Article Content
Creating a New Conduct Rule Breach
Overview
A Compliance Officer must record all rule breaches within the system by creating a rule breach record.
User Account Requirements
The user account used to log into Kroll's Managed Compliance Software must have Compliance Officer permission to access the Breaches section.
Required Information/Setup
Please refer to the Closing a Completed Rule Breach article for further information on closing a conduct rule breach.
Navigation
- From the Home screen, click the Home dropdown menu.
Home Dropdown Menu
- Click the Compliance Team Portal link.
Compliance Team Portal Link
- From the Personal Trade screen, click the Breaches tab.
Breaches Tab
Creating a New Conduct Rule Breach
- From the Breaches screen, click the + Add Breach button.
+ Add Breach Button
- From the Create a New Breach screen, select the Conduct Rule Breach from the Breach Type field by clicking the radio button.
- Conduct Rule Breach: A conduct rule breach occurs when an individual breaks an organization's policies and procedures intentionally or unintentionally.
Breach Type Field
- Enter a firm name in the Impacted Firm(s) field and select a firm from the dropdown menu. Users can select multiple firms.
Impacted Firm(s) Field
- (Optional) Click the X icon next to a firm name or Rule Breach Type to remove it from the fields.
X Icon
- Enter a concerned individual's name in the Individual Concerned field and select an individual from the dropdown menu.
Individual Concerned Field
- Click the Next button.
Next Button
- Enter the date the breach occurred using the Calendar pop-up under the Date Breach Occurred field, by clicking a Date.
Date Breach First Occurred Field
- Enter the date the breach was identified using the Calendar pop-up under the Date Breach Identified field, by clicking a Date.
Date Breach Identified Field
- Enter a brief description outlining the conduct rule breach in the Description of the conduct rule breach field.
Description of the Conduct Rule Breach Field
- Select an option to the question: Have you completed an investigation on alleged conduct rules breach(es) in line with the Firm's policies? field.
Have you completed an investigation on alleged conduct rules breach(es) in line with the Firm's policies? Field
- For an employee conduct rule breach, select the conduct rule or rules that were breached from the Conduct Rule(s) Breached dropdown menu. If this field does not apply, please select NA (not applicable) from the dropdown menu.
Conduct Rule(s) Breached Dropdown
- For a senior manager conduct rule breach, select the conduct rule or rules that were breached from the Senior Manager Conduct Rule(s) Breached dropdown menu. If this field does not apply, please select NA (not applicable) from the dropdown menu.
Senior Manager Conduct Rule(s) Breached Dropdown
- Enter a summary of the conduct rule breach and any actions taken to resolve the breach in the Please provide summary of investigation and of the relevant conclusions field.
Please provide summary of investigation and of the relevant conclusions field
- Select an option to the question: Was any disciplinary action taken against the individual? If the user selects Yes is selected the user must include additional information in the Please provide more details surrounding the disciplinary action field.
Was any disciplinary action taken against the individual? Field
- Select an option to the question: Have you notified the relevant regulator?
- Yes: The user must include additional information in the Please provide more details surrounding your notification to the relevant regulator field.
- No: The system will automatically create a regulatory notification in the Compliance Officers My Tasks section to remind them to report the breach to the regulatory body.
Please provide more details surrounding your notification to the relevant regulator field
- Include support documentation by dragging and dropping files into the designated area on the Attachments field or select the top proportion of the Attachments field and select a file from the connected PC.
Attachments Field
- Click the designated area on the Attachments field to add a web link. For more information on adding a web link to the project, see the Adding a Web Link article.
Web Link
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(Optional) Click the following icons to edit or delete an image from the request:
- Edit: Click the Edit icon to rename the file.
- Delete: Click the Delete icon to remove the file from the request.
Image Icons
- Click the Complete Review button.
Complete Review Button
- The conduct rule breach will transition to a pending state. Once the breach is reported to a regulatory body (e.g. FCA) and the Compliance Officer has a breach update, the Compliance Officer must update the conduct rule breach by closing the breach.