SENIOR MANAGEMENT
1 . Senior management need to periodically review the effectiveness of policies to address deficiencies .
2 . Specific responsibility for each of the requirement areas should be allocated to a member of senior management . The responsibility should be documented and a record kept .
3 . Senior management must be aware of any remedial measures that have been taken as a result of problems discovered by the audit , risk or compliance teams .
4 . There should be a ‘ supervisory function ’ within the firm that keeps watch over the senior management .
PAY AND BONUSES
1 . Companies must have remuneration policies that keep in mind clients ’ interests and ensure they are treated fairly .
2 . Remuneration policies must not create a conflict of interest for a person to favour their own interests over a client ’ s .
3 . Senior management are responsible for the day-to-day remuneration policy and monitoring compliance risks relating to the policy .
4 . Pay structures should not be based purely on quantitative commercial criteria and should include metrics on regulations , client treatment and quality of service .
5 . There should be a balance between fixed and variable remuneration components .
COMPLAINTS HANDLING
PERSONAL TRANSACTIONS
1 . Firms must have clear procedures for handling complaints – not just from clients but potential clients also .
2 . The complaints management policy should be up-to-date and endorsed by management .
3 . Clients and potential clients should be able to complain free-of-charge .
4 . A ‘ complaints management function ’ should be established at all firms .
5 . This individual / team should keep a log of complaints data for the compliance team .
1 . Firms shall put in place arrangements to prevent people making personal transactions based on the misuse of confidential information .
2 . Company employees must not disclose delicate information to others , knowing that they or one of their associates would enter into a financial transaction benefitting them .
3 . Firms must ensure they chart and record personal transactions of staff .
4 . Outsourced firms must keep records of their staff ’ s personal transactions .
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