As part of complying with the SM&CR, Senior Managers have to confirm and outline the 'reasonable steps' they have taken to comply with the conduct rules that apply to them. Here's how Corteum can help you maintain a record of these steps.
Click WORKBENCH and then click DATASETS.
Then click SM&CR.
Then choose Senior Managers Regime.
Then click on Senior Manager 'Reasonable Steps'.
Then select 'Reasonable steps' framework.
A list of any staff members for which you have recorded 'reasonable steps' will appear.
To amend the record of reasonable steps taken for a staff member that have already been recorded within Corterum - click on the name of the staff member who's record you'd like to amend, and in the pop-up window that appears, select EDIT. Then edit the data as needed. You can follow on from step 9 below as a guide.
To add a record of reasonable steps taken for a new staff member click the + symbol.
A pop-up window will open.
This pop-up is in the form of a table dataset <Link> where every individual reasonable step is recorded as a row in the table.
Select the staff member to whom this record pertains from the dropdown list.
Enter the date that a particular 'reasonable' step was taken.
From the dropdown box , select the 'Conduct Rule under consideration' to record which of the FCA's conduct rules this reasonable step concerns.
Under 'DEPP 6.2.9-E Factor' use the dropdown box to select the relevant factor.
Under 'Elements of control' choose the most relevant option from the dropdown list.
If the relevant element of control is not listed, select 'Other' and provide the element in the text box to the right of the dropdown.
Under 'Evidence of Reasonable Steps' choose the type of evidence you are recording. Again, if the relevant evidence type is not listed, select 'Other' and provide the evidence type in the text box to the right of the dropdown.
Under 'Details' use the text box to give a summary of the reasonable steps taken.
Under 'Remediation action required (if any)', use the text box to describe any remediation action needed.
Then under 'Remediation action required by', use the dropdown box to confirm the member of staff that is required to perform the remediation action outlined in the previous step.
Under 'Remediation deadline', set out the date by which this action needs to be completed.
Under 'Rag Status', select the appropriate level of urgency/importance from the dropdown box.
You can also upload any supporting documents (or view/remove any already uploaded) by clicking the button under 'Documents'.
If you want to add another row to input details of another reasonable step - click the 'ADD ROW' button at the bottom-right of the pop-up window.
If you have added a row in error - move the scroll bar to the very right-hand side of the pop-up and click the 'X' next to the row you want to remove.
Once you are finished editing this dataset - click 'Save' and then 'Close'.