Our discussions with you
We aim to have open and honest discussions with you to keep your compliance activity progressing according to plan. We will generally discuss with you the information we need and the risks identified, together with any information-gathering concerns we have.
This cooperative approach allows both parties to raise issues in a timely manner. Ongoing and open discussions about our information requirements help us to:
- better understand your circumstances
- keep the process as simple as possible and avoid unnecessary escalation.
During these discussions, we will explain your rights and obligations and our approach to information gathering, including escalation processes. In addition, we may discuss:
- our risk hypothesis and how it determines the information being sought
- the nature of your information systems and record keeping
- who has custody or control of the records and where they are kept
- the circumstances that would cause us to use a formal approach.
We may also reach a common understanding about:
- the level of cooperation we expect and the circumstances where we believe this cooperation is not being met
- protocols for the supply of information
- timeframes for information gathering and the consequences of not meeting them
- how documents covered by legal professional privilege, the accountants' concession or corporate board advice concession will be handled
- arrangements to interview staff.
Where key personnel are available for interview and are willing to provide full and frank responses to our questions, we will generally not issue a formal notice requiring them to attend and give evidence.
We may also ask for details of:
- what information is available, including information held in an electronic format
- key personnel with knowledge of the risks we have identified
- authorised company contacts, including the contact person for information requests
- how you prefer to give the information.