1. Purpose

This Referral Partner Standard (Standard) sets out the role, scope and limitations applicable to referral partners who introduce clients to Steadfast Life Pty Ltd (Steadfast Life, We or Us).

The primary purpose of this Standard is to clearly delineate “mere referral” activity from regulated financial services activity, and to ensure that all referral arrangements are structured, documented and supervised in a manner that protects our clients and supports our compliance with the relevant laws.

Referral arrangements present heightened regulatory risk. Activities described as introductions may, in substance, constitute financial product advice, arranging or dealing. Unstructured referral fee structures may contravene conflicted remuneration requirements.

It’s not simply a matter of technical compliance. Marketing or co-branding may mislead our clients about who is providing advice.

ASIC scrutiny focuses on substance over form.

Accordingly, this Standard centralises and controls referral risk and forms a core component of our Compliance Framework.

2. Mandatory Referral Agreement

No referral arrangement may commence unless, and until, a written Referral Agreement has been executed by Steadfast Life and the Referral Partner.

To be clear, verbal, informal or implied referral arrangements are prohibited. Any verbal, informal or implied referral arrangements currently in place were immediately and irrevocably terminated by the publication of this Standard.

Our Referral Agreement:

• Defines the scope of permitted referral activities.
• Prohibits the provision of financial product advice, dealing or arranging.
• Sets out remuneration terms and disclosure requirements.
• Requires compliance with this Standard.
• Provides audit, monitoring and termination rights.

It protects your interests as well as ours.

Critically, referral fees are only payable where a valid, current Referral Agreement has been executed. We will not pay any remuneration for any referral made contrary to this Standard.

Further, any referral made in breach of this Standard, outside the scope of permitted activities or in contravention of the executed Referral Agreement is automatically void for remuneration purposes.

Furthermore, Steadfast Life has no obligation to pay, and expressly disclaims liability for, any referral fee arising from non-compliant conduct, regardless of whether a policy is ultimately issued.

If remuneration was paid before non-compliance was identified, we reserve our right to claw back, set off or otherwise recover any referral fee paid in connection with the non-compliant referral. Referral Partners must promptly repay such amounts upon written demand.

3. Status of Referral Partners

Referral Partners:

• Are not our authorised representatives.
• Must not provide financial product advice.
• Must not deal in or arrange financial products.
• Must not represent that they act on our behalf.
• Must not hold themselves out as authorised by us.

All communications must clearly state that the Referral Partner is not authorised to provide financial product advice and that advice is provided by Steadfast Life under its own Australian Financial Services Licence.

For the avoidance of doubt, this Standard governs the Referral Partner's activities solely in the context of this referral arrangement with Steadfast Life. It does not limit or affect the Referral Partner's authority to provide financial services under their own Australian Financial Services Licence.

4. Permitted Activities

Referral Partners may:

• Inform a person that Steadfast Life provides life insurance advice services.
• Provide our contact details.
• Disclose that they may receive a referral fee, where applicable.
• Only provide Steadfast Life-approved content.
• Facilitate an introduction by passing contact details with documented client consent.

Referral Partners must not:

• Recommend a product or insurer.
• Compare policies.
• Express an opinion about suitability.
• Pre-qualify clients for insurance.
• Assist in completing applications.
• Negotiate premiums or policy terms.
• Arrange cover.
• Collect underwriting information.
• Use language implying endorsement or recommendation.

If a Referral Partner is asked product-specific or suitability questions, they must state that they are not authorised to provide advice and offer to arrange contact with Steadfast Life.

5. Marketing and Communications

Referral Partners must ensure that their marketing, websites and communications:

• Do not imply that they provide life insurance advice.
• Clearly identify Steadfast Life as the advice provider.
• Do not present our services as their own offering.
• Do not use co-branding in a manner that creates ambiguity about who provides advice.
• Do not use Steadfast Life’s logo or branding without our prior written approval.

Referral Partners must not tailor marketing communications based on knowledge of individual clients' circumstances. All client-facing communications must use general statements only.

Steadfast Life will provide pre-approved marketing templates and referral campaign materials that Referral Partners may use immediately without further approval. These materials must be used as provided and must not be materially altered.

Where a Referral Partner wishes to use marketing or communications outside of the pre-approved materials, those materials must be submitted to Steadfast Life for approval before use. Steadfast Life will review submitted material sent to distribution@steadfastlife.com.au within 48 hours of submission.

6. Remuneration and Conflicts

Referral remuneration must:

• Be structured to minimise conflicted remuneration risk.
• Not incentivise product recommendation.
• Be disclosed to clients prior to referral.

Referral Partners must not describe remuneration in a misleading manner or imply independence where a financial benefit is received.

7. Privacy and Client Consent

Before transferring client information, Referral Partners must:

• Obtain express written consent.
• Disclose the purpose of disclosure.
• Disclose any referral fee arrangement.

Referral Partners must not collect sensitive information for underwriting purposes.

All handling of personal information must comply with the Privacy Act 1988, the Australian Privacy Principles and Steadfast Life’s Privacy Policy.

8. Supervision and Monitoring

Steadfast Life will:

• Approve scripts and marketing materials.
• Conduct periodic compliance reviews.
• Review public representations.
• Require annual compliance attestations.

Referral Partners must maintain records of referrals and evidence of client consent.

9. Training

Referral Partners must complete training prior to making referrals, including training on:

• Advice versus factual information boundaries.
• Conflicts and remuneration disclosure.
• Privacy and consent requirements.

10. Breaches and Escalation

Referral Partners must notify Steadfast Life immediately of any actual or suspected breach of this Standard.

Steadfast Life may suspend referrals, withhold remuneration, require remediation or terminate the Referral Agreement.

11. Regulatory Framework

This Standard incorporates:

• Corporations Act 2001
• ASIC Act 2001
• National Consumer Credit Protection Act 2009, where applicable
• AML/CTF Act 2006
• Privacy Act 1988
• Relevant ASIC Regulatory Guides including RG 104, RG 175, RG 181 and RG 234
• ASIC INFO 208 and INFO 212

12. Document Control