Finance Monthly March 2020 Edition

BUSINESS & ECONOMY - SM&CR 35 www.finance-monthly.com 6. Systematic approach to SM&CR: Finally, to embed SM&CR as a cultural aid and to be able to have the oversight and good governance that the regulator is demanding, firms really need a cross-function and collaborative approach to operating the regime across their business, covering areas such as HR, Compliance and Operations. For firms to develop an approach that maintains all the current and historical records in a single place, manages all the workflow to ensure actions and reports get done ‘to time’ and ‘to standard’ should be the “holy grail”; thus, allowing the business to demonstrate that it is compliant with the regime, whilst generating business benefits from the oversight and transparency a systematised approach will bring. “To embed SM&CR as a cultural aid and to be able to have the oversight and good governance that the regulator is demanding, firms really need a cross-function and collaborative approach to operating the regime across their business, covering areas such as HR, Compliance and Operations.” Working on these six areas alone won’t guarantee a positive, strong, healthy culture. However, it will create the foundations for a safer and stronger future for both firms and the industry as a whole. Good conduct and culture is most likely to develop effectively and embed well within businesses when it is driven from the top, but cultures really only grow to be the ones that people like to operate in when every employee accepts that they are responsible for it too. The FCA can’t force you to adapt, but by using SM&CR they aim to be able to spot leading indicators of poor culture and evidence strongly suggests that they are prepared to act.