Quality Assurance in BPO Process Outsourcing

Governance

Structure

• Board Oversight: Felcorp Support maintains oversight through a designated risk and compliance committee. This committee meets every 3 months to discuss risks, review reports and set up mitigation strategies.
• Local Compliance Leads: Appointed local compliance officers in India and Philippines to report to the compliance committee.
• Cross-Jurisdictional Policy Alignment: Our policies are standardised across jurisdictions with local adaptations as required.

Roles and Responsibilities

• C-Suite Executives: Accountable for overall compliance and risk identification across all jurisdictions.
• Middle management (Line and division managers) - responsible for identifying client and staff risk and escalating it to senior management.
• Allocated staff (your allocated staff team) - responsible for some risks specifically around decision making upon client's practice and advice compliance areas. It is middle management's responsibility to regularly audit compliance of the allocated staff.
• Human Resources - Responsible for identifying specific staff risk as well as organisation-wide staff risk.

Expectations of Clients

Below are the expectations Felcorp imposes on clients operating in financial services. Please note that this is not the entire list of expectations, but rather expectations relating to regulatory compliance.

• Heightened duty of care - Felcorp classifies that financial advisers have a heightened duty of care over other areas of Felcorp clients. It is the adviser's responsibility to be accountable for the advice provided to their client, the instructions given to all Felcorp staff and their own organisation and time management.

• Sole responsibility for compliance-related activities - Felcorp classifies that financial advisers are exclusively responsible for all regulatory, licensee and advice compliance activities.
• Sole responsibility for advice review - It is the adviser's exclusive responsibility that they review the work produced by Felcorp staff and undertake diligence and care when reviewing documents.
• Responsibility for workflow management - It is the adviser's responsibility that they are across their workflow, delegate tasks appropriately and take the initiative to follow up tasks that have missed their deadlines.

• Expectation to support and lead staff to success- Felcorp expects that financial advisers deal with Felcorp staff truthfully and assist them to help prevent them from making mistakes.
• Expectation to prevent Felcorp staff from making unauthorised decisions - Felcorp expects that financial advisers do not lead Felcorp staff to make financial advice decisions, practice management or compliance decisions.

• Expectation to prevent Felcorp staff from making illegal or dangerous decisions - Felcorp expects that financial advisers do not lead Felcorp staff to make actions that could implicate Felcorp in illegal activities or end up harming the staff physically or mentally.

Expectations of Felcorp Support

Below are the expectations upheld by Felcorp that supports the provision of advice-related tasks. This is not our full list of expectations. The full list can be found in our Terms of Service document.

• Responsibility to train staff on adviser obligations - Felcorp has a responsibility to ensure allocated staff are aware of financial adviser and licensee obligations but are not responsible for such obligations.

• Responsibility that staff are trained and competent to perform their functions - It is our responsibility to assess the skills of each staff member and evaluate their skillset competency, ensure they meet the minimum competency standard as per the scope of work and designation (junior, intermediate, senior etc).

• Responsibility to provide daily or real-time workflow progress of tasks prepared by Felcorp - It is our responsibility to report on all workflow tasks prepared by Felcorp staff on at least a daily basis.

Risk Management

Framework

Felcorp's risk management strategy is informed by a formal Governance, Risk, and Compliance (GRC) approach, aligning with ISO 31000 and the expectations of Australian regulatory bodies. Our framework is designed to provide structured processes to identify, assess, manage, and monitor risks arising from offshore operations and business processes.

Key components include:

• Maintenance of a centralised risk register covering financial, operational, cyber, reputational, legal, compliance, and human resource risks.
• Quarterly risk assessments and annual enterprise-level risk reviews.
• Integration of control assurance and effectiveness reviews as part of internal audits.
• Embedding of risk accountability through clearly defined roles, with escalation processes built into team management structures.
• Proactive use of internal analytics and performance benchmarking
• Risk reporting integrated with Board and Committee governance cycles.

Governance Structure:

• Risk and Compliance Committee: Meets quarterly to review risks, incidents, and mitigation performance.
• Line Managers: Own day-to-day risk identification and resolution in workflows.
• C-Suite executives: Track risk trends and maintain register integrity.
• Staff: Participate in risk identification and escalation processes through designated reporting channels.

Risk Mitigation Measures

• Mandatory bi-annual compliance training with additional targeted CPD requirements based on benchmarking outcomes.
• Regular audits (monthly operational checks, quarterly internal audits, and annual independent assurance reviews).
• Ongoing IT security audits and enforced use of DMARC/DKIM/TLS protocols.
• Enforced use of secure internal systems for data and communication.
• Systematic access controls, endpoint encryption, and VPN policy enforcement.
• Integration of job performance and policy adherence reviews into bi-annual staff performance evaluations.
• Governance, Risk and Compliance dashboard monitored by senior leadership to ensure centralised reporting,

Regulatory Compliance

Corporations Act 2001 (Cth):

For Felcorp staff that operate within Australian financial services industry the following applies:

Offshore personnel must act under the direct supervision of the Client (AFSL holders or authorised representative of the AFSL), ensuring no unauthorised provision of financial services. This framework upholds the general obligations of AFSL holders under section 912A, which include:

• Acting efficiently, honestly and fairly;
• Maintaining the competence to provide financial services;
• Ensuring that representatives are adequately trained and comply with financial services law;
• Having in place adequate risk management systems;
• Maintaining the resources (including financial, technological and human) to carry out operations in compliance with the Act. (This is a stipulation of our Terms of Service) For Felcorp Support in the provision of offshore staff we must:
• Establish clear delegation and supervision activities to demonstrate AFSL or authorised representative control over offshore personnel.
• Maintain records of training, quality assurance and competency reports.
• Ensure that any or all financial product advice is not materially altered, incorrectly implemented or processed by offshore personnel that is inconsistent with the formal advice document on file or agreed-to file notes.  

ASIC Regulatory Guidance

• RG 104.34 – Responsibility for outsourced functions: Felcorp acknowledges that the Client (AFSL and the Authorised Representative) remains ultimately responsible for all outsourced activities. Felcorp does not operate under an AFSL or is bound by financial advice obligations as we are not licensed or ever purport to be.
• RG 104.85 – Training standards of admin support and paraplanners: Felcorp acknowledges that the Client remains responsible for all financial services provided under their licence. However, Felcorp will undertake the responsibility that Felcorp admin support and paraplanning staff are trained and competent to perform their role and functions (RG 104.85(a)(i)).
• RG 146.18 – Training standards of personnel not providing financial advice: Felcorp acknowledges that persons who do not provide financial product advice are not required to meet the training standards. While Felcorp staff do not provide advice, we will take the responsibility to train staff to an adequate and competent standard that is in line with the scope of service, role designation (junior, intermediate, senior, etc.), and the desired skillset as directed to us by the Client.

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CPA and APESB

For Felcorp staff that operate within Australian accounting industry the following applies:

Felcorp delivers accounting outsourcing services in accordance with the relevant professional and ethical standards issued by CPA Australia, Chartered Accountants ANZ, and the Accounting Professional & Ethical Standards Board (APESB), specifically APES 320 Quality Management for Firms and APES GN 30 Outsourcing.

While Felcorp is not a registered tax agent or public practice firm in Australia, we recognise and uphold the compliance responsibilities of our clients (registered public practice firms, tax agents, and other regulated accounting service providers).

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1. APES 320 – Quality Management for Firms

Felcorp acknowledges that the Client — being the registered practice or tax agent — remains ultimately responsible for compliance with APES 320 and the quality of professional services provided to their clients.
Felcorp:

• Maintains internal quality management systems designed to support the Client’s compliance with APES 320 requirements.
• Implements documented processes for risk assessment, resource allocation, staff supervision, and ongoing performance review.
• Ensures that all services delivered are within the agreed scope of work and meet professional and ethical standards.

2. APES GN 30 – Guidance Note on Outsourced Services

Felcorp acknowledges that the Client retains responsibility for the outcome of all outsourced services. In line with APES GN 30, Felcorp will:

• Establish clear agreements outlining the scope of services, quality expectations, and reporting requirements.
• Maintain robust confidentiality, data security, and information-handling procedures in line with professional obligations.
• Ensure that all outsourced activities are delivered to a standard that enables the Client to meet their professional and legal responsibilities.

3. Competency and Training of Personnel

Felcorp undertakes to ensure that all accounting and support personnel:

• Are trained and competent to perform their allocated roles and functions in line with the Client’s expectations and professional standards.
• Receive role-specific induction, technical training, and ongoing skills development aligned with APES 320 principles.
• Work under supervision and quality review processes to ensure accuracy, compliance, and ethical conduct.

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Australian Privacy Principles (APPs) – Privacy Act 1988 (Cth)

For all BPO operations within Australian jurisdiction:

Felcorp complies with the 13 Australian Privacy Principles as set out in Schedule 1 of the Privacy Act 1988 (Cth), ensuring the proper handling of personal information in all offshore and onshore operations. Specifically, Felcorp will:

• Only collect personal information that is necessary for agreed services, and do so lawfully and fairly (APP 1–3).
• Obtain informed consent where required and clearly communicate the purpose of collection (APP 5).
• Ensure personal information is accurate, up-to-date, and complete (APP 10).
• Implement secure storage, access controls, and encryption to protect data from unauthorised access, modification, or disclosure (APP 11).
• Allow individuals access to their personal information and provide correction mechanisms upon request (APP 12–13).
• Not disclose personal information to overseas recipients unless authorised by the Client or compliant with APP 8 cross-border disclosure requirements.
• Maintain a publicly available Privacy Policy that sets out how Felcorp manages personal information in line with all 13 APPs

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Implementation Activities

• Monitoring: Continuous oversight of staff productivity through automated timesheet and project tracking systems.. Real-time data collection on task completion and turnaround times supports proactive performance management.
• Audits: Random quality assurance audits and spot checks are conducted regularly to assess service accuracy, document integrity, and adherence to client protocols and internal procedures. These audits are supported by peer reviews and escalation procedures for identified issues.
• Feedback Loops: Formalised feedback channels with Australian-based AFSL teams provide continuous input on service quality, compliance observations, and client satisfaction. Insights are used to adapt processes and training initiatives.
• Technical Skill Assessment: All offshore personnel undertake mandatory technical skill assessments aligned with their functional role. Based on results, a personalised training program is implemented to bridge any gaps. Staff are required to complete a minimum of 40 hours of annual professional development to sustain and enhance their competence.
• Workflow Management: The workflow management portal offers real-time visibility into applications and implementation tracking. Clients and supervisors have a centralised dashboard showing task statuses, staff actions, and workflow analytics, ensuring full transparency and traceability.
• Management Supervision: Each staff member is assigned to a line and division manager responsible for daily supervision and workflow oversight. Tasks are peer-reviewed, and a structured escalation process is in place to address bottlenecks and inconsistencies in quality.
• Business Interruption Mitigation: Standardised processes, documented workflows, training videos, and centralised resource libraries ensure knowledge continuity. These tools support rapid resumption of operations in the event of disruption and reduce onboarding time for new staff.