Are you ready to conduct your SM&CR orchestra?


I have been trying to come up with an analogy that best describes a scenario I come across regularly when helping firms deal with the Senior Manager and Certification Regime regulations.

Imagine you are a senior manager and you have been invited to your company’s own version of last night at the Proms – A very special evening for your employees and key customers. You arrive on the evening to find that you are the guest conductor of the newly formed orchestra. You have no experience of this and are somewhat concerned.

You are told that there is no need to worry all you need to do is stand in front of the orchestra and wave your baton. Everything will be okay. You are told that all sections of the orchestra have been practising very hard . To settle your nerves you decide to ask people in the orchestra about their preparations.

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 are relieved to find out that all sections the strings, brass, woodwind and percussion have all been attending rehearsals regularly and are ready to perform . You become much more concerned when you discover that although a lot of practising has been undertaken none has been done with all musicians together. The different sections of the orchestra have been rehearsing separately and have been practising different musical pieces. They have never played as an orchestra.

Rather than create a rather unpleasant experience for your employees and key customers you decide that it is best that they deliver individual pieces that evening without the assistance of an active conductor. You promise to perform such a role next year when they have all had the opportunity of practising the same piece and you have had some training and practise at being a conductor.

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 SM&CR regulations? Instead of musical sections you have Compliance, HR, Senior Management and Training Department. Each has been busily working away at the various aspects of the senior management and certification regime regulations. All are confident that they have covered the requirements of the regulations and already for you to sign them off and take over.

In a similar way to the orchestra not practising together you find that compliance are talking about having a code of conduct. a fit and proper process and breach reporting process in place. 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 whilst training a talking about the presence of a T&C scheme, the competence and ethical behavioural standards and evidence gathering.

None of the departments have been working together yet they expect you to stand in front of them and be able to orchestrate an approach that brings everything together in an harmonious way.

This is not going to happen and the likelihood is that you will create the unpleasant experience for employees and customers that you chose to walk away from in our orchestra example.

To make or create the right approach requires all sections to work harmoniously together to produce the end result. Failure to do this means that you may have all the parts in place , they may perform individually but never achieve the true expectations of the regulators 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

Jeff Abbott

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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