SMCR ‘season’ has come around once again and we’re heading towards the time of year when refresher training on the Conduct Rules will be on everyone’s ‘to do’ list.
The SMCR’s been around for quite some time now and if we’re not careful, other regulatory topics will take the front seat and refresher training on the Conduct Rules can easily become stale. This kind of training needs to be highly engaging and meaningful so that it’s a ‘real-life’ learning experience, not a mandatory compliance exercise.
We see some high-quality content and delivery of this training in some firms. For others, a fresh perspective’s required because without it, run-of-the-mill Conduct Rules training will be a complete waste of time and effort.
Conduct’s as important as it ever has been, if not more so with the FCA’s focus on non-financial misconduct. So how do we make it hit the right notes?
A great learning experience will mean that employees will have actions they can take away with them and apply directly to their role.
One way of doing this when it comes to Conduct Rules training is to teach your Tier 1 employees about the Tier 2 Conduct Rules that their senior managers have to follow and what this should look like in practice.
Is this overkill? Absolutely not. If Tier 1 employees understand what’s required of their senior managers, the results are two-fold:
Tier 1 employees are more likely to help their senior manager to align to the Tier 2 Conduct Rules, by offering their support. For example, proactively providing them with regular, high quality management information, or perhaps highlighting a risk that they’ve noticed that’s within their senior manager’s scope of responsibility, without being asked.
If a Tier 1 employee experiences, or suspects ‘questionable’ conduct, or any kind of non-financial misconduct at SMF level, they’ll be more assured about speaking up about it, because they’ll know exactly where the bar is set. This means that behavioural issues at senior level (which shouldn’t happen, but sometimes do) will be caught much earlier, resulting in less harm and far less pain overall.
Even better, if you add some content about Psychological Safety and in parallel have your senior managers visibly and regularly driving this narrative out on the ‘floor’ you’ve made a great step forward in developing the culture within your firm.
And that’s what you’re really aiming to achieve if you want meaningful application of the Conduct Rules within your firm at all levels.
If you’re planning your next round of Tier 1 or Tier 2 Conduct Rules refresher training and you’re looking for something different, get in touch with us on 0203 879 9093, or email julie@chameleoncompliance.co.uk.