3.1. Proportionality, predictability and reasonable expectations are the foundations of the Central Bank's approach to implementation of the IAF.

3.2. An important concept in the IAF Act is the taking of reasonable steps by individuals to discharge their responsibilities and duties (e.g. the Duty of Responsibility and the Conduct Standards).

3.3. In determining the circumstances that are relevant for consideration in respect of reasonable steps under the Duty of Responsibility and the Conduct Standards the legislative text indicates a range of matters to be considered. These include the following:

(a) the nature of the business of the regulated financial service provider, including its scale and complexity,

(b) the functions of the person in relation to the regulated financial service provider, and the level of knowledge and experience that a person with such functions could reasonably be expected to have,

(c) the level of knowledge and experience of the person,

(d) the existence and application (or otherwise) of -

(i) appropriate and effective systems (including risk management systems, internal control mechanisms and governance arrangements),

(ii) effective oversight of any delegation of responsibilities and effective safeguards against any inappropriate delegation, and