Media Release

ASFA and JANA Publish Draft Guidance Note to Strengthen Investment Management Operational Due Diligence Ahead of CPS 230

Published 26 June, 2025

Published 26 June, 2025

JANA and the Association of Superannuation Funds of Australia (ASFA) have today released a draft Guidance Note on Investment Management Operational Due Diligence for consultation with ASFA’s membership to help the superannuation sector meet new regulatory obligations.

The proposed updates aim to strengthen operational resilience and ensure investment managers are demonstrating the effective management of risks as they support the long-term objectives of superannuation funds.

In November 2024, ASFA and JANA announced their partnership to lead an industry-wide effort to enhance and replace the existing guidance on investment management operational due diligence in preparation for APRA’s new prudential standard CPS 230 Operational Risk Management Standard, which comes into effect on 1 July 2025.

The draft Guidance Note has been shaped through engagement with a broad working group of asset owners, managers and consultants and is intended to support consistent practices across the industry.

Proposed key updates in the draft Guidance Note:

Regulatory alignment: Updates to align with CPS 230 and also CPS 234 Information Security, reinforcing a strong, enterprise-wide risk management culture.

Investment manager operational due diligence review process: Encouraging investment managers to engage independent specialists for operational due diligence reviews, helping to lift industry standards, support consistency in assessments, and promote greater transparency.

Enhanced guidance: Providing detailed guidance for independent reviewers and asset owners who self-service.

Expanded review criteria: A more comprehensive set of criteria covering governance, personnel, IT security, ESG factors, business continuity, and data governance to align with CPS 230.

Updated format: The new format is designed to enable review of enterprise and investment strategy alongside CPS 230 requirements.

Regular reviews and updates: Recommendations for continuous improvement and alignment with evolving industry standards.

Emphasis on transparency and independence: Encouragement of independent and specialised assessments to strengthen due diligence effectiveness.

Jo Leaper, Head of Operational Consulting at JANA said, “We’re proud to be working with ASFA and industry stakeholders to develop this draft Guidance Note. This partnership underscores JANA’s commitment to driving industry-wide improvements in investment management operational due diligence. CPS 230 marks a significant shift in operational resilience, and this draft framework is designed to support consistent and practical risk management practices across both APRA-regulated and non-regulated entities.”

Mary Delahunty, CEO of ASFA added, “Strengthening operational due diligence is critical for the stability and integrity of our industry. This updated guidance provides a clear roadmap for superannuation funds and investment managers to meet the evolving regulatory landscape and enhance their risk management frameworks to the benefit of everyday Australians.”

As the industry prepares for the implementation of CPS 230, JANA and ASFA remain committed to supporting superannuation funds and investment managers in adopting best practices in operational due diligence. This collaboration reflects a broader effort to enhance risk management, governance, and resilience across Australia’s financial sector.

The draft Guidance Note is open for feedback from ASFA members until Thursday 24 July, via Policy@superannuation.asn.au.

For further information, please contact:

Isabella Palmer
Honner
Phone: 0413 587 827
Email: isabella@honner.com.au 

Richard Garfield
Association of Superannuation Funds of Australia (ASFA)
Phone: 0451 949 300
Email: mediaunit@superannuation.asn.au

About JANA

JANA is Australia’s largest investment consulting organisation and a trusted and respected partner of many of the country’s leading institutional investors. Since its inception in 1987 it has expanded its reach to over 85 institutional clients across superannuation, wealth, not-for-profits, insurance and more. JANA is fully management owned.

Total funds under advice as 31 March 2025 is A$1.6 trillion, while Implemented Consulting clients benefit from the scale of A$16 billion across the broader platform used for JANA clients.

For more information, please visit: https://www.jana.com.au

About ASFA

ASFA, the voice of super, has been operating since 1962 and is the peak policy, research and advocacy body for Australia’s superannuation industry. ASFA represents the APRA regulated superannuation industry with over 100 organisations as members from corporate, industry, retail and public sector funds, and service providers. We develop policy positions through collaboration with our diverse membership base and use our deep technical expertise and research capabilities to assist in advancing outcomes for Australians.

We unite the superannuation community, supporting our members with research, advocacy, education and collaboration to help Australians enjoy a dignified retirement. We promote effective practice and advocate for efficiency, sustainability and trust in our world-class retirement income system.

Acknowledgement of Country

We want to respectfully acknowledge the Traditional Owners and Custodians of these lands, seas, and waters throughout Australia. We pay our respects to Elders both past and present. We acknowledge the history, the resilience and the continual contributions of Aboriginal and Torres Strait Islander peoples of their Country.

ABN 29 002 786 290

Carmen Beverley-Smith

Executive Director - Superannuation, Life & Private Health Insurance, APRA

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Carmen joined APRA in March 2023 and holds the role of Executive Director, Life and Private Health Insurance and Superannuation. 

She has had an esteemed career in financial services, spanning over 25 years. She has held diverse leadership roles at Westpac and Commonwealth Bank of Australia, including across risk, transformation and change, product and portfolio development, and sales and service.

Prior to joining APRA, she held the role of General Manager, Risk Transformation Delivery Integration at Westpac. This involved leading the group-wide implementation of a suite of solutions to uplift risk management capability and develop data, analytics and reporting.

Carmen leads with a values-driven approach and a particular interest in developing and mentoring talent.

She holds a Bachelor of Commerce and Accounting, is a certified Chartered Accountant and a Graduate of the Australian Institute of Company Directors.

Amy C. Edmondson

Novartis Professor of Leadership and Management, Harvard Business School

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Amy C. Edmondson is the Novartis Professor of Leadership and Management at the Harvard Business School, a chair established to support the study of human interactions that lead to the creation of successful enterprises that contribute to the betterment of society.

Edmondson has been recognized by the biannual Thinkers50 global ranking of management thinkers since 2011, and most recently was ranked #1 in 2021 and 2023; she also received that organization’s Breakthrough Idea Award in 2019, and Talent Award in 2017.  She studies teaming, psychological safety, and organisational learning, and her articles have been published in numerous academic and management outlets, including Administrative Science Quarterly, Academy of Management Journal, Harvard Business Review and California Management Review. Her 2019 book, The Fearless Organization: Creating Psychological Safety in the Workplace for Learning, Innovation and Growth (Wiley), has been translated into 15 languages. Her prior books – Teaming: How organizations learn, innovate and compete in the knowledge economy (Jossey-Bass, 2012), Teaming to Innovate (Jossey-Bass, 2013) and Extreme Teaming (Emerald, 2017) – explore teamwork in dynamic organisational environments. In Building the future: Big teaming for audacious innovation (Berrett-Koehler, 2016), she examines the challenges and opportunities of teaming across industries to build smart cities. 

Edmondson’s latest book, Right Kind of Wrong (Atria), builds on her prior work on psychological safety and teaming to provide a framework for thinking about, discussing, and practicing the science of failing well. First published in the US and the UK in September, 2023, the book is due to be translated into 24 additional languages, and was selected for the Financial Times and Schroders Best Business Book of the Year award.

Before her academic career, she was Director of Research at Pecos River Learning Centers, where she worked on transformational change in large companies. In the early 1980s, she worked as Chief Engineer for architect/inventor Buckminster Fuller, and her book A Fuller Explanation: The Synergetic Geometry of R. Buckminster Fuller (Birkauser Boston, 1987) clarifies Fuller’s mathematical contributions for a non-technical audience. Edmondson received her PhD in organisational behavior, AM in psychology, and AB in engineering and design from Harvard University.

Daniel Mulino MP

Assistant Treasurer and Minister for Financial Services

Sessions

Keynote 8 – Navigating the energy transition: opportunities, investor strategies and policy needs

Born in Brindisi, Italy, Daniel was a young child when he moved with his family to Australia. He grew up in Canberra and completed his first degrees – arts and law – at the ANU. He then completed a Master of Economics (University of Sydney) and a PhD in economics from Yale.

He lectured at Monash University, was an economic adviser in the Gillard government and was a Victorian MP from 2014 to 2018. As Parliamentary Secretary to the Treasurer of Victoria, Daniel helped deliver major infrastructure projects and developed innovative financing structures for community projects.

In 2018 he was preselected for the new federal seat of Fraser and became its first MP at the 2019 election, re-elected in 2022 and 2025. From 2022 to 2025, Daniel was chair of the House of Representatives’ Standing Economics Committee in which he chaired inquiries; economic dynamism, competition and business formation and insurers’ responses to 2022 major floods claims.

In 2025, he became the Assistant Treasurer and Minister for Financial Services.

In August 2022, Daniel published ‘Safety Net: The Future of Welfare in Australia’, which aims to explore the ways in which an insurance approach can improve the effectiveness of government service delivery.