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Robust governance led by senior managers and Approved Persons can ensure that changes to your operations and your services for customers are well managed and that important risks are surfaced early and dealt with. A simple structure of policy groups chaired by senior management and supported by strong risk, compliance and technical functions can act as a brake on sometimes chaotic change and align your services with your business objectives and your customers’ needs as well as reducing unnecessary spend and distracting initiatives.

Enterprise Learning can independently assess your existing governance structures to validate them and advise on improvements, reviews which can be provided to regulators if required as proof of your commitment to strong governance. We can help you put in place a streamlined structure, developing Terms of Reference for your groups and Role Profiles for your senior managers. We can also help you ensure these groups and people receive the right management information as well as understand regulatory expectations and how competitor firms operate. We can work with your Risk/Compliance functions to strengthen their approaches and help ensure their monitoring and policy approaches are effective as well as practical. If necessary we can carry out independent audits on behalf of senior managers or Risk/Compliance or provide specialist resource to help Risk/Compliance functions.

If necessary we can help you prepare for regulatory reviews and visits or manage your relationships with regulators after visits or when you are moving into new business areas.

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Benchmarks

  • I have appropriately skilled and senior people on my governance groups and other decision making teams to decide policy and make decisions.
  • I have robust and effective Change Control procedures when authorising any changes to regulated standards or processes, and ensure a full archived record of decision making is maintained.
  • I regularly review any customer operations using appropriate MI to identify and act on areas of concern.
  • I lead on risk management and ensure major risks (including Conduct Risks) are identified and appropriate systems are in place to ensure these are monitored and managed.
  • Senior managers keep up to date with regulatory thinking and requirements

Negative Indicators

  • Decision makers appointed who do not have the required level of seniority/capability.
  • Authorising changes without change control procedures which allows haphazard changes to processes or guidance without due consideration and authorisation.
  • MI is distributed but recipients do not use it or do not understand when they should take action/ what action to take.
  • Risk Function assumes that because MI is available, the operational leadership is capable of using this data to identify risks and mitigate them successfully.