On 3 May 2017, the financial services team held its latest 40 minute briefing – Senior Managers’ Regime: Extension, Proportionality and Lessons Learnt.  The briefing covered:

  • Who will the extension apply to?
  • Latest thinking from the regulator on proportionality
  • Lessons learnt from the banking sector’s experience with implementing the regime – financial services law matters
  • Lessons learnt from the banking sector’s experience with implementing the regime – employment law matters
  • The duty to take reasonable steps
  • Approaching your implementation project: Our SM&CR Implementation Toolkit.

Our SM&CR toolkit includes:

  • Template project plan covering all required work streams
  • Pro-forma Statements of Responsibilities based on generic role profiles
  • Pro-forma Management Responsibilities Map
  • Employment law clause bank (to change employment contracts)
  • Online training module on the conduct rules
  • Template fit and proper policy and certification procedures
  • Template breach reporting policy
  • Template policy for senior managers to access independent legal advice
  • Template notifications policy
  • Template handover policy and handover certificate
  • Template “living will” to assist senior managers document their reasonable steps
  • Template regulatory references policy
  • Template whistleblowing policy
  • List of changes required to the employee handbook
  • Template record keeping and documentation policy

If you would like a copy of the 40 minute briefing slides or further information on the SM&CR toolkit please contact Charlotte Henry.