SMCR – Are you ready to conduct your orchestra?


Are you ready to take up the baton to conduct your SMCR orchestra? When helping firms deal with the SMCR (Senior Manager & Certification Regime) regulations you may wish to use this analogy with an orchestra.  It helps put things in perspective and helps you plan the next steps

For this analaogy, imagine you are a senior manager and you have been invited to your company’s own version of last night at the Proms. For your key customers and employees this will be a special evening. You find out, on arrival,  that you are the guest conductor of the newly formed orchestra. You are concerned as you have no experiemnce of this

People tell you not to worry.  Just stand in front of the orchestra and wave your baton. Everything will be okay. All sections of the orchestra have been practising very hard. You decide to ask people in the orchestra about their preparations to help settle your nerves.

The different sections of the orchestra have been rehearsing separately and have been practising different musical pieces. They have never played as an orchestra.

You find out that all sections; strings, brass, woodwind and percussion have all been at rehearsals. The orchestra thinks that they are ready to perform.  The musicians have been practising hard. The musicians have not been practising as a complete orchestra.. The sections of the orchestra have been rehearsing apart and have been practising different musical pieces. They have never played as an orchestra.

You do not want to risk creating a rather unpleasant experience for your employees and key customers. Instead, you decide that it is best that they deliver individual pieces that evening without the assistance of a conductor. You promise to perform such a role next year. They have all had the opportunity of practising the same piece. You will have had some training and practise at being a conductor.


The Compostion of your SMCR Orchestra

So, if you are not prepared to perform as a conductor for the orchestra on the night of the Proms why would you chance it for the SMCR regulations? Instead of musical sections you have  departments such as Compliance, HR, Senior Management and Training Department. Each department has been busily working away at the aspects of the senior management and certification regime regulations. All the departments are sure that they have covered the needs of the regulations. They are ready for you to sign them off and take over.

However, there may be some issues. Firstly, Compliance are talking about having a code of conduct. a fit and proper process and breach reporting process in place. Whereas HR are talking about job descriptions, competencies and performance management.  Senior Managers are talking about the company culture, values, business purpose, objectives and governance structures. Lastly, Training department is talking about the presence of a T&C scheme, the competence and ethical behavioural standards and evidence gathering.

However, it turns out that the departments have not been working together. Worringly, they expect you to stand in front of them. They expect you to build an approach that brings all aspects together in an harmonious way.

This is not going to happen. As a result your key customers and employees will not enjoy a great time. You may chose to walk away from in our orchestra example.

All sections must work well together to produce the end result. Failure to do this means that you may have all the parts in place  but never achieve the true goals of the regulators for SMCR and your customers.

Unlike the orchestra example you do not have until this time next year to make things right. Perhaps you should start to ask questions?


About Author

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I provide consultancy and support to UK based financial services companies helping them to design and implement practices that develop their people, achieve their business goals and comply with the needs of the regulators. I specialise in T&C, competence assessment and conduct which may be of particular interest to companies as they address the requirements of the Certification Regime and Code of Conduct requirements. My specialities include: Knowing you have a business to run Valuing your people as your greatest asset Keeping things simple, practical and relevant Engaging the business to promote ownership Ensuring Compliance is a natural by product of doing things well

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