Simple Governance Solutions for Complex Governance Challenges



The Senior Manager and Certification Regime (SM & CR) is part of the UK regulators’ drive to improve culture, governance and accountability within financial services firms. It aims to deter misconduct by improving individual accountability and awareness of conduct issues across firms.


There are a number of administrative elements that relate to the implementation of SM & CR. These are things like the management of the certification of executives to specific responsibility, the mapping of what the regulation calls reasonable steps to protect the business and the clear delineation and cascading of associated responsibility.

These include:


  • Those tasked with managing the implementation of SM & CR, amongst other things will need to determine how the personal responsibilities of individuals are supported by policy and demonstrate the effective monitoring of them.

  • For an executive with certified responsibility the effectiveness of oversight and the certainty with which a picture of compliance is delivered has a bearing on future personal risk.


An executive might have more than one certified responsibility with a large number of policies and controls supporting each one.


Obtaining transparency without exposure


Outside of the task of oversight itself a great deal of administration and orchestration lies behind the monitoring process (scheduling of discovery, issuing reminders and chasing of responses) and the orchestration of tasks between stakeholders as they move through the processes of assessment, validation and sign off which can benefit greatly from automation.

A clear, intuitive view of how the business is performing against these requirements has until now been difficult to achieve but with the introduction of the SM & CR regulation, finding ways to improve the way that an executive is able to the oversee the policy performance of his or her sphere of accountability is becoming an increasing priority.

Historically, the kind of information required has taken the form of lengthy periodic reports, making it difficult to spot the important information for which action might be required. At the same time it is not easy to see the detail that sits behind such a report and with the administrative burden limiting the capacity of oversight, not all policies are monitored, leaving open the possibility of accumulated risk.

PRIMED is an agile platform which means it can be used to address one or all of the challenges of SM&CR in a flexible iterative way

It allows those holding certificated accountability to define and automate the oversight routines and enable the monitoring and recording of reasonable steps and at the same time review the results in up to date intuitive dashboards, capture dialogue and record actions at the same time.

With PRIMED you can:

  • Establish a map of how policies and controls relate to risk and regulation and in in turn to operational inventory.

  • Track the orchestration and status of certification and the way that responsibilities are cascaded to support certified individuals.

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