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SM&CR Series Insight 3: Employee SM&CR Compliance

The aim of this post is help you, an employee of an insurer, to be aware of the Conduct Rules and provide some practical guidance on complying with them.

Your employer is responsible for providing you with training and making you aware of the Conduct Rules. Your employer is also responsible for ensuring that the process of complying with the Conduct Rules is properly documented.

Now that we’ve covered your employer’s responsibilities, let’s look at the five Conduct Rules that apply to you as an employee.

Rule 1: You must act with integrity.

In the course of your daily work activities, you need to ensure your conduct is all above board. If you question the morality or ethics of a task you’re supposed to do, raise it with your superior and obtain greater clarification.

Rule 2: You must act with due care, skill and diligence.

This rule hits on your ability to do the job; it means that you understand what’s required of you and that you are able to fulfil the responsibilities your role requires. Therefore, you should have received the proper training for it, have any necessary qualifications and keep abreast of the issues in your area.

Rule 3: You must be open and cooperative with the FCA, the PRA and other regulators.

If you do have to liaise with the regulators, as maybe it’s part of your job, you need to be completely transparent with them. If you have information that is unfavourable for your company, you should make sure that you’ve reported it properly within your company and also disclose it to the regulators.

Rule 4: You must pay due regard to the interests of customers and treat them fairly.

Your customers should be your main focus and whilst we know you wouldn’t, you should not look for ways to exploit them. Acting poorly can result in harm to your customers, which is not something that the regulators take lightly!

Rule 5: You must observe proper standards of market conduct.

Both you and your organisation are expected to comply with relevant market coduct guidelines. The best way to do this is to regularly review the regulators websites.

Further details about SM&CR can be found here.