Credit Reporting Governance Statement

Smile Right Capital Pty Ltd ACN 139 675 424

Smile Right Payment Plans Pty Ltd ACN 650 069 060

Smile Right Pty Ltd ACN 601 445 041

Automated Collections Services Pty Ltd ACN 144 738 796 (and our related businesses)

Purpose of this Statement

This Credit Reporting Governance Statement explains how Smile Right Group manages credit reporting responsibilities and related compliance obligations under the Privacy Act 1988 (Cth), including Part IIIA (Credit Reporting) and the Privacy (Credit Reporting) Code 2014 (CR Code).

This statement is provided to ensure transparency regarding:

The entities involved in credit reporting activities
How responsibility is allocated within the group
How credit reporting obligations are governed and controlled

Credit Provider and Legal Responsibility

Smile Right Capital Pty Ltd (ACN 139 675 424)

Smile Right Capital Pty Ltd is the credit provider for the purposes of the Privacy Act 1988 (Cth).

Smile Right Capital Pty Ltd is solely responsible for:

All credit reporting decisions and reporting activity
Ensuring credit information is accurate, up to date, complete, and not misleading
Compliance with Part IIIA of the Privacy Act 1988 (Cth)
Compliance with the Privacy (Credit Reporting) Code 2014
Handling correction requests and credit reporting disputes
Responding to regulatory inquiries in relation to credit reporting

All credit reporting obligations under Australian law rest exclusively with Smile Right Capital Pty Ltd.

Operational Service Providers and Internal Group Functions

Smile Right Capital Pty Ltd is supported by related entities and service providers that perform operational and administrative functions under its authority.

Smile Right Pty Ltd (ACN 601 445 041)

Smile Right Pty Ltd provides loan management and customer-facing services on behalf of Smile Right Capital Pty Ltd.

Its functions include:

Customer onboarding and account management
Loan administration and servicing support
Customer communications
Coordination of operational credit reporting activities

Automated Collection Services Pty Ltd (ACN 144 738 796)

Automated Collection Services Pty Ltd provides servicing and collections support functions on behalf of Smile Right Capital Pty Ltd.

Its functions include:

Arrears and collections management
Administrative servicing support
Assistance with credit reporting-related operational processes
Coordination of dispute investigation workflows

Governance and Responsibility Framework

The following governance principles apply to all credit reporting activities:

Sole Statutory Responsibility

Smile Right Capital Pty Ltd remains the only entity within the group that:

Acts as a credit provider under the Privacy Act 1988 (Cth)
Holds legal responsibility for credit reporting obligations

Delegation of Operational Functions

Operational credit reporting and servicing functions may be performed by related entities or authorised service providers.

However:

Delegation does not transfer legal responsibility
Smile Right Capital Pty Ltd retains full accountability for all credit reporting activities

Decision-Making Authority

All decisions relating to:

Credit reporting disclosures
Corrections or amendments to credit information
Dispute resolution outcomes

are made under the authority of Smile Right Capital Pty Ltd.

Credit Reporting Disputes and Corrections

Where a request is made to correct credit information, Smile Right Capital Pty Ltd will:

Assess the request in accordance with Part IIIA Division 5 of the Privacy Act 1988 (Cth)
Investigate the accuracy of the relevant information
Consult credit reporting bodies or service providers where necessary
Determine whether correction is required
Notify the individual of the outcome in writing

Where appropriate, Smile Right Capital Pty Ltd will request credit reporting bodies to update their records.

Regulatory Compliance Position

Smile Right Group maintains a credit reporting governance framework designed to ensure compliance with:

The Privacy Act 1988 (Cth)
Part IIIA (Credit Reporting provisions)
The Privacy (Credit Reporting) Code 2014

This framework is supported by:

Internal policies and procedures
Delegated operational service arrangements
Oversight by Smile Right Capital Pty Ltd as credit provider

Transparency and Public Access

This statement is intended to provide clear public transparency regarding:

The structure of credit reporting responsibilities within the group
The allocation of operational and legal functions
The entity responsible for compliance under Australian law

Contact for Credit Reporting Matters

All credit reporting enquiries, correction requests, or complaints should be directed to:

Operations Manager

Smile Right

PO Box 7795

Cloisters Square WA 6850

Alternatively you can call us on 1300 793 983