1. Author:
Heath
Buck,
7th
May
2015
2015 impact of new Regulations on
Financial Services HR Departments
This presentation explains some of the impact on HR departments of
the new regulations on accountability from the FCA and PRA. If you
work in a Financial Services HR Department and you believe your
organisation might be affected you should seek support as soon as
possible.

2. Author:
Heath
Buck,
7th
May
2015
Previously….
Impact of Regulation Changes on HR in Financial Services
Now….FCA
&
PRA
Focus
on
a
small
number
of
individuals
FCA
&
PRA
Use
firms
as
mini-­‐regulators
to
ensure
fitness
&
propriety
of
staff
Regulatory
Change
is
coming
in
3
@ers….
1. Senior Manager’s Regime
• Replaces
the
current
Significant
Person
FuncAon
of
the
Approved
Persons
Regime.
• Will
ensure
there
is
an
individual
accountable
for
every
regulated
acAvity.
• Reverse
burden
of
proof
means
Senior
Managers
must
be
able
to
show
they
have
taken
reasonable
steps
to
prevent
regulatory
breaches.
2. Certification Regime
• Is
a
new
Aer
of
people
who
perform
funcAons
which
represent
a
“significant
risk
or
harm”
to
the
firm
itself
or
customers
and
must
be
approved
as
fit
and
proper.
• The
firm
itself
carries
out
the
cerAficaAon.
3. Conduct Rules
• Will
cover
all
remaining
employees
except
staff
who’s
duty
would
be
the
same
in
any
industry
(e.g.
cleaners,
recepAon).
The
above
regulaAons
may
transfer
a
lot
of
HR
acAviAes
from
following
discreAonary
objecAves
to
meeAng
compliance
requirements
as
shown
in
the
next
two
slides…

3. Author:
Heath
Buck,
7th
May
2015
Current people objectives across the employee journey
I
AM
RECRUITED
EMPLOYEE
JOURNEY
ADDED
VALUE
OBJECTIVES
COMPLIANCE
OBJECTIVES
I
AM
MANAGED
I
EXIT
Paid
correctly
and
on
Ame
• Objectives have been separated from tools (e.g. performance is an objective, appraisals are a tool)
• “Compliance” activities are something that must be done, where as “Added Value” does not have to be done, but the degree to which it is done could
impact the employer
Systems
access
iniAated
Conduct
&
behaviours
RemuneraAon
at
the
right
level
Performance
Culture
Succession
Poor
staff
exited
Finds
candidates
Staff
developed
Staff
handover
Onboarding
Systems
access
Quality
candidates
sourced
Systems
access
removed
Staff
engaged
Employer
brand
managed
Compliance
training
EffecAve
organisaAonal
structure
Employee
RelaAons
cases
managed
Management
within
legal
parameters
Lawful
exit
(fair
dismissal
process)
Exit
data
gathered
Clear
responsibiliAes
for
each
job
Quality
candidates
selected
Suppliers
managed
Return
of
company
equipment
Background
checks
People
Strategy
Employers have had a lot of discretion on how they manage their people. The HR function was an additional cost
base which would be invested in if the employer felt it would add enough value.

4. Author:
Heath
Buck,
7th
May
2015
Regulations impact!
I
AM
RECRUITED
EMPLOYEE
JOURNEY
ADDED
VALUE
OBJECTIVES
COMPLIANCE
OBJECTIVES
I
AM
MANAGED
I
EXIT
Paid
correctly
and
on
Ame
Systems
access
iniAated
Conduct
&
behaviours
RemuneraAon
at
the
right
level
Performance
Culture
Succession
Poor
staff
exited
Finds
candidates
Staff
developed
Staff
handover
Onboarding
Systems
access
Quality
candidates
sourced
Systems
access
removed
Staff
engaged
Employer
brand
managed
Compliance
training
EffecAve
organisaAonal
structure
Employee
RelaAons
cases
managed
Management
within
legal
parameters
Lawful
exit
(fair
dismissal
process)
Exit
data
gathered
Quality
candidates
selected
Suppliers
managed
Return
of
company
equipment
Background
checks
People
Strategy
Employers will now be expected to prove to the regulator certain activities will be taking place.
Some of the “added value objectives” will have an impact on “compliance objectives” that they could
also be moved into that section (e.g. performance, succession).
Clear
responsibiliAes
for
each
job

5. Author:
Heath
Buck,
7th
May
2015
What you should be doing next…
Item
Ac@on
The
regulaAons
are
not
yet
final!
Ensure
a
good
regulatory
feedback
loop.
Work
with
retained
lawyers
or
other
financial
regulaAon
experts,
HR’s
job
is
to
translate
their
experAse
into
a
tacAcal
plan
for
the
firm.
Become
friends
with
risk/
compliance
Risk,
compliance,
and
HR
will
all
need
a
strong
harmonious
relaAonship
to
deliver
the
requirements
of
the
new
regime,
start
to
setup
those
workshops,
meeAngs,
and
discussion
groups.
IdenAfy
individuals
who
will
be
captured
by
the
new
regulaAons
Start
to
coach
them
through
the
likely
impact.
Understand
what
support
they
will
need.
Ensure
they
are
ready
for
the
incoming
Define
reporAng
lines
and
responsibiliAes
All
regulated
acAviAes
should
be
assigned
to
an
individual
who
has
responsibility.
Start
working
on
the
assumpAon
the
“prescribed
responsibiliAes”
will
come
into
force
and
any
transiAon
is
likely
to
be
smoother.
Processes
What
happens
and
when?
How
are
new
people
captured?
What
trigger’s
a
report
to
the
regulator
of
non-­‐compliance?
There
needs
to
be
clear
workable
processes.
Systems!
With
the
reverse
burden
of
proof
you
will
need
evidence
of
compliance
(responsibility
map
should
be
in
a
single
up
to
date
document,
you
must
demonstrate
reasonable
steps
taken
to
comply).
To
avoid
be
swallowed
by
administraAon
you
will
need
systems
to
manage
your
evidence
base.
Training
Start
a
rolling
training
program:
-­‐ New
employees
will
need
inducAons.
-­‐ How
will
you
cerAficate
new
employees
(you
have
4
weeks
to
do
so!)
-­‐ What
core
training
is
needed
to
ensure
compliance
-­‐ Provide
guidance
manuals
and
support
for
senior
managers
Equip
your
HR
team
HR
will
need
a
logical
and
systemaAc
approach
if
they
are
to
deliver
compliance
without
becoming
overwhelmed
with
work.
This
may
require
support
and
training.
You
might
need
to
consider
taking
on
addiAonal
support
for
an
interim
period
to
deliver
what
is
needed.
This
affects
your
most
senior
stakeholders
–
gedng
it
right
is
essenAal!

6. Author:
Heath
Buck,
7th
May
2015
Appendix 1 - HR Tools
Employment Contracts
Background checking
Management Advice
Occupational Health
Coaching
Appraisals
HR Systems
Recruitment
E-Learning
Training
Whistleblowing
Exit Interviews
Policies
Management information and reportingHR Admin
To provide clarity on the difference between HR objectives and HR tools used to achieve those objectives, I have
included a list of the primary tools HR departments use. Different departments will use a different mix of tools
according to their needs and resources.
The tools highlighted in red are likely to rise in prominence when the new regulations are implemented.

7. Author:
Heath
Buck,
7th
May
2015
Appendix 2 - Heath Buck Overview
Profile:
Request my CV for full details.
My Linked In profile shows my work based references from Board Directors and Heads Of HR that I have previously devlivered for:
heps://uk.linkedin.com/in/heathbuck
• Successful HR generalist with experience of managing HR departments through periods of significant change.
• Lead financial services HR teams through significant HR controls audits to receive performance awards for our improved
delivery.
• Performance award from Barclays for delivery of HR response to an FCA skilled persons audit.
• 6-Sigma and PRINCE2 project management qualified.
Financial sector companies I have worked with include:
• NEST Pension Fund (National Employment Savings Trust)
• Barclays Bank
• Mizuho Corporate Bank
• State Street Bank and Trust