T&C Scheme framework – How to build your scheme

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We are often asked how to build or structure a T&C scheme or framework. To build a robust Training & Competence (T&C) scheme use these framework elements.  These are based on both the TC sourcebook and industry best practice.  You should try to satisfy all the indicators within each element.

T&C Scheme Framework – COMPETENCE

By understanding their role and personal performance against known standards employees know how they personally contribute to the company achieving their corporate outcomes.

  1. Each job holder has a clear understanding of their job role.
  2. Each job holder  understands and accepts what measures they need to achieve to be deemed competent in their role.
  3. Any difference between standards associated with competence and the highest levels of achievable performance in the role are clear.
  4. Standards used must be measurable.
  5. The standards associated with competence result in meaningful business outcomes being achieved.  This helps ensure that competence standards are set at the appropriate level.
  6. Competence standards ensure that personal performance delivers acceptable outcomes against any values, competency or behavioural framework.
  7. Each job holder  understands how competence in their role helps the company achieve defined corporate outcomes. (These may include the TCF consumer outcomes).
  8. Competence considers the whole job and not just specific elements within it.
  9. The standards associated with competence are reviewed periodically to ensure that they continue to deliver expected business outcomes.

T&C Scheme Framework – RECRUITMENT

Employees are selected for roles based on an objective assessment of their potential and suitability to fulfill the standards required for the role.

  1. Persons performing tasks within the selection process must be competent to do so.
  2. Policy is clear whether you recruit INE (Inexperienced New Entrant) or ENE (Experienced New Entrant) or mixture and shape the selection process accordingly.
  3. Selection processes must use elements that consider the applicant’s current knowledge, skills and behaviour  compared to those required  for the prospective job
  4. All relevant qualifications must be supported by original examination certificates.

T&C Scheme Framework – TRAINING

Training follows a continuous cycle to ensure needs are identified, addressed and result in improvements in business quantity and/or quality

  1. A gap analysis is performed for each new entrant to determine the inputs required on the pathway to competence.
  2. Training is carried out by those people competent to do so.
  3. Training interventions are preceded by a pre-brief and followed by a post brief.
  4. Follow up ensures that learning is transferred to the job.
  5. All development plans indicate the improvement in quantity/quality that will result assuming the development is successful
  6. Training is periodically reviewed and evaluated to ensure that it was and remains fit for purpose.
  7. There is a training planning process that covers strategic, operational and individual training to ensure that there are no conflicts and the plans are manageable

T&C Scheme Framework – ASSESSING COMPETENCE

Competence is assessed reliably across the business against relevant standards designed to achieve specific business outcomes

  1. Whoever performs the role of assessor must be competent to do so
  2. Sufficient evidence must be gathered to evidence competence
  3. To be competent the person must routinely demonstrate the ability to perform the task to the required standards.
  4. Sufficient evidence requires the assessor to consider the range of activities, different customer types or permutations that might be engaged.
  5. The standards used to assess competence must be clear, understood and accepted by the parties involved.
  6. Competence is assessed reliably across the business.
  7. Evidence used to assess competence must be the most recent examples of the persons performance.
  8. Evidence used to assess competence must be valid for the element of competence to be assessed.  E.g. you would normally not use a case study to evidence a soft skill.
  9. Evidence used to assess competence must be objective, not subjective.
  10. Evidence used to assess competence must be capable of being confirmed for authenticity.
  11. Once a person has attained competence they continue to take steps to keep their knowledge, skills and expertise up to date.
  12. Individuals take responsibility for the ownership of their competence.

T&C Scheme Framework – SUPERVISION

Through effective supervision performance gaps and/or risks are identified and addressed.

  1. The focus of supervision is on the effectiveness of the supervisory invention
  2. Supervisors must be competent to perform their role
  3. Supervision is appropriate to the possible risks identified in achieving the desired outcomes.
  4. Supervision is based on a continuum ranging from 100% to minimum benchmark levels. The criteria used to apply this supervisory continuum are clear.
  5. Key performance measures are defined and measured against key job outputs.
  6. Any assessments are performed by people that do not have a vested interest in the outcome.  If they do appropriate measures are in place to sample the appropriate application of the assessment decisions
  7. Performance is reviewed on a frequency appropriate to the experience and competence of the person.
  8. As a minimum requirement performance must be reviewed annually
  9. Supervision is focused on the management of competence/highest level of achievable performance not by the need to complete a minimum number of activities.
  10. Measurement of performance can  pinpoint  the level someone is performing and not just whether they are competent or not.
  11. Development is able to progress an individual beyond competence towards the highest level of achievable performance
  12. The outcome of performance reviews is commensurate with the standards of competence
  13. Supervisors  continue to refresh evidence of competence to ensure that it remains reflective of the individual’s current performance.
  14. For regulated roles the employee must pass the regulatory module of the exam before starting regulated activities with customers.
  15. Adequate supervisory resource is deployed at all times
  16. Where supervisory responsibilities are split the demarcation of responsibilities is clear.
  17. Each individual has an active development plan

T&C Scheme Framework – QUALIFICATIONS & TESTS

Employees can demonstrate knowledge required for roles they undertake through passing professional examinations and/or job specific assessments.

  1. Development through the achievement of appropriate qualifications is encouraged.
  2. A control framework is built around any qualifications stating time frames and number of attempts permitted.
  3. Any tests designed to assess knowledge aspects of competence are sourced against a knowledge syllabus.
  4. Test questions are written by people competent to do so.
  5. A failure policy is appropriately applied ensuring that support is available in between test attempts.
  6. Formal role plays  have defined briefs for participants and assessors with clear objectives as to what is being measured
  7. For regulated roles the person must pass the appropriate examination before being deemed competent

T&C Scheme Framework – REPORTING & CONTROLS

Senior Management can demonstrate how they ensure consistent application of these principles are applied within their business area

  1. Senior Management can demonstrate how effectively the scheme is working at national level against expected outcomes
  2. You can interrogate high level information to drill into root causes at lower levels
  3. There is a clear 2 way flow of relevant information from first line supervision to approved persons
  4. It is clear who takes overall responsibility for the approaches taken and how governance works.
  5. There must be a change control policy
  6. There must be a version control policy
  7. Remuneration approaches are geared to rewarding the desired outcomes of quantity and quality.
  8. There is process in place to ensure consistent communication of the approaches to be taken.
  9. You can demonstrate the robustness of Management Information.
  10. A process in place to escalate risks and issues up to the governance committee as appropriate.
  11. Existing corporate processes are utilised wherever possible to ensure consistency across the business and avoidance of ‘reinventing the wheel’
  12. Exit interviews are conducted to ensure risks and issues are identified.
  13. Supervisors changing roles/leaving ensure that all records and activities have been completed to the required standards.
  14. There is an appropriate supervisor handover process
  15. A process in place to gather and review feedback from users and customers. Such processes could include focus groups, complaints analyses and exit surveys
  16. There is a process in place to share best practice

T&C Scheme Framework –  RECORD KEEPING

Record keeping is embraced as an essential and effective business practice satisfying regulatory requirements as a by-product

  1. Sufficient records are kept to provide evidence of a person’s current level of competence
  2. Records that are kept are capable of being understood and enable continuity of management where appropriate
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About Author

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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