Creating Effective Policies and Procedures

Course outline and objectives

In a summary of key issues cited in FCA disciplinary procedures, it was stated that poor quality/inadequate policies and procedures were mentioned in 100% of disciplinary actions prosecuted by the FCA. Policies and procedures are fundamentals of risk management and control and are often poorly drafted and unfit for their intended purpose, or are ignored by the business because they are drafted by Compliance.

This comprehensive course explores the purpose of policies and procedures, their link to the firm's risk mitigation measures, common errors made in the drafting of policies and procedures (and how to avoid them), how to ensure they achieve what they are intended for and how to "red team" policies and procedures to minimise the chance of those procedures being "gamed" by staff.

Using case studies and worked examples, the focus will be on enabling delegates to produce clear, intelligible policies and procedures that are fit for purpose, not subject to being "gamed" and which underpin high quality risk management at firms.

By the end of the course, participants will:

• Understand the different purposes of policies and procedures
• Understand how policies and procedures need to be aligned with the firm's risk appetite, not just a regurgitation of the FCA rules
• Understand how to link the firm's policies and procedures to risk appetite and the governance structure
• Recognise the concept of "gaming" policies and procedures by staff leading to unintended consequences
• Recognise the importance of engagement of the business in procedure drafting so they remain relevant and likely to be adopted by the business
• Understand what guidance from the FCA and other sources are available and how to leverage it
• Understand how applying a "hacking" mindset and concepts such as "red teams" can improve the resilience of procedures against being "gamed"
• Understand what "good" looks like in terms of quality policies and procedures that are fit for their intended purposes

Who will it benefit?

This programme is specifically designed for financial services professionals who have to draft policies and procedures. It is also relevant to Compliance and Risk so they can advise those drafting on how to do so effectively to meet FCA standards and Internal Audit professionals so they are able to audit policies and procedures in a more value-added and effective way.

Training Approach

The course programme will comprise a blend of trainer presentations, group discussion, practical examples and case studies. There will be ample opportunity for questions, experience sharing and networking. All course materials will be provided.