systems and administrative procedures;
• report and …show more content…
Risks are identified through consultation with key business resources.
(b) Step 2 – Identification of risks – likelihood and impact assessment
The likelihood and impact of the risk is assessed from a stakeholder (primarily client) perspective.
(c) Step 3 – Identification of risks – treat risk based on assessment
The results of step 2 enable appropriate risk management strategies to be developed and prioritised. Once identified and assessed, risks are treated appropriately:
• Accepted – Zagga is aware of the risk and has controls in place to monitor the risk.
• Rejected – The risk is considered too high so Zagga will avoid the risk by not engaging in the relevant activity.
• Transferred – The risk can be transferred to another party, for example through insurance cover.
• Reduced – The risk is identified and Zagga has implemented controls to reduce the risk. For example, through the segregation of duties to reduce possibility of internal fraud or disclosure in the event of conflict of interest.
(d) Step 4 –