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Manually creating a new member of staff subject to Conduct Rules

This is how to create a new member of staff subject to the Conduct Rules only under SM&CR

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Written by Jack Smurthwaite
Updated over 3 years ago

We highly recommend that you use the 'Add a new staff member' function found under WORKBENCH > FREQUENTLY PERFORMED ACTIONS to add staff members, but if you want to manually create a member of staff, you would:

You would then need to add in all the regulatory information for this person. to do this you would:

  1. Select WORKBENCH from the top menu.

  2. Select ENTITY DATABASE from the side menu.

  3. Click the dropdown to select PEOPLE.

  4. Click on the newly created staff Person ENTITY

  5. On the right-hand side click the DATASETS tab.

  6. Click Staff.

  7. Then, click Staff Information

  8. Then click the PLUS Symbol.

  9. The STAFF INFORMATION dataset menu will then appear.

  10. Fill in all requested details.

  11. Click SAVE and CLOSE.

NB - If you're creating a staff member subject to the Conduct Rules - the FCA requires that you collect at least the following information:

Data point needed

Reason data is required

Detailed personal information ( e.g. title, surname, ALL forenames incl middle names, previous names, date of birth, place of birth, national insurance number, current address, nationality, passport number, contact number & Email address)

The FCA may never request this information but it is best practice to store it in case there is a Conduct Rules breach. If there is, the FCA will probably request it.

Information about current role (e.g. role title, role description).

This will help you assess how much risk this staff member poses to your firm. You may eventually decide, as a result of storing this information that this staff member is or has become a Certification Regime (CR) employee.

Your attestation that your firm has given the staff member training around how the FCA’s Conduct Rules apply to them and to their position.

Under SM&CR, all FCA regulated firms must explain to new employees how the Conduct Rules apply to them and to their positions. We recommend that you attest that you have done this in Corterum.

A decision around whether or not this person is a purely ancillary member of staff.

Some staff members (e.g. cleaners or kitchen staff) in FCA-regulated firms pose such little corporate & financial risk that they are deemed ancillary. Ancillary staff must maintain responsible conduct but the audit trail you keep for them can be much leaner than the one you keep for SM’s, CR’s and Conduct Rules staff.

Information about any past actions that were, or would have been, violations of FCA Code of Conduct rules.

The FCA requires you to report any Conduct Rules breaches to them as soon as they happen. In some cases, you may learn that a staff member breached an FCA Conduct Rule when they worked in a non-FCA regulated firm. You may still need to report this to the FCA. Conduct rules breaches can be stored in Corterum.

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