Article Content
Submitting a Fitness & Propriety Assessment for Review
Overview
A Compliance Officer must complete a Fitness & Propriety Assessment review once an employee has completed the assessment before it can be sent for a final review.
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.
Navigation
- From the Home screen, click a Fitness & Propriety Assessment listed in the My Tasks section. The Fitness & Propriety Assessment will be labelled with the employee's name followed by F&P Assessment.
Fitness & Propriety Assessment Link
- (Optional) Click the Fitness & Propriety Assessment chart to narrow down the listed results on the My Tasks list to include only Fitness & Propriety Assessments.
Fitness & Propriety Assessment Chart
Alternate 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 the F&P Assessments tab.
F&P Assessment Tab
- From the F&P Assessments screen, click an F&P Assessment link that is in the Assessment state under the Pending Review section.
Note:
Enter an employee name in the Search field to narrow down the search results.
F&P Management Link
Submitting a Fitness & Propriety Assessment for Review
- From the F&P Assessment screen, select a Senior Management Function for the employee from the Senior Management Function dropdown menu.
- SMF 1: Chief Executive
- SMF 2: Chief Finance Officer
- SMF 3: Executive Director
- SMF 4: Chief Risk Officer
- SMF 5: Head of Internal Audit
- SMF 7: Group Entity Senior Manager
- SMF 9: Chair of the Governing Body
- SMF 10: Chair of the Risk Committee
- SMF 11: Chair of the Audit Committee
- SMF 12: Chair of the Remuneration Committee
- SMF 13: Chief of the Nomination
- SMF 14: Senior Independent Director
- SMF 15: Chair of the With Profits Committee
- SMF 16: Other Overall Responsibility
- SMF 17: Money Laundering Reporting
- SMF 19: Head of Third Country Branch
- SMF 22: Other Local Responsibility
- SMF 24: Chief Operations
- SMF 27: Partner
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 for the employee 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/Contract 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 Sign Off section, select whether 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 Sign Off 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.