Category Archives: Conduct Risk & TCF

Training & Competence – T&C

Training & Competence – T&C

Training & Competence t&c

The importance of this section cannot be under stated. Due to the changes in this area and post-Brexit potential changes, we consider it prudent to provide a link to the FCA Handbook 

Additionally, you may find these points useful;

How are individual training needs identified and by whom?
Identifying the training needs for each role in the T&C scheme should start with the professional knowledge / qualifications required of that role. Professional bodies like the CII (Chartered Institute of Finance) and Chartered Institute for Securities and Investment (CISI) run both training programmes and provide qualifications. A second source of guidance is your professional trade body. Many trade bodies host interest groups on T&C that will enable networking and the opportunity to benchmark with other similar organisations. The third source of guidance should be your internal HR team. If you don’t already have the competency requirements defined for the roles in the T&C scheme, they should have the expertise to help you define what these are. HR should be a key resource for guidance on the competency requirements of each role beyond the core set of professional knowledge / qualifications. Once defined for each role, these competency frameworks form the basis for the identification of training needs that should be aligned by role. All that remains then is to organise any training needs in a logical sequence. On a final note, training needs can arise at any time and a key part to effective identification is supervisors who are trained and capable of not only spotting training needs but providing appropriate support to resolve them.
How are the learning objectives, timescales, responsibilities and measurements set defined for each training need identified?
This depends on the nature of the training needs. There is a great deal of discretion for firms to decide how they define and subsequently deliver their training. Professional bodies usually set annual standards for continuing professional development (CPD) for their members and many firms will also have their own in-house expectations too. These CPD requirements will often be split into structured versus unstructured learning. In fact, the FCA requires that retail investment advisers need to complete 35 hours of CPD each year. Successful completion of this CPD enables the individual to retain their Statement of Professional Standing (SPS). Beyond the CPD targets set by professional bodies, firms can and do set their own CPD requirements. This should be linked to the required measurements and timescales and be evidenced as part of the T&C Scheme arrangements.
In essence, any training identified should be noted via a SMART training plan that allows anyone looking at an individual’s development to be able to see when the need was identified, how will it be met and, when it is met, how will the change be measured.
What is in place to ensure training remains effective and up to date?
Training plans should be subject to regular review. There should be corporate training input that is managed by a central training team and typically will cover the provision of e-learning together with behavioural type inputs such as selling skills, handling difficult clients etc. Then you have the localised training that will tend to be managed by the T&C Supervisor. This is where small needs are identified through other T&C activities and then localised on the spot training is delivered to meet the need.  The trick here though is once again for a well-trained supervisor who can identify, manage and deliver against these needs, ensuring of course that everything is documented on the individual’s records, because if you can’t evidence it then in the eyes of the regulator it didn’t happen.
Who is responsible for ensuring training is timely, appropriate and evaluated?
At a localised level it is the T&C supervisor that needs to cater for the needs of the individual through either 1:1, group or referred training. Each training intervention should be evidenced through some type of Training Event Record that details what the training need is, what the proposed solution is and how this will be taken into the workplace. A structured approach of this nature then allows the T&C Scheme activity to be reviewed by the most senior overseer of the scheme to help ensure that training needs are either being met in the field or referred where a more formalised response is required.
How is training evaluated and by whom?
Who takes responsibility for making assessments about the competence and capabilities of individuals will vary across different organisations. However, responsibility for evaluating the effectiveness of training tends to fall to the staff member’s immediate line manager, dedicated T&C supervisors or, in some cases, a mix of both. Because whilst training is the input, the most effective way of evaluating its success is looking at the output and that means reviewing the individual whilst operational in role. The T&C scheme should define who assesses what activities and training will typically be evaluated at the point of delivery (by the training team) and at the point of use by the supervisory team.

If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on 0207 097 1434 or email

This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

Why Is Document Version Control So Important?

Why Is Document Version Control So Important?

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Why is Version Control Important?

Version control is important when documents are being created, and for any records that undergo a
lot of revision and redrafting or annual reviews. It helps us to track changes and identify when key decisions were
made along the way. It is particularly important for electronic documents that are being reviewed
by a number of different users.

Knowing which version of a document you are looking at is important if you are trying to find out which version of a policy is currently in force, or which version of a policy was in use at a particular time. It forms good records keeping practice which is particularly important in meeting our obligations under the Freedom of Information Act.

The aim of this document is to provide best practice guidance for applying version control to
different types of document at the University of Nottingham. This guidance covers best practice use
1. File Naming conventions
2. Version Numbers
3. Version Control Tables
4. Document control Tables

File Naming Conventions
At the simplest level you can use file naming conventions to identify the version of a document. Use
the file name of the document to determine both the version and status alongside the subject , for

Records Management Policy Draft v0.1

Records Management Policy Draft v0.3


Records Management Policy v1.0

Records Management Policy v1.1 (note: first revision – minor)

Records Management Policy v2.0

Remember to update the version number on the file name as well as the header (or footer) of the
document itself. It is easy to update a document and forget to rename the version number on either
the file name or the document which can lead to confusion.

Unless you don’t need to keep previous versions of the document, always save updated versions as
‘Read-only’ tag to ensure you are forced to create a new version the next time to go to update it.

File naming conventions alone will not tell you who made the change and what the change was. If it
is important to record this information use a version control table.

Version Numbers
Version numbering helps to distinguish one version of a document from another. For some
documents, you may decide that a simple numbering system consisting of consecutive whole
numbers is sufficient to help you keep track of which version you are working on. However,
documents that go numerous stages of development before a final version is reached, and for those
that are developed through input by multiple individuals, you may decide to adopt version numbers
to keep track of both minor and major changes to that document.

Minor Revisions
Minor revisions are small changes made to a document such as spelling or grammar
corrections, and other changes that… Minor revisions to a document are reflected by making
increments to the decimal number.

Major Revisions
Major revisions are changes to a document that require the document to be re-approved
(either by an individual or a group). Major revisions are reflected by incrementing the whole
number by 1.

document control version control

compliance consultants london fca authorisations

document control version control

Remember – when electronically storing documents, it is often best practice to include the date at the front in reverse, as computers store files incrementally. So – 1st March 2021 becomes 20210301.


If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on

0207 097 1434 or email

This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

FCA Fine? You may be in good company!

Compliance Monitoring Plan template

FCA Fine? You may be in good company!

Penalties for regulatory compliance breaches can be eye-watering in scale.

2020 largest Fines
1. Goldman Sachs International (fined £97m)
PRIN 2 and PRIN 3 breaches – Risk management failures

2. Lloyds Bank, BoS & The Mortgage Business (fined £64m)
PRIN 3 & 6 breaches – Poor handing of mortgage customers

3. Commerzbank (fined £37.8m)
PRIN 3 breaches – AML failings

4. Barclays (fined £26m)
PRIN 6, PRIN 3, and CONC rules breaches – unfair treatment of customers in the Retail Banking sector

5. Charles Schwab (fined £8.96m)
PRIN 10 and 11, CASS and Section 20 FSMA breaches – Safeguarding and Compliance Issues

6. Moneybarn (fined £2.8m)
PRIN 6 & 7 and CONC rules breaches – Unfair treatment of customers

How could these fines have been avoided?

The FCA’s ‘Principles for Business’ (PRIN) set out the fundamental obligations for firms under the regulatory regime.

According to the FCA principle 3, a firm ‘must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems’.

This refers to a firm’s:

  • Robust governance arrangements – rules, practice and processes. How Can We Help? We can review your arrangements.
    Skills, knowledge and expertise of staff – in other words train people!
  • Outsourcing responsibilities – know your suppliers and make sure they are compliant. How Can We Help? We can review your arrangements.
  • Reasonable steps – under SMCR you need to ensure you have decision making fully and appropriately records. How Can We Help? We can review your arrangements.
  • Record-keeping – keep records, and make sure they are accurate and up-to-date. How Can We Help? We can review your arrangements.
  • Conduct Risk – keep records of any T&C breaches, mis-selling, product design etc. How Can We Help? We can review your arrangements.
  • Conflicts of interest – keep a compliance register to avoid issues. How Can We Help? We can review your arrangements. 

The FCA will identify potential or actual consumer harm caused by the actions of firms or markets and take action to address that conduct. These penalties should act as a clear warning to any companies who aren’t taking financial compliance as seriously as they should be.

If you would like to have any of your processes, files, procedures, governance or strategy planning reviewed, in confidence, we can be contacted on the above number. Or, just complete the form below.


    Fca Principles For Business Conflicts Of Interest, Fca Principles For Business Rules, Fca Principles For Business Smcr, Fca Principles For Business Sourcebook, Fca Principles For Business Tcf, Fca Principles For Business Treating Customers Fairly, Principles For Business, Principles For Business Sustainability, Principles For Business Vulnerable Customers

    Treating Customers Fairly – TCF Checklist

    Treating Customers Fairly – TCF

    Treating Customers Fairly TCF Checklist

    The FCA no longer carries out TCF specific visits, however this does not mean that they think it is any the less important. It does mean that by now they expect the principles of TCF to be embedded in all firms and to be the bed rock of their business models. The principle is to ‘put the customer first’ in everything which we do. Therefore, if during a visit or an interview they get the impression that TCF is no longer a priority, they will certainly investigate further and this is where you will need FCA compliance consultant by your side.

    TCF applies to both Product Providers and Intermediaries. Broadly, the Regulator intends that:

    Product Providers should ensure that:
    • their products are appropriately designed for the target market
    • the marketing material is clear, fair, not misleading, and likely to be understood easily by those reading it
    • the product should perform according to the expectations given
    An Intermediary’s primary responsibility is to ensure that:
    the customer has all appropriate information in an understandable format, which means;
    For advice sales:
    • the clients’ attitude to investment risk and capacity for loss has been properly established
    • the product is suitable for the customer
    • the product is affordable
    • the post sales service meets the expectations created
    The TCF exercise, which all regulated firms should undertake no less than annually, is essentially a “Gap Analysis.” For the purposes of Risk Management, the FCA expectations could be broken down into 6 key areas:
    1. Senior Management Responsibilities
    2. Communication with Clients
    3. The Advice Process
    4. The Post Advice Process
    5. Disclosure and Payment for Services
    6. Staff Competence
    The following is a non-exhaustive list for your guidance.
    The TCF Outcomes Management Statement
    • TCF is central to our corporate culture
    • Senior management can demonstrate how TCF is embedded in our business strategy
    • The fair treatment of customers is central to our Firm’s culture
    • Senior management practice what they preach and re-inforce TCF on a day to day basis
    • Senior management have undertaken a TCF audit / gap analysis
    • An action plan has been agreed and is/has been implemented
    • Critical elements of TCF are included within our MI. This is regularly reported and acted on
    • Staff routinely share best practice and can explain what TCF looks like to them
    • Adherence to TCF practices are rewarded
    • Remuneration policy and staff rewards support TCF
    • Actions taken demonstrate adherence to TCF obligations are recorded
    • Feedback processes are in place to gauge client satisfaction
    • Responsibilities for TCF are clear, e.g. for taking action, monitoring results / identifying improvement areas
    • Staff are engaged, motivated and trained in what TCF means
    • Everyone within the business is truly client focused
    • All our people are well trained for the roles they perform
    Products and services marketed….meet the needs of identified customer groups and are marketed accordingly 
    • Advisers are able to identify target markets for specific products
    • Financial promotions are regularly reviewed for relevance and clarity
    • Advisers/managers demonstrate their knowledge of products
    • The sign-off process for advertising and promotions is rigorous
    • We are confident in our expertise to recommend and manage in our chosen markets
    • Our promotions are targeted to ensure they are aimed at the right clients
    Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
    • TCF principles are reflected within T&C documentation, e.g. observation form
    • Content of documentation is not overly technical, e.g. suitability letter
    • Clients can clearly see the advice given and why, e.g. it isn’t buried in other documentation
    • Clients always understand the benefits of the advice / products recommended
    • Clients always understand the limitations and risks associated with the advice / products recommended
    • Documentation (such as suitability letters) are always tailored to individual clients
    Advice is suitable and takes account of their circumstances
    • Attitude to risk is clearly identified, understood by the client, documented, and matched by recommendations
    • Advice covers, where appropriate, non-income earning recommendations, e.g. National Savings, utilizing IHT annual allowance, repayment of debt
    • Soft facts are always collected on the fact find — not only what, but why?
    • Knowledge of adviser / supervisor products and associated advice areas is spot on —this is current and has been objectively assessed
    • There is no sales bias
    • Clients fully understand the status of the adviser and clearly understands the merits of the different remuneration methods
    • `Know your customer’ requirements are fully documented, e.g. limited advice or `client not prepared to disclose’ are the exception rather than the rule
    • We take time to understand our clients’ needs
    • We regularly review our stance on investment and technical issues
    • The fact find document readily captures all of the information we need about the clients circumstances for us to fully advise them.  
    Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect
    • Advice process includes a measurement of client satisfaction
    • Service standards (where agreed with a client) are met, e.g. time to write a report
    • Ongoing client reviews are always conducted as agreed with the client
    • Advice to existing clients is always the same as that to potential new clients, e.g. some advisers would not now recommend WP investments to new clients — what do we do about existing clients with WP investments?
    • Client reviews / contact methods are established with each client
    • Whatever client contact is agreed, this is followed through for both new and existing clients
    • Information is reviewed for relevance, accuracy, and clarity
    • Ensure clients expectations match provider service
    • Clients regularly complement us on our service
    Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint 
    • Complaints data / client feedback is reviewed to identify TCF issues
    • Staff and advisers know what a complaint is defined as and what to do when one is received
    • Service standards are in place and adhered to
    • Complaints investigated in a impartial manner without confrontation
    • Complaints processes in place and regularly reviewed (as applicable)
    • All client data is accurate, up-to-date, easy to use and accessible
    • Our database enables most client queries to be dealt with by support staff
    • Our software supports the main advice and business process

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on

    0207 097 1434 or email

    compliance consultants london
    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    Directors and/or Partners Responsibilities and Further Training

    Board of Directors – Understanding and Further Training?

    compliance consultants london-director-training
    Is it evident that the Directors understand:-
    • Directors’ liabilities and corporate governance
    • What is a company? What can it do?
    • What is a director? Types of director
    • Director’s responsibilities (SMCR & 
    • Internal governance
    • Corporate administration
    • Financial difficulties and investigations
    • General duties
    • Promoting the success of the company
    • Embedding duties
    • Reasonable steps (SMCR – See DEPP 6.2.9-E)
    • Legal context
    • Duty to act in good faith and with due care
    • Conflicts of interest
    Are there plans to enhance the board by:-
    • What will you do to improve your approach to governance and your role as a director?
    • What will be different about your next board meeting?
    • Board maturity
    • What do performance and success mean to your board?
    • Are there key messages / assumptions you need to challenge?
    • Do you have adequate succession plans in place?
    • What are your board’s future and legacy issues?
    • Action plans
    • Turning rhetoric into reality
    • Starting conversations to develop board and senior management team insight
    • Evaluating board and senior management effectiveness
    • Improving information flows between the board and the senior management team

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on 0207 097 1434 or email

    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    Regulatory Complaint Handling & The FCA

    Regulatory Complaint Handling & The FCA

    regulatory complaints handling image

    The FCA’s complaint handling requirements and the Financial Ombudsman Service (FOS)

    The FOS is an independent adjudicator of consumer complaints linked to the supply of finance.
    Firms must have their own internal complaints handling procedures and comply with rules (set out in the DISP chapter of the FCA Handbook) which set out timescales within which responses to complaints must be given to customers. The firm must have an adequate regulatory complaints policy and procedures as well as effective means of recording their categories and responses in a compliant way.
    If, at the end of a firms internal complaints-handling process (generally eight weeks), the customer remains dissatisfied, they have the right to refer the complaint to the FOS for adjudication and resolution. FOS’s decision is not binding on customers, who remain free to pursue their complaint in the courts if they wish: the decisions are however binding on firms and FOS can order firms to take corrective action and where appropriate pay redress up to £350,000.
    This was increased from £150,000 on 1st April 2019. The increase only applies to complaints referred after 1st April 2019. For complaints referred after 1st April 2019 about earlier complaints, the limit increased from £150,000 to £160,000.

    If you need to create, review or execute your Governance. Risk or Compliance strategy, call us today on

    0207 097 1434 or email

    compliance consultants london
    This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

    Non-Financial Conduct Risks & How To Mitigate Them

    Non-financial misbehaviour – what is it?

    Obviously financial misbehaviour comes under the guise of financial crime, fraud or embezzlement, but non-financial misbehaviour can come in lots of guises such as, discrimination, harassment, bullying and victimisation and more.

    If these type of behaviours fly under the radar in your business, it promotes a culture where individuals do not feel safe to speak up, a crucial area of considerable focus for the FCA in their guidance of culture through the culture drivers they have highlighted. Through this increased supervision, the FCA is seeking to ensure that all companies understand the need to promote a healthy culture.

    Are people just being oversensitive? 

    While a few of this can be hard for senior management to spot, there’s some essential checkpoints you can utilise and typical indicators that will flag up any problems.
    Consider non-financial misconduct when performing fitness and proprietary assessments and meetings. Sincerity, stability, integrity and credibility is every bit as important as competence to perform the role and the onus of this assessment sits with the company. Although HR can be a good source of these red flags, they may not be the best to investigate it, due to their company bias, unlike compliance, internal Senior Manager or external independent consultants.
    It is vital that all head of departments and directors or partners take the obligation for tackling non-financial misconduct that happens on their watch. Any failure to take reasonable actions to deal with non-financial misconduct needs to be considered when considering the viability & performance of senior managers and other leaders. The SMCR relies on “Reasonable Steps” to be taken and recorded and you can see our blog on these, HERE.
    Review your processes and procedures for dealing with non-financial misbehaviour. Look at it through an official and informal lens, making sure there aren’t any barriers to the creation of a beneficial environment and blameless culture where everyone feels it is safe to speak up. This kind of cultural pattern decreases the danger of unethical and anti-social behaviour. You must always bear in mind that speaking up doesn’t always come naturally to some people it’s just as essential to have a listening culture and senior managers need to promote this. Compliance interview techniques are particularly useful in this scenario to establish the proof.
    To promote good conduct, create incentive structures the right conduct is rewarded through online reviews such as Trustpilot, Google, Feefo etc. In our experience, the majority of businesses recognise with the balanced approach of suggesting rewards aren’t solely based around financial efficiency, but wider things like having an internal anonymous voting system for nominating others and communications from the Board about the firm’s clear purpose can assist with reinforcing this, which is something many firms struggle with. Any culture change task requires us all to view the bigger picture and take a part in promoting a great culture.

    If you need help with establishing, reviewing, assessing or investigating your non-financial conduct code or rewards system, contact us on 0207 097 1434.






    Compliance Support Services Explained

    Once your organisation has accomplished authorisation, you’re dedicated to satisfy a variety of on-going FCA compliance responsibilities. Companies either pick our consultancy services to help resolve specific issues or to handle the effect and impact of new policy or we tailor a retainer agreement to satisfy their particular continuous requirements.

    Retainer agreement
    Our extremely skilled group of compliance specialists have market and regulatory backgrounds supplying an unique mix of skillsets and giving you the confidence that your continuous regulatory responsibilities will be satisfied to a high expert requirement.

    With retainer service contracts separately tailored to your organisation we provide an agreed service delivery and schedule. Having operated in your sector, our professionals understand your compliance obstacles and opportunities. They share their backgrounds and understanding to solve issues; so you reap the benefits of a unique sum total of competence.
    Supplying you with budget certainty and on-demand access to an extremely trustworthy compliance partner and a topic expert panel, usually, our retainer contracts include:
    • Compliance management; setting up and your Compliance Monitoring Programme, including automating it if required.
    • Compliance audits; independent bench-mark reviews and health-checks to make certain your systems, controls, policies and regulatory procedures are kept up to date
    • Documents/Governance; such as policies and written processes or procedures
    • Financial promotions including initial reviews and ongoing assessments or critiques, including video and social media marketing
    • Training; e.g., informing personnel on anti-money laundering or assisting senior management create a suitable governance framework
    • Regulatory reporting; consisting of GABRIEL returns and evaluation of prudential requirements
    • For Payment Services companies based on PSD2, we provide distinct service plans particularly created satisfy the increased regulatory needs and responsibilities.
    • And Capital Market companies gain from a specific methodology which permits us to craft a bespoke, flexible assistance package
    • Companies fall into the Asset Management, Broker Dealers & Traders, Corporate Finance, Crowdfunding, FinTech, Infrastructure, Investment Management, P2P Lending, Private Equity, Venture Capital and Wealth Management can all benefit from individual; and tailored packages.

    Contact us today on 0207 097 1434 or email

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      EMI Compliance Manual Template

      OK, So Why Should I Need A Compliance Manual?

      For any Compliance Officer or SMF16 who has been in the UK financial services industry for any more than a year, this document is important.

      Critically they will know that one of the first documents that they, as well as all staff, have to read and attest to having done so, is the Company Compliance Manual.

      Although this is not a regulatory requirement …

       it is becoming a regulatory expectation!

      There are a number of elements that the regulators not only expect to be documented, but also somewhere that explains the rationale behind the way company’s manager their risks. This would clearly be best summarised in a regulatory Operational or Compliance Manual.

      The Regulator expects a firm to have a personalised and firm-specific compliance operating procedures manual pertinent to the firm and embedded within its processes and culture.

      Most on-line and centrally maintained manuals offered by some consultancies are considered NOT to be personalised, firm specific OR relevant enough to the individual firm.

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      An additional function is where the firm can articulate how they expect the staff to operate and the standards that they are expected to adhere to.

      But what do I put in it?

      Often Compliance Manuals can be used to document the sales process for adviser’s to follow including, for example, transaction only clients.

      There has to be  clear distinction for specific procedures and, for example when to assess a client for appropriateness when they refuse to provide sufficient details for suitability.

      We do not suggest you fill your Compliance Manual with just processes as it is a valuable place to store certain high level explanations of policies such as the Data Protection Act, Bribery Act, Outsourcing Policy and Whistleblowing protocols.

      Additionally this invaluable document can be used to point to other company documents such as policies and forms or other constantly updated items such as the Anti-money Laundering and Terrorist Financing procedures or even areas such as your Approved Persons Policy or possibly additional changes from Euroland.



      Conduct Risk Stress Test Checklist

      Conduct Risk Check List Template

      Assessing Conduct Risk – A Checklist Solution

      We would normally be the last people to recommend check list compliance as an option.

      Sometimes, all you need to get the ball rolling is a check list. That in itself brings in further challenges, as you ask yourself, what do I put in as a question, when I may already know the answer and cannot counter my personal bias?

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      The Answer is clear – The Compliance Consultant “Conduct Risk Stress Test Template”

      The checklist gives you 4 pages of questions in the sections of;

      • Risk Assessment

      • Oversight, Framework and Leadership

      • Standards

      • Alignment with HR Practices

      • Communications and Training

      • Reporting & Response

      • Monitoring and Assessment

      • Culture

      And it includes Bonuses, promotions, exit strategy, internal code of conduct and many more!


      This simple yet powerful addition to your annual compliance monitoring plan (buy yours here!) will help you assess your initial and ongoing Conduct Risk Improvements.

      • It will show any 3rd party the developments you have embarked on.
      • Show staff what changes you have made
      • Identified the cultural risks that lurk in every organisation
      • Can be done company wide or departmentally
      • Can be used as qualitative Management Information for the Board/Partners

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