Senior Managers & Certification Regime

The new Senior Managers and Certification Regime (SM&CR) came into force on 9 December 2019. In their latest business plan, the FCA state their aim is:

"to drive a cultural change in the industry that puts consumers and market 
integrity at the heart of the way firms do business." 

The SM&CR is intended to help meet this objective. The FCA have also called on firms: 

"to demonstrate how they are delivering a culture that rewards good conduct, 
that sets out clear accountability and encourages good decision making."

Under the SM&CR, the Chairperson, Chief Executive, Directors and Senior Managers of a business have prescribed responsibilities with a new set of conduct rules as the foundation for how all those involved in the business should behave. One of those rules is that:

"You must pay due regard to the interest of customers and treat them fairly."

But as a Senior Manager or a Non-executive Chair, how can you evidence that all your clients are being treated in line with the new conduct rule? Simple - ask them and ask your employees. Investor in Customers' (IIC) unique 5-minute independent online survey puts in place a methodology and process to continually improve the customer experience, whilst also helping to meet the needs of the fourth conduct rules. Not only does this provide clear evidence of your client centricity and employee understanding for the need to focus on clients, our results show a clear correlation between enhancing the customer experience and improving profitability. 

How can IIC help with SM&CR compliance?

Let's start with the five conduct rules:

1. You must act with integrity

2. You must act with due care, skill and diligence

3. You must be open and cooperative with regulators

4. You must pay due regard to the interests of customers and treat them fairly 

5. You must observe proper standards of market conduct

SM&CR means firms need to take responsibility for their employees being fit and proper to do their jobs, including Non-Executive Directors. Additional conduct rules apply to Senior Managers who must be assessed at least once a year. Client centricity is central to SM&CR, and is directly referenced as one of the five conduct rules.

An IIC assessment can:

  • Provide an independent assessment of employee and client perception of the culture of the firm - asking the right questions to the right people
  • Allow parts of the SM&CR compliance work to be outsourced with annual client auditing, segmented by department, team and individual
  • Identify areas of strengths and weaknesses
  • Help monitor and deliver plans to achieve culture change
  • Save time and save internal resource
  • Provide performance benchmarking across the business

IIC gives you the insight and evidence you need