Financial Services Guide

About this Guide

• The services we can offer you
• How we and our associates are remunerated
• How we manage conflicts of interest
• Our internal and external dispute resolution procedures and how you can access them

If you are a client and we give you personal advice, we will provide you with a Statement of Advice (where required by law) or a record of our advice. Any Statement of Advice or record of advice we provide will set out our advice, the basis of our advice and information on any remuneration, associations or other interests, which might reasonably have influenced our advice.

If you are a retail client then before we either arrange an insurance policy for you, or we provide advice to you recommending that you buy a particular insurance policy, we will give you a Product Disclosure Statement to so do. It is prepared by the insurer and is designed to give you important information on the features, benefits and risks of the policy to assist you in making an informed decision about whether to buy the product or not. It may be more than one document.

The Financial Services covered by this Financial Services Guide (FSG) are provided by:

SRG Group Pty Ltd trading as SRG Corporate and the following of its Authorised Representatives who act on its behalf in providing the Financial Services set out in this FSG:

Owen Bray, Authorised Representative Number 259676

Jenny Manuel, Authorised Representative Number 409205

SRG Group Pty Ltd and the Authorised Representatives are, unless stated otherwise, referred to in this FSG as “we” or “us” and can be contacted at:

SRG Corporate Wembley Green Building, Units 14-16, 127 Herdsman Parade WEMBLEY WA 6014
PO Box 2115 CHURCHLANDS WA 6018
Telephone: 1300 551 969
Facsimile: 08 9442 1111
Email: info@srgcorp.com.au

Our ABN Number is 52 113 333 109 and our AFS Licence Number is 288320.

A Guide to Our Relationship with You and Others

What Services can we Provide?

SRG Group Pty Ltd is an Australian Financial Services Licensee and are licensed under the Corporations Act to advise and deal in relation to all general insurance products.

Each of the Authorised Representatives has been authorised by SRG Group Pty Ltd to provide financial product advice on and deal in general insurance products on its behalf under its licence.

We can act in a number of roles in providing our services.

We usually act on your behalf. However in some cases, we may act on behalf of the insurer or their representative or on our own behalf (e.g. as a referrer to another service provider). We tell you if this is the case as this means we do not act for you when we provide the service.

Our Services

This is where we arrange for the application, acquisition, variation, renewal or cancellation of an insurance policy for you. The process differs depending on the type of insurance and we explain it to you when you apply for the insurance.

Providing Advice to You

There are two types of advice service we provide and it is important to understand the difference:

• Personal Advice - this is advice provided by us to you on the suitability of general insurance policies to meet your particular needs. We will agree with you when this service is to be provided and what the scope of our personal advice will be. For example, in some cases we may only provide personal advice on which of a selected list of products is appropriate for you. Before we provide any personal advice we will need to undertake a needs analysis so we can provide you with appropriate advice.
• General Advice - this is where we provide a general recommendation or opinion to you on a general insurance policy which is not based on our consideration of your personal needs. We tell you when this is the case because if general advice is given you need to consider if the general advice and any relevant product is right for your circumstances as we have not done this for you.

Acting for Insurers

In some circumstances we may have an agreement with an insurer or their representative to arrange insurance policies on their behalf and not on your behalf. This means that we act for and in the interest of the insurer as our principal in providing the services, not yours.

If we are given a "binding authority" from an insurer, this means we can enter into insurance policies and/or handle or settle claims on their behalf without reference to them, provided it is within the authority they have given us. We will tell you when we act for an Insurer and not for you.

Claims Assistance

We can also assist you when you need to make a claim. If a claim occurs contact us and we can help you decide what to do. We do not do anything without your consent. We provide this assistance as part of our overall service for no separate charge unless we tell you otherwise. We don't provide this service if we no longer act for you.

Any claims documentation, insurance company settlement cheques and other information received by us on your behalf will be provided to you as soon as reasonably practicable.

Premium Funding

In some cases insurers require the full premium payment up front. Premium funding is one way of not having to pay your premium in one lump sum. You will, however, have to pay interest to the premium funder on the amount borrowed.

We and Austbrokers Holdings Limited (ABN 60 000 000 175), have a preferred supplier arrangement with Pacific Premium Funding Pty Limited ("Pacific") for the arrangement of premium funding. In arranging premium funding with Pacific, or any other premium funder, we do not provide personal advice or represent that any of the funder's products and services are right for you or that they are the most appropriate. You need to make your own decision based on the information provided.

Variety of Services

It is important to note that given the wide variety of general insurance products available and the need to remain competitive we may provide a variety of the above services to you and act in a variety of roles.

For example, where you require a number of different covers we may provide personal advice for some products you need and act on your behalf in relation to them. For others we may only provide you with general advice and for others only act as agent of the insurer not you. We can provide a further explanation of why this is the case and we make sure we tell you what the service is and our role before or at the time we provide the service.

Ask us if you need more detailed information or do not understand our explanation.

How can you give us instructions?

You need to give us instructions in writing by letter or fax or by another method agreed by us. We will tell you what is possible when you contact us.

What information do we maintain about you and how can you access it?

We maintain a record of your personal profile. That record contains information about insurance policies that we have arranged for you. The record may also contain details of your objectives, financial situation and needs collected for the purpose of giving you personal advice. We also maintain records of any recommendations made to you.

We are committed to implementing and promoting a Privacy Policy, which will ensure the privacy and security of your personal information. A copy of our Privacy policy is located on our website at www.srgcorp.com.au.

If you would prefer to have a copy mailed to you, please ask us. If you wish to access your file please ask us.

Renumeration

When we act for you in advising on and/or arranging insurance

When we act on your behalf in advising on or arranging insurance we can be remunerated in a number of ways. They can vary according to the service you require and/or our arrangements with the relevant insurer or their representative.

We are remunerated by:

• commission from the insurer
• fees we charge you
• remuneration from an insurer based on the profitability or volume of the business we place with them; or
• a combination of the above.

Where the financial services are provided by any of the authorised representatives, SRG Group Pty Ltd will be entitled to the relevant remuneration, but will pay the Authorised Representative a percentage of the commission it receives and any fees charged.

Commission paid by the insurer to us

Unless we tell you in writing that we will provide our service on a "Fee Only - no commission" basis, we are remunerated by commission from the relevant insurer whenever you enter into an insurance policy arranged by us (including renewal and some variations which increase the premium payable).

The commission is a percentage of the insurer's base premium (i.e. premium excluding stamp duty, fire services levy, GST or any other government charges, taxes, fees or levies). Different insurers can agree to pay us different commission rates for the same type of products. The rates also vary for each product type.

The commission does not represent our profit margin as it also reimburses us for administrative and other expenses we incur in providing our services. The commission is included in the premium amount set out in your invoice and we receive it when you pay the premium or at a later time agreed with the insurer.

If we act on your behalf and you cancel a policy and obtain a refund of premium, you agree that we can keep our commission. (even when you exercise a cooling off right). If we didn't do this we would not be properly paid for the services we provide to you.

Other remuneration arrangements we have with insurers

We are also a member of the Austbrokers Group of insurance brokers.

Austbrokers Holdings Limited (ABN 60 000 000 715) (AHL) and IBNA Limited (ABN 43 086 563) are joint owners of A & I Member Services (AIMS) a company that provides marketing, distribution and training services to members of the Austbrokers and IBNA Groups. Some insurers pay a commission to AIMS on selected products arranged by Austbrokers member insurance brokers which is an agreed percentage of the base premium (before government fees or charges). Different insurers may pay different commission rates to AIMS.

This money funds the provision of AIMS services to Austbrokers and IBNA members, We, other Austbroker Group Members and IBNA members benefit from this support and it helps ensure we can continue to provide you with our extensive range of services.

Although SRG Group Pty Ltd receives the benefit of these arrangements the Authorised Representatives receive a percentage of them depending on the amount of business they have arranged with the insurer during the relevant period.

If you have any queries or want more information please do not hesitate to contact us.

SRG Group Pty Ltd are participants in the QBE Insurance (Australia) Limited (ABN 78 003 191 035), Allianz Australia Insurance Limited (ABN 21 000 006 226) and the Zurich Australian Insurance Limited (ABN 13 000 296 640) programs, which include profit share components. The amount of the profit share is variable and is determined by the amount of premium earned when compared with the claims experience within applicable portfolios. The profit share is calculated and received on an annual basis. It is possible that the underwriting profit of policies arranged by us will not reach the required amount in which case we would receive no profit share.

As part of the Zenith Program, we are entitled to $5,000 annually from Zurich Australian Insurance Limited that must be spent on training and developments.

See below for soft dollar benefits we may also receive from insurers and our policy on this.

Fees Paid by You

Unless we specifically agree in writing before providing our services to charge on a "Fee Only - no commission" basis, the fees will be paid in addition to any commission we receive. We may charge you:

• a broker fee - this is an administration fee payable when you enter into an insurance policy
• a pre agreed set amount for specific services
• an amount based on a pre agreed rate for the time we spend providing the service; or
• on some other basis agreed with you before we provide the service

Credit Card Fees

If you pay by credit card we will charge you a credit card fee, which is added to the amount shown on the invoice and is nonrefundable.

This fee reimburses us for extra charges / costs and internal time generated for credit card use. The fee charged for payments made on VISA or MasterCard is 1.5% inc GST and on American Express is 3.3% inclusive GST

Where we act for the insurer

Where we act for an insurer, not you, we receive commission from the insurer as our principal and may also charge you an administration fee. The amount of the fee will vary depending on the complexity and type of services that we provide you with. The fee is payable when you buy the policy or at such earlier time as we agree with you in writing. It is noted in the invoice we send you and is not refundable (even where you exercise a cooling off right).

Where there is a referral

Where a third party has referred you to us, we may pay them an agreed percentage of our remuneration or an agreed amount for the referral as a commission or fee. This amount will be paid after we have arranged insurance for you. A commission or an agreed fee may also be paid on renewal and in some cases on variation.

If we refer you to another service provider we will be remunerated by them by way of a commission or fee for doing this unless we tell you we are not. The amount is generally a percentage of their remuneration the amount of which may depend on the circumstances. A commission or an agreed fee may also be paid on renewal and in some cases on variation.

In making any referral we do not advise or represent that their products and services are right for you and take no responsibility for the products and services they may provide to you. You need to make your own decision based on the information they provide.

Our staff's remuneration

Our staff receive an annual salary that may include bonuses based on performance criteria (including sales performance) and achievement of company goals. They may also receive certain soft dollar benefits or remuneration for arranging premium funding described further below.

Receipt of soft dollar benefits policy

From time to time we and our representatives may also receive what are commonly referred to as "soft dollar benefits" from product issuers and other financial service providers we deal with.

These can include entertainment (e.g. lunches, sporting events, movies etc), conferences (e.g. attendance at a product issuer conference or sponsorship of our Austbroker Group Annual conference by a product issuer), accommodation and travel, business tools (e.g. software), gifts (e.g. product issuer or service provider branded promotional items and other occasional small gifts such as bottles of wine or hampers on special occasions etc).

These benefits are provided by a wide range of product issuers and service providers. In most cases they relate to our development of an understanding of the product issuer and/or service provider and their product ranges and practices etc. Ultimately, this assists us in better servicing and representing you.

Our policy is that any of the above received by us or our representatives that exceed $300 per item or transaction in estimated value are potentially material.

This means they must be disclosed to our Conflicts Manager in writing. The Manager determines if appropriate procedures are in place to manage or avoid any potential conflict of interest which might arise. They only approve benefits where this is the case and retain a record of this which you can access on request.

The above restriction does not apply to conferences or functions, the principal purpose of which is professional development and where the right to attend is not based on sales volumes.

Premium Funding

If you use Pacific, we receive (a) a commission which is a percentage of the amount of funding provided to you; (b) a payment based on a percentage of all loans arranged each month; (c) a payment based on a percentage of certain fees and interest received by Pacific on the total amount of outstanding loans less certain expenses; and (d) a proportion of certain upfront payments received by Austbrokers Holdings Limited from Pacific based on the value of loans arranged with Pacific in an agreed period when compared with those arranged by other Austbroker members. We are owned partly by Austbrokers Holdings Limited and benefit from any profit made by this entity due to this arrangement.

If you need more information or explanation of the above, please ask us.

Austbrokers Holdings Ltd (ABN 60 000 000 715), have a preferred supplier arrangement with Pacific Premium Funding Pty Limited ("Pacific") for the arrangement of premium funding. In arranging premium funding with Pacific or any other premium funder, we do not provide personal advice or represent that any of the funder's products and services are right for you or that they are the most appropriate. You need to make your own decision based on the information provided. If you use Pacific, our authorising licensee receives

(a) a commission which is a percentage of the amount of funding provided to you; (b) a payment based on a percentage of all loans arranged each month; (c) a payment based on a percentage of certain fees and interest received by Pacific on the total amount of outstanding loans less certain expenses; (d) a proportion of certain upfront payments received by Austbrokers Holdings from Pacific based on the value of the loans arranged with Pacific in an agreed period when compared with those arranged by other Austbrokers Brokers. Our authorising licensee is owned partly by Austbrokers Holdings and benefit from any profit made by this entity due to this arrangement.

If you need more information or explanation of the above, please ask us.

Further information about remuneration received by us or others

Where we don't provide you with personal advice as a retail client you can ask us to give you more particulars of our remuneration (including commission) or other benefits within a reasonable period after receiving this FSG and before we provide you with the financial service to which this FSG relates, unless we agree otherwise.

If we provide you with personal advice as a retail client, then at the time the advice is provided to you, or as soon as practicable afterwards, we will tell you either:

The amount of any remuneration (including commission) or other benefits we or other persons receive that might reasonably be expected to be, or have been capable of, influencing us in providing the advice; or

if the amount is not known, the manner of calculation.

Money Handling Arrangements

Do we have any relationships or associations with insurers or related bodies corporate that might influence our service or advice?

SRG Group Pty Ltd is a member of the Austbrokers group of insurance brokers.

In some cases we may refer you to or advise you to use the services of one of our related body corporates. They may act as agent of the insurer and you will be told when this is the case. As a member of the same corporate group we may indirectly benefit from any such referral or advice if it improves the group performance.

Please refer to our remuneration section for the normal benefits we can receive under such arrangements.

Conflicts of Interest

We take any potential conflicts of interest seriously and have a Conflict of Interest Policy which we and our representatives must comply with and you can access by contacting us. Compliance is audited on a regular basis.

Conflicts of interest are circumstances where some or all of your interests as our client, are or may be inconsistent with, or diverge from, some or all of our interests.

Our procedures and training are all designed to properly manage any conflict of interest and it is important to note that we have legal duties we owe you when we act as your professional adviser. We treat these very seriously.

A key conflict faced when we act on your behalf is where we receive benefits from someone other than you - this can potentially influence us to act in their or our interests rather than yours. Where we arrange a policy an insurer can pay us commission (see above for details). It is the major form of insurance broker remuneration and can create a potential conflict of interest because it may be in our interest to recommend the product issuer or service provider that pays us the most because it increases our remuneration. This may not be in your interest in certain circumstances.

Another key conflict is where we may be seen to favour the interest of one client or group of clients over another because it is in our interests to do so. Due to the extensive number of our clients and their varied requirements, we have a variety of procedures in place to manage these potential conflicts of interest. For example, we tell you about our remuneration arrangements in this Guide and you can ask for more detailed information if you need it before you proceed. If we provide you with personal advice we have a legal duty as a professional to put your interests ahead of our own and can only provide you with advice that is appropriate for you. This obligation also extends whereby we represent the interests of one or more clients involved in a transaction.

We and our representatives are trained in this important duty and compliance with it is monitored regularly. Should you have any questions, please ensure you ask us. Cooling Off Period A cooling off period may apply to an insurance policy issued to you as a retail client. During the period you may return the policy. Details of your cooling off rights are included in the relevant Product Disclosure Statement document. In some cases an insurer can deduct certain amounts from any refund.

Ask us if you do not understand the right.

Other Terms of our Service

You must read the Important Information about your insurance document we give you (tell us if you have not received it) and ask us if you have any questions or do not understand anything we have set out in that document. It will help you understand some important matters about your insurance.

Misstatement of Premium

We try to tell you the correct amounts of premium and statutory and other charges that apply to your insurance. In the event that we misstate that amount (either because we have made an unintentional error or because a third party has misstated the amount), we reserve the right to correct the amount. Where permitted by law, you shall not hold us responsible for any loss that you may suffer as a result of any such misstatement.

Professional Indemnity Insurance Arrangements

We and our representatives are covered under professional indemnity insurance that complies with the requirements of section 912B of the Corporations Act.

The insurance (subject to its terms and conditions) will continue to cover claims in relation to our representatives/employees who no longer work for us (but who did at the time of the relevant conduct).

Complaints and Disputes

If you have any complaints about the service provided to you, you should take the following steps.

Contact us and tell us about your complaint.

If your complaint is not satisfactorily resolved within 24 hours, please contact our Complaints Officer on telephone number (08) 9442 1107 or put your complaint in writing and send it to the Complaints Officer at: SRG Group Pty Ltd, PO Box 2115, CHURCHLANDS WA 6018.

Please mark the envelope "Notice of Complaint". We will try and resolve your complaint quickly and fairly.

If the complaint can't be resolved to your satisfaction within 20 business days, you have the right to refer the matter to the Financial Ombudsman Services (FOS). We will provide you with further details about FOS upon lodging your dispute with us, or at any time upon your request. If you have any further questions about this FSG, please contact us on (08) 9442 1107.

The distribution of this FSG by the named Authorised Representatives has been authorised by us.

Date: 01 August 2011 - Version 2.6