Here is a Senior Manager and Certification Regime (SM&CR) Starter Kit for all new FCA-authorised firms:
Complete a mapping exercise (and org chart) to ensure you've captured all your Senior Managers Functions (SMFs) and Certification Staff (CFs), and prepare Statements of Responsibility for each SMF which includes their prescribed responsibilities. Make sure you have a documented Succession Plan for each SMF.
Create a Fitness and Propriety (F&P) Certification framework, which includes the fitness and propriety assessment checklist of your Senior Managers and Certification staff both at the recruitment stage and annually thereafter. Assign someone in your firm (ideally from HR) who will perform these assessments.
Train all staff on the FCA Code of Conduct (COCON) rules 1 to 5, and ensure all Senior Managers are trained on the additional conduct rules SC1-SC4.
Review your recruitment procedures to ensure you have captured the right processes when onboarding new Senior Managers and Certification Staff (as well as NEDs who are not Senior Managers), including the process of requesting regulatory references from former employers, background checks including criminal record checks, and induction training on the Conduct Rules and regulatory expectations.
Ensure your employment contracts for Senior Managers and Certification Staff include the correct SM&CR provisions relating to fitness and propriety and their regulatory duties.
Ensure your Breach Reporting and Whistleblowing Policies are updated to include the relevant SM&CR provisions, including notifying the FCA of conduct rule breaches, and within the relevant timelines.
Compliance Angle can help review your SM&CR framework to get it right from the start.