Governance and asset stewardship

About Us

Sandhurst Trustees (Sandhurst) is a wholly owned subsidiary of Bendigo and Adelaide Bank Limited (the Bank) and is part of the Bendigo and Adelaide Bank Group of companies (the Group). Sandhurst provides wealth solutions and services to the Bank and it’s customers.

The Bank’s vision is to be Australia's bank of choice. The Bank’s purpose is to feed into the prosperity of our customers and communities, not off it.

Like the Bank, Sandhurst has a strong focus on supporting people, communities and initiatives from which we draw our ongoing success.

Sandhurst was formed in 1888, with a long history of managing financial products for Australian investors. In 2018 Sandhurst celebrated a milestone of 130 years in business. Sandhurst had approx. $5.5 billion in funds under management with over 55,000 customers as at 31 March 2024. The Investment Team has over 60 years of investment experience and our Sandhurst Trustees Board (STL Board) has over 100 years of financial services experience.

As a modern full-service asset manager, Sandhurst undertakes several activities and roles in providing financial products and services to both retail and wholesale markets including:

• Managed funds
• Commercial loans
• Corporate trustee and custodial services

Sandhurst acts as the responsible entity for a number of registered managed investment schemes and undertakes some of the asset management activities of these registered schemes. 

Our embedded processes

Sandhurst has an established governance framework and policies which are designed to ensure it applies a sound governance approach, conducts its affairs with a high degree of integrity, and promotes a good governance culture. It is also designed to ensure that business decisions are in the best interests of customers, and that when making decisions the impact on customers is always considered.

All employees are required to comply with the frameworks and policies of the Group and Sandhurst, and to adhere to the highest standards of integrity and fair dealing. Sandhurst is committed to promoting a culture of compliance and ethical behaviour, where all our decisions, actions and behaviour reflect and reinforce our corporate values and purpose statement. We understand that it is important to continually improve outcomes for all our stakeholders.

The frameworks and policies include and are not limited to:

Code of Conduct

The purpose of the Code of Conduct is to ensure that we all have a common understanding of our values and expected standards of conduct. The Code, including our Corporate Values - Leadership, Teamwork, Performance, Engagement, Integrity, and Passion, captures the spirit of our organisation and provides a framework for all of us to use to guide our behaviour and decisions.

Risk Management

The recognition and management of risk is critical to our success. Sandhurst's regularly reviewed risk management framework represents the totality of systems, structures, policies, procedures, processes, and people that the business uses to identify, assess, manage, mitigate, and monitor all internal and external sources of inherent risk that could have a material impact on its business operations or customers.

Sandhurst's approach to risk management is inclusive of several risk areas, including financial risks: credit, market and investment, liquidity risks and non-financial risks: operational, governance and strategic risks. Sandhurst employs the 'three lines of defence model' in order to ensure effective risk management and control. Sandhurst uses many systems to measure and monitor investment risk to ensure alignment between investment returns and the investment objectives and benchmarks of our products.

The STL Board is responsible for ensuring a sound risk management culture and the risk management framework is in place at all times, to appropriately manage material risks to Sandhurst's business operations. It is recognised that all levels of Sandhurst's staff must take an active role in maintaining an effective risk management culture including identification and reporting of any actual or potential risk events.

Personal Trading

Our policies set out obligations that are imposed on all employees, contractors, consultants and directors regarding the laws governing the conduct for buying, selling and otherwise dealing in securities. The objective is to ensure the Bank and its representatives are beyond reproach in their dealings in the securities and inside information of the Group and include, as examples, adherence to blackout periods and trading restrictions as well as the forbidding of insider trading and front running.

Speak Up and Whistleblowing

Sandhurst is committed to promoting a culture of integrity and ethical behaviour, where our decisions, actions and conduct reflect and reinforce our corporate values. We understand that it is important to identify problems early to assist in improving outcomes for all our stakeholders. Our policies are designed to facilitate the resolution of concerns and offer protection to anyone who reports concerns in good faith under those policies.

Remuneration

Our remuneration programs are designed to attract, retain, and motivate employees to achieve the Bank’s strategic objectives, within our risk appetite and risk management framework. The guiding principles for the remuneration framework are:

• Strategy led reward;
• Reward balanced outcomes;
• Recognise people for their impact;
• Transparent and simple metrics; and
• Embedded risk management.

Customer Feedback

We love to hear from our customers whether it's a compliment, suggestion or an expression of dissatisfaction. It is important for us to know what we do well, and we are just as keen to hear when we have not met our customer's expectations.

We consider Internal Dispute Resolution (IDR) to be an important and necessary first step in the complaint handling process, as it gives us an opportunity to hear when we do not meet our customer’s expectations and address them genuinely, efficiently and effectively. We are also a member of an external dispute resolution (EDR) service, being the Australian Financial Complaints Authority (AFCA).

Training and Development

Our policies stipulate that staff have adequate experience and qualifications. They ensure staff are competent to provide financial services including requiring continuing training of staff to appropriate levels. We recognise the importance of maintaining and improving our skills, whether through internal training and development, or via financial assistance for external training.

Fees and Costs

The Product Disclosure Statement (PDS) for Sandhurst's investment products outlines the fees and costs that may be charged. These costs may include management fees and costs, indirect costs, performance fees, transaction costs and buy/sell spreads and do not include any advice fees agreed to be paid to financial advisers, if engaged by an investor.

Error Correction

Sandhurst is committed to ensuring that remediation events are: appropriately identified, investigated, root causes are understood, control/s put in place to prevent re-occurrence and customers are remediated to put them back into the position they would have been had the event not occurred. The remediation framework and procedures have been designed to uphold principles to support remediations. This includes customer focused culture where an approach is required to be designed to err in favour of the customer. This is achieved through providing adequate information to customers, allowing customers opportunity to provide further feedback, providing access to internal and external dispute resolution schemes and promoting continuous improvement to deliver the most effective customer outcomes.

Equitable Asset Valuation and Pricing

Our managed fund constitutions and policies detail the calculation methods or background considerations used in reaching decisions regarding the discretions for asset valuation and pricing. The policies provide guidance on how discretions are permitted to be exercised.

Best Execution and Trade Allocation

The Funds Management Investment Governance Framework outlines the governance of the asset management activities when Sandhurst is the Asset Manager. This includes trading activities such as best execution considering: prices, urgency, importance of execution and research. Fair allocation including price averaging is performed when trades are for multiple Funds.

Frameworks and policies outline trading protocols to ensure that investors' interests are maintained ahead of corporate interests and individual officer interests, our license and legal obligations are complied with, and our actions and activities promote the integrity of capital markets. Key controls are adopted including segregation of duties, dual signoff of trade instructions, execution processes, trading authorisation and conflicts management.

Where Sandhurst uses external Asset Managers, we consider their execution and allocation policies as part of our due diligence. See ‘Manage the Manager’ section below for details on collaboration activities.

Conflicts of Interest

The Conflicts of Interest Framework, the Conflicts of Interest Policy and related documents identify relevant duties and interests of our staff which provides a means to ascertain potential and actual conflicts. The policy provides guidance to staff and representatives for identifying and effectively managing and monitoring any actual, perceived or potential Conflicts of Interest that may arise. Conflicts are managed by a combination of internal controls, disclosure and a strong conflicts management culture where each staff member owns risk management and compliance. The Framework and Conflicts of Interest policy extend to gifts and entertainment and related party transactions. Registers of all conflicts, gifts and transactions are available to all staff, and are maintained and reported on regularly.

The effectiveness of Sandhurst’s Conflicts of Interest Framework and Policy is reviewed at least biennially. Group Internal Audit, the Group’s internal audit function and third line of defence in the ‘three lines of defence model’, conducts regular audits. A review of the appropriateness, effectiveness and adequacy of the Risk Management Framework is carried out annually, while an independent party conducts a comprehensive review at least every three years.