of the use of agents by the two companies at its meeting in april 2006. as a result of that discussion, the two companies were asked to provide the reserve bank board with their policies on agents. mr thompson, at that time chairman of the boards of both npa and securency, responded to this request in july 2006, and provided the policies and associated documents for both companies. this correspondence noted that the companies had recently reviewed and strengthened their bis central bankers ’ speeches policies. while each company had its own policies and procedures, both articulated the following key elements : • the respective boards reaffirmed the companies ’ policies against any direct or indirect involvement in corrupt, unethical or otherwise questionable practices, and asked management to ensure that all agents formally acknowledge and commit to this policy. the agency agreements provided for termination when this commitment was breached ; • a process was established to inform the respective boards about the appointment of agents, the applicable commission rates and payments made ; and • a process of annual review of these policies was established. the npa board sought updates on implementation of its revised policies at the february 2007 npa board meeting. on hearing management ’ s responses, the npa board requested that faster progress be made and that an information paper on the state of play with agents be prepared for the may 2007 meeting. the rba, through the assistant governor ( corporate services ) and director of npa, mr campbell, also sought or received updates on the implementation of the policies from the npa manager of corporate service. in november 2006 and march 2007. no probity concerns were raised in response to these requests for updates. the may 2007 npa board paper, the audit at npa and the memo from the npa manager during the course of implementing the revised agent policies at npa, in about mid april 2007, the npa manager raised concerns with mr campbell ( assistant governor ( corporate services ) of the reserve bank, and director of npa ) about comments that had apparently been made by two of npa ’ s agents and about the conduct of certain npa management. mr campbell encouraged the npa manager to seek answers to the queries he raised and to include his concerns in the may 2007 npa board paper on agents which had been requested by the npa board. the paper, authored by the npa manager ( as company secretary ) and the ceo, was presented at the 16 may 2007 npa board meeting. it noted that two of three agents had yet to

review of securency ’ s agent policies and procedures by kpmg. at the request of the afp, securency did not immediately retain kpmg, so as not to hinder the afp ’ s initial access to documents. in early june 2009, the reserve bank board was provided with an update on securency ’ s referral to the afp for investigation. the reserve bank board was informed that the afp ’ s investigation was in an assessment phase, during which the afp would determine whether a further investigation was necessary. the afp informed securency around the end of june 2009 that the afp would proceed with a full - scale investigation and that it did not object to securency engaging kpmg. securency offered full cooperation to the afp, as did npa when the afp inquiry was subsequently widened to include possible wrongdoing at npa. in july 2009, with the afp ’ s agreement, the board of securency approached kpmg and asked them to conduct an independent investigation of securency ’ s policies and procedures regarding agents. the reserve bank board was subsequently informed at its july 2009 meeting that securency had engaged kpmg to conduct an independent review of securency ’ s agent policies and procedures. in october 2009, kpmg informed dr rankin that kpmg had discovered documents indicating that a former employee of securency had raised concerns over the use of overseas agents in early 2007. a progress report was provided by kpmg to the securency board in november 2009 which confirmed that their forensic work had discovered material which indicated concerns about possible corrupt payments had been raised by a securency employee with securency senior management in early 2007. these concerns had never been made known to the securency board or the audit department when it conducted either bis central bankers ’ speeches the 2007 or 2008 audits. at the time the ceo and cfo of securency were stood down and the use of agents suspended pending further inquiry. the preliminary findings reported by kpmg also indicated that there had been failures to fully implement the procedures specified in securency ’ s agent policies and procedures. kpmg ’ s final report was released publicly by securency in march 2010. it contained a number of recommendations, which have been implemented. the charges charges were laid against a number of individuals who were former employees of npa and securency from july 2011. the companies were also charged. further charges were laid against securency in august 2011,