Comprehensive Crime Insurance

About This Policy

Crime losses are often discovered long after they occur, frequently involve people you trust, and can be devastating to a business. This policy covers seven categories of crime:

— Insuring Clause 1 — Employee dishonesty

— Insuring Clause 2 — Forgery and alteration

— Insuring Clause 3 — Computer crime

— Insuring Clause 4 — Funds transfer fraud

— Insuring Clause 5 — Social engineering fraud

— Insuring Clause 6 — Theft of money and securities

— Insuring Clause 7 — Theft of other property

This is a discovery policy. It covers losses you discover during the policy period, regardless of when the criminal act occurred — subject to the retroactive date.

This policy, together with your schedule and any endorsements, forms your contract of insurance. Words in bold have special meanings — see Section 1.

Note on the Insurance Contracts Act 1984 (Cth): this policy is designed to operate consistently with, and does not seek to contract out of, the Act. See clause 7.6 for the general savings position and clause 7.5 for the duty of disclosure.

Schedule

1 Definitions

Words in bold below have the special meaning given here wherever they appear in this policy, your schedule, and any endorsement, unless a section expressly states a different meaning for that section.

Computer system means any computer, server, network, hardware, software, firmware, data storage system, cloud service, hosted platform, application, or communications system owned by you, leased by you, or operated on your behalf under a written contract.

Counterfeit means an imitation of a genuine document, security, or currency that is intended to deceive.

Discovery means the point at which any responsible person first has reason to believe, on the information then available, that a loss covered by this policy has been or is likely to have been sustained, whether or not the amount, cause, or full circumstances of the loss are then known, and regardless of when the underlying act occurred.

Employee means any natural person who: (a) works for you under a contract of employment (including permanent, fixed-term, casual, and part-time); (b) is a volunteer or intern working under your direct supervision; (c) is a person seconded to you from another organisation, while working under your direction and control; (d) is a temporary or labour hire worker, while working under your direct supervision; or (e) was formerly any of the above, for acts committed during their employment or engagement. Does not include independent contractors, external auditors, or agents (unless specifically covered).

Endorsement means a document attached to this policy that changes its terms.

Excess means the amount shown in the schedule that you must pay as the first part of each loss.

Financial instrument means any cheque, draft, promissory note, bill of exchange, letter of credit, certificate of deposit, money order, warrant, or other written order or instruction to pay money.

Forgery means the signing of another person's name, or the material alteration of a document, with the intent to deceive.

Funds transfer means the electronic, telegraphic, telephonic, or written instruction to a financial institution to debit or credit an account, or to pay or transfer funds.

Limit of liability means the amount shown in the schedule.

Loss means the direct financial loss that you sustain, directly resulting from a criminal act covered by the Insuring Clause under which you claim. This is the only causation test applied under this policy — where an Insuring Clause or Extension also describes loss as “caused by” a peril, that phrase refers to this same test and does not impose an additional or different threshold. Loss includes the reasonable costs of proving the loss (forensic accounting, investigation costs) incurred with our prior consent. Loss does not include: (a) indirect or consequential loss; (b) potential income or revenue not earned due to the criminal act; (c) costs of enhancing systems or security; (d) salaries or compensation paid to a dishonest employee; or (e) costs of reconstructing data or records, except as covered under Insuring Clause 3.

Manifest intent means the clear intention to: (a) cause you direct financial loss; and (b) obtain a personal financial benefit for the perpetrator beyond their normal compensation from you.

Money means currency (coins and banknotes), bullion, and precious metals, whether held physically or in a custodial or allocated account.

Named insured means the entity shown in the schedule.

Policy period means the period shown in the schedule.

Property means tangible property other than Money and Securities, including equipment, inventory, and other physical assets. Property does not include electronic data (loss involving data is addressed under Insuring Clause 3, Computer Crime).

Responsible person means any director, officer, partner, principal, risk manager, compliance officer, internal auditor, chief financial officer, or head of finance of the named insured; or, where the named insured has no natural person holding any of those roles, its most senior officer or manager responsible for its financial affairs at the relevant time.

Retroactive date means the date shown in the schedule. We only cover losses arising from criminal acts that first occur on or after this date.

Schedule means the document titled “Schedule” issued with this policy.

Securities means all negotiable and non-negotiable instruments, including shares, bonds, debentures, notes, units in trusts or funds, options, warrants, rights, and other ownership or debt instruments, whether held in physical or electronic (dematerialised) form.

Subsidiary means any entity in which the named insured holds more than 50% of the voting rights, or over which the named insured has effective management control, at the time of the loss.

Third party means any natural person or entity other than: (a) you; (b) an employee; or (c) a third-party service provider acting within the scope of its written contract with you (whose conduct is separately addressed in Extension 3.5). For the avoidance of doubt, a customer, supplier, contractor outside Extension 3.5, or member of the public may be a third party.

Third-party service provider means a person or entity engaged by you under a written contract to perform services on your behalf, including payroll processors, fund administrators, custodians, transfer agents, and IT managed service providers.

We / us / our means the insurer named in the schedule.

You / your means the named insured and any subsidiary.

2 What Is Covered

Insuring Clause 1: Employee Dishonesty

We will pay your loss caused by a dishonest or fraudulent act committed by an employee, acting alone or in collusion with others, provided: (a) the act was committed with manifest intent; and (b) the loss is first discovered during the policy period.

This covers: theft of money, securities, or tangible property; fraudulent alteration of your accounts or records; fraudulent electronic funds transfers; deliberate destruction of property or data to conceal a dishonest act; embezzlement and misappropriation; inventory theft; and payroll fraud (fictitious employees, inflated hours, unauthorised bonuses).

Discovery after termination: If you discover an employee's dishonesty after their employment ends, the loss is covered provided it is discovered during the policy period and the dishonest act occurred during the employee's employment.

Insuring Clause 2: Forgery and Alteration

We will pay your loss caused by: (a) forgery of, or fraudulent alteration to, any financial instrument, cheque, draft, or written instruction, resulting in payment from your account or a payment you are legally required to honour; or (b) your acceptance in good faith of any counterfeit currency or counterfeit financial instrument. The loss must be first discovered during the policy period.

Insuring Clause 3: Computer Crime

We will pay your loss caused by: (a) the fraudulent entry of data into, or fraudulent modification or deletion of data within, your computer system by a third party; (b) the fraudulent preparation or modification of electronic data or instructions directed to your computer system, resulting in an unauthorised transfer of money, securities, or property from your account; (c) the introduction of malicious code into your computer system by a third party with the intent to cause you financial loss; or (d) the theft of confidential data from your computer system by a third party, where the stolen data is used to cause you direct financial loss.

The costs of restoring data or systems after a cyber attack are not covered here — that is a cyber insurance exposure. This insuring clause covers the direct financial loss caused by computer-enabled theft or fraud. See also clause 5.7(a) for the priority rule that applies where a cyber policy also purports to cover this loss.

Insuring Clause 4: Funds Transfer Fraud

We will pay your loss caused by a fraudulent funds transfer instruction issued by a third party who, without your authority, has gained access to your communications or banking systems and impersonates you or an authorised representative. The fraudulent instruction must result in the transfer of your money or securities from your account to an account not controlled by you. The loss must be first discovered during the policy period.

Insuring Clause 5: Social Engineering Fraud

We will pay your loss caused by a funds transfer or delivery of money, securities, or property that you make in good faith as a result of a fraudulent communication that: (a) impersonates a genuine client, supplier, vendor, business partner, or senior officer of yours; (b) uses a spoofed, compromised, or deceptively similar email address, phone number, or communication channel; and (c) induces you to make a payment, transfer funds, or deliver property based on false pretences.

Examples: Fake invoice fraud, CEO impersonation (business email compromise), vendor bank detail change fraud, and impersonation of a client requesting a payment redirect.

Verification procedures: Whether you followed a particular verification procedure before acting on the fraudulent communication is not a condition of cover, and we will not reduce or deny your claim solely because a particular verification step was not followed. Evidence about the verification steps you did or did not take is relevant only to establishing whether the payment was in fact induced by the fraudulent communication described in this clause — that is, whether this Insuring Clause is engaged at all. It is not used, on a scale or otherwise, to reduce the amount we pay once a covered loss under this clause is established.

Insuring Clause 6: Theft of Money and Securities

We will pay your loss of money or securities caused by: (a) theft from your premises, including from a locked safe, vault, or cash register; (b) theft while in transit by you, your employees, or a professional carrier; or (c) mysterious disappearance from your premises (money or securities that cannot be accounted for and where a reasonable investigation suggests theft). The loss must be first discovered during the policy period. See clause 5.4 for the valuation basis that applies to this Insuring Clause.

Insuring Clause 7: Theft of Other Property

We will pay your loss of property caused by theft by a third party from: (a) your premises; or (b) while in transit by you, your employees, or a professional carrier. The loss is measured at the lesser of: (i) the replacement cost of equivalent property; or (ii) the actual cash value at the time of loss. The loss must be first discovered during the policy period.

3 Extensions of Cover

3.1 Forensic Investigation Costs

We will pay the reasonable costs of engaging a forensic accountant or fraud investigator to determine the existence and extent of a loss covered by this policy, with our prior consent.

3.2 Legal Costs to Establish the Loss

We will pay your reasonable legal costs incurred in establishing that a loss covered by this policy has occurred and quantifying the amount.

3.3 Reconstitution of Records

If a criminal act covered by this policy results in the destruction, alteration, or corruption of your financial records, we will pay the reasonable costs of reconstituting those records to the extent necessary to determine the nature and extent of the loss.

3.4 Credit Monitoring for Affected Persons

If a criminal act covered under Insuring Clause 1 or 3 involves the theft of personal information of your customers, employees, or other persons, and you provide credit monitoring or identity theft protection services to those persons, we will contribute to the reasonable costs.

3.5 Third-Party Service Provider Dishonesty

We will cover loss caused by a dishonest or fraudulent act committed by an employee of a third-party service provider while performing services for you under a written contract — provided the act is committed with manifest intent and directed at you. This extension does not apply to losses caused by general negligence, incompetence, or breach of contract by the third-party service provider.

3.6 Client's Property

We will cover loss of money, securities, or property belonging to your clients that is in your care, custody, or control, caused by a criminal act covered by this policy — to the extent you are legally liable to the client for the loss.

This extension is liability-triggered: it responds only where, and to the extent that, you are legally liable to the client — not simply because the property was in your care, custody, or control. A broader Care, Custody and Control extension that responds independently of proven legal liability is not included in this policy and, if required, must be arranged by endorsement.

3.7 Newly Acquired Subsidiaries

Automatic cover for 90 days from acquisition. Notify us within 90 days.

3.8 Telephone and Communications Fraud

We will cover your loss of telephone charges or communication service charges caused by the unauthorised use of your telephone system, PBX, voicemail, or communication network by a third party.

3.9 Reward

We will pay a reward offered with our prior consent for information leading to the arrest and conviction of any person responsible for a loss covered by this policy.

4 What Is Not Covered

4.1 Indirect and Consequential Loss

Any loss other than direct financial loss — including loss of income, profit, business opportunity, interest, goodwill, or market value.

4.2 Trading and Investment Losses

Loss arising from trading in shares, securities, commodities, currencies, derivatives, or other financial instruments — whether authorised or unauthorised — except to the extent the trading was conducted by an employee with manifest intent and the loss is covered under Insuring Clause 1.

4.3 Inventory Shortages — Unexplained

Loss consisting of unexplained shortages in inventory, stock, or accounts that cannot be attributed to a specific criminal act. General stock shrinkage or bookkeeping errors are not covered. However, inventory shortages that are demonstrated by forensic investigation to result from employee theft are covered under Insuring Clause 1.

4.4 Prior Discovery

Any loss that was discovered, or ought reasonably to have been discovered, before the start of the policy period, or that was notified or should have been notified under any prior insurance policy.

4.5 Losses Before the Retroactive Date

Any loss arising from a criminal act that first occurred before the retroactive date.

4.6 Directors' and Officers' Dishonesty

A dishonest act committed by a director, officer, or partner of yours who is also a beneficial owner of more than 15% of the named insured's issued shares or equity — unless the act is committed in collusion with an employee and the employee's involvement is independently established.

4.7 Government and Regulatory Action

Loss arising from a fine, penalty, tax, levy, or confiscation order imposed by any government or regulatory body — except forensic investigation and legal costs covered under Section 3.

4.8 War, Terrorism, and Nuclear Risks

Loss arising from war (declared or not), terrorism, or nuclear risks.

Sanctions are addressed separately, not as a peril under this exclusion — see clause 7.9 (Sanctions Limitation), which limits payment regardless of whether a loss is otherwise covered under this policy.

4.9 Contractual Penalties

Loss consisting of contractual penalties, liquidated damages, late delivery charges, or similar amounts that you owe under a contract — as distinct from the direct financial loss caused by a criminal act.

4.10 Fees and Commissions

Loss of fees, commissions, or revenue that you would have earned but for the criminal act. We cover what was taken, not what was lost.

4.11 Legal Liability to Third Parties

Your legal liability to third parties for damages, compensation, or defence costs arising from a criminal act — except as specifically covered under Extension 3.6 (Client's Property).

5 How Much We Will Pay

5.1 Limits Per Loss and Aggregate

Each Insuring Clause has its own per-loss limit and aggregate limit as shown in the schedule (Item 4). Where the schedule also shows an overall aggregate limit, that overall aggregate is a single shared cap across all Insuring Clauses: it is eroded by, and erodes concurrently with, every payment we make under any Insuring Clause. Our total liability under this policy for the policy period will not exceed the lower of (a) the sum of the applicable per-clause aggregates for the losses claimed, and (b) the overall aggregate. Sub-limited Extensions in Section 3 are payable within, and do not increase, the per-clause aggregate of the Insuring Clause to which the Extension relates, unless the schedule states that an Extension carries its own separate additional limit.

5.2 Single Loss

Single loss means all individual losses arising from the same criminal act, or from a series of the same, similar, or related criminal acts, by the same person or group of persons acting together (whether acting alone or in collusion, and whether or not every person involved is identified), and is treated as one loss for the purposes of the limit and excess under the Insuring Clause(s) it falls within.

Where a single loss would otherwise be discovered in, or would otherwise span, two or more consecutive policy periods issued by us to you, it is treated as occurring in, and is subject to the limit, excess, and terms of, the policy period in which it is first discovered under clause 7.1 — even if the criminal acts making up the single loss continue, or further amounts are discovered, in a later policy period. This clause is subject to clause 7.2 (Prior Insurance and Superseded Policies) where the loss began under a genuinely separate, expired prior policy.

5.3 Excess

You must pay the excess shown in the schedule (Item 5) for each loss. The excess may differ by Insuring Clause. Where clause 5.5 (Multiple Insuring Clauses) applies, only the excess applicable to the Insuring Clause under which we pay applies to that loss.

5.4 Valuation — Money and Securities

Where this policy pays for the loss of money or securities: (a) securities are valued at their market value as at the date of Discovery, or, at our election, we may instead pay the reasonable cost of a replacement in kind, or arrange a bond of indemnity — whichever we determine most appropriate for the security in question; (b) foreign-currency money is converted to Australian dollars at the exchange rate published by the Reserve Bank of Australia (or, if no rate is published for that currency, a comparable published rate we reasonably nominate) applying on the date of Discovery; and (c) where a security or currency has no readily ascertainable market value on the date of Discovery, we will determine its value using the most recent published value before that date, adjusted as reasonably necessary to reflect known intervening events.

5.5 Multiple Insuring Clauses

If a single loss falls within more than one Insuring Clause, cover applies under the Insuring Clause that carries the highest applicable per-loss limit for that loss. Only one excess applies — the excess applicable to the Insuring Clause under which we pay. Amounts are not aggregated, and the loss is not paid more than once, across Insuring Clauses for the same loss.

5.6 Recoveries

If we pay a loss and you later recover any amount from the perpetrator or any third party: (a) the recovery is first applied to reduce your uninsured loss (amounts you bore, including the excess and any amount above the limit); (b) the remainder is applied to reimburse us for our payment.

5.7 Other Insurance

(a) Crime/cyber priority. Where a loss under Insuring Clause 3 (Computer Crime) or Insuring Clause 4 (Funds Transfer Fraud) — being direct theft of money, securities, or property caused by computer-enabled fraud — is also covered, or purportedly covered, under a cyber insurance policy you hold, this policy responds as the primary policy for that loss, regardless of any term of the cyber policy purporting to make it excess to, or contributory with, this policy. This priority rule does not apply to the extent a cyber policy is specifically written and rated to attach in excess of this policy (a dedicated excess or difference-in-conditions cyber-crime layer), in which case that policy's excess status is unaffected by this clause.

(b) Primary position generally. Except where the schedule states that this policy is excess over a named underlying policy, this policy pays its applicable limit of liability without regard to any other insurance you hold that also covers the loss. A provision in another insurer's policy that purports to make that policy excess to, or to relieve it of liability by reason of, this policy does not affect our obligation to pay under this policy.

(c) Contribution tie-break. If, despite (a) and (b), this policy and another insurer's policy each purport to be excess over the other in respect of the same loss (a residual circularity), we will contribute on a proportional basis according to the respective limits of liability each policy would otherwise provide for that loss, and will not decline the loss merely because the other insurer's policy contains an equivalent clause.

(d) Named excess layer. Where the schedule states that this policy is excess over a specified underlying policy, this policy responds only after the limits of that underlying policy (and any other specified underlying layer) have been exhausted by covered payments, consistent with s 45 of the Insurance Contracts Act 1984 (Cth), which voids a provision that purports to reduce or exclude liability by reference to other insurance except where the policy is itself expressed to be excess over a specified underlying policy.

6 Your Obligations

6.1 Notify Us Promptly

Tell us in writing as soon as reasonably practicable after discovery of a loss. Provide: (a) the nature and circumstances of the criminal act; (b) when and how it was discovered; (c) the identity of the perpetrator (if known); (d) an estimate of the loss; and (e) details of any other insurance that might cover the loss.

6.2 Assist Our Investigation

Give us all information, documents, and access we reasonably need. Allow us to interview employees and inspect records and systems.

6.3 Report to Authorities

Report the criminal act to the relevant law enforcement authorities as soon as reasonably practicable. You must cooperate with any police or regulatory investigation. We will not require you to pursue a criminal prosecution, but you must not obstruct one.

6.4 Mitigate

Take all reasonable steps to prevent further loss after discovery — including securing compromised systems, freezing accounts, and suspending the suspect's access.

6.5 Preserve Evidence

Preserve all evidence relating to the criminal act. Do not destroy, alter, or dispose of relevant documents, records, or data without our consent.

6.6 Subrogation and Recovery

Cooperate with our efforts to recover from the perpetrator or any third party. We may take action in your name to recover amounts we have paid. Do not settle with or release the perpetrator without our written consent.

6.7 Proof of Loss

Provide us with a detailed proof of loss within 120 days of discovery (or such longer period as we agree), supported by relevant financial records, forensic reports, and other evidence of the loss.

6.8 Maintain Controls

Maintain reasonable financial controls and internal procedures throughout the policy period, including segregation of duties, dual authorisation for significant payments, reconciliation procedures, and access controls.

The obligations in this Section 6 are subject to clause 7.6 (Insurance Contracts Act 1984 (Cth) — General): we will not refuse to pay a loss by reason only of a post-contractual act or omission except to the extent s 54 of the Act permits.

7 General Conditions

7.1 Discovery Trigger

This policy operates on a discovery basis. A loss is covered if it is first discovered during the policy period, regardless of when the criminal act occurred (subject to the retroactive date).

7.2 Prior Insurance and Superseded Policies

If this policy replaces a prior crime or fidelity policy, we will cover a loss that is first discovered during this policy period — even if the criminal act occurred during the period of the prior policy — provided: (a) the prior policy has expired and no claim has been made under it for the same loss; (b) the loss would have been covered under the prior policy at the time the criminal act occurred; and (c) the loss is not excluded under this policy.

7.3 Discovery Period

If this policy is not renewed, or is cancelled by you or by us, for any reason other than replacement by an equivalent crime policy, you have an automatic discovery period of 90 days (or such longer period as shown in the schedule) from the date of non-renewal or cancellation to notify losses arising from criminal acts that occurred before that date and that would otherwise have been covered. Extended discovery periods for a longer duration are available for additional premium, as shown in the schedule. This discovery period does not reinstate or increase the limit of liability, and losses notified during it remain subject to the limit, excess, and terms that applied immediately before non-renewal or cancellation.

7.4 Cancellation

By you: Cancel at any time in writing. Proportional refund less amounts paid or reserved.

By us: We may only cancel this policy on grounds permitted by the Insurance Contracts Act 1984 (Cth) s 60. Where we are entitled to cancel, we will give you written notice as required by s 59, and will refund the premium for the unexpired portion proportionally.

7.5 Duty of Disclosure

This is a commercial (non-consumer) contract of insurance. Before entering into, varying, or renewing this policy, you have a duty under sections 21 and 21A of the Insurance Contracts Act 1984 (Cth) to disclose to us every matter that you know, or that a reasonable person in the circumstances could be expected to know, is relevant to our decision to accept the risk and on what terms. As between us and each insured person, disclosure is assessed individually — the non-disclosure or misrepresentation of one insured person does not affect the cover of an innocent insured person seeking cover in their own right.

If you fail to comply with this duty, we may be entitled under s 28 of the Act to reduce our liability for a claim proportionately or, in the case of fraudulent non-disclosure or misrepresentation by the insured person seeking cover, to avoid the policy from inception in relation to that person. We will not exercise the s 28(3) proportionate-reduction remedy against an insured person who did not know of, and was not party to, the relevant non-disclosure or misrepresentation.

7.6 Insurance Contracts Act 1984 (Cth) — General

Nothing in this policy excludes, restricts, or modifies the operation of the Insurance Contracts Act 1984 (Cth). In particular, s 54 of the Act applies to any act or omission by you after the criminal act giving rise to a loss (including in connection with the obligations in Section 6) — we may not refuse to pay a loss by reason only of such an act or omission except to the extent the Act permits. Where any provision of this policy is inconsistent with the Act, the Act prevails.

This policy operates on a discovery basis, not a claims-made basis. The circumstance-notification mechanism in s 40(3) of the Act (designed for claims-made covers) has no direct work to do here — the Discovery trigger in clause 7.1 and the prompt-notification obligation in clause 6.1 serve the equivalent function for this policy.

7.7 Governing Law

This policy is governed by the laws of the state or territory of Australia shown in the schedule as at the policy's inception (Item 9). The parties submit to the non-exclusive jurisdiction of the courts of that state or territory and the courts that hear appeals from them.

7.8 GST

Amounts payable under this policy are calculated without regard to any GST component you can recover as an input tax credit, consistent with the intent of A New Tax System (Goods and Services Tax) Act 1999 (Cth), including its s 48. If a payment under this policy is consideration for a taxable supply, or if you incur GST on a third-party claim we indemnify that is not fully recoverable as an input tax credit, we will gross up our payment so that you are not left out of pocket for that irrecoverable GST component.

7.9 Sanctions Limitation

We are not liable to provide any cover, or to pay any claim or benefit, under this policy to the extent that doing so would expose us or our reinsurers to enforcement action under: (a) the Autonomous Sanctions Act 2011 (Cth) and the Autonomous Sanctions Regulations 2011 (Cth); (b) the Charter of the United Nations Act 1945 (Cth) and regulations made under it; or (c) the applicable trade or economic sanctions laws of the United Nations, the United States, the United Kingdom, or the European Union. This clause is a limitation on payment, not an exclusion of a peril, and applies regardless of when a loss otherwise covered by this policy is discovered. See also clause 4.8 (War, Terrorism, and Nuclear Risks).

7.10 Disputes

Internal dispute resolution: Contact us first using the details shown in your schedule. We will acknowledge your complaint and aim to resolve it through our internal dispute resolution process within the timeframes required by ASIC Regulatory Guide 271.

AFCA: If you are not satisfied with the outcome, or we have not resolved your complaint within that timeframe, you may refer it, free of charge, to the Australian Financial Complaints Authority: www.afca.org.au | info@afca.org.au | 1800 931 678.

Endorsement Library

Endorsements E01–E11 are listed below as titles for selection at Schedule Item 7. Each carries its own operative wording, sub-limits, and (if applicable) additional premium in the endorsement document issued with the schedule when selected; the anchor-clause column shows which base clause each endorsement relates to or amends.

Meridian Commons — Open Source Insurance Wording · CC BY 4.0 · 2026/CRI/0001 · v1.2.0-DRAFT · July 2026

Designed for the Australian market. Assumes application of the Insurance Contracts Act 1984 (Cth). Users are responsible for their own legal review, regulatory compliance, and reinsurance alignment. This draft is not for use until Wording Partner sign-off is recorded.

DRAFT — SUBJECT TO LEGAL REVIEW — NOT FOR USE