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.