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Starting a Fitness & Propriety Assessment Through the Employee Screen
Overview
A Compliance Officer can start an F & P Assessment through the Employee screen. The F&P Assessment takes into account the roles and responsibilities that an Individual assumes with the Firm. It must be completed prior to a member staff carrying out a Senior Manager Function or a Certified Function and must be completed at least once a year.
User Account Requirements
The user account used to log into Kroll's Managed Compliance Software must have Compliance Officer permission to access the SMCR Management section.
Related Information/Setup
Please refer to the Completing a Fitness & Propriety Questionnaire article for further information on completing an F&P Questionnaire.
Navigation
- From the Home screen, click on the Home dropdown menu.
Home Dropdown Menu
- Click the SMCR Management link.
SMCR Management Link
- From the Employees screen, click an Employee link.
Employee Link
Starting a Fitness & Propriety Assessment Through the Employee Screen
The employee's F&P questionnaire must be submitted first prior to completing the Fitness & Propriety Assessment.
- From the Employee screen, scroll to the Fitness & Propriety section.
Fitness & Propriety Section
- Click an Assessment listed under the Fitness and Propriety section.
Assessment
- From the Create a new Fitness and Propriety Assessment pop-up, click the Begin button to start the assessment.
Begin Button
- From the F & P Assessment screen, select a Senior Management Function from the Senior Management Function dropdown menu.
Senior Management Function Dropdown Menu
- Select whether the employee will be a Non-SMF (Senior Management Function) Director or not, by selecting the corresponding radio button under the Will the Employee be a Non-SMF Director? Field. An employee who is a non-SMF Director is a non-certified employee and is not an SMF manager but is a director at the firm.
Will the Employee be a Non-SMF Director?
- Select a Certified Function/NEDs option for the employee from the Certified Functions/NEDs dropdown menu. A Certified Function/NEDs are functions that have the potential for significant harm to the firm or its customers.
Certified Functions/NEDs Dropdown Menu
- Select an employment option from the Nature of Employment/Contract field. If Other is selected, a Please Specify field will appear where you can add additional information.
Nature of Employment Field
- Enter the employee's Job Title in the Job Title field.
Job Title Field
- Answer the question, Is an appropriate job description on file for the candidate?
Is an Appropriate Job Description on File for the Candidate?
- Enter the name of the employee's line manager in the Employee's Line Manager field.
Employee's Line Manager Field
- From the Regulatory Matters section, answer the question, Have regulatory references been obtained (for employees who have worked at the firm for 6 years or less)?
- Yes: If Yes is selected, a References field will appear, drag and drop a reference file into the designated area or click the designated area and select a file from the connected PC. User can also add a web link by clicking the designed area and filling out the Web Links pop-up.
- No: If No is selected, the Explain why regulatory references were not obtained field will appear where you can explain why the regulatory references were not obtained.
Have regulatory reference been obtained?
- Answer the question, Is there any adverse information identified from the regulatory references?
- Yes: If Yes is selected, the Please provide an explanation as to the adverse information and include any assessment of its impact on the F&P of the employee field will appear where you can provide an explanation.
Is there any adverse information identified from the regulatory references?
- From the Criminal Proceedings section, answer the question Have you obtained a standard DBS check (or equivalent criminal records check if the individual has worked/lived in another county)?
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Yes: If Yes is selected, the following question will appear Was there any adverse information identified in the DBS/Criminal Records check?.
- Yes: If Yes is selected, a Please provide an explanation of the adverse information and how you have considered this within the assessment field will appear where you can add an explanation regarding adverse information
- No: If No is selected, the Please explain why no DBS/Criminal Record check was obtained field will appear where you can add an explanation.
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Yes: If Yes is selected, the following question will appear Was there any adverse information identified in the DBS/Criminal Records check?.
Have you obtained a standard DBS check?
- From the Business and Employment Matters section, answer the question Please summarize the assessment of the candidate's knowledge and experience that makes them suitable for the role.
Please summarize the assessment of the candidate's knowledge and experience that makes them suitable for the role.
- Answer the question, Are you aware of any other adverse information that could impact the assessment of the employee as fit and proper? For example, breaches of our Employee handbook, Compliance Manual, policy and procedures, or FCA conduct rules.
- Yes: If Yes is selected, the Please provide an explanation as to the other adverse information field will appear where you can enter an explanation.
Are you aware of any other adverse information that could impact the assessment of the employee as fit and proper?
- Answer the question, Has the employee been provided with/made aware of all relevant procedures for the proper discharge of their responsibilities?
Has the employee been provided with/made aware of all relevant procedures for the proper discharge of their responsibilities?
- Answer the question, If the role has a professional qualification requirement as per the FCA Training and Competence Handbook confirm which qualifications the candidate holds (otherwise enter N/A)?
If the role has a professional qualification requirement as per the FCA Training and Competence Handbook confirm which qualifications the candidate holds
- Answer the question, Segregation of Function. If the employee is going to perform more than one role within the firm, what controls has the firm established to ensure that this does not and is not likely to prevent them from performing all of their functions soundly, honestly, and professionally?
Segregation of Function
- From the Compliance Signoff section, select whether or not the employee is a fit or not a fit for the role by selecting one of the corresponding radio buttons:
- Considering all relevant factors, the individual is fit and proper for the role
- Considering all relevant factors, the individual is not sufficiently fit and proper for the role
Compliance Signoff Radio Buttons
- Enter any additional comments in the Overall Assessment field.
Overall Assessment Field
- Click the Submit for Review button. If the Submit for Review button does not appear the employee must complete the F & P Questionnaire in order for the button to appear.
Submit for Review button
- The employee's F & P Questionnaire will move to the In Progress section on the F&P Questionnaire screen and will require a final review.