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BSB podcast: The Certification Regime and assessing F&P

certification podcast
Jenna Cotter, Linda Reed, Ande Hardiman, Sara Thorpe


In January 2016 the BSB set up a working group of members to look at fitness and propriety in the context of the Senior Managers and Certification Regime, which came into effect on 7 March this year.

Collating the working group’s deliberations to date, the BSB published a Consultation Paper setting out voluntary guidelines to help member firms with the implementation of the regime. We invite responses to this consultation by 7 September.

Three months on from the introduction of the regime, the BSB gathered together some of the members of the working group to discuss some of the key challenges of developing an industry-wide approach to certification of fitness and propriety with reference to the guidelines.

Taking part in this first BSB podcast is:

  • Sara Thorpe, Cambridge & Counties Bank. Sara is Director of HR for Cambridge & Counties Bank. Prior to joining CCB, Sara ran her own company for over 10 years supporting SMEs to effectively manage and develop their staff. She draws on over 20 years’ experience, having worked in both L&D and HR management for a range of different organisations, including financial services, utilities, insurance and not for profit.
  • Ande Hardiman, BNY Mellon. Ande has worked in the Human Resources department of global investments company BNY Mellon for nine years supporting the personnel needs of the firm’s business lines. Most recently, he has worked closely with EMEA regional management and provided HR input into the implementation of the Senior Managers’ Regime in the UK at the company.
  • Linda Reed, Buckinghamshire Building Society. Linda has worked at the Buckinghamshire Building Society as Compliance Manager for almost a year, which is her first foray into the Building Society Sector. She is responsible in her current role for ensuring good customer outcomes and promoting a positive Compliance culture.
  • Jenna Cotter, Santander. Jenna is an Employee Regulation Manager for Santander UK. She has specialised in the interpretation and launch of the Senior Managers and Certification Regime since late 2014. She has a particular interest in the impacts of the regime on current HR practices.
  • Mikael Down, Banking Standards Board. Mikael is Director of Policy and Analysis at the Banking Standards Board, responsible for the BSB’s policy work and its annual assessment of bank/building society culture. He led the development of the Senior Managers and Certification Regime at the FCA, having previously worked in a number of financial services policy roles at HM Treasury.

We hope you find this first podcast from the BSB useful and informative in thinking around your firms’ own approach to certification. You may find it helpful to reread our Consultation Paper while listening, and please remember to submit your firms’ responses by 7 September 2016.

If you are a BSB member and interested in joining the working group, please do not hesitate to get in touch.


Senior Managers and Certification Regime

Exploring how the SMCR - and especially Certification - can be implemented in the most effective way across the sector.

The Senior Managers and Certification Regime is a major regulatory change that will affect all banks and building societies. Responding to recommendations by the Parliamentary Commission on Banking Standards, the government and regulators have together developed a comprehensive framework to ensure better accountability and responsibility for behaviour, competence and culture in banks and building societies. The new framework provides an opportunity for the industry to focus on and demonstrate a culture of professionalism. We are working with firms and regulators to facilitate this, including areas where a common approach across firms could support both the objectives of the regime and the skills and development of the people covered by it.


Evaluating whether a more 'professional' approach to banking would improve behaviour and competence across the industry.

The Parliamentary Commission on Banking Standards found that 'banking culture has all too often been characterised by an absence of any sense of collective responsibility to uphold the reputation of the industry', and argued that a greater focus on professionalism could be an answer to this. Working with a leading team at the University of Leeds, we are researching the issues around professionalism in banking. In particular, we are reviewing how professional qualifications are currently used across the sector, and at whether a stronger role for professional bodies, along the lines seen in some other sectors, like medicine or law, would help raise standards. To inform this work and develop a rounded picture of 'professionalism' and what it means in banking, we are surveying banks and building societies, professional bodies and a wide range of other interested groups, including consumer bodies and investors.


Providing an honest and impartial assessment to Boards of progress against objectives on behaviour, competence and culture.

The BSB assessment exercise presents Boards with an objective and impartial view of their firm's culture, identifying where things are working well and recommending areas for improvement. It draws on information not only from Boards and senior teams, but also from employees, investors (or members), trade unions, customer groups and other relevant bodies. In doing so, it will provide constructive challenge to each firm individually, while building a collective understanding of common issues across the industry, or sectors within it. We undertook our first annual assessment exercise in 2015 with ten firms (Barclays, Citi, HSBC Bank, Lloyds Banking Group, Metro Bank, Morgan Stanley International, Nationwide, RBS, Santander UK and Standard Chartered). The BSB itself will not publish individual assessment reports - each firm owns its own report - but key themes and messages will be set out in the BSB's annual report, the first of which will be published in Spring 2016. Given that Board engagement is central to the assessment work, only firms that have their headquarters in the UK are eligible for the full assessment exercise. All firms, including branches of firms headquartered overseas, will however be included in a focused membership-wide survey, which will allow each participating firm to benchmark itself against its peer group.



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