In a recent webinar hosted by CEO of Actus, Lucinda Carney, the topic of the FCA’s Senior Management and Certification Regime (SM&CR) and embedding the ethos of culture change was discussed. This topic is particularly relevant for HR and Compliance Professionals tasked with implementing SM&CR within their solo-regulated firm by the December deadline.
One of the reasons why the FCA introduced SM&CR was to embed an ethos of genuine responsibility. This is why the regime is unique, as it requires HR and Compliance professionals to work in partnership together. Without working in partnership, firms are likely to go down the ‘tick-box’ compliance route. Conversely, firms may treat the regime as a genuine opportunity to drive the right behaviours in their firm.
So, we know from what’s been put out by the FCA that they are looking for ‘true responsibility and accountability’, that you can actually evidence. Therefore, a high-quality and consistent process must be put into place.
So, it’s not sufficient to put things on a spreadsheet once, a lasting, ongoing control process must be established. This could be on paper, it doesn’t necessarily need to be on a system. However, manual control mechanisms and spreadsheets are less able to demonstrate a solid SM&CR control process. This is because such processes are unlikely to provide the visibility of responsibilities and tracking of behaviours required.
In businesses with an existing process in place, this may well fit into the performance management process. This is where the link with HR fits well. In fact, last year, Actus was approached by a pensions firm looking for a combined performance management and compliance system. This resulted in us working with them to create Actus Comply – affordable, effective and simple SM&CR software that can be used in harmony with the Actus performance management software.
You can listen to the webinar recording as part of The HR Uprising Podcast series hosted by Lucinda by clicking here. For more information about Actus Comply or to read a recent customer case study, click on the buttons below. We are currently running a series of free online SM&CR webinars before the December deadline. Please get in touch should you wish to sign up for one.